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Home My WebLink About00-00635 - - ,- 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 COURT OF COMMON PLEAS CIVIL DIVISION CHASE MORTGAGE COMPANY WEST, F/K/ A MELLON MORTGAGE COMPANY 1775 SHERMAN STREET DENVER, CO 80203 TERM (!tc~~CT~ Plaintiff v. NO. :<060 - I.J.S CUMBERLAND COUNTY PAULL. DEHART MARJAN E. DEHART 1943 KENSINGTON STREET HARRlSBURG,PA 17104 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE [N BANKRUPTCY AND TH]S DEBT WAS NOT REAFF]RMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGA]NST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO 'yOUR 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 (717) 249-3166 Loan#: 5801114348 ~-'-''''- _..........,-". 1. Plaintiff is CHASE MORTGAGE COMPANY WEST, FIK/A MELLON MORTGAGE COMPANY 1775 SHERMAN STREET DENVER, CO 80203 2. The name(s) and last known addressees) of the Defendant(s) are: PAUL L. DEHART MARIAN E. DEHART 1943 KENSINGTON STREET HARRISBURG, PA 17104 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/14/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1337, Page 467. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 6/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ~~ . 6. The following amounts are due on the mortgage: Principal Balance Interest 6/1/99 through 1/1/00 (Per Diem $17.88) Attorney's Fees Cumulative Late Charges 8/14/96 to 1/1/00 Cost of Suit and Title Search Subtotal $73,543.31 3,826.32 3,677.00 177.36 550.00 81,773.99 Escrow Credit Deficit Subtotal 118.84 0.00 (118.84) $81,655.15 TOTAL 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The mortgaged premises is vacant and abandoned. 10. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. S 1680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." II. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Defendants. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $81,655.15, together with interest from 1/1/00 at the rate of $17.88 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. 1~?~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - , 0, ~ "'-" - IiIIiIiiiIIil o CHAS- Z 553 486 826 Chase Manhattan Mortgage Corporation 1775 Sherman Street Denver, cO 80203 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. December 15, 1999 00 not use for International Mail (See reverse) Sent to Street & Number Post Office, State, & ZIP Code Postage 1$ Paul L Dehart Marian E Dehart 1943 Kensington St Harrisburg, PA 17104- Re: Loan Number 5801114348 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortga$e on your home is in default, and the lender intends to foreclose. Spec~fic information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home, This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are attached to this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with im- paired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counsel~ng Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar associ- at~on may be able to help you find a lawyer. La Notficacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende e1 contenido de esta notificacion obtenga una traduccion irnmediatamente llamando esta agencia (Pennsylvania HOUSING FINANCE AGENCY) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado rrHomeowners' Emergency Mortgage Assistance Program II al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT LENDER/SERVICER: Paul L Dehart Marian E Dehart 641 Cedar Ridge Ln Mechanicsburg PA 17055 5801114348 Chase Manhattan Mortgage Corporation HOMEOWNER'S EI1ERGENCY MORTGAGE ASSISTANCE PROGRAM You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments ~f you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act oi 1983 (The "Actn). You may be eligible for emergency mortgage assis~ tance if your default has been caused by circumstance beyond your control, 1f you have a reasonable prospect of being able to pay your mortgage payments, and if you meet other eligibility requirements estab- lished by the Pennsylvania Housing Finance Agency. DE052/016-D8E EXHIBIT A U~ !!..d~,-""~_ , -. . . ~ ' o CHASE Chase Manhattan Mortgage Corporation 1775 Sherman Street Denver, CO 80203 Page 2 December 15, 1999 5801114348 TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Ilface.to-facell meeting with one of the consumer credit counseling agen- cies attached to this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the con- sumer credit counseling agencies attached to this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated con- sumer credit counseling agencies for the county in which the property is located are attached to this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intent- ions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this ~roblem with the lender, you have the right to apply for financial asslstance from the Homeowner's Emergency Mortgage Assistance Program. To do SO, you must fill out, si$n and file a com- pleted Homeowner's Emergency Assistance Program Appllcation with one of the designated consumer credit counseling agencies attached to this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLO- SURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your applica- tion. Durin$ that time, no foreclosure proceedings will be pursued against you ~f you have met the time requirements set forth above. You will be notified directly by the pennslyvania Housing Finance Agency of its decision on your application. t:'::':'2: Iti' YOU ;J.~S C'T:~?;:;:.t:T':':':: P~O"i'E:'1'ED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assis':ance.) DE052/016-D8E EXHldiT A - ~~ M__ - ""' ~.._"-~'-~, ~... CHASE .., Chase Manhattan Mortgage Corporation 1775 Sherman Street Denver, CO 80203 page 3 December 15, 1999 5801114348 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 641 Cedar Ridge Ln, Mechanicsburg PA 17055, IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for July 01, 1999 and sub- sequent payments and the following amount is now past due: $ 5,239.15. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 5,239.15, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. pay- ments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Chase Manhattan Mortgage Corporation, 1775 Sherman Street, Denver, CO 80203. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediate- ly and you may lose the chance to pay the mortgage in monthly install- ments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to ~ay all reasonable attorney's fees actually incurred by the lender even ,f they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees, OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure pro- ceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. DE053/016-D8E EXI..n:1il"f :\ t,~l..,.,1~ I r~ - --.- - - o CHASE Chase Manhattan Mortgage Corporation 1775 Sherman Street Denver, CO 80203 Page 4 December 15, 1999 5801114348 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default w~ll increase the longer you wait. You may find out at any time exactly what the re- quired payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Nwnber: Fax Nwnber: Contact Person: Chase Manhattan Mortgage Corporation 1775 Sherman Street, Denver, CO 80203 800-458-1017 (303) 837-2225 Attention: Collections Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a law- suit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You mayor X may not sellar transfer your home to a buyer or tranferee who wiTl-assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other require- ments of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Consumer Credit Counseling Agencies serving your County is attached. Very truly yours, Chase Manhattan Mortgage Corporation Collection Department County Code: 41 ))E053jOI6-D8E EXH!LJlT i\ ~. ' '" Pen~ylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) CLINTON COUNTY CCCS of Northeastam P.!\. 16~1 S Athe=n Se . Swta 100 Stata College. PA 16801 (814) 2:38-3668 F.~(814) 238-3669 Lycoating-Clint.on Counti Coaunission F es. 2138 w=l.a S~e~o=umty .~tioll (STEP) P. O. Box 1328 ~~~";;'lO~l'A 17703 F.~~(5iO) 322.2197 CCCS oOlor-..heastern P!\. 201 Basin Streee . Williams (5iO) 32:3~~t"li703 FA.~(5iO)323'~626 COLUMBIA COU"l'O"TY CCCS ofNortheastam Pennsvlvania 1400 Abington E."(..,.~tive Park Suita 1 Clarks Summitt PA 18411 (570) 587.9163 or (800) 922.9537 FAX (5iO) 587.913419135 31 W. Market Street PCB 1127 WUkes.Barre. PA 18702 (570) 821-<1837 or (800) 922.9537 F.~~(570)821.1785 Co=ission on ECtlnomics Opportunity of Lw:eme COWlt:' 163 Amber Lane WUkes-Barre, PA 18702 (570) 826-<151Q or (800) 822-<1359 FA."{ (570) 829.1665-CALL BEFORE FAXING (570) 455-4994 HAZELTON F_~,,{ (570) 455.5631-CALL BEFORE F.~"'{J:NG (570l 836-4090 TUNKH.>.J."'NOCK Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814l453.5744 FA."{ (814) 453-5749 John F. Kennedy Center, Inc. 2021 East 20th Se"""t . Erie, PA 16510 (814) 898-<1400 FAX (814) 898-1243 CRAWFORD COUNTY Greater Erie Communi!:'J Action Commit'"..ee 18 West 9th Street Erie, PA 16501 (814) 459-4581 F.~ (814) 456-0161 Shenango Valley Urban League. Inc 601 Indiana Avenue Farrell. PA 16121 (412) 981.5310 CCCS of Westem Pennsylvania. Inc. 2000 Linglest.own Road Har.isburg, PA 17102 (717) 541.1757 Urban League oO[etropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 2:34.5925 F.~"{ (717) 234.9459 Community Ac:ion Comm of the Capital Region 1514 De"" Street Harrisbur,;, P.'" 17104 (717) 232.9757 FAX (71 7) 23-1-2227 CUMBERIA."'ID COUNTY Financial Counseling Semces of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA17013 (717) 243-3818 F.~"{ (717) 731-9589 Adams County Housing Authori!:'J 139-143 Carlisle Se Gettysburg, PA 17325 (717) 33-1-1518 F....."{(717) 334-8326 EXHIBIT A PEHNSYl.VANIA BULl.ETlN, VOL. 29, NO, 2:l, JUNE S. 1999 ~ ;, --,,.,,."', .' ALL TIlAr CERTAIN piece or parcel of land, situate in Upper Allen Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Cedar Ridge Townhouses, prepared by John C. Brilhart, Surveying and Mapping Services, last revised on January 13, 1978, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 32, Page 73, as follows: BEGINNING at the intersection of the northerly right-of-way line of Cedar Ridge Lane, a private street (50 feet wide) and the dividing line between Lot ,Nos. C-3 and C-4: thence North thirty-seven degrees, twenty-three minutes, thirty seconds West (N 31' 23' 30" w) along said dividing line, a distance of 85 feet to a point at Common Open Space: thence South fifty-two degrees, thirty-sil< minutes, thirty seconds West (S 520 26' W) along Common Open Space, a distance of 24 feet to a point on the dividing line between Lot Nos. C-2 and C-3: thence South thirty-seven degrees, twenty-three minutes, thirty seconds East (s 370 23' 30. E) along said dividing line, a distance of 85 feet to a point on the northerly right-of-way line of Cedar Ridge Lane; thence along said northerly right-of-way line of Cedar Ridge Lane, North fifty-two degrees, thirty-sil< minutes, thirty seconds East (N 520 36' 30"E) a distance of 24 feet to the point and place of BEGINNING. CONTAINING Two Thousand Forty Square Feet (2,040 sq. ft.) BEING LOT C-3 on the said Final Subdivision Plan. HAVING thereon erected a two-story townhouse dwelling unit known and ..~~~&red aa 641 Cedar Riege Lane. PREMiSES: 641 CEDAR RIDGE LANE , " \ \. --", VERIFICATION MICHELLE: D. VINER hereby states that she is ASSISTANT VICE-PRESIDENT of CHASE MORTGAGE COMPANY WEST (CO) mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foteclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ \.cl f.Q.O sr--- Michelle D. Vinez: Assistant Vice pz:esident --- DATE: lhrg lOb " p[.J (*- ~ ~ <:: ~ .. ~ ~ ~ ~ \) B '0 ~ D (J I I - ~ J " 'J,-i o c: ~ -oro r;"~~'1 ~~y~: '<:LJ -l>c'\ 2' --0 >c :z --{ -< o C> ..,., fT1 ;:;'0 n -1'1 .,-! '.......,.~. f(j l <JY (..-) !.,,~6 V) ""'"') ::~~: ::..r-t :b \~~ () ~5.fd '-:? -~ )> ~ :J1 .1"" " . - _":""-~,., 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, f/kla Mellon Mortgage COIl1pany 1775 Sherman Street Denver, CO 80203 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 2000-635 Paul L. Dehart Marian E. Dehart 1943 Kensington Street Harrisburg, P A 17104 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 Paul L. Dehart and Marian E. Dehart, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 1/1/00 to 3/14/00 $81,655.15 $1,323.12 $82,978.27 TOTAL 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. 1/l~ 4-1A/lMfJ.,Ih J FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED, ~ DATE: fY6uuJ... It ;;"000 k,/ (L, -i.;;) /2., ~ . 'PRO PROT "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE]S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT 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 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-635 PAUL L. DEHART MARIAN E. DEHART Defendant(s) TO: PAUL L. DEHART 641 CEDAR RIDGE LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: MARCH 3, 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 CONSTRUE~ BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT "Y/1 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 th. court your defenses or objections to the claims set forth against you. Unless you act wi thin 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, 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 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-635 PAUL L. DEHART MARIAN E. DEHART Defendant(s) TO: MARIAN E. DEHART 641 CEDAR RIDGE LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: MARCH 3. 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 wi thin 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 ybu can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3 166 Frank Federman, Esquire Attorney for Plaintiff "~ :"'< FEDERMAN AND PHELAN Frank Federman, E~quire 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 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY PAUL L. DEHART MARIAN E, DEHART NO, 2000-635 Defendant TO : MARIAN E. DEIiART 1943 KENSING~ON STREET HARRISBURG, PA 17104 DATE OF NOTICE: ~CH 3. 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 PROEPRTY, 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 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-635 PAUL L. DEHART MARIAN E. DEHART Defendant(s) TO: PAUL L, DEHART 1943 KENSINGTON STREET HARRISBURG, PA 17104 DATE OF NOTICE: MARCH 3. 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 wi thin 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 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. 2000-635 Paul L. Dehart Marian E. Dehart 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 inforn1ation 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 Paul L. Dehart is over 18 years of age and resides at 1943 Kensington Street, Harrisburg, PA 17104, (c) that defendant Marian E. Dehart is over 18 years of age, and resides at 1943 Kensington Street, Harrisburg, PA 17104. This statement is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. ::r ./V1J.~/ 1- ~AN FRANK FEDERMAN Attorney for Plaintiff ~, (Rule of Civil Procedure No, 236 - Revised) Chase Mortgage Company West, flkla Mellon Mortgage Company : Cumberland COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-635 Paul L. Dehart Marian E. Dehart Defendant(s) Notice is given that a Judgment in the a]Jove captioned matter has been entered against you on March JJi .2000. . -By. kf,a; e../ r 7pcnA.-vDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215) 563-7000 **TillS FffiM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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"""~ ~. ~-ilWillil. '~i- -,,",,--, - "~illiIiMll~~'!iil.:;,Iil;lllhrllill! d --,,'~" -'''''l~ ,~ - ~--- - iliil~, c ~ ~ ~ 0 <::1 ~ C <::1 s:: 1- -.0 ~w, 3: ;:J , """ 0 ::0 ,'9\::0 Z:rJ :QE9 r --0 C> ~~ U1 ,..'" ,-) J.,J ?3 KO ". ~6 ~o ::z -<..=ti ~ ..::) -U "",,0 9 ~?tl ;S >!;;;; ~ l"I ~ ~ f/ r' 01 ~ . Ii' f\,) -< r--.... --zt ~ ,-~ , ,. .J ~-, ,"- - , , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE CO WEST ET AL VS DEHART PAUL L 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: DEHART MARIAN E but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, pennsylvania, to serve the within COMPLAINT - MORT FORE On March 1st , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Docketing Service Surcharge Costs: 6.00 9,30 10,00 ,00 .00 25.30 02/29/2000 FEDERMAN & PHELAN ~~ ~/~ R. Thomas Kline - Sheriff of Cumberland County Sworn and subscribed to before me this ,21A--1-- day of fl1Al..uA../ ;Mn;v A.D. ~, f} P~/~~6~ , l"~', SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-0063S P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MORTGAGE CO WEST ET AL VS DEHART PAUL L 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: DEHART PAUL L but was unable to locate Him in his bailiwick, He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE 1st , 2000 , this office was in receipt of the On March attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9,00 Surcharge 10,00 Dep. Dauphin Co 31,SO ,00 68,SO 02/29/2000 FEDERMAN & PHELAN ~~ . R. 'Thomas Kl ine . Sheriff of Cumberland County Sworn and subscribed to before me this ~/.M-- day of ~ tLlY1YO A . D , q"r ' ~ c. h", 11;-'......; A ~..11 Prothonotary ,~~ @lfitt of tlp~ ~4~:riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant ChiefDepuly Dauphin County Harrisburg, Pennsylvania 17l 0 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania CHASE MORTGAGE COMPANY WEST vs County of Dauphin DEHART MARIAN E ~ -: -----'-'. Sheriff's Return No. 0304-T - -2000 OTHER COUNTY NO. 20-635 AND NOW: February 11, 2000 at 11:58AM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon DEHART PAUL L by personally handing to DEFT 1 true attested copy (ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at 1943 KENSINGTON STREET HBG, PA 17104-0000 ~ Ci. {t)aWu0 So Answers, Jt~ Sworn and subscribed to before me this 16TH day of FEBRUARY, 2000 PROTHONOTARY Sheriff of Dauphin County, Pa. B~~ Deputy Sheriff Sheriff's Costs: $31.50 PD 02/10/2000 RCPT NO 133272 RH ",,' ~.......~o @flite of tq~ ~4~:riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17l 01 ph: (717) 255-2660 fax: (7]7) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania CHASE MORTGAGE COMPANY WEST vs County of Dauphin DEHART MARIAN E Sheriff's Return No. 0304-T - -2000 OTHER COUNTY NO. 20-635 AND NOW: February 11, 2000 at 11:58AM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon DEHART MARIAN E by personally handing to PAUL DEHART 1 true attested copy(ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at 1943 KENSINGTON ST HBG, PA 17104-0000 Sworn and subscribed to So Answers, Jf~ before me this 16TH day of FEBRUARY, 2000 .'J~ ~) )h1 . . '-__I:; C-.. f~ PROTHONOTARY Sheriff of Dauphin County, Pa. B~~ Deputy Sh riff Sheriff's Costs: $31. 50 PD 02/10/2000 RCPT NO 133272 RH ~ '.-- , . In The Court of Common Pleas of Cumberland County, Pennsylvania Chase MortgageCompanyWes t, et. aL . VS. Paul L. Dehart, et. al. Serve Marian E. Dehart No, 20-635. Civil . NoW, 2/9/00 ,20 00, I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff, ~~NJ.4t:~t Sheriff of Cumberland 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 known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this day of , 20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ . ' - - '"~ , " In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Mortgage Company West,et. al. . VS. Paul L. Dehart) J. ClO Serve: Paul L. Dehart' No. 20-635 Civil Now, 2/9/00 ,20 (X), I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. -AI d'. ~ .-*,J>~. ~t' Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a . copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Swomand subscribed before me this_day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ .,_.~~.~ - iIlrlfilj" 't'r.~, ~',-, ,,'j,~.j \\(4~J""'" PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Chase Mortgage Company West, fJkIa Mellon Mortgage Company Cnmberland County Plaintiff, v. No. 2000-635 Civil Term Paul L. Dehart Marian E. Dehart Defendant(s), TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $82.978,27 Interest from 3/14/00 - 9/6/00 $2.400.64 and Costs (per diem - $13.64) $85.378.91 TOTAL F K FE E , ESQUIRE T 0 PENN C NTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property,No. ~"''1 " ;c'~lf%; w . .. ~~C' tl... > "rj "'= dZ ~. ~ ::::.., @: - (1l P.- ~Q == (1l l"'Jl"'J '" tl ~tl ~ ?: ... ~ ~ =...."'= jtll ::::'" ~o (1l '" :::: (l ~ \Q ~ = "'1 ::::",= == ~~ >-J '" ., ... = :4.0 = :4. .,\H_ ;0 ;0 (1l ~ Fi]'~t"' ~:;o ::l. = =IJQ tlo ~ ~ r::r . ~~ ;0 - ::::;0 g"'1 = '" ~ = t"' =IJQ IV '" ., = < :4.'" S ~ ~. ~ "'1~ l"'J' '" IJQtl Ztl 0 . = l:l" ~ .., . ~ "'0 0 ~ "'= IJQ ;0 ~'" ~ = 0 >S":4. ~ 0 '" l:l" IJQ 13 ~~ > eT l:l"~ '"'Cl (1l ....== ="'1 ;0 ., tl;O ~ '" --100 ~ l"'J ::\..... =.5l l"'Jo (1l ........ Zz ::! 0" 1~ .g~ (1l ...i! Z",= p.. .... tl ;0 '" OOt"' = '" ><l"'J d <<.r+ .., t"'> ... ~~ =:c:::: 0 Z ;0 ... ;0 >"'1 =l \H ::l. Fi]' ~ ;0 r::r '" == = == l"'J ., '" . I!'l 5' ~ "'=~'" >=l:l" ....=ei --100.... ........ 0" ...i! .... -if , J9liIII!Il~ ,~" ~~,.'"" ~ ,~ ,- - ".~~""'~,~" " .' ~~ll~"~"~"'~R';i'''''T?>jJ,~If)-;~~J!I)!t''.llRi~~ ..llo_iJillll.!llil!~:L' , ~io'\~~" ~"',~~ DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Upper Allen Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Cedar Ridge Townhouses, prepared by John C. Brilhart, Surveying and Mapping Services, last revised on January 13, 1978, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 32, Page 73, as follows: BEGINNING at the intersection of the northerly right-of-way lineof Cedar Ridge Lane, a private street (50 feet wide) and the dividing line between Lot Nos. C-3 and C-4; thence North thirty-seven degrees, twenty-three minutes, thirty seconds West (N 37 degrees 23' 30" W) along said dividing line, a distance of 85 feet to a point at Common Open Space; thence South fifty-two degrees, thirty- six minutes, thirty seconds West Css2degrees 36' 30" W) along Common Open space of distance of 24 feet to apoint on the dividing line between Lot Nos. C-,2 and C-3; thence South thirty-seven degrees, twenty-three minutes, thirty seconds East (S37degrees 23' 30" E) along said dividing'lipe, a distance of 85 feet to a point on..the 1l0rtherlY,right-of-wayJlne of CediIT Ridge Lane; thence ~ong- the northerly right-of-way line dfCedar Ridge Lane; North fifty-two-degrees, thirty-six Minutes, thirty seconds East (N 52 degrees 36'.:30".:E) a distance of 24 feet to the point and place of beginning. CONTAINING Two Thousand Forty Square Feet (2,040 sq. ft.) .. . BEING Lot C-3 on the said Final Sut1divisio~ Plan. HAVING thereon erected a twocstoi'y 'townhouse' dwelling unit known and numbered as 641 Cedar Ridge Lane. Tax Parcel #42-24-0792-008 TITLE TO SAID PREMISES IS VESTED IN Paul L. Dehart and Marian E, Dehart, husband and wife by Deed from John M, Lori, married man dated 8/29/1990 recorded 9/5/1990 in Deed Book T-34 Page 545. -- ~~;jfJ:_-""LG",i"""'''!l!c,,,",,,J5,_~;flk~- lIR~__I~!i!jdl~ . --_mJ--~; ".M Q c::) ~ .----, -1": ~. "P " ... i,q. . ~ III f' rei :;_::Ir. l:t. il:. "1 Iv ..0 ~ /:: ..'0...- ~ ~ ~ , &} :'Y z . f1 Q D SJ,,::.: . ~ 6 d 0 r.u ~~i_'~_ ..() ~ C 0 C CY 2::'~~ ~ 0 ,- ..0 I I i'; ~o I \ I ., ....". C/) .. (j r-- ~ ~ ":"v ~ ~ en {' ... .. , 1- ~ , ... , - - ^ .. , yJ ~ , .. . .. . .. '- ~ - '-'~4 ! .. ~.....-Wi .- ~. ',~ ..J ~~,~ ~ ~"--~ ~ '" ,/ Chase Mortgage Company West, f/k/a Mellon Mortgage Company CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION Paul L. Dehart Marian E. Dehart NO. 2000-635 Civil Term Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Chase Morte:ae:e Company West. fIkIa Mellon Morte:ae:e 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 641 Cedar Ride:e Lane. Mechanicsbure:. P A 17055. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Paul L. Dehart 1943 Kensington Street Harrisburg, PA 17104 Marian E. Dehart 1943 Kensington Street Harrisburg, PA 17104 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 ,," .- ~J~ "~ ,~: . .' 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,) MERS-Nominee for Household Finance Corporation P.O. Box 2026 Flint, MI 48501-2026 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 641 Cedar Ridge Lane Mechanicsburg, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Cedar Ridge Homeowner's Association Attn: Stephen G. Eddy, President P.O. Box 265 Mechanicsburg, P A 17055 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 ofl8 Pa, C,S, Sec, 4904 relating to unsworn falsification to authorities. Aoril 27. 2000 DATE -" -^ltii;'~ 1!iiI1Rl!9rn-~!<!!li~~k-#.0M;l"'''--'''''!8''-'J&'''""","~~B_''''"~''''''''~ < _ .~, ___V"~~_,~ _ ~ >..~ ~ -" >, "'^~- - '~,^- . ,..'-. -, - '- . -,- ~. - --~ ~:..; ""'. -' CJ c:: <~~ -Ve-:' n'I,1. 2:::>.) tii~_: r-~ ~!~ ~ -~ ,~ . , M' . c' C~.; ~ - ; ):C:' :-.;:,.,. , ,'-, :"-' en ~, ;~ -< f :J'" ..--. - . ~ ~ . AI>.:. ~ __'"~ .""",,,~:'c FEbE~NandPHELAN , 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, flk/a Mellon Mortgage Company CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION Panl L. Dehart Marian E, Dehart NO. 2000-635 Civil Term 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: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C,S. Section 4904 relating to unsworn falsification to authorities, " ~~~III!!!iIi!ii!!~,!!!~li;f~'lil~,y-,"!"00,I,ill2'"""-"':I!,'1_I;"'i;'h.lll~t-. "" o ~ ll' C'O" ..-~";-~~-- ~, C) C:::;- C) C c ') :::::- -[1 C/o; - -",,' rn , z: ~J_ "" 2: '- (l'j - r';:' ('~- ~-=: 7.::~~ c.' C.i :Z J..,. )> C: C / --i --< (,)"1 '"- .........), '- . l\'; "".". ~-" ,~"'-'~ " "j . ~ ~-iIolIis'.M'", . -~ Chase Mortgage Company West, fJk/a Mellon Mortgage Company Plaintiff, CUMBERLAND COUNTY No. 2000-635 Civil Term v. Panl L. Dehart Marian E. Dehart Defendant(s), April 27, 2000 TO: PaulL. Dehart Marian E. Dehart 1943 Kensington Street Harrisburg, P A 17104 641 Cedar Ridge Lane Mechanicsburg, PA 17055 "TillS 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, TillS 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 641 Cedar Ridge Lane, Mechanicsburg, P A 17055, 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 Mortgage Companv West, f/kIa Mellon Mortgage Company (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 THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. 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~'"""'-=" , ~ ,~ _1lrIIliIIlIIiIl ~ .~~_-..> ,./ , You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE 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 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 "~ . ~ ~~~;i" r' ~. DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in Upper Allen Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Cedar Ridge Townhouses, prepared by John C. Brilhart, Surveying and Mapping Services, last revised on January 13, 1978, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 32, Page 73, as follows: BEGINNING at the intersection of the northerly right-of-way lineof Cedar Ridge Lane, a private street (50 feet wide) and the dividing line between Lot Nos. C-3 and C-4; thence North thirty-seven degrees, twenty-three minutes, thirty seconds West (N 37 degrees 23' 30" W) along said dividing line, a distance of 85 feet to a point at Common Open Space; thence South fifty-two degrees, thirty- six minutes, thirty seconds West (s52degrees 36' 30" W) along Common Open space of distance of 24 feet to a point on the dividing line between Lot Nos. C-2 and C-3; thence South thirty-seven degrees, twenty-three minutes, thirty seconds East (S37degrees 23' 30" E) along said dividing line, a distance of 85 feet to a point on the northerly right-of-way line of Cedar Ridge Lane; thence along the northerly right-of-way line of Cedar Ridge Lane; North fIftyctwo degrees, thirtycsix Minutes, thirty seconds East (N 52 degrees 36' 30" E) a distance of 24 feet to the point and place of beginning. CONTAINING Two Thousand Forty Square Feet (2,040 sq. ft.) BEING Lot C-3 on the said Final Subdivision Plan. HAVING thereon erected a two-story townhouse dwelling unit known and numbered as 641 Cedar Ridge Lane, Tax Parcel #42-24-0792-008 TITLE TO SAID PREMISES IS VESTED IN Paul L. Dehart and Marian E. Dehart, husband and wife by Deed from John M. Lori, married man dated 8/29/1990 recorded 9/5/1990 in Deed Book T-34 Page 545. ~~~iiii~~!ilSh"-~,'i"""~i""b1"-L_~ill"",,,~~ 'h"'~ """- "~__IIl.' J~ '~ n ~~ -':J ':-~ [I';;", --;::.-, "<:"-,-' -:;.-oJ' ~, ::Q .-" [:~ C~' ~~= ~ :z -I ~< ., I .~ ., c::) t.;::;; C) n';', =~'" Ui ~ ~ ~~ ...., .<~ JU ""t!t:iB(: AFFIDAVIT OF SERVICE PLAINTIFF Chase Mortgage Company West, flk/a Mellon Mortgage Company Cnmber]and Connty No.2000-635 Civil Term DEFENDANT(S) Panl L. Dehart Marian E. Dehart Type of Action - Notice of Sherifrs Sale SERVE AT 1943 Kensington Street Harrisburg, PA 17104 Sale Date: September 6, 2000 NOTE: THIS SERVICE IS IN DAUPHIN COUNTY. SERVED Served and made known to at o.'Ju . o'clock Pm., at 9.4v ( L 1>GhJ4/l.r k.e", S J "'9 J".." . Defendant, on the , '" ~ siv/,J k~f/Il.IS/Jv~ day of A fV.14 '1 ,200~ 19 V..1 , Commonwealth of Pennsylvania, in the manner described below: +-Defendant personally served. Adnlt family member with whom Defendant( s) reside( s), Relaijimship is Adult in charge ofDefendant(s)'s residence who refuse!! t<1 give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age ~ Height f 'S~ Weight // t::> Race ~ Sex r Other I, f/ C.h-AttJ) ~/z/Jl.- , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale ~e~ann . o/t fo . ,issued in the captioned case on the date and at the address indicated above. . l Sworn to and sub~bed be r e this D- day of Notary: I CMstle . , Camp Hill, Cumbertand County My Commission Expires June 24, 2002 On the day of ~ NOT SERVED ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of .200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire -l.D. No, 12248 Two Penn Center Plaza, Snite 900 Philadelphia, P A 19102 (215) 563-7000 :} . l~jlliil\!:i~~!l!iil~~~lSI1l;l;~~~k",-t>lc'"",")"'''''''-\C&\U.ott"",,~":..w''''",,,1lfilIi'-.jjA.li .- liii' ,l ~i1l~iltlf~ o c :;- "'t)ra !1lQi Z,.J" ze UJ J~- -<L: !<:o J>c:; z,~, 5>'..:-.) c:: Z -' -< o o <- c: -z o -n '-l --,- ."~~ ~~~~ r3rn ~ :0 -< I \.D -0 :::J;; N .:...J (J1 - ., - ~, .~ AFFIDAVIT OF SERVICE PLAINTIFF Chase Mortgage Company West, f/k1a Mellon Mortgage Company Cnmberland Connty No.2000-635 Civil Term DEFENDANT(S) Paul L. Dehart Marian E. Dehart Type of Action - Notice of Sberiff's Sale SERVE AT 1943 Kensington Street Harrisbnrg, PA 17104 Sale Date: September 6, 2000 NOTE: TillS SERVICE IS IN DAUPHIN COUNTY. SERVED Served and made known to tvlA1...IIJ.N [' J>~ ~AP-- ,Defendant, on t7; Jc's:, K at~!1o ,O'clock{.m.,at 1'11.3 ~n.JJ"ft.... si JJ.Sr r:r day of fL1,A- '1 ,200E, , COIr.momvealth of Pennsylvania, in the manner described below: Defendant personally served. I J d ~ )t" Adult family member with whom Defendant(s) reside( s). Relationship is # "J J.>~II 'f Adult in charge ofDefendant(s)'s residence who refused \0 give name or relationship. Manager/Clerk of place oflodging in which Defendant(s)reside(s). Agent or person in charge ofDefendant(s)'s office or usu~l place of business. an officer of said Defendant(sj's company. Other: Descri tion: Age (p[) Height ~'J-'t WeightJ)b Race L.,v Sex F Other I, . c./"'AJI. I,hlt'--" , a competent adult, being dl11y sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth he ein, issued in the captioned case on the date and at the address indicated above. ~ ~ " Sworn to and su scribed ~, beft e is 7 day NOTARIAL SEAL of , 200 q Christie L. Underkoffler, Notary PubUc nr}i'p~ - Ca ill, ClWlP,erland County ~ J rxpires June 24, 2002 NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of ,200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I,D. No. 12248 Two Penn Center Plaza, Suite 900 Pbiladelphia, PA 19102 (215) 563-7000 f'([ il!IIliliilI~~!!>i!l!tlil!c~l~liii1t~.;ooIi<.-';;;Ji-'~.!li4~~T~I*'.i"'1>>lIlL_'!r__~~el.."'1lf,r.;;Wilil ",-~-"~.."~ J /~ , if' 5 ;/'J ~~ . -~- . ~~'" ~...,-;1ii;!'Iiii" . , r "'~"Ul ~ ~.... .. - ~; C') 0 0 C 0 -., 5: c..... -, -00.7 -- ~J: :!J mrn ::E il'r::- Z::C.: I ,~...." .1 zr --!} 0 UJd;: v:.> :-.. L -<~ ;~$ ~C' -0 ~n .....". ~~?() - Zo r:-? C5rn )> ,C ~ Z 'W ~ :<: (n ~ , I--~~ ~ -~""-' " ~-.-- ,~ ~__w",","--,-- . .,. -.-",. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MORTGAGE COMPANY WEST, F/KlA MELLON MORTGAGE COMPANY Plaintiff CIVIL DIVISION vs. No. 2000-635 CIVIL PAUL L. DEHART MARIAN E. DEHART 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/K1A MELLON MORTGAGE COMPANY, hereby verify that on MAY 2, 2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on MAY 2, 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ~~~ ~A.~<~ FRAN FE RMAN, ESQU~ Attorney for Plaintiff Date: AUQust 10. 2000 "-~'l"~. _ "0"'; t"" -'0 ~. 0_ o ~ . 0- - .... .... .... .... .... '" 00 --l a, V. .... w tv .... ~ Z v. .... 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The, Return R~jpt will show to whom the article was delivered and the date delivered. :or. icle Addressed to: ,r":-,:'C! q ~~~.~,~.- 1.94'~~ Sl1lImT ~1tWff'PA 11104 - "-~ 6. Signa. X PS FORM 3811, December 1994 i ltlli\~jIU Li JII;} .11 n j..'" jjj , 'j' I J. =~.-"-' SENDER:.. ';"",~<,':' ,., "";"~;~~,; . Check ~:~~t.If,yOu req'L!lre Re~,~d'~~~ ._..7,~ . Print yoUr' name and addresS 'on the reveise: of this' form so that we can return this oard to you. -"';, f:, ~ "" '.'\ ' , . Attach this form tofhe front ~ th,9,~rPiede. or 0" th~~k if space does not permit . TI1e"ReturnRe&iptwiU ~how_.to WhWn the artfcle wa~fCteJivered and the date delivered. 3. Article Addressed to: 5. Received By: (Print ~ L~ PS FORM 3811, December ;iiiH\'\/f\4,~!.i .lli ; ,!;: i!!!! il .1 \ttltil'iU(J i I iiii i iiii litl! it it = ...""........ ,~ """"'-~",.'"-,"',"'-,;,,;~ J also wish to receive the'" " following services (for an eXlrii fee) 'tic(,'Restricled Delivery , ~n~lt postmaster ~or fee.' 4a. Article Number p 910 60.1 974 4b. Service Type )( CERTIFIED. I also wish to follow,ingservi?es ( ~. .Re~~~e " ..'" -~"'""" nsutt postm 4a. Article Number P 974 910 600. '; ',..,'c;r.{;.~': 4b. Service Type )( CERTIFIED Domestic Return Receipt .'" - ~~ ~ . ~,,,,_"'___-"';1,,<h...,_,, C1 o ..D "'I POSTAGE POSTMARK OR DATE RETURN RESTRICTED DELIVERY RECEIPT J CERTlFIEO FEE + RETURN RECEIPT SERVICE TOTAL POSTAGE AND FEES 1< ~, SENT TO: NO INSURANCE covE,~lte PROVl!?Eil . NOT FO~Jt~Tffllt~~~~AL MAIL PAUl. -. f:d:.rt~]':.T ..:l43 l(}....~.~S.L~bTQN S".c~~'i .dARKl ;..;r"~;'!..G ,J iNt !7UJ4 PWl[< f (:l rl C- 12 w 0. o -> we >, ze w' u.' 0' 0.: 0;': I ~ ~ ' i< ff1 ~.~ , > , , , .:T l'- C- o. PS FORM 3800 US Postal Service Receipt for Certified Mail " -'''-. --: --. ---~ ,--- -.'''- -- ~ - ._~ -- .--7 --.-.._------ -~- -- RETURN 1 POSTAGE POSTMARK OR DATE RESTRICTEDDEUVERY RECEIPT i CERTIFIED FEE ~ RETURN RECEIPT SERVICE TOTAL POSTAGE AND FEES SENT TO: NO 1~~~R~~~~~~~~:~~'1~EO SEE OTHR SlDE hAiU"-,, .t,. .Jb.it<4U 1~43 Ki1i5:i~\jGl'ON STR~T .IA,fGiISB.U~~G~ 'J;" ilJ.ll4 u. DWlK o fo- W 0. o -> we" :>'/ Z4 w" u.C OC ., o.z F?f;: !a~ a:cr Wu. "'C U~ i=T tIl(E W- uo. .,u. ->= 0.1- PS FORM 3800 US Postal Service Receipt for Certified Mail >== Z 1! a: o 0. ;! --. -----~.. ,-,~ -- --~ ~~I~l1Mlil~~!:iI!,~~~~ftill!~~fi'~;<!IiffWl';''''L'''J",-,,,,.,.,,,~,~;:.~lI!ilttir~ ~:\liI"'W"'''' .~. . ~ . ~ll -.... .. ~tiJl <"~ '~ . n <:::) 0 ~; C> -n ~.... 'J;:> --1 -OeD c-::: ;:'::0 tTlr-n W> ;.1\ Z::rJ --;:)111 zr:;:: (J'\ ~D9 ~~:-~~ (1-"'- ,,:,u r:::.:c:.: -0 "J.:::g ~ r) _!..J -"'0 ::.1:' ~~~o z~ L-m 5>2 ~ ~ Z N ~ ::< \0 ..i -, " .,., ~ ..;,.::;,,L.:.;.,,, -"" . ~- .. , STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. I, _ ____~~~.!'E~_!'_ _~~~.lt~'=:: __ __ _ __ _________ ____h_ ___ _____ __ __ __ _ _ __ __ __ __ _ __ ___ _ Recorder of Deeds in and for said Connty and State do hereby certify that the Sheriff's Deed in which h______________ _____________~!)!iJl_1;.s1_J!.QID!).J,QllILl1tg..JlDpp_--- _________________h______n_____h__ is the grantee the same having been sold to said grantee on the _____fi.~I)___________h__________________________ day of _________h__~:~:_e_III~~:_________________ A. D" 19:,:~9_0_~_, nnder and by virtue of a wriL_____________ _____________lj:,l>!)~J1J;;i,.9n.h________h____________ issued on the ------___l.st;.________________________ day of ______K"X________________ A, D" 19x.2.JlUQ, out of the Court of Cornman Pleas of said Connty as of _h_h __ _____c:!~!__~_________ _ _.. __ _ __ ________ h_ _ __ ___h __ _h __ h ___ __ _____ __ __ __ _ Tenn, WK2illlU_ Number _____~_3_~_____, at the suit of ____<:~:'.i_s_'=__~.!'JL~~_~~.!'__~J:~_~'=!J5'E._~.!=.lt________h-h------_ _ __ ___ __ _ __ _____ _____ _____ __ _ __ ____ againsL~au.L..L_ D..ehar..t....& _M.aJ:.ia.n-.E.____ __ __ __ __ __ _______ is duly recorded in Sheriff's Deed Book No. ___~Z9____h' Page _l19JL______. IN TESTIMONY WHEREOF, I have herennto set my hand and seal of said office this _i!:ce~_ day of -~---------J.. D., l!l::2:.~ -~~~-~O;~ Recortler 01 Deeds. Cumberland County, Cartisle, PA My Commission EKpiros Ihe FiliI Monday of Jan. 2002 - ~~- ~~ r Chase Mortgage Company West F /k1a Mellon Mortgage -vs- PaulL. Dehart and Marian E. Dehart In the Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-635 Civil William DieW, Deputy Sheriff who being duly sworn according to law, says on July 12,2000 at 7:29 o'clock P,M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of PaulL. Dehart and Marian E. Dehart located at 641 Cedar Ridge Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff who being duly sworn according to law, says hr made diligent search and inquiry for the within named defendants to wit: Paul 1. Dehart and Marian E. Dehart, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the above Real Estate Writ Notice Poster and Description according to law. Dauphin County Return: and now May 12,2000 at 11 :45 A.M> served the within Real Estate Writ Notice Poster & Desp. Upon PaulL. Dehart by personally handing to Paul Dehart Jr. 1 true and attested copy of the original Real Estate Writ, Notice Poster & Desp. And making known to him the contents thereof at 1943 Kensington Street, Harrisburg, PAc So answers: 1. R. Lotwick, Sheriff Dauphin County. And now May 12, 2000 at 11 :54 AM served the within Real Estate Writ, Notice Poster and Des, Upon Marian E. Dehart by personally handing to Paul Dehart Jr. 1 true and attested copy of the original Real Estate Writ, Notice Poster and Desp. And making known unto him the contents thereof at 1943 Kensington Street, Harrisburg, Pennsylvania. 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: Paul 1. Dehart by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to 1943 Kensington Street, Harrisburg, Pennsylvania, This letter was mailed under the date of July 11,2000 and received by Paul Dehart on July 12,2000 the return receipt card signed by Paul Dehart. 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: Marian Dehart by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to 1943 Kensington Street, Harrisburg, Pennsylvania, This letter was received by Marian Dehart on July 12, 2000 the return receipt card signed by Paul Dehart, 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: PaulL. Dehart to 1943 Kensington Street, Harrisburg, 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 he served the above Real Estate Writ Notice Poster and Description in the following manner: The 1 w..n - '.~ " . c '~_JS!:lll<iij"" Sheirff mailed a notice of the pendency of the action to one of the within named defendants to wit: Marian E. Dehart by regular mail to 1943 Kensington Street, Harrisburg, Pennsylvania. This letter was mailed under the date of July 14, 2000 and never retufned 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 premises at public venue or outcry 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 Federal Home Loan Mortgage Corporation. It being the highest bid and best price received for the same Federal Home Loan Mortgage Corporation of Mail Stop 61, P.O. Box 5000, Vienna, VA being the buyer in this execution paid to sheriff R. Thomas Kline the sum of $ 981.87 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 Dauphin County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 30.00 19.25 15.00 15.00 30.00 10.00 .sO 1.00 6.82 15.19 15.00 30.00 9.00 31.50 372.35 306.23 23.53 25.00 2Q.iQ $ 981.87 Pd By Arty 9/21/00 Sworn and Subscribed To Before Me This~Dayof [Je.ta.........., 2000, A. D. ~ (2~J df.17 Pro notary soansc~~ R. Th~liJl.KLin!l~)~J:leriff ByJ2:/;;.---;.y j()",r/f: ,~ Real Estate Deputy 0/ !JopV \,~ CJe ')1H '7 L /0.:10/2.- - -"'~ .. __..."""\{X!<tIl~'''''''^ . , ~ . , , Chase Mortgage Company West, f/k/a Mellon Mortgage Company CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION Paul L. Dehart Marian E. Dehart NO. 2000-635 Civil Term Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Chase Mortl!:al!:e Comnanv West. flk/a Mellon Mortl!:al!:e Comnanv , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Executionwas filed the following information concerning the real property located at 641 Cedar Ridl!:e Lane. Mechanicsburl!:. P A 17055. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Paul L. Dehart 1943 Kensington Street Harrisburg, P A 17104 Marian E. Dehart 1943 Kensington Street Harrisburg, PA 17104 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 - ~----"">,~"I~ ^ . . 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.) MERS-Nominee for Household Finance Corporation P.O. Box 2026 Flint, MI 48501-2026 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 641 Cedar Ridge Lane Mechanicsburg, P A 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Cedar Ridge Homeowner's Association Attn: Stephen G. Eddy, President P.O. Box 265 Mechanicsburg, P A 17055 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ADril 27. 2000 DATE __J . I ~_,~ .... ... ... Chase Mortgage Company West, f/kla Mellon Mortgage Company Plaintiff, CUMBERLAND COUNTY v. No. 2000-635 Civil Term ~ . Paul L. Dehart Marian E. Dehart Defendant(s). April 27, 2000 TO: Paul L. Dehart Marian E. Dehart 1943 Kensington Street Harrisburg, P A 17104 641 Cedar Ridge Lane Mechanicsburg, P A 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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 641 Cedar Ridl!:e Lane. Mechanicsburl!:. PA 17055, is scheduled to be sold at the Sheriffs Sale on Seotember 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 Mortl!:al!:e Comoanv West. f/k/a Mellon Mortgal!:e 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 MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. - I. ~ ...' .... .. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of yoUr property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from .the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TmS 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) 990-91 08 . " . , - -..' .. .- DESCRIPTION ALL THAT CERTAIN piece or parcel of land, simate in Upper Allen Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Final Subdivision Plan for Cedar Ridge Townhouses, prepared by John C. Brilhart, Surveying and Mapping Services, last revised on January 13, 1978, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 32, Page 73, as follows: BEGINNING at the intersection of the northerly right-of-way lineof Cedar Ridge Lane, a private street (50 feet wide) and the dividing line between Lot Nos. C-3 and C-4; thence North thirty-seven degrees, twenty-three minutes, thirty seconds West (N 37 degrees 23' 30" W) along said dividing line, a distance of 85 feet to a point at Common Open Space; thence South fifty-two degrees, thirty- six minutes, thirty seconds West (SS2degrees 36' 30" W)along Common Open space of distance of 24 feet to a point on the dividing line between Lot Nos. C-2 and C-3; thence South thirty-seven degrees, twenty-three minutes, thirty seconds East (83 7degrees 23' 30" E) along said dividing line, a distance of 85 feet to a point on the northerly right-of-way line of Cedar Ridge Lane; thence along the northerly right-of-way line of Cedar Ridge Lane; North fifty-two degrees, thirty-six Minutes, thirty seconds East (N 52 degrees 36' 30" E) a distance of 24 feet to the point and place of beginning. CONTAINING Two Thousand Forty Square Feet (2,040 sq. ft.) BEING Lot C-3 on the said Pinal Subdivision Plan. HA VING [hereon erected a two-story townhouse dwelling unit known and numbered as 641 Cedar Ridge Lane. Tax Parcel #42-24-0792-008 TITLE TO SAID PREMISES IS VESTED IN Paul L. Dehart and Marian E. Dehart, husband and wife by Deed from John M. Lori, married man dated 8/29/1990 recorded 9/5/1990 in Deed Book T-34 Page 545. - ~~j- . WRIT OF j:XECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-635 CIVIL fgC Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Chase Mortgage Company West f/k/a Mellon M6rtgage PLAINTIFF(S) from l'rllll To. Dph"rt- "nil M"r;"n 1':. DPh"rt-, 1 <)4, Kp;nR;ngrnn Srrf'f'r. Harrisburq. PA 17104 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell_ See Legal Description ;" . 'C"'%;:' . ,;,,'!'~-, ;';; ~,"'.,i'" ;' .-,_!., .' (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ~ ,: .....__ l GARNISHEE(S) as follows: .. . '''' and to nomy 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 thedefendant(S)h6(levredu~n an subject to attachment is fou~dinthe possession of anyone other than a named garnishee, YOliare direotedto notify hirillherthat he/she has been added as a garnishee and is enjoined as above stated. L.L. Due Prothy Other Costs $.50 $1.00 Amount Due $82.978.27 from 3/14/00 - 9/6/00 per diem - Interest $13.64 $2,400.64 Atty's Comm % Atty Paid Plaintiff Paid $165.80 Date: May 1, 2000 Curtis R. Long Prothonotary. Civil Division ,--bv: ~ n _ P. 7p~~/ Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza, Suite 900 Attorney for.: Telephone: Supreme Court ID No. Philadelphia, PA 19102 Plaintiff 215-563-7000 12248 n"" ~_;i~'-'""'-'1IIIi ' '>"I~iliiIi"",""'-_..........L ~ -. ___~_;!lMili' , -, - - ...cll ~-' "" 1< .J . REAL ESTATE SALE No.l~ 011 /'fYta.p 3 ~ the sheriff levied upon the defendants interest in the real property situated In < <j4/JI' _4fLorL..--kHl'-'lIY' Cumberland County, Pa., known and numbered as: ~~IO,..t.., Lfule<~~ -111 o~L."'t~~n~ and more fl1iij ,jescribed on exhibit "A" filed with ~ this writ and by this reference incorporated herein. ;:';' ~~ /J~~ f'-.l '--;r-r1, "late'./'J1tjl'7F 3 '2ri BY~ . ..' ? r<l ..:' ~~- N n, '-V -'. . (j) '-.'>::r .~" ; , ~ (::.: f11 ~;;lJ .......- .._. -<"Tl ___, -n /!r!: .~'""-'-'.~'", . -. ESTATE SALE MiI:~ Writ No. 2000-635 Clvtl Chase Mortgage Company West. f/k/ a Mellon Mortgage Company vs. Paul L. Dehart and Marian E. Dehart Atty.: Frank Federman DESCRIPTION ALL TIiAT CERTAlN piece or par- cel of land, situate in Upper Allen Township. Cumberland CounW. Penn- sylvania. bOWlded and described in accordance with a F1nal Subdivision Plan for Cedar Ridge Townhouses. prepared byJolmC. Brilllart. Survey- ing and Mapping Services. last revised on Janrnuy 13. 1978, and recorded in the Cumberland County Recorder of Deeds Office in Plan Book 32. Page 73. as follows: BEGINNING at the intersection of the northerly right-of-way line of Ce- dar Ridge Lane. a private street (50 feet WIde) and the dividing line be- tween Lot Nos. C-3 and C-4: thence North thJrty-seven degrees. twenw- three minutes, thirty seconds West IN 37 degrees 23' 30" W) along said dividing line, a distance of 85 feet to a point at Connnon OpenSpace: thence South fifty-two degrees. thirty-sJx min- utes. thirty seconds West (S 52 degrees 36' 30" W) along Common Open space of distance of 24 feet to a point on the dividJng line between Lot Nos. C-2 and C-3: thence South thirty-seven degrees. twenty-threem1nutes. thirty seconds East (S 37 degrees 23' 30" E) along said dividing line. a distance of 85 feet to a point on the northerly right- of-way line of Cedar Ridge Lane: thence along the northerly rlght-of- way line of Cedar Ridge Lane: North fifty-two degrees. thJrty-six Minutes. thJrty seconds East IN 52 degrees 36' 30" E) a distance of 24 feet to the point and place of beginning. CONTAINING 1\vo Thousand Forly Square Feet (2.040 sq. ft.). BEING Lot C-3 on the said Final Subdivision Plan. HAVING thereon erected a two- story townhouse dwelling unit known and numbered as 641 Cedar Ridge Lane. Tax Parcel #42-24-0792-008. TITLE TO SAID PREMISES IS VESTED IN Paul L. Oehart and Mar- ian E. Dehart. husband and wife by Deed from Jolm M. Lori. married man dated 8/29/1990 recorded 9/5/1990 in Deed Book T -34 Page 545. ~JI i, ~ ~"' '....... - "-..IIII..~ " ,-I - i.~~i . . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe 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 officiallegal 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 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 matter of the aforesaid notice or advertisement, and that all allegations in the foregoing staternents as to time, place and character of publication are true. Roger L Morgenthal, Editor ~ SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 . ~J NOTMIAlSw LOIG E. SNYDEit.:HIiiioIy PubIfc Co.......... Cu....~~COutlty"I'A' My CommIeolon ~M#h'5, 2ool. , ": HEAL'ESTATESALE No. 16 lit .--'~-.:,~jfWrftNo,2QOO-635 1i!:':~~,~---rl\:'JlTerm --,-~_ _ - : t.;:nase _M_OrtgasltCompany ;= . ., - ..-':'WOSfflkla Mellon ,J\!orto~ i:Qmpany , .. _~,-,..EauJ L Dehart ~- . p-'Mrian E. Dehart ----- - --:- -~!tY; I1ftt1k Federman b;...,,,.-; ':~lJE'SCRIPTJON -- -, ~ J\.lJ~lliAI CERTAIN piece or paTel'] of j@.l,Jf,(->>LU..;tleJD1..ipperAllt.>nTownship, tetItfili~kw.n!p .P~ylvania,. bounded ~aesm-,;ed in accordance \\ith J. Final Riffiaj\~S.io_I!..___Pl<!J.,___joL-Cedar Ri.dge ~~~p.r.ep~~~9__bv ]QbILLBrilhart. ~a:mn:rapping ~I"\ices,.last revbed =-orr-1anuarr 13, 1978,. and recorded in thl.: ~~crlJnd CQYDlr __ Rc.cordcr of ~ed.:. M:- - ~~l. 32,..fugc 73, as -follows: . .. ~-~..&b.lb.e -ioter~c(tion of lhe _' _ . . ~~,d':fuly line of Cedar Ridge - ---~ private !>lreet (50 Leet widt') and tfie Pil~g line between Lot Nos. (-3 and (-4; ~ence- North thi1t}'~e\'en degrees; twent\'- ii tlll'ec minute., Uility seconds We~1 (N j7 11- ~.~-----:-~~~~~_J.timg..said di\.,jding jin(>, a ~{)f Ri 'o>t1o...Lpoint at COmmon en "5Dac~ (henel'_ s.outh fifty-two degn:es, " , '_~econ&. ~_Ve$t_ (552 , Common Open I ' '~llQ_a point on the ~ - ~eC.n_ LOt Nos. C-2 .md C-3;- '_, 5?u,th, thirt,-.seren degrers, tw('nh~ "~~_mJl:!J,IJC>~ -tI:tiJ.t)'_..ie.c.QncI.s.-----East (531 ~ees""L.,:'jW:Q_aluris-said dil'iding line, a -_ tJ,nce.of..~,i~~l.!Q_a poin~ on lhe northerly ~l-_\\~.lj' 1J1)(> of Cedar Ridge Lanl'; Ihenel' =- - fbe norlherly right-oJ-\\ay line of Cedar ~g..J.an.~NQtlb fifb.;:l1\'-O Liegr('(!~, thirty-~ix ~~t}, sec:onds Ea"l (N 52 degrees 36' :?fi''Ef a distance of 24 feet to the. point and place of BEGINNJ\rG. __rr\i\'T"\!MN.G~Tl1'Q __Thousand Forty ~,,'~.@:N~. ~.l -c_.~" u ~C;~:lr:'!_c".3,..on_the.--S.ljd Final '~ciiJ:Plan. ----; o~_t:rArTh"G th~reon erected a two-ston: ..-W\\;'.QhgYSL _.dwelling unit known ana ~jj!.llnheredas 1H1 Cedar Ridge Lane. '. ,n;~OOi.."." _ .u.' PR'USfistSlSVESTEDIN Marian E. Dehart, tJfe,.b\' Del.'d from John M. ~"'- -~w:i~g man dAkclBl2911990 recorded ;"",}~1.iuJl.~1C'U4.&'5~.._ I~' " - I"L.i.-,' 1.1'111.... " """'l~,";', ',", \; \ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Het No. 587. Hooroued Mau 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, respectiveiy, 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 editionslissues which appeared on the 1st, 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 ;~any and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin i4 scellaneous Book "M", vo~u:: ~~'::~I:~ --------------SZ------------------------------- COpy . 30th day of gust 0 A.D. S ALE #16 Notarial S..I Teny L. Russell. Notal'! Public Harrisburg. Dauphin county My Commission E.plres June 6, 2002 NOTA Y PUBLIC Member. Pennsylvania AsSOCiation at NMyI'~ommission expires June 6, 2002 ~ 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 $ 304.73 1.50 306.23 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. By....................................................................