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Home My WebLink About00-00508 ;i;, FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? l'i) ';1>1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MORTGAGE COMPANY - WEST, F/KJ A MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON, TX 77006 TERM Plaintiff NO, :xx:D - SD1l uAi1 T--€/unl v. CUMBERLAND COUNTY MATTHEW R. LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, P A 17070 Defendant( s) CTVTT. ArnON - LAW MORTGAGR FORRCT.OSrTRR NonrF You have beeu sued in Court. If you wish to defend against the claims set forth in the following pages, you must take aetion within twenty (20) days after this Complaint and Notiee are served, by enteriug a written appearanee personally or by attorney and filing in writing with the eourt your defenses or objections to the elaims set forth against you. You are warned that if you fail to do so the ease may proeeed 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 elaim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3 166 Loan #: 5700717399 ",!"' , j I .' 1, Plaintiff is CHASE MORTGAGE COMPANY - WEST, F/K/A MELLON MORTGAGE COMPANY 31 00 TRAVIS STREET HOUSTON, TX 77006 2, The name(s) and last known addressees) of the Defendant(s) are: MATTHEW R. LAMAN JENNIFER D, LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter deseribed. 3, On 8/31/95 mortgagor(s) made, exeeuted and delivered a mortgage upon the premises hereinafter deseribed to MCA MORTGAGE CORPORATION whieh mortgage is reeorded in the Offiee of the Reeorder of CUMBERLAND County, in Mortgage Book No, 1280, Page 248. By Assignment of Mortgage dated 12/18/95 the mortgage was assigned to PLAINTIFF whieh Assignment is reeorded in Assignment of Mortgage Book No, 514, Page 696, 4, The premises subjeet to said mortgage is deseribed as attaehed. 5. The mortgage is in default beeause monthly payments of prineipal and interest upon said mortgage due 5/1/99 and eaeh month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire prineipal balanee and all interest due thereon are eolleetible forthwith. ~L 6. The following amounts are due on the mortgage: Principal Balanee Interest 4/1/99 through 1/1/00 (Per Diem $22.41) Attorney's Fees Cumulative Late Charges 8/31/95 to 1/1/00 Cost of Suit and Title Seareh Subtotal $100,837.80 6,162.75 4,000,00 154.64 55.iLOll 111,705.19 Eserow Credit Defieit Subtotal 0,00 1fi3..26 1fi3..26 TOTAL $112,468.45 7, The attorney's fees set forth above are in eonformity with the Mortgage doeuments and Pennsylvania Law, and will be eolleeted in the event of a third party purehaser at Sheriffs Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be eharged, 8, This aetion does not eome under Aet 6 of 1974 beeause the original mortgage amount exceeds $50,000,00. 9. Pursuant to the Fair Debt Colleetion Praetiees Aet, 15 U.S.C. S 1692 et seq. (1977), Defendant(s) may dispute the validity ofthe debt or any portion thereof. IfDefendant(s) do so in writing within thirty (30) days ofreeeipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verifieation thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days ofreeeipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original ereditor if different from above, WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $112,468.45, together with interest from 1/1/00 at the rate of $22.41 per diem to the date of Judgment, and other eosts and charges eolleetible under the mortgage and for the foreclosure and sale of the mortgaged property, ~~ ~~nk Fp.i1erman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~I '"~=........J ," ~, , "--.., ,~ ALL THAT CERTAIN crace of l~nd s~Cua~e in the Borough of New Cumberland. Couney af Cumberland and state of Penn8y~vania. more parti~ularly boundad and described $8 fo~10ws. co wie: DEGINNXNG at a p01nc on the nor~hwes~ corner of Woo~land and River Avenuesj thence in 8 w..tsrly d1rect~on a~Oft8 River Avenue, one hundred forty (140) feet co Oak Avenue; chenee in a nor~ler1y direct~o~ along Oak Avenue, fifty (50) reet t.o che 1:1.ne of Lol:. No. 24, Block "V". :in the here:in.afccl. mentioned Pla:n: 'thence ;1.n an 1liJ.8sc6':rly cl:irect:i.on a10ng said li.ne, one hundred forty (140) fe~t co Wood- l.s.nd Avenue; chene. in II southerly d;i.rec::t:.:i.on al.ons Woodl.iD.hd Aven~le. -tift.y (SO) f.4C to the Place oE BEGINNING. BEING Lots Noa. 25 and 26. 'Block "VII, on 'the Plan of George W ~ Buttorff I S Second 'Addi~ion to New Cumberland. wh~~h P1an ~s recorded ~n che C1Jmberl.and County Re- corderts Offic8 in DeQ~ Book~S. Page ~4S. BE'ING !'nown JlInd number~d as 3:14 WOQdl.attd Avenue. Ne.w Cumber13f1d. Pennsyl.vania. BEING THE SAME P~'EMISE.S which R1.ehard ,,,. Sponaugle and Ann A. Sponaugle, hl.labiH'ld and w~fe, by. th~1r Deed dated May 16, 1968 enu recorded May 17. 1968 in the Off1G~ of che Reco~der ot Deeds in and ~or Cumberl.and Councy in Deed Bock 'r. Vol- ume 22. Page 862. gran1:.ec1 and c.onveyed unt:.o Max E. Schmi.dt. an.d Muriel 1'1. Sd\lni.dt. hU$band and wite, Grantors herein. ,. ~ .""~ VERIFICATION i; " 1\ i; r, 1~ DEBORAH SPRITZER hereby states that she is ASSISTANT VICE-PRESIDENT of CHASE MORTGAGE COMPANY WEST, F/KJA MELLON MORTGAGE COMPANY mortgage servieing agent for Plaintiff in this matter, that she is authorized to take this Verifieation, and that the statements made in the foregoing Civil Aetion in Mortgage Foreclosure ,'; " are true and eorreet to the best of her knowledge, information and belief. The undersigned understands that this statement is made subjeet to the penalties of 18 Pa. C.S. See, 4904 relating to unsworn falsifieation to authorities. r'~ I " ," 1': I': " f; , , DATE: I-{ilf DO " ;~ ~~ '" ~~ b; l; t; ~,; j~ ", I' 1, " ') '& f.'~': .... ....,." '..;....,... ',' " , ',' ",' ;'i;~'J: t,~l, ~... '. , -:",:: ~'l;;:;: ~:., .''''..~~} ; ~ ',,-, ,l:~,'1-: ';;,,~~~;' .~, ., ',.' ; '" " ,~~ :!-.: ,\i-c,yt, ~ "'.r<~' , ....,.. .., , '" i~~:", ,:.. ;"\' "<" , j , ~ , j i "'i ! '.....'-" ,~ "'-"'- . SHERIFF'S RETURN - REGULAR CASE NO: 2000-00508 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE COMPANY WEST VS LAMAN MATTHEW R ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LAMAN JENNIFER D the DEFENDANT , at 0018:15 HOURS, on the 2nd day of February, 2000 at 1719 PEYTON RANDOLPH COURT NEW CUMBERLAND, PA 17070 by handing to JENNIFER LAMAN a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sr:;;:?~~~( R. Thomas Kline Sworn and Subscribed to before ~ ;L:r ~ day of 02/09/2000 L FEDERMAN & PH ~ By: Deputy herlff me this 'it:;:; ~ AD , (]. ~~~ Prothonotary' -~ ~" '... SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00508 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MORTGAGE COMPANY WEST VS LAMAN MATTHEW R ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LAMAN MATTHEW R but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , LAMAN MATTHEW R DEFT. NO LONGER RESIDES AT ADDRESS STATED, RETURN NOT FOUND AS PER ATTORNEY. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 10.54 5.00 10.00 .00 43.54 s~~ R. omas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/09/2000 Sworn and subscribed to before me ci25~ day of .3'~ this ~o-o-lJ A . D . ~ o. /rt.- ~P~. / L~"7i' prtnonotary , , - ~ '. ....................._ jjELK ~ , FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (71 'i) 'i1i1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MORTGAGE COMPANY - WEST, F/K/A MELLON MORTGAGE COMPANY 3 I 00 TRAVIS STREET HOUSTON, TX 77006 TERM Plaintiff NO. dfX)O-SO'8' CWcQ. T~ v, CUMBERLAND COUNTY MATTHEW R, LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, P A 17070 Defendant(s) CIVIL ACTION - LAW MORTr.Ar.R FORRCI.OSTTRR NOTWF You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take aetion within twenty (20) days after this Complaiut and Notiee are served, by entering a written appearanee personally or by attorney and filing in writing with the eourt your defenses or objeetions to the elaims set forth against you. You are warned that if you fail to do so the case may proeeed without you and a judgment may be entered against you by the eourt without further notiee 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (7\7) 249-3166 Loan#: 5700717399 TRUE COpy FROM RECORD . In T estimooy whllroof, I here unto 9l'lt my hanO We hereby certify the d and the seal of said Court at CartIsIe, Pt. within to be a true an rht~ ~ '~~correctcOPYOfthe ,,' 4 ~ { , 'l"--J original med of record . onotaryFEDERMAN AND PHELAN ""- ". ~ ~- ~" "iL"t' . 1. Plaintiff is CHASE MORTGAGE COMPANY - WEST, F/K/A MELLON MORTGAGE COMPANY 3100 TRAVIS STREET HOUSTON, TX 77006 2, The name(s) and last known addressees) of the Defendant(s) are: MATTHEW R. LAMAN JENNIFER D. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter deseribed. 3. On 8/31/95 mortgagor(s) made, exeeuted and delivered a mortgage upon the premises hereinafter deseribed to MCA MORTGAGE CORPORATION whieh mortgage is reeorded in the Offiee of the Reeorder of CUMBERLAND County, iu Mortgage Book No, 1280, Page 248. By Assignment of Mortgage dated 12118/95 the mortgage was assigned to PLAINTIFF whieh Assignment is reeorded in Assignment of Mortgage Book No. 514, Page 696. 4. The premises subjeet to said mortgage is deseribed as attaehed, 5. The mortgage is in default beeause mouthly payments of prineipal and interest upon said mortgage due 5/1/99 and eaeh month thereafter are due and unpaid, and by the terms of said mortgage, upon default in sueh payments for a period of one month, the entire prineipal balanee and all interest due thereon are eolleetible forthwith, _.~~., u ~ ~ . < ( 6, The following amounts are due on the mortgage: Prineipal Balanee Interest 4/1/99 through 1/1/00 (Per Diem $22.41) Attorney's Fees Cumulative Late Charges 8/31/95 to 1/1/00 Cost of Suit and Title Seareh Subtotal $100,837.80 6,162.75 4,000,00 154.64 .5..iU..O.Q 111,705,19 Eserow Credit Defieit Subtotal 0.00 1.6J..2.6 1.6J..2.6 TOTAL $112,468.45 7. The attorney's fees set forth above are in eonformity with the Mortgage doeuments and Pennsylvania Law, and will be eolleeted in the event of a third party purehaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be eharged. 8. This aetion does not eome under Aet 6 of 1974 beeause the original mortgage amount exeeeds $50,000.00. 9. Pursuant to the Fair Debt Colleetion Praetiees Aet, 15 U.S.c. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days ofreeeipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verifieation thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days ofreeeipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original ereditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $112,468.45, together with interest from 1/1/00 at the rate of $22.4 I per diem to the date of Judgment, and other eosts and eharges eolleetible under the mortgage and for the foreclosure and sale of the mortgaged property. /,,/ Fr:lnk Ff':nP.rm:ln FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~. ~~ ...._~~, . . ""-, ALL THAT CERTAIN crae~ of land a~cua~e in the Borough of Na~ Cumber~and. Ccun~Y of Cumberland and Sta~c of Pen"8y2van~a. more p~rc~cularly bounded and deseribad as ~o~1ows. ~o ~i~: BEGINNING a~ a po1nc on the northwes~ corner c~ Woodland snd River Avenuesj thence 1n a: we'sterly d.irection a~on8 River Avertus. one hundred .forcy (140) feet co Oak Avenue; thense in a nor~\erly ~reee~an alona Oak Avenue, fifty (50) reet to che line of Lot. No. 2.4, l3lock IIVn ~ :l.n the here:l..natte:1." meJ"lt::i.oned. Pla:n; ehliJnc:e. 1n an aa~c~rly direet~on along $aid l1ne. on~ hundred forty (140) fa$t to Wood- land Avenue; chene. ~n G aoutherly d~rection alona WoodLand AVen~e. fifty (SO) f..t to the Place of BEGINNING. BEING Lots Nos. 25 and. 26. 'Block nVfl, on the pJ.an of Georse W_ ButtoJ:"ff's Second .Add1e1on eo New Cumbe~1and. wh~~h Plan ~s recorded in ~he Cumberland Co~nty Re- ~orderfs Off~ee ~n D..d goo~U5. Psge ~B. BEING known 9nd numac4ed as 314 WQodkand Avenue_ New Cumberland. Pennsylv~nia. BEING THE SAME PREMISllS which R:ichard \J. Spo~ug~e and Ann A. Sponaug] e. hUHballd and w~fe, by. cheir Deed dated May 16, 1968 end recorded May 17, 1968 in ehe Ol21ce at che Reco~der ot Oeeds in snd ~or Cumber1and Couney in Deed Book 'r. Vol- ume 22, Page 862. granted and conveyed unco Max E, Schm:l.dt. and. Muriel M. Sc:.hanidl:. husband end wile. Graneors herB1n. ~ -~ ~~ - ~ VERlFICATION DEBORAH SPRITZER hereby states that she is ASSIST ANT VICE-PRESIDENT of CHASE MORTGAGE COMPANY WEST, FIK/A MELLON MORTGAGE COMPANY mortgage servieing agent for Plaintiff in this matter, that she is authorized to take this Verifieation, and that the statements made in the foregoing Civil Aetion in Mortgage Foreclosure are true and eorreet to the best of her knowledge, information and belief. The undersigned understands that this statement is made subjeet to the penalties of 18 Pa, C.S. See. 4904 relating to unsworn falsifieation to authorities. DATE: I-Qll- 00 ~', '~ i (1Ij .~' B:' . i I I I I I , , , i I , , , ! " ,'I -n I' II II II II II II Ii 1'1 FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CHASE MORTGAGE COMPNAY-WEST, F/K/A MELLON MORTGAGE COMPANY COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. MATTHEW R. LAMAN JENNIFER D. LAMAN Cumberland County Defendants No. 2000-508-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ;;--~ ~~k.. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: March 1, 2000 -1_~!il1.~"""""'.II!IillliW.iIAI_ "'~""'iUii~~!!l~;mlll~_' - k, --.... '~_"h ~>'.: @ () CJ 0 C CJ -n ~~ :x .--j ;Hili '"'" T f'n ;;0 hi:!] Z:rj , Z~ I -.om ~. -' 86 z. ;<0 ,~.-{ -0 5+1 p :x z8 -.(") )>c T':Y iSm ~ .::- ~ N -< r ( - SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00508 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE COMPANY WEST VS LAMAN MATTHEW R ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LAMAN MATTHEW R but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania, to serve the within COMPLAINT - MORT FORE 23rd , 2000 , this office was in receipt of the On March attached return from LEBANON Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 DEP. LEBANON CO 26.25 .00 63.25 03/23/2000 FEDERMAN & PHELAN ~~ R. 'Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this d'~ day of ~.1 cPrrvV A. D . o 'r" 0. ':7vr-lII,~ -' OfZi- Prothonotary' L ( ^,.,'-' ", ~'I '_ " _,0',-,,__',< , ~' , ,"< REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE No. 2000-508 Lebanon, PA, March 21, 2000 CHASE MORTGAGE COMPANY-WEST vs. FRANK FEDERMAN, ESQ. (RETURN TO CUMBERLAND CO. SHERIFF) MATTHEW R. LAMAN DOCKET PAGE 14852 STATE OF PENNSYLVANIA } COUNTY OF LEBANON } SS: Deborah A. Miller, Chief Deputy Sheriff, being duly sworn according to law, deposes and says that she served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon MATTHEW R. LAMAN, the within named DEFENDANT, by handing a true and attested copy thereof, to him, personally, on March 9, 2000, at 12:15 o'clock P.M., at the Sheriff's Office, 400 South Eighth Street, Lebanon (City), Lebanon County, pennsylvania, and by making known to him the contents of the same. Sworn to and subscribed before me this 21st day of ~ March, A.D., 2000 SO ANSWERS, ;t::J~#- ~ CHIEF DEPUTY SHER F /V~5 Notary Public _A/4f N T ARIAL SEAL NCY L, S1 ARNER. Notary Public eoanln, Lebanon Clunt,. Pa. My C,mmlSSlIn [XPlres Au/a.l 8, 2002 SHERIFF'S COSTS IN ABOVE Advanced costs paid on 3/9/00 Check No. Costs incurred: Refund: Check No. 7930 PROCEEDINGS 70954 Amount Amount Amount 100.00 26.25 73.75 All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 't'- ~L~~,j~~;(~~~?~~ffil~~;,:,,:,:~;,t~~::;,,>~~_; ~,.- . ." , . ~,'l:'~~..fJ()~rt of Common Pleas of Cumberland County, Pennsylvania Chase; Mortgage Company-Wes t; et., al. , "VS. Mat thew R.Lamari' Serve. Matthew R.,Laman No. 20-508 Civil Now, 3/7/00 , 200" , I,' SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this , deputation being made at the request' and risk of the Plaintiff. _ r~J'If!lfC~f Sheriff of Cnmberland County, P A Affidavit of Service Now, ,20 , at o'clock M. served the within upon '.. at .. by handing to a copy of the original and made mown to . the contents thereof. So answers, Sheriff of County, PA , , -Sworn and subscribed before me this day of 20 '- COSTS SERVI€E .'_ MILEAGE AFFIDAVIT $ $ i:-' ~ ".T:' ~-=-"A'ccount Total -$ " <" ,.'-~: ~~,-:". - "-,...~... ':::''::~:':~~ '~'.-~. '2'oi<..:,:_..;_.""....;:_;~Ji :'.:-:~' :,-- '>"NO. .3613b -; 'J~q , . )S~' ~ ,.::; ~ ~M'L.&.<-- , / /{}tJ, # DOLLARS t?1JA/!ej~o/Me tlJ. 11/'e:u- JU , (V-O jM-;r.f4a,J e, CtIJtA~,.J "/(}(J, ~tJ ~ '0..""'" ,---: 1 , '", jp--- -=== ;---cR'ECEIVED FROM ~ - f!k.. 109.5"1-' =;~- ;)..{JoO - .-QJ f" :';.;.:.. ArnoulIt Paid $ ~'.~, f- Sa Is nee Due $ ~ ':rHE.EFFICiENcy"UN'':'"ANAMl>Ai,PROOUCl'-- =- ~- -,t:! -_..:'!j: ~ J , ,---,-- ~,-',,- ,-'- - -" ,L , ~i FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Chase Mortgage Company West fIkIa Mellon Mortgage Company 3100 Travis Street Houston, TX 77006 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DIVISION vs. Matthew R. Laman 314 Woodland Avenue New Cumberland, P A 17070 : NO. 2000-508 Civil Jennifer D. Laman 1719 Teyton Randolf Court New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Matthew R. Laman and Jennifer D. Laman, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 1/1/00 to 4/18/00 $112,468.45 $2.442.69 TOTAL $114,911.14 I hereby certifY that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~{)~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. if;! (] V> -.1./1 J 7:? ~ . , PRO PROTHY DATE: 4,/19 /o~ / ""TIIIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY REcEIVED A DiSCHARGE IN BANKRUPTCY AND TIIIS DEBT WAS NOT REAFFffiMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATI'EMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. ----- - - - -- ---~ ~ ------ - ----- ------ -- FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MORTGAGE COMPANY- WEST,F/K/A MELLON MORTGAGE COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY MATTHEW R. LAMAN JENNIFER D. LAMAN NO. 2000-508-CIVIL Defendant TO: .:JENNIFER D. LAMAN 1719 TEYTON RANDOLF COURT NEW CUMBERLAND, PA 17070 DATE OF NOTICE: APRIL 7. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff J -,-~ - " FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MORTGAGE COMPANY- WEST,F/K/A MELLON MORTGAGE COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY MATTHEW R. LAMAN JENNIFER D. LAMAN NO. 2000-508-CIVIL Defendant(s) TO: MATTHEW R. LAMAN 314 WOODLAND AVENUE NEW CUMBERLAND, PA 17070 DATE OF NOTICE: APRIL 7. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff "',' ~" ~"" 't, , CASE NO: 2000-00508 P SHERIFF'S RETURN ,L REGULAR ...J '. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE COMPANY WEST VS LAMAN MATTHEW R ET AL ' SHAWN HARRISON , Sheriff or Deputy Sheriff of ""(::'.'jj.~ 4~~ Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE LAMAN JENNIFER D was served upon the DEFENDANT , at 0018:15 HOURS, on the 2nd day of February, 2000 at 1719 PEYTON RANDOLPH COURT NEW CUMBERLAND, PA 17070 JENNIFER LAMAN by handing to a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. Prothonotary S~~~4C~t R. Thomas Kline 02/09/2000 FEDERMAN & By: Deputy ... , -- I REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE No. 2000-508 Lebanon, PA, March 21, 2000 CHASE MORTGAGE COMPANY-WEST vs. FRANK FEDERMAN, ESQ. (RETURN TO CUMBERLAND CO. SHERIFF) MATTHEW R. LAMAN DOCKET PAGE 14852 STATE OF PENNSYLVANIA } COUNTY OF LEBANON } SS: Deborah A. Miller, Chief Deputy Sheriff, being duly sworn according to law, deposes and says that she served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon MATTHEW R. LAMAN, the within named DEFENDANT, by handing a true and attested copy thereof, to him, personally, on March 9, 2000, at 12:15 O'clock P.M., at the Sheriff's Office, 400 South Eighth Street, Lebanon (city), Lebanon County, Pennsylvania, and by making known to him the contents of the same. Sworn to and subscribed before me this 21st day of March, A.D., 2000 ;;;:;~~. -..h ,/ Notary Public NbTARIAL SEAL oJ!;", NCY L. STARNER. Notary PwMic l,ban,", L ,banon C"ntJ. Pa. ~~_~~I~~_~,~p~e~ AlItllst B. 2002 SO ANSWERS, ;t::5~ If. h-~ CHIEF DEPUTY SHERIFF ~~5 ~~t/,a,'1(. 4~' SHERIFF'S COSTS IN ABOVE Advanced costs paid on 3/9/00 Check No. Costs incurred: Refund: Check No. 7930 PROCEEDINGS 70954 Amount Amount Amount 100.00 26.25 73.75 All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 ",-"'..'~"< 0' ..', ;'""'~<,_,;,,, ~.,,,'__,, ,'.,~Y,,'" ._ , , i FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Chase Mortgage Company West f/k/a Mellon Mortgage Company : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-508 Civil Matthew R. Laman Jennifer D. Laman Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Matthew R. Laman is over 18 years of age and resides at 314 W oodland Avenue, New Cumberland, P A 17070. (c) that defendant Jennifer D. Laman is over 18 years of age, and resides at 1719 Teyton Randolf Court, New Cumberland, P A 17070. l' This statement is made subjeet to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~d W~4- FRANK FEDERMAN Attorney for Plaintiff , ' I .' ~. ^ (Rule of Civil Proeedure No. 236 - Revised) Chase Mortgage Company West flk/a Mellon Mortgage Company : Cumberland COUNTY : Court of Common Pleas Plaintiff : CML DMSION vs. : NO. 2000-508 Civil Matthew R. Laman Jennifer D. Laman Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on Anril /q .2000. ' -B,v L/,a.--..." .> Q '7fo?/2/-rc.IDEPUTY If you have any questions eoncerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TmS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ~~i"~I.!U~~~' - "'""'.........~Il$iIiiI/:l ~J~ ,'''.' -'-i . . . t ~ ~ ~ 't :-0 D - 0 ~ n CJ .(J () ~ -v c..: Cj 'n ~ 7- :1:10> j -DC;' -,-, ~ ~ p:: l!)L;'-, :;.";:;) - Ti ;,;>.:f:- -;-j, Tl l1' ~ r'~ rr, ~'_. '.0 1;:':1 V} "-'". k f' -..... ~"':- ("'J 1.. ~:C~; -~jC) ~.~ ""t----,-, ij~ :X; :;;--0::-1'1 'o:;:},(S '2 l5n1 ...;:.. ~ :~ --; .}:J --< <:J -< . ~- " " ~ ~ . ,j , it PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Chase Mortgage Company - West, f/k/a Mellon Mortgage Company Plaintiff, Cumberland County v. No. 2000-508 Civil Matthew R. Laman Jennifer D. Laman Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due) $114.911.14 / Interest from 4/18/00 - 9/6/00 $2.663.49 and Costs (per diem - $-18.89) $117.574.63 TOTAL , ESQUIRE RPLAZA F FEDE TW PENN CEN SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. 3f4-, WDC>A{~~ Nv.-U CUwt&..v[C4vLfJA 11070 >- If) ~ a: ;<( M ~ Z :UJ~ :;;:'4 0-0 "QO :c ::.):S --, I "jf-- :)3: ',.L;-,..L a... ~15 0 ''75:' :~ :ws: ',-'tJ) :::3:2: ~I.U >- o::z ::L: ""= LU!..U t-' :c mo- LL ;;;;: 0 0 ::;:, ('1.... "-=> C) D ~ >-t:I "l:l c:jz ~. ~ :s:.., - !t (I) ~~ p,. g:J~ '" ('1 ~ '" ~ ~ 1S('1 i~ :s:'" ,., "d....:s: c..,:s: ~~ ~g '" e!.~= o I'!j ,t:l ::l "0 5IZ=: ~O a'~ o ,~ >-3 .g IJQ ~ 1:1 =: I:IIJQ ~ '-o!l 0 =- ~ .. =- :s:~ ('10 ~ ~ ~ ~ IJQ :;; ;0'" Ol'!j '" ~=-?:l '" .. :l! o '" ~('1 I'!j!:a < ~('1 - El !='?:l '!' 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DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northwest corner of Woodland and River A venues; thence in a Westerly direction along River Avenue, one hundred forty (140) feet to Oak Avenue; thence in a Northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Block "V", in the hereinafter mentioned Plan; thence in an Easterly direction along, said line,., one hundred forty (1.40) feet to Woodland Avenue; thence in a Southerly direction along Woodland Avenue, fifty (50) feet to the place of beginning. BEING Lots Nos. 25 and 26, Block "V", on the Plan of George W. Buttorff's Second Addition to New Cumberland, which Plan is recorded in the Cumberland County Recorder's Office in Deed Book N5. page 498. BEING known and numbered as 314 Woodland Avenue, New Cumberland, Pennsylvania. Tax Parcel # 25-25-0008-103 TITLE TO SAID PREMISES IS VESTED IN Matthew R. T Jlman and Jennifer D. Laman, husband and wife by Deed from Max E. Schmidt and Muriel M. Schmidt, husband and wife dated 8/31/95, recorded 9/1/95, in Deed Book 127, Page 755. , '~,",-",~~'~-"I~~:!l1HII,,\!i"'l.\'M~ ~l.iI~~ ~~ilIl \~)R '''----- ~ ~ ~~ ~ ~ 1"8 1" ""'- '-IS ~ ~ ~ ~ .{:;. " ~)t ~- :! -~ ~ ~ ~ " ~ "~ ~ J ~ ~~~ ~~.-\ ( " ""'.... 0 c::> 0 c:: c::> -n $: :x -j -OeD - i'l~:o mfn -< -)hi z.,., -~ b6 zc c::> CD",; b ~o ~:;!'1:7 .." 0" ~;() ::Ii:: zO ~O - om Pc .. :!5 z ~ :<l Ul -< " (W '" ~ ~Ilil ~ " FEDE~andPHELAN By: FItANKFEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Chase Mortgage Company - West, f/kIa Mellon Mortgage Company CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION Matthew R. Laman Jennifer D. Laman NO. 2000-508 Civil Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~Ilh' ~~"""""lIlll\lllliftn'*'1t4i~'mJii'.lill~lWiJiil~~~iMKai~*~,;.\i"Oll;i,~~;J!j!oilt.."""".' 11' H ""- illo>" " "'- ~'N_'lJIJ! 1lll>iIB!;i 0 CJ 0 C CJ -n S ::l: --I -ucCt ~ ~_'C -T1 rnrn -n'F Z::rJ - -"m :zC C06 5:Qz c:> 0 ~c --0 ':i!:ij ~Q, :J;: Q~ =- ~-L. (5 ?'c "" Z W ~ :<l (n . . , '~' \ , Chase Mortgage Company - West, f/kIa Mellon Mortgage Company CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION Matthew R. Laman Jennifer D. Laman NO. 2000-508 Civil Defendant(s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) Chase Morteaee Company - West. flk/a Mellon Morteaee Companv. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 314 Woodland Avenue. New Cumberland. P A 17070. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Matthew R. Laman 130 North Railroad Street, Front Palmyra, PA 17078-1739 Jennifer D. Laman 1719 Teyton Randolf Court New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~~. " . ' . 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Life Savings Bank 7751 Belfort Parkway Suite 150 Jacksonville, FL 32256 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 314 Woodland Avenue New Cumberland, P A 17070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 8. 2000 DATE ~11h~lili_i:i-'ljIw..~,*"~"-~lIllilllfi',~m>ll~-:Milt_,""'..,,,,,,,,,,,M<W!<;<;j';~'~'<;"~.;~~,,,,,,,"" ~.~ ~.......~'"' ,Co -'~ ~._~~.,.,.'" .~ ffii" .~ ~.. CJ CJ 0 C CJ -r1 -7 Z. --1 ::':> ~~ -U OJ :P" cnrn -" -(ih1 Z::n ,e'er zr;: CJ , 0, U)~:,7 ~~,I~ 2('"' """ ;r~ ~ .... -' --:>"" e__ ::r Co :-;/'0 15rrl ~6 - ~c .- ~ ~ ':-;J ~ (J'l Chase Mortgage Company - West, f/k/a Mellon Mortgage Company Plaintiff, CUMBERLAND COUNTY No. 2000-508 Civil v. Matthew R. Laman Jennifer D. Laman Defendant(s). May 8, 2000 TO: Matthew R. Laman Jennifer D. Laman 130 North Railroad Street, Front Palmyra, PA 17078-1739 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" i I ,I I il ',I I,j :j I' I Ii I, , Your house (real estate) at 314 Woodland Avenue. New Cumberland. PA 17070, is scheduled to be sold at the Sheriffs Sale on September 6. 2000 at 10:00 a.m. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Chase Morte:ae:e Company - West. f/kIa Mellon Morte:ae:e Companv (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. _'_ L~;. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SANE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 i-~- ~ , , , ~_. ,oc ! DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northwest corner of Woodland and River Avenues; thence in a Westerly direction along River Avenue, one hundred forty (140) feet to Oak Avenue; thence in a Northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Block "V", in the hereinafter mentioned Plan; thence in an Easterly direction, along said line, one hundred forty (140) feet to Woodland Avenue; thence in a Southerly direction along Woodland Avenue, fifty (50) feet to the place of beginning, BEING Lots Nos. 25 and 26, Block "V", on the Plan of George W. Buttorff's Second Addition to New Cumberland, which Plan is recorded in the Cumberland County Recorder's Office in Deed Book N5, page 498. BEING known and numbered as 314 Woodland Avenue, New Cumberland, Pennsylvania. Tax Parcel # 25-25-0008-103 TITLE TO SAID PREMISES IS VESTED IN Matthew R. Laman and Jennifer D. Laman, husband and wife by Deed from Max E. Schmidt and Muriel M. Schmidt, husband and wife dated 8/31/95, recorded 9/1/95, in Deed Book 127, Page 755. ~~IIIIliIll~W~~iIItl~ tlllllll :~~~~~al''lI'''''''''''''' b"'", ~ _.'''J ',", .... ~ . '" "II;, () 0 0 C c:> -r1' :;;::"" ::;:: ...-1 -,~~ :1:.." -OC):I :i:-~ rn"" -< f!.1:$= ~~~ 0 cfj% ,:) -,"-1~. ,-:"G -0 ," .t ~- :x O~ cC-' Le - aT Pc ., rl ~ ..p ~ (J1 ""~"" " _I . fri- AFt/IDA VIT OF SERVICE ( . PLAINTIFF Chase Mortgage Company - West, fJk/a Mellon Mortgage Company Cumherland County No.2000-508 Civil DEFENDANT(S) Jennifer D. Laman Type of Action - Notice of Sheriff's Sale SERVE AT 1719 Teyton Randolph Court New Cumberland, P A 17070 Sale Date: September 6, 2000 SERVED Served and made known to ~C:J ~~~efendant, on the 6J. ,,-t:/..... day of 111~ ,200.0, at f.p;L($,o'eloek}!!.m.,at {r/g ~R~~ CJ~JP.JA.J(},hm-6-uJ~mmonWealth of Pennsylvania, in the manner desetibed below: X Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in eharge ofDefendant(s)'s residenee who refused to give name or relationship. Manager/Clerk ofplaee of lodging in whieh Defendant(s) reside(s). Agent or person in eharge ofDefendant(s)'s offiee or usual plaee of business. an offieer of said Defendant( s)' s eompany. Other: ..-1..1 I CJ 0_ Desetiption: Age C) 1- 3 $" Height~ 'i! Wei~ Raee c.,.J Sex F Other I, {-{Iff? IE ~ L ' Gr/(G6J ,a eompetent adult, being duly sworn aeeording to law, depose and state that 1 personally handed a true and eorreet eopy of the Notiee of She tiff's Sale in the manner as set forth herein, issued in the eaptioned ease on the date and at the address indieated above. Sworn to and SUbser~'Il>}d before me this .iJJL'f'\jay f..- of~20 ". fl.- N ot..ry: " d By: x^~ OT SERVED /' On the day of ,200_, at o'cloek _.m., Defendant NOT FOUND beeause: Moved Unknown No Answer Vaeant Other: Sworn to and subseribed before me this _ day of . 200 _' Notary: By: Attornevfor Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Snite 900 Philadelphia, PA 19102 (215) 563-7000 ~~~lli~ii~~~!l;,_","l\~,,,~,~~,'~R"" Ai' """Ii -- "" 0 0 0 c: 0 :s:: ''1 c... -or).) c::; "-I fllrn T 2:n z ,"';-:n 11'-- 2'-' I :gtj GO J.> W ;:S;2~ '::J . <C) -0 ~-if.~ EC) :x ,;~:B' 2" ::::-~o :;;:8 r:-? onl 2 --, -- w 55 -< CJ1 -< ~ , ,I, . '-,' AFI?IDA ''..IT OF SERVICE I PLAINTIFF Chase Mortgage Company - West, f/kIa Mellon Mortgage Company Cumberland County No.2000-508 Civil DEFENDANT(S) Matthew R. Laman Type of Action - Notice of Sheriff's Sale SERVE AT 130 North Railroad Street, Front Palmyra, P A 17078-1739 Sale Date: September 6, 2000 SERVICE IS IN LEBANON COUNTY. SERVED Served and made known to JY)f1Jlk-<<.J 1(. >) ~' ,Defendant, on the d- if -u. at':,;:/?' .o'e1oek~.m.,at ,-?,o,JK~#J -fJ.~1 of Pennsylvania, in the manner described below: day of IYJ '(J . 200,Q, P",- J . Counuonwealth ><' - Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in eharge ofDefendant(s)'s residenee who refused to give name or relationship. Manager/Clerk ofplaee oflodging in whieh Defendant(s) reside(s). Agent or person ineharge ofDefendant(s)'s offiee or usual plaee of business. an offieer of said Defendant(s)'s eompany. Other: Deseription: Age-;(I-2Jc/ Height~ ~ Weighti100-f Raee w.. Sex MOther I, /<QI'@i\. L. d r.e.'€J') ,a eompetent adult, being duly sworn aeeording to law, depose and state that I personally handed a true and eorreet eopy of the Notiee of Sheriff's Sale in the manner as set forth herein, issued in the eaptioned case on the date and at the address indieated above. Sworn to and subserfued before me this ~d of 'J11V~ ,2000. Notary: R-l--- Bl,.t--v--X'~ NOT SERVED On the day of ,200~ at o'cloek _.m., Defendant NOT FOUND beeause: Moved Unknown No Answer Vaeant Other: Sworn to and subseribed before me this _ day of .200_. Notary: By: Attornev for Plaintiff Frank Federman, Esqnire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 , ~~llI!i!iIIiUif&~;lillMij-";~oI.liiiijll:.MiM' ~"'~M",",,,,<,,,,-,-,,,*,,';b-,~,,",,>w,,,",';J.c'A~jl / - ,CJ .~ II11d .~' , e Cl 0 Cl -1"1 s: S:: ,--I -0 DJ ,- ~~f-~ mfTl % Z:>J I '~!28 zc;:: ~~~ \.0 ;j r :..'10 kG -0 g~ Pc ::;;: zc: ;"---:;il1 - . ~ Pc -, ~ W ;g ::tJ en -< , ~--~~" ~'.~ , . "~ -......."'. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MORTGAGE COMPANY - WEST, F/KlA MELLON MORTGAGE COMPANY Plaintiff CIVIL DIVISION vs. No. 2000-508 CIVIL MATTHEW R. LAMAN JENNIFER D. LAMAN Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CHASE MORTGAGE COMPANY - WEST. F/KlA MELLON MORTGAGE COMPANY, hereby verify that on MAY 11. 2000 AND MAY 30. 2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on MAY 11. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ERMAN, ESQUI E r Plaintiff Date: AUQust 14. 2000 "^ ~ -. . ~ ~ lO..:a Chase Mortgage Company - West, flk/a Mellon Mortgage Company CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION Matthew R. Laman Jennifer D. Laman NO. 2000-508 Civil Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Chase Mortgage Companv - West. f/kla Mellon Mortgage Companv, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 314 Woodland Avenue. New Cumberland, PA 17070. l. Name and address of Owner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Matthew R. Laman 130 North Railroad Street, Front Palmyra, PA 17078-1739 Jennifer D. Laman 1719 Teyton Randolf Court New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ;~' - '"= ~-~- 1_ I~ "'" "~'""'~>. 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Life Savings Bank 7751 Belfort Parkway, Suite 150 Jacksonville, FL 32256 AND 8031 Phillips Highway #6 Jacksonville, FL 32256 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 314 Woodland Avenue New Cumberland, PA 17070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.8. Sec. 4904 relating to unsworn falsification to authorities. August 14. 2000 DATE FAA.NKFEDE ~~Q~ Attorney for Plaintiff '=,k4~ ~_ ~--,- "~"'~ , ~"~~"","""",,___iIiIiIlIiIliIiI__ .lIIiIIlliIIiIlIl!!liIlIIHIIi8jl_~ ."..., ~r S n - - - - - - '" 00 ~ Z V> ... 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SAVINGS BANK 8031 PHILLIPS HIGHWAY #6 JACrrSON7ILLE, FL 32256 PS Form 3817, Mar. 1989 ... . 4 ~ ~., I/. ~ '" :1 , , .~ -.: ."-",,, .. .- -- '....-, -~ .= ;=- ii;~;' ''-~ C':l ; .j" "- , hr'C-.i I , "~"./,-",,--;q- 1"'\ .;.", -'.'H..;~ ~:f ;%...;;-~:::;; ~.,. . ;<' "~:;;..a : ,J J,. ,.~.)"'.:-1:0 . ..!~... ,.,,,,-'00 . -:or.. "'):1"0',,,.'" " ,):'/- ~:.../;; ) ".:;f~~U,~-!,- ::: ----~ 1"-;(.1 ;:l~.'''';' C,.' r ',/1',,,,"', ~N t...'"" ji;'.'~""1 z:-' / \.:)$ ''tl7 ~ r><t!...~.' '~ ,~,.., ('l. ....-..,....< , ,,::' - -., ,~~~,.-lti. ". . . ,- I , ,u....."', ~._""-, . " "__~~_~I~~'k~ - ~ ~.. , I SENDER: I ~ Cheek box at right if you require Restricted Delivery, :f;~ur name and address on ~he reverse of this form so that we can return this card .. . A~itthis'!~rm to the fi?nt of t~ mailpiece, or on the liack if space dOes not permit. . T~RErtum.f;liaceipt will show to whom the article was delivered and the date delivered. 3. Article Addressed to: I also wish to receive the following services (for an extra fe, ,p< Restricted Delivery Consult postmaster for fee. 4a. Article Number :'lI\'nllliW R. !..\..'Wl 130 NORTll RAlLOOMl S'BRF.T. PAL.~. PA 1701:1-1131 P 974 910 746 " 4b, Service Type )( CERTIFIED ate of Delivery 5. Regeived By: (Print Name) jY)AIT )-Ie (fl 6. Signature: (Addressee or X -' PS FORM 3811, December 1994 ,t'V\sB,.. .. ; ,." ~------- Dq/llestic Return Receipt ...0 RETURN 1 POSTAGE - POSTMARK OR DATE RESTRICTED DELIVERY ~ ~ ',i'r i'., RECEIPT J - CERTIFIED FEE + RETURN RECEIPT SERVICE ~)9'(" TOTAL POSTAGE AND FEES SENT TO, NO INSURANCE C.g:i~RAGE P VIDEO- "...... -.,. NOT FO~.~~~rw~~f1J,l?.!'!AL MAIL SE E SOE ;,,<~TI~E1r. H.~ l....&';A..~ 130 ~OR!..-i xL>\U...ROisJ) S'J'R.E:6T .,. F:JJJ0;1' i'Al.~R"".. 21\ 1707::>-1739 pWl K f'- o ,., <r .:r f'- <r Cl. PS FORM 3800 US Postal Service Receipt for Certified Mail ----.---------- ----------. t~----------------------- I I f'- .:r f'- POSTAGE POSTMARK OR DATE RETURN ')? > RESTRICTED OELlVERY RECEIPT ..-.- , CERTIFIED FEE + RETURN RECEIPT , " SERVICE , ,- TOTAL POSTAGE AND FEES ,19) -~ SENT TO: NO INSURANCE COVERAGE PROVIQED- " NOT FORs~~~~t~~r.AL MAIL i':; ,. 1 ';f.~1l1nR -n !....~~..,x , ... lill) 't,t.ltfY~~ ,J:t~~~l)C~...~ CUiJi:T . " ~~~~ C1J!o18E:~LAi~i) , fA 17G7C OW1 ~ o ,., <r .:r f'- <r Cl. PS FORM 3800 US Postal Service Receipt for Certified Mail ~~i~lillliuilli;J>iII,"""_;i;;;~Ill~.B!IO~l;m;iW;8!",;io,~"""".",*"!iIO""",,,",,,~~ - ~ ~. "'-" II~ """""-~'"""- ." ^' _100: " 0 0 (~ C 0 u~ --n ~ r1'1 f!--~ r'- 2~,,; C) -- 2:C , 'rtf'l: (n~L-. -.J <I? -<2~ r.-., :;C) ~'--' :..'" ~o ,;;j?~ ).>0 c r:? Cirn 2: s;t :< c- r>:> ::J:J -< . ~~. ", ~;; FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE 1.0. NO. 12248 SUITE 900/TWO PENN CENTER PHILADELPHIA, PA 19102 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CHASE MORTGAGE COMPANY WEST F/KlA MELLON MORTGAGE COMPANY CIVIL DIVISION VS, CUMBERLAND COUNTY NO. 2000-508 CIVIL MATTHEW R. LAMAN JENNIFER 0, LAMAN PRAECIPE TO MARK JUDGMENT TO.THE USE OF PLAINTIFF AND ENTRY OF APPEARANCE NUNC PRO TUNC TO THE PROTHONOTARY: Please mark the jUdgment in the above-captioned matter to the use of THE BANK OF NEW YORK, AS TRUSTEE OF THE C-BASS MORTGAGE LOAN BUYOUT TRUST 2000-A, 101 BARCLAY STREET, NEW YORK, NY 10286, ENTRY OF APPEARANCE NUNC PRO TUNC TO THE PROTHONOTARY: Kindly enter my appearance on behalf of THE BANK OF NEW YORK, AS TRUSTEE OF THE C-BASS MORTGAGE LOAN BUYOUT TRUST 200-A, Use Plaintiff. Date: October 10, 2000 "',, ~.iIiiiiIii "'0 ..~, ,"",> I'tIIt~ .""",."",,~ . - - o c <" -of,=~ fTl,',--' ~ t~~~ ~~i~; ~C~; ;i;2 :z: :::< c- O o C} -1 ". '. ." ~. ".... o GO " " ~'J '...../ (~.; " .c~ , ~ -- CJ C5f"n --; ~:;:::: ':J.J .< - - N .J7 . ~- ,,--',,', ,- "', , . 'ii-, STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, ________________________________________ ______________________________________ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ____n____nnn Bank of New York Tr for C-Base Mtg Ln Buyout Trust 2000-a . - -- -- - -- - -- -- --------------'- -- --- -------------- - _ __ _____ __________ ___ __ _ ____ __ _____ _ IS the grantee the same having been sold to said grantee on the n~_t_~_____________n___n__n______________n_ day of September xx2000 ___n_n______nn__n___n_____________ A. D., 19________, under and by virtue of a wriL_n__________ Execution . ed h 10th ________________________________________________IS5ll on t e _____________________________________ May 2000 day of ____________________n_n_ A. D" 11\:'nn_' out of the Court of Cornman Pleas of said County as of Civil 1(x2000 ___ _n__ ___ n_____ ___ __ ___ __ _ _.. _n __ _ _ __ ___ ___ __ _____nn ___n____ n n n n n n __ _ Term, 11I_ n ____ i r' I: I'] i: i' Number __~Q!l_________, at the suit of _____<;:!>_,~'!_.U!.t:.lL<;:_o__=_\\l~.!'_t:._~l<_'!.J!~.1)_~!U!.t:.lL<;:_~n_---____n___ 1 Ii 'I ________ __________ __ ___ _____ ___ ____ againsL_ _~_~~ ~~~_~ _~_ !:~~~:'_ _~ _!_':.~~~_f_:.:_ ~_______ __ __ __ _ is !,j i: duly recorded in Sheriff's Deed Book No. _~~~________, Page _~?_~___n__' IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this __.!.1~___ day of ---~----7-----%.A. D., ~~~- ~~~;}~~-~o;~ Recorder 01 Deeds, Cumberland County Carlisle PA M, CommiSsiOJj bpire.s the Fil$\ Mandi, 01 Jan: 2002 co,1 i . Chase Mortgage Company-West F/k/a Mellon Mortgage Company -vs- Matthew R. Laman Jennifer D, Laman In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-508 Civil Richard E. Smith Deputy Sheriff, who being duly sworn according to law, says on July 13,2000 at 7:16 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Matthew Laman and Jennifer Laman located at 314 Woodland Avenue, New Cumberland, Cumberland County, Pennsylvania according to law. Harold J. Weary, Deputy Sheriff, who being duly sworn according to law says he se~ed a true copy ofRe~1 ~state Writ Notice Poster ~d De~cription in the above ~ntit1ed ".5\l~~ actIOn upon one of the Within named defendants to Wit: Jenmfer D, Laman by making ./ . known unto Jennifer Laman at 1719 Peyton Randolph Court, New Cumberland, r Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same, R. Thornas Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry for one of the within named defendants to wit: Matthew R. Laman, but was unable to locate him in his bailiwick. Hetherefore deputized the Sheriff of Lebanon County to serve the within Real Estate Writ Notice and Description according to law. Lebanon County Return: Basil E. Achey Deputy Sheriff, being duly sworn according to law deposes and says that he served the within Real Estate Notice & Description upon Matthew R. Laman, the within named defendant, by handing a true and attested copy thereof, to him personally, on May 18,2000 at 12:15 o'clock P.M. at the Sheriffs Office, 400 South Eighth Street, Lebanon (City), Lebanon County, Pennsylvania, and by making known unto him the contents of the same. So answers: Basil E, Auchey, Deputy Sheriff Lebanon County. R. Thornas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following Manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Matthew R, Laman, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to 130 North Railroad Street, Front, Palmyra, PA. This letter was mailed under the date of July 11,2000 and received by Matthew R. Laman on July 22, 2000 the return receipt card signed by Matthew Laman. R. Thornas Kline, Sheriff, who being dcly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Matthew R. Laman by regclar mail to 130 North Railroad Street, Front, Palmyra, Pennsylvania. This letter was mailed under the date of July 23, 2000 and never returned to the Sheriff's Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Jennifer D. Laman, by regular mail to 1719 Peyton Randolph Court, ~._'~. - ~,: New Cumberland Pennsylvania, This letter was mailed under the date of July 14,2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premise at public or out cry at Court House, Carlisle, Cumberland County, Pennsylvania on September 6, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00 to Attorney Dale Shughart Jr for The Bank of New York, as trustee off the C-Bass Mortgage Loan Buyout Trust 200-A. It being the highest bid and best price quoted for the same The Bank of New York et allO 1 Barclay Street, New York, New York being the buyer in this execution paid to SheriffR. Thomas Kline the sum of$ 937.68 it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Out of County York County Lebanon County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 30.00 18.35 15.00 15.00 30.00 10.00 .50 1.00 21.70 6.75 15.00 30.00 18.00 39,75 29,00 293.30 288.30 23.53 25.00 27.50 $937.68 Pd By Atty 10/13/00 Sworn and Subscribed To Before Me sOE ~-~ ?"'1 ~ ~t:.,- ~ R. Thomas Kline, Sheriff BY~'" A~ Real Estate Deputy This.2 /, ~ay of @ e..a.- A.D. ~Q /h,PI,-,/# rothonotary v ~' ~ 3D ,oJ I, :)0 ~1J 201 rn.. !~' '~ ~.J, ,- .. Chase Mortgage Company - West, flk/a Mellon Mortgage Company CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION Matthew R. Laman Jennifer D. Laman NO. 2000-508 Civil .. Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) Chase Mortgage Companv. West. fIkIa Mellon Mortgage ComDanv, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 314 Woodland Avenue. New Cumberland. PA 17070. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Matthew R. Laman 130 North Railroad Street, Front Palmyra, PA 17078-1739 Jennifer D. Laman 1719 Teyton Randolf Court New Cumberland, PA 17070 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None / / I I I .. : . ~~, ~![ " Aame and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Life Savings Bank 7751 Belfort Parkway Suite 150 Jacksonville, FL 32256 5, Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) t'i ,i None .. ri i) l! :i :, H " \! I II :,] 1,1 ,. 'I t: I: II ,: ;1 .; :1 H 1'< " !! i! ,; .' Ii ,I :1 7. Name and address of every other person whom the plaintiff has knowledge who has any iliterest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 314 Woodland Avenue New Cumberland, P A 17070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities. May 8. 2000 DATE ._._ ,,' --"", ,p,:::'RlfF Orr"-- -- "," :,'J~T't Cl~i" . ., '\~1 \ \ PC \~ \.; ". . -"""""-- l\ (;1 "'/ f".\; 1;-\ ~~~.. -,...,. \ . j ,,~ ~._",""""1~_"",,,-,.,,,,,,,,,""'''' ~, ~-,.., 006ltlillll~~ " ~ , , " ~ , d, " . .J Chase Mortgage Company - West, f/kla Mellon Mortgage Company Plaintiff, CUMBERLAND COUNTY No. 2000-508 Civil v. Matthew II. Laman Jennifer D. Laman Defendant(s). May 8, 2000 TO: Matthew R. Laman Jennifer D, Laman 130 North Railroad Street, Front Palmyra, PA 17078-1739 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 314 Woodland Avenue. New Cumberland. PA 17070, is scheduled to be sold at the Sheriff's Sale on SeDtember 6. 2000 at 10:00 a,rn. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Chase Mortgage ComDanv - West. f/kla Mellon Mortgage ComDanv (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TmS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: l. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ,~' =~ ~~ ,~ '.. ,1. Y.' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to rernain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ,,,"",,,j~-- , ~ ,j A" TI . - -. DESCRlPTION ALL THA T CERTAIN tract of land situate in the Borough of New Curnberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northwest corner of Woodland and River Avenues; thence in a Westerly direction along River Avenue, one hundred forty (140) feet to Oak Avenue; thence in a Northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Block "V", in the hereinafter mentioned Plan; thence in an Easterly direction along said line, one hundred forty (140) feet to Woodland Avenue; thence in a Southerly direction along Woodland Avenue, fifty (50) feet to the place of beginning. BEING Lots Nos, 25 and 26, Block "V", on the Plan of George W. Buttorff's Second Addition to New Cumberland, which Plan is recorded in the Cumberland County Recorder's Office in Deed Book N5, page 498. BEING known and numbered as 314 Woodland Avenue, New Cumberland, Pennsylvania. Tax Parcel # 25-25-0008-103 TITLE TO SAID PREMISES IS VESTED IN Matthew R. Laman and Jennifer D. Laman, husband and wife by Deed from Max E. Schmidt and Muriel M. Schmidt, husband and wife dated 8/31/95, recorded 9/1/95, in Deed Book 127, Page 755, ~ I, I II i'~ ~= .-r,.,....- r,r ^,:,,,- ~;H:.Rlff:. 0',,,,,,,."" ,.'" ''',rY' e \ ";, ~ '~ '" I, " ~" , K~y \ \ L\ . , , " , " 0 L,J tl ~ , '" , ' ~" \,'.,'-,J,',j,;; \!\ F t:.. ~ ~ I "( ~) . '" . 0- ,ll!:1I ~.~,~..., ~~Im'Ili\~~~fiI"mrl:l J.,..". ~... ~'IM!JlIi'IIIIlNlQl9lPl!l!ltI~~ .. "~. '< . ~ ;, i " " , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 2000-508 CIVIL 19_ CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Comnanv Chase Mortqaqe Company - West f/k/a Mellon Mortgage PLAINTIFF(S) from Matthew R. Laman Jennifer D. Laman 314 Woodland Ave. New Cumberland. P.". 17070 (1) You are directed to levy upon the property of the defendant(s) and to sell DEFENDANT(S) r=:PP lp~l rlpr=:r'r;p+;on " (2) You are also directed to allach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an allachfflljl)l hfiS been issued; (b) the garnishee(s) is/are enjoined from paying any , t. '" '^,' 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 allachment is found in the possession Of anyone other 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 S114.911.14 Interest from 4/18/00 - 9/6/00 (ner diem - $18.89) Ally's Comtn - % Ally Paid $194.79 Plainmt Paid L.L. $2,663.49 andDue Prothy Costs Other Costs $.50 $1. 00 Dale: May 10, 2000 Curtis R. Long Prothonotary, Civil Division by: ,~~ ~, ~~. J:ff Deputy REQUESTING PARTY: Name Frank Federman. Esa. Address: Two Penn Center Plaza Suite 900 Philadelohia. PA 19102 Allorney for: PJ aintiff Telephone: '(.1:>1 'i) 'i1i3- 7000 Supreme Court 10 No. 12248 __WlIl!Ii:lI>lllliI!;iWi.uai~' r ~:JliIU"Ill.~<IIl';~~i~_..~_.,",~ , -1lli!Il!ll~ilIIil~.iIRI" liliIIIli--- ...- REA[ ESTATESALE No. "..... On tYYl ~ J ~ . ~ the sheriff levied upon the defendants Interest in the real property situated in/Y1.4J ~~ Cumberland County, Pa" known and numbered as: 31'1 wurntlc _/ 4..,." <w - /'jIw ~nd more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. O'Ie(1'J"t/~. ~ ~1~ . .~ ~I ;J!ji ffi V1 ;,1 \/ }\-"j}. ~:': i,1 :',':] d , . .,,, 1'1 II k~U (' T: !:p n l'. .' ," ~,'\ , ' "~I-' . .... ..10nJ M" " "" u, ~~\~i'jW~ ~~I\J .-hl :;<~\j~1\1 ~,--=- ",'", ~ ,""'" . ~ ,.' ',-,,=-,,=', ~ ~ ~.' __""".'. : HEALEST.~f.f~.A(F,N.q..2.'. . . . . Writ No, 2001l-51)8 , 'CivilTerm . .. i~ Chase Mortgage Company-West '~ -_fM~ Mell,on MO,rtgage, , ~ P,QJ!lP'any , vs' , Milttfrew'R. Laman , - Jenmlel'D, Laman ~t:tY~ F'rallH fe.9,~man OES-cRIPTION ~ALl. THA1...CE:tiAThUratLoJJand situate ~l:phQ..BorQygl1 oJ ~~. C;:umGe!l~nd! County !;'9o;::qmb~~~, ,J.1}9, ?t.at~ ofP~!!syl\'ani<l, .:.:: m'ore particularly bOunded and deSl:rlbed ilS :-ffill6Ws-;-fov.;t: .:: ~ :~',...:....JjEQr\NING at J point On the Northwest :::;-;-CQufer-o( \\l(){)dland and River Avenues; iijenl=C, in it ,\ Ve~terl~' djrectio.n ~long, ~iver :'"' ~,u~, one[1u~4ie~i9r!J' (14q) fe~t T6 Oak ~\i'.e-nJIe; thence In a"NorllierIv directIOn along ~~v,enue; fift)1 (5tIi ft>e! to "the liiie-of lot , 0.44.- 'Block "V", in. llit.' hereinafter e Man; th~nce in an Easterh along said lin~, one, hundre'd fort}' 'I to Vi'aodland A\'enue;, thence in a y-'direct1on along Woodland Avenue, feet lei the place of BEGINNING. ,NQ.tcits No~.25'~n.d26) 13locl<''\''',on ~ ""J10 of Georg,e'~. ,Buuorff's Setond ~lk!.]fiQll to. New ,C!:1mb:e!lang~,which Plan is ~c"arded in the Cum1erJand County ~ecdfaer'roffiC€1fi' ,~ed13oQk N5 pa.ge 498, ~ ,;JQNG 1910wn ra,lld numper,ed ,as 314 Fl~i:iLtn.d. Av~t'!ut}". ~e,~' Cumb~rland, t'~n,I1S.}'I\'ama. ',' . c-=':' ,,'~' TaxParcel #25.25-000-S~103. EtimE to SAID PREMISES IS VESTED ~-- }; alev.:'-KLaman and Jennifer u. [iman, ,,_,~bancl.and wife bv Deed fr.om Ma): E. ~s,'9.iiDidt JlrF",,?\turi~1 ,r~'" ?~~l;l'lJdth h.!1sba~d ~a-".ife, aated: si31}95.1 recoroea 9/1195, In ~~~ej--S~9k, 1~7" ~~ge 755.' " ------ '----~'--"~~<,~---, l;/>J" ~ ~ ~ ~....... "1"-'" " I:! r: THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication l,i " , Under Het No, 587, Hooroued May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the CommonWealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT- NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since: That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 1 st, 8th and 15th day(s) of August 2000. 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 Mis?neous Book "M", '::~~~':;,:~ ---------1~~-----~~---- COpy Sworn to and subscribed before h's 30th day Augus 00 A.D. S ALE #21 Notanal Seal Terry l. Russe<<, Notary Harrisburg, Dauphin Cou My Commission E,pires June 6, 2002 N TARY.PUBLIC Member, Pennsylvania Association MofiIillillmission expires June 6, 2002 :i \1 " !i Ii 11 ,1 ;1 II Ii I' " ;1 CUMBERLAND COUNTY SHERIFFS 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 $ 286.80 1.50 288.30 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. THE PATRIOT-NEWS CO. B~.................,................_....,.,......................_ II '11~.:i.I' <,' ~ l~ = "' REAL ESTA'llE SALE NO. 21 Writ No. 2000-508 Civil Chase Mortgage Company-West, f/k/ a Mellon Mortgage Company vs, Matthew R Laman and Jennifer D. Laman Atty.: Fnmk Federman DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of New Cum- berland, County of Cumberland and State of Pennsylvania, more particu- larly bounded and descrtbed as fol- lows. to wit: BEGINNING at a point on the North- west corner of Woodland and River Avenues; thence in a Westerly direc- tion along River Avenue. one hun- dred forty [140) feet to Oak Avenue; thence in a Northerly direction along Oak Avenue, fifty (50) feet to the line of Lot No. 24, Block "V", In the here- tnafter mentioned Plan; thence in an Easterly dJrection along said line, one hundred forty [140) feetto Wood- land Avenue; thence in a Southerly direction along Woodland Avenue. fifty (50) feet to the place of begin- ning, BEING Lots Nos. 25 and 26, Block ..V', on the Plan of George W. But- torffs Second Addition to New Cum- berland, which Plan 1s recorded in the Cumberland County Recorder's Office In Deed Book N5, page 498. BEING known and numbered as 314 Woodland Avenue. New Cumber- land, Pennsylvania. Tax Parcel #25-25-0008-103. TITLE TO SAID PREMISES IS VESTED IN Matthew R Laman and Jennifer D. Laman, husband and wife by Deed from Max E. Schmidt and Muriel M. Schmidt, husband and wife dated 8/31/95, recorded 9/1/95, inDeed Book 127, Page 755. '"' - PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P, L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being dilly sworn, according to law, deposes and says that the Cumberland Law Joumal, 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 alllegal notices, and has, since January 2, 1952, been regnlarly 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 28,AUGUST 4, 11,2000 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 rnatter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~ Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before rne this 11 day of AUGUST. 2000 NOt . sw- '. LOI& E. S/'IYDEI,~ PubIc Cortlole Ion>, eu'""-rtG..ctcounty, PA My Commiaion Expi... Morell;', *1 .. '-~, I> , \: ii'! iil (j I, I" i~ I:' , t': i I: i" i I! , , , [' I'; , ie' I] i .'1 'i I .1 :1 ~i [j " :j , j 'I 'I , ;1 I " '1 i ,'j 1 1 1 , A 11 , 'I 1: ,j "j , ;~ 'oj .f , ;;! '~i "~ , t~'" "','.o~ .i: ',lit ;? ~I ;~, ....' ;:'.J ,~-;::.;., ;;;,~. ,'Y) ~ ,:J~ .:b ,^- ...... ,..~../ I:!::! \::;, "",:.:tJ .'1-) [:;r 4~ 4 ";', ii- ~ ~ J ..- ~ 1 u ~6'881 '" ~ '" (D:4'~~ '" _1-1 0 '"OO~1-11 >g[$ ~(1) (1) -,)W<:l"O 0..0 0 1-1 ~" " 0 v.> ::;.... ~ ~ go (1) ::; <:lo 1$ $: '" (1) , ....:.J 0., \: I ' ' 'I, 1'" , , : ~ ~ ~" .' " , " ~ j.. """ ~ (Rule of Civil Procedure No. 236 - Revised) Chase Mortgage Company West f!k!a Mellon Mortgage Company : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-508 Civil Matthew R. Laman Jennifer D. Laman Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on ADril ICf . 2000. --.Bv k2~ 2 ~At'0EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVJlOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** , -' r' FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Chase Mortgage Company West t'lkIa Mellon Mortgage Company 3100 Travis Street Houston, TX 77006 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. Matthew R. Laman 314 Woodland Avenue New Cumberland, P A 17070 : NO. 2000-508 Civil Jennifer D. Laman 1719 Teyton Randolf Court New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Matthew R. Laman and Jennifer D. Laman, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 1/1/00 to 4/18/00 $112,468.45 $2,442.69 TOTAL $114,911.14 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~{}~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. 17 ~ ~ DATE: LI/tqf(){) IsjULA-/;:')K-_ . , , PROPROT '*THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBTW AS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. , ~, ",Ll', '" ,. ,",',n~~, "r 'i~",~_;,'~" ,j",., ~ i , FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CHASE MORTGAGE COMPANY- WEST,F/K/A MELLON MORTGAGE COMPANY Plaintiff ATTORNEY FOR PLAINTIFF i I i j I I I I COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY MATTHEW R. LAMAN JENNIFER D. LAMAN NO. 2000-508-CIVIL Defendant TO: .JENNIFER D. LAMAN 1719 TEY'l'ON RANDOLF COURT NEW CUMBERLAND, PA 17070 DATE OF NOTICE: APRIL 7. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff " FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MORTGAGE COMPANY- WEST,F/K/A MELLON MORTGAGE COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY MATTHEW R. LAMAN JENNIFER D. LAMAN NO. 2000-508-CIVIL Defendant(s) TO: MATTHEW R. LAMAN 314 WOODLAND AVENUE NEW CtJMBERLAND, PA 17070 DATE OF NOTICE: APRIL 7. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOClA nON 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff :1 I' ',I '<'2 ,,"_" <~ SHERIFF'S RET~5N,\ REGULAR 4~ I i I .I ! I I I I 1 J , , CASE NO: 2000-00508 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE COMPANY WEST VS LAMAN MATTHEW R ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of i 'I I 1 j Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LAMAN JENNIFER D the DEFENDANT , at 0018:15 HOURS, on the 2nd day of February, 2000 at 1719 PEYTON RANDOLPH COURT NEW CUMBERLAND, PA 17070 by handing to JENNIFER LAMAN a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: f.'~~t R. Thomas Kline me this day of 02/09/2000 ~ FEDERMAN & PH ~ By: Deputy her~ff . Sworn and Subscribed to before A.D. Prothonotary .. , ! i i I III! ,,_.~:, .,"" <''''') . ' ,,'~.. ",-,,", '-", ",", ,1: , ". REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE No. 2000-508 Lebanon, PA, March 21, 2000 CHASE MORTGAGE COMPANY-WEST FRANK FEDERMAN, ESQ. vs. (RETURN TO CUMBERLAND CO. SHERIFF) I .1 i I 1 I A '1 1 'I 1 j j ! 1 I MATTHEW R. LAMAN DOCKET PAGE 14852 STATE OF PENNSYLVANIA } COUNTY OF LEBANON } ss: Deborah A. Miller, Chief Deputy Sheriff, being duly sworn according to law, deposes and says that she served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon MATTHEW R. LAMAN, the within named DEFENDANT, by handing a true and attested copy thereof, to him, personally, on March 9, 2000, at 12:15 o'clock P.M., at the Sheriff's Office, 400 South Eighth Street, Lebanon (City), Lebanon County, Pennsylvania, and by making known to him the contents of the same. Sworn to and subscribed before me Notary Public SO ANSWERS, ;eJ~~~ CHIEF DEPUTY SHER FF ;/.V V /l/~ .s this 21st day of March, ;;r1l'~,~ y:~ ~/4.e':'-'L"'/ A.D., 2000 NOTARiAL SEAL. "?,,. NCY L. 5, ARNER. Notary Pwb!i. l'~'n". LeIlan.n County. Pa. -~-~;~~==-~'--~ ~p~,:_!; ,.~.~!:~:,~~_ 2002 J -<./.:;Y SHERIFF'S COSTS IN ABOVE Advanced costs paid on 3/9/00 Check No. Costs incurred: Refund: Check No. 7930 PROCEEDINGS 70954 Amount Amount Amount 100.00 26.25 73.75 All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 'l,", ~ J "" 1 , FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No, 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Chase Mortgage Company West flk/a Mellon Mortgage Company : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-508 Civil Matthew R. Laman Jennifer D. Laman Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its AHies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Matthew R. Laman is over 18 years of age and resides at 314 Woodland Avenue, New Cumberland, PA 17070. (c) that defendant Jennifer D. Laman is over 18 years of age, and resides at 1719 Teyton Randolf Court, New Cumberland, P A 17070. This statement is made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. I~a J))~~^ FRANK FEDERMAN Attorney for Plaintiff