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HomeMy WebLinkAbout02-5674IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. JOHN M. SANDERSON, Defendant. TO DEFENDANT CIVIL DIVISION NO.: - W -7? TYPE OF PLEADING CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF Al 0MVEY FOR PLAINTIFF 1 HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANT IS: 4162 Kittatinny Drive Mechanicsburg, PA 17055 ?•1?11„c ?z t ti `?CC,t C .t E ?- ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 4162 Kittatinny Dr Hampden Township (CITY, BORQ TOWNSHIP) (WARD) AT'1 JKNEY FOR PLAINTIFF Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, vs. NO.: JOHN M. SANDERSON, Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 PHONE (800)-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, vs. NO.: 0,22 - S--6 7 q JOHN M. SANDERSON, Defendant. Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendant, John M. Sanderson, is an individual whose last known address is 4162 Mechanicsburg, Pennsylvania 17055. 3. On or about September 12, 1997, Defendant executed a Note in favor of Eastern Mortgage Services, Inc. in the original principal amount of $85,500.00. 4. On or about September 12, 1997, as security for payment of the aforesaid Note, Defendant made, executed and delivered to Eastern Mortgage Services, Inc. a Mortgage in the original principal amount of $85,500.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997 in Mortgage Book Volume 1405 Page 208. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. On March 27, 1998 Eastern Mortgage Services, Inc. assigned the aforesaid Mortgage and Note to Plaintiff pursuant to the terms of a certain Assignment of Mortgage, recorded in the office of the Recorder of Deeds of Cumberland County at Mortgage Book Volume 572 Page 232. 6. Defendant is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendant is due for the July 1, 2002 payment. 8. Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. § 1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title 11 of the National Housing Act (12 U.S.C. §§ 1707-1715z-18). 9. Plaintiff was not required to send Defendant written notice of Plaintiffs intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. § 101 and the Defendant is not a "residential mortgage debtor" as defined in 41 P.S. §101. Premises. 10. The amount due and owing Plaintiff by Defendant is as follows: Principal Interest through 11/10/02 $49,859.96 Late Charges through 11/10/02 $ 1,595.32 Corporate Advances $ 115.00 Escrow Deficiency through 11/10/02 $ 132.98 $ 1 Attorney's fees 9.23 Title Search, Foreclosure and $ 1,250.00 Execution Costs 2,500.00 TOTAL $55,472.49 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $55,472.49 with interest thereon at the rate of $9.90 per diem from November 10, 2002, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIIR IIC, P.C. BY: ,at[ ca/??CCcD?? e M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Exhibit "A"? N uuZco93 Pucel Nunl-: 16-15_ IW5-115 ik),oZO? ?a?ti3 .. "J.°+0; Die.JS .":IC@RLAND Couni1-Pe '97 SEP 16 RM 1107 54131038 le Por p.Wp DMI OR I Thu yl Comm9Dweldth of Pt°691'1vinlw v"I n` MORTGAGE HA C- He a4 - TNISMORTDA(111 vnryyumm<nnulmum The MPnleloru JOHNM. SANDERSON September 12 1997 whore <JJn°° 4162 KITTATINNY DRIVE MECHANICSBURG, PA 17055 . (•EOmwer•) Thu Seanry 4mrum<m u mvm, b EASTERN MORTGAGE SERVICES, INC. whmh NOrlemu4 em Jb kwa ar COMMONWEALTH edak+<u 26555 IN INTERPLEX DRIVE OF PENNSYLVANIA ' TREVOSE, PA 19053 wJ,we Eighty Five Thousand Five Hmdred and no/100 (4mer) Rormwnowm lemur Je Pmw,lul mm of DoumN3 i 85.500.00 _ Imma,ew tobe? ), rhmh gortln kr Amy... w"'Ne AJl lebLd-ptl W." n?jJ eWYWk??N<um<4aku W<S<curky hY ft Now. wnm mkrtw, em VI rtwwW, «¢bbu <m mm Th,e 4ennry LuWn,e,v mcartr m Lender. to 4b rt Ym of me dew evtlenreJ mve„wJ umn P"mah 7 b Jkeoom of oe Noe. N) oe PYmenrartll mar mm, w,m menm. Vrtemenk umer Ws Sew probe, me <w.onry ofJU Smunry kewmem, utl (e) me pertomeoee orEmrowere w<enmu em mwey mkmer bd lemurs t'wm<'esmrs <?tl Jrt NOm PorW<Wranu. RUmwerm<nutlemm?MWn 4hr4oa hembY YmvW nww aw olmw,m 4untkJ vmpero lonba m TOWNSHIP OF HAMPDEN CUMBERLAND LEGAL DESCRIPTION ATTACHED H Cmmy, hnmykuw. A PART HEREOF. VETO AND MADE M hu W.dare,m 4162 KITTATINNY DRIVE 17055 MECHANICSBURG Worn (•Propero AdJ,au•): TO NAVE AND 7Tl MOLD q,a umn Omer W 4mer'r u,weuou W eumm, romer. mlemm wnh ell me bertabmersbd m qe Pmpero W wl ell mu,wnk, rghu. eppurepewur, ,mY, mYemee, mmeml, wJ em ?mv ?? for Yak utlWMum mwwhertehere pn of Je wnwro All mpkwmub em.JNOpnr Nwh m w YmR?@rm?fu, wmr Aa of We fomp,q b nfemd m n Nu SecunrY Insmumnr u db .Pnmero • by mu leant b ,meu. 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NON-UNIFORM COVENANTS pormwer mid Lmda hmhtr mvmme ad1 *w ii folIM: 17. Assignment of Reels. p =W r awedawmry snap me a.mhu m [elan as Be Ron am meow ores plop,, aemeer wlhprms Lasnerm Ieate"a. m wlkm as rtw ma meoae.ed Laedmor lsodsr'a seem Nowe.cr, k?Yeim°mh w.m am. FmPerbmwr eertmm imamvr rsaR rataa.ed nom all rtmr m?Lamn•s.ase a mmmrallmmWra br..m a aro oormm ertlrvmm m es 9emlb fvapamm rt.rmes el m P'^P.rry u mm fm db aenefl a lender a.d BOrNWer.lhm aupmaam oommm m aamme nWlmmamd m w saanam far MdmoW °nn9'oMy It Land" X" ease of mach m Bamapr h) m non nRWd by taWUer mall he yep by Bourse a Wrap tar bola alandn say. m se AMmd m es mm moved by Be Sen o lmumm. (p Lem" mW he mmed m calm am reemw al ante urn ante pnpro. ase (.) mesa Wass' Of Bem 1"Pi'my aba?pyy We seem mused unped a lemer or leader. arm an Luster. arm demon m as soma m new mdse ch. prmmp l) m Purr ugmmm a ds remit wd pn m eon ma mpllmm al9' as ms aputl Meum leedw fmm nmeums Iemn not an sa mgaad s en"-Pan. oR wane! 0w morose de Popp bum or am llama wdce or anam m ¢aWeer. xoapar. LsWrwatubcmp .ppma causer mY ao a a very ante menu • mum mama uq odwnW mrtm4y ofLemer ran uWmmuaamaee A^1'Wpinmaeanm er4 ememaauve.y a.haru ? u Pm a fait Prepero rmR ammo wow dodo mmua q air Sectary Imlmm Id. Foreclosure Procedure. If fonder requires Immediate payment in fail abler paragraph 9, Leader way foreclose this Security Instrument by judicial Proceeding. I,mdw shell be emitted to collect all expenses incurred in pmaud"i I the remedies provided in this paragraph 18, including. but not limited for reammMn atomays' fees and mats of title evidenle. Ir the l order's interes t in this Security Instrument It held by the Secretary and the payment in fail muter Paragraph 9, the B alSeendary e provided e Inth immediate Mortgage Foresimmr Act of 1994 rActn) (IZ $.?3 51 at by requesting the oy ja sl powerorals ProvMed In the Single espompy under the Act to commence foaM and sail the Property a eel in th d. Nothin n the precea. weed shad deprive the Seentary of any rights ahermavailable to a as Leader under the this Paragraph a raph i 13 in or the preceding law. a 9. Release. u w applicable Ian wrmm orw oar mvW gmusorry lnsp-esn, urn Savnry Iamummsm do"m ounwoaceaaem was Mee call as-now, Lem" coal auwrye as swab eu Sear'aY temmmn oedema nOpY led sup wa-mm am mmn nom. corm. m Ramose tmWaermru P.Y W Zd. WmPere. awmwer, m me seen pmmed q maaRa. hr, wn" am mym my rawer arum m ppmymt. a wmm mu smog moll!mm..ed sang wmeer me m?mf- of wY Pmmw or hmn hwr llama, rem my a eu- onopp a aeu. uenmwv Boa Ammma•very am ab, atl aam"sW meppaw 21. Reinstatement Period. Rerawa's arc a nmsm wway n possess, to mW mead move sear pared es 1 22. PmrhmeamonmMoeony Mortgage. y, Moeas er nose r.k peon n eu ean-ry Imtlpmmlr tgage. lrmry Dram arm mud q es Sauey tea-men u Ion a uoWwer serous sue m m Papery. urn Russ taWaem en a pna.n mercy mpye 23. Interest Ram Judgmgment. seraaer ones ase anom am Nee asrsJedrlmumaammnn Nm ormnon Riders to is Sec wed Riders to this Security Instrument. p.YSNe Rom One nmm order daNm 24. Ridurity IneM. xprc er mar urns" oemm q "mou"sed eemady mgemer wW urn Saar9 woos. 1 . see de ach eder rasp m mwRORW wa tw mw amen red mppemn.( w.wnu.m vmmeeu e1 Wr Smvmy Immmmn A rsa rams) wart m. pan d urn Santry mnaoumen IrJraa.pplwae mx(u)1 ? Cesd m Raer ? Mediae Rea Ran Q Phnnon U. De ,van U.r ? ?1O'MOw PWm' Ran BY MGNWG BELOW, Barmwer.a.M aw ? Ono hymen Rtler ? Omer (mecp) eonowpr W may wed n. wmr m me area eammaj m u tlm Snvrry Imwmea am m wy raa(s).aavmd q Wmmaa". C? JOFA? s a ?? Jai seen.., (Seep am..w . rasa) - (See) aaa. AOSIMW 1maJ.sm.p -ml9d Pye4 ad 80og1405rgsa 211 i cvtlDcRte of ReaMeoae ORIGINAL 1. CAROLYN A. DONAH ao 4-by -r-fl ft Pe wan„mna of Pe wvem,mmrn ,meer a 26535 3 DiTERPI-Ex DRIVE. TREVOSE, FA 19051 Wanes my mna ft 12th agar Sep[wbe Lm 101, OR COMMONWEALTH OF PENNSYLVANIA, . C COMRERLAND JOHN M. SANDERSON 4Y o, S*Mbw 1997 . peon m, ar oMelryoy alEeer, penauiy nF,orta k m w(or mm,mmnly Fmera) mhau pe 06 wpam nme(? (S nbcnbel m Pe wlPm auoameN W wpnowl,dRW dv, HFISYRQifY Imam, Pe .me ,n ab q,ry,m, pert. wnowa M WITNESS WHEREOF. I Rnunm,n mY p,M ud oRmmi ay /, f/ an;v nRl SW SIgA.meE Wapner. NNgqy.yy Purim HampWn Twp, CUmp,avavla Cpmry 01 At, pty Cammmsron Engres,p,y 75, EpO, Denlper. M1nmyhanl, Aavnatlon axwap 3[E7M LAND 7RVkWM H& -? 5oo64a „m„ws,am e9ON14059m 212 i• PTPA-63 FIRST AMICAN TITLE INSDRANcR COMPANY Commitment No. 500062 SCHEDULE C ALL THAT CERTAIN lot or tract of land with the improvement, Pennsyerectedvaniathereon, as setuforthnonHampden the e Townshi, Cumberland Subdiva on Plan fornty, Mountain View village, Phase IV, also known as Wyndham Place, d Recorder Of ated June 1, 1989 and recorded May 7, 1990 in the Office of the Plan Book 60, ePagei87, more particularly bounded Pandsdescribednas follows to wit: BEGINNING at a point on the northern right-Of-way line of Kittatinny Drive (64• wide private), at the dividing line of Lot #62 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds west 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point, Thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 eet ; Thence line of centeroofta partition wall #62 and through f o seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the Place of BEGINNING. CONTAINING 2,000 square feet. BEING Lot #63 on Final Subdivision Plan of Mountain view village Phase IV Recorded in Plan Book 60, Page 87B. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-way of record. her to be$reco ded8simultaneouslyHherewith Sandrain thebOffie of theed Recorder of Deeds of Cumberland County, granted and conveyed unto John M. Sanderson. E9oK1405esE ,213 JOE KOONCE Assistant Secretary, and duly authorized representative of Plaintiff, deposes and says subject to the penalties of IS Pa. C.S.A. Section 4904 relating to unswom falsification to authorities that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to his information and belief. Q44L,-", JOE KOONCE , Assistant Secretary Grenen & Birsic, P.C. Verification ?? Q `T -I LSI ' ! A V r ?+ ?? ?-, ?: G -. ?,; ? =' ., J am ? ? C " ^TJ - °i " C, i ' i ?? ?? t ??+ ? a cJ "? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, Vs. JOHN M. SANDERSON, Defendant. NO.:02-5674 ISSUE NO.: TYPE OF PLEADING: PRAECIPE TO REINSTATE CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE 1 CODE - FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. Nine West One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. JOHN M. SANDERSON, Defendant. CIVIL DIVISION NO.:02-5674 PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO:PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. At rmeys for Plaintiff Ir, C:) 0 -TI `- v CIO ?9 ? °' aC7 SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-05674 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M R. Thomas Kline , Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: SANDERSON JOHN M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT , SANDERSON JOHN M NOT SERVED , as to UNABLE TO SERVE PRIOR TO EXPIRATION, ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing Service Affidavit Surcharge .00 18.00 Y/f- 17.94 ,4.-R. TB 10.00 SH RI .00 45.94 GRENEN & BI S 12/26/2002 Sworn and subscribed to before me this day of -2 un,? A. D. OF CUMBERLAND COUNTY Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JOHN M. SANDERSON, Defendant. NO.:02-5674 TYPE OF PLEADING: MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO SPECIAL ORDER OF COURT CODE- FILED ON :BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa.I.D.#77991 GRENEN & BIRSIC, P.C. One Gateway Center, Nine West Pittsburgh, PA 15222 Firm #023 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, NO.:02-5674 vs. JOHN M. SANDERSON, Defendant. MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Chase Manhattan Mortgage Corporation, by and through its attorneys, Grenen & Birsic, P.C., and files the within Motion for Special Service of Civil Action - Complaint in Mortgage Foreclosure Pursuant to Special Order of Court, under Pennsylvania Rule of Civil Procedure 430 as follows: 1. On November 25, 2002, Plaintiff filed a Civil Action, Complaint in Mortgage Foreclosure against the Defendant, John M. Sanderson, at the above term and number. 2. On or about November 25, 2002 and January 2, 2033, Plaintiff delivered to Cumberland County Sheriff a copy of the Civil Action, Complaint in Mortgage Foreclosure, with instructions that it be served upon Defendant at the last known address being 4162 Kittatinny Drive, Mechanicsburg, PA 17055. 3. On or about December 26, 2002 and February 3, 2003, Cumberland County Sheriff notified Plaintiff that they were unable to serve Defendant at 4162 Kittatinny Drive, Mechanicsburg, PA 17055, with a copy of the Complaint since Defendant could not be served at said address, although numerous attempts were made. True and correct copies of the Cumberland County Sheriff's returns are marked Exhibit "A", attached hereto and made a part hereof. 4. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, John M. Sanderson, is marked Exhibit "B", attached hereto and made a part hereof. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Cumberland County Sheriff to post a copy of the Complaint on the property at 4162 Kittatinny Drive, Mechanicsburg, PA 17050, and permit the Plaintiff to serve Defendant, John M. Sanderson, by mailing a true and correct copy of the Complaint by certified mail, return receipt requested and by first class mail, postage pre-paid to 4162 Kittatinny Drive, Mechanicsburg, PA 17050. Service of the Complaint shall be deemed complete and valid upon posting and mailing by the Plaintiff. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT "A" SHERIFF'S RETURN - NOT SERVED CASE NO: 2002-05674 i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M R. Thomas Kline Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: SANDERSON JOHN M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT NOT SERVED , as to SANDERSON JOHN M UNABLE TO SERVE PRIOR TO EXPIRATION, ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: So ?ers• Docketing 18.00 Service 17.94 Affidavit 00 -f1L9. T140 PAS KLINE Surcharge 10.00 SH.RI F OF CUMBERLAND COUNTY .00 45.94 GRENEN & BI S 12/26/2002 Sworn and subscribed to before me this day of A.D. Prothonotary From: 02/03/2003 13:21 9158 P.002/002 SHERIFF'S RETLMN - NOT FOUND CASE NO: 2002-05674 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M 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 SANDERSON JOHN M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , SANDERSON JOHN M UNABLE TO SERVED PRIOR TO EXPIRATION ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: So answers: Docketing 18.00 Service 13.80 Not Found 5.00 R. T omas Kline Surcharge 10.00 Sheriff of Cumberland County .00 46.80 GRENEN & BIRSIC 02/03/2003 Sworn and subscribed to before me this A.D. day of Prothonotary EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. NO.:02-5674 JOHN M. SANDERSON, Defendant. AFFIDAVIT PURSUANT TO PA. R.C.P. 430 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, of GRENEN & BIRSIC, P.C., attorneys for Plaintiff, deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, John M. Sanderson, named in the above-captioned matter: 1. On or about December 20, 2002, Plaintiff mailed to the United States Postmaster at Mechanicsburg, Pennsylvania 17055, a certain Request for Change of Address or Boxholder Information Needed for Service of Legal Process for Defendant. 2. On or about January 2, 2003, Plaintiff received a response from the aforementioned United States Postmaster stating that the Defendant moved, left no forwarding address. A true and correct copy of said response is marked Exhibit "1", attached hereto and made a part hereof. 3. A search of a nationwide computer database found a current address of 4162 Kittatinny Drive, Mechanicsburg, PA 17050 for Defendant, John M. Sanderson. True and correct copies of the search is marked Exhibit "2", attached hereto and made a part hereof. 4. The Defendant is listed in the Cumberland Area telephone directory, however he requests his information to be non-published. 5. A search of the County Voter Registration records revealed that Defendant is registered to vote in Cumberland County. A true and correct copy of said Voter Registration records are marked Exhibit "3", attached hereto and made a part hereof. Finally, affiant deposes and says that the last known address of Defendant, John M. Sanderson, is 4162 Kittatinny Drive, Mechanicsburg, PA 17050. Kri tine,M. An ou, Esquire SWORN to and subscribed before me this day of Q b (,1 a n , 2003. f i Notary Public bec? t G 1"101ry Fub1,c city nY P??x , ? tcFl ny COLiiAV 2 `i.nZ Exhibit Ill" Date December 20, 2002 Postmaster Mechanicsburg, PA 17055 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) for the following: Name: John M. Sanderson Address: 4162 Kittatinny Drive NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(4)(1) and (2) and corresponding Administrative Support Manual 352.41a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself):Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: Chase vs. Sanderson 4. The court in which the case has been or will be heard: Common Pleas of Cumberland 5. The docket or other identifying number if one has been issued:02-5674 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I ertify th at the above information is true and that the address information is needed and will be used solely for srvice of legal pro s 'n c nnection with actual or prospective litigation. S gnatur J nnifei A. indley rinted Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY - No change of address order on file. - Not known at address given. POSTMARK NEW ADDRESS OR BOXHOI-DER'S NAME and STREET ADDRESS .?¢llp (' ??q? C' J? " U L _YW \110SPS ?cf o Moved, left no forwarding address _ No such address. Exhibit "2" Search - 3 Results - 184-48-94 Page 1 of 2 Source: My_. Sources > Public .._Records > Person ._Locator > EZFIND Combined Person Locator Nationwide Terms: 184-48-9422 (Edit Search) Select for FOCUSTM or Delivery 17, SANDERSON, JOHN M (MALE) THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY PERSON LOCATOR - P-SEEK Name: SANDERSON, JOHN M (MALE) Social Security Number: 184-48-XXXX Consumer Name Last Updated: 11/27/2000 Address: 4162 KITTATINNY DR MECHANICSBURG, PA 17050-9137 Address Type: SINGLE FAMILY Address Created: 10/29/1997 Address Updated: 11/27/2000 Previous Addresses: 646 S 2ND ST STEELTON, PA 17113-2909 Address Type: SINGLE FAMILY Address Created: 12/11/1990 Address Updated: 12/3/1997 52 WINCHESTER GDNS CARLISLE, PA 17013-4615 Address Type: SINGLE FAMILY Address Created: 4/17/1994 Address Updated: 8/30/1995 Birthdate: 1972 On File Since: 12/11/1990 Date Vendor Record Last Updated: 11/27/2000 Source: My_Sources > Public.Records > Person Locator > EZFIND Combined Person Locator Nationwide (D Terms: 184-48-9422 (Edt Search) View: Full Datelrime: Monday, January 20, 2003 - 10:40 AM EST httn: //www.lexis.com/research/retrieve?_m=5a lcc66888 l6Oa2624083ab2b8 81 eff3&docnt... 01/20/2003 Search - 3 Results - 184-48-92 - Page 1 of 1 Source: My._Source s > Public.Records > Person Locator > EZFIND Combined Person Locator Nationwide Terms: 184-48-9422 (Edit Search) ,F Select for FOCUST"' or Delivery SANDERSON, JOHN M THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY ` PERSON LOCATOR - P-TRAK Name: SANDERSON, JOHN M Social Security Number: 184-48-XXXX Address: 4162 KITTATINNY DRIVE APT. D MECHANICSBURG, PA 17050-9137 Address Updated: 9/1/1997 Previous Addresses: 646 2ND STREET STEELTON, PA 17113-2909 Address Updated: 5/1/1996 Birthdate: 9/1971 Telephone: 732-6714 On File Since: 10/1/1990 Source: My Sources. > Public Records. > Person Locator. > EZFIND Combined Person Locator Nationwide Q Terms: 184-48-9422 (Edit Search) View: Full Date/Time: Monday, January 20, 2003 - 10:41 AM EST About_LeXisNexis I Terma and Conditions copyright © 2003 LexisNexis, a division of Reed Elsevier Inc:. All rights reserved. http://www.lexis.comlresearch/retrieve?_m=5alcc66888l6Oa2624(183ab2b88l eff3&docni... 01/20/2003 Search - 3 Results - Sanderson ohn M. Page 1 of 1 Source: My_Sources > Public__Records. > Person._Locator > boter_Registra_.tion;> > Pennsylvania Voter Registrations d Terms: sanderson, john m. (Edit Search) -Select for FOCUSTM or Delivery SANDERSON, JOHN M *** THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY *** PENNSYLVANIA VOTER REGISTRATIONS Name: SANDERSON, JOHN M Resident Address: 4162 KITTATINNY DRIVE MECHANICSBURG, PA 17050 County: CUMBERLAND Date of Birth: 6/14/1972 Gender: MALE * * * * * * VOTER INFORMATION * * * * * * Registration Number: 0001038622 Party Affiliation: REPUBLICAN Registration Date: 8/30/2000 Congressional District: 17 State Senate District: 31 State House District: 087 Precinct: HAMPDEN 11 Source: My Sources > Public Records > Person Locator > Voter Registrations > Pennsylvania Voter Registrations Q Terms: sanderson, john m. (Edit_Search) View: Full Date/Time: Monday, January 20, 2003 - 10:42 AM EST About LexisNexis I Tens_a.n..d Conditions Copyri_ght:© 2003 LexisNexis, a division of Reed Elsevier Inc. All rights reserved. http://www.lexis.comlresearch/retrieve?_m=89172d4aaa55c220df,98b7ac2O96eac 1 &docnt... 01/20/2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. ORDER OF COURT AND NOW, to wit, this day of , 2003, upon consideration of the within Motion for Special Service of the Complaint and all subsequent pleadings in Mortgage Foreclosure Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, John M. Sanderson, with a true and correct copy of Plaintiff's Complaint, by causing the Sheriff of Cumberland County to post the real property, being 4162 Kittatinny Drive, Mechanicsburg, PA 17055, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by first class mail, postage pre-paid at 4162 Kittatinny Drive, Mechanicsburg, PA 17055. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. BY THE COURT: CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court was mailed to the following on this W-41 day of C h r u 2003, by first class U.S. Mail, postage pre-paid: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 GRENEN & BIRSIC, P.C. Kristi Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 C? ? C7 c- ?.?, ? i= ? --, r,=, , ? ., = fr ?- c;- « - r__s:: t- _ , ?_-- ?? ? y' - ,? ?1 r j -+n ? ? - c? ? FEB 1 1 2003 ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. ORDER OF COURT AND NOW, to wit, this /3 ` day of A4V f 2003, upon consideration of the within Motion for Special Service of the Complaint and all subsequent pleadings in Mortgage Foreclosure Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, John M. Sanderson, with a true and correct copy of Plaintiff's Complaint, by causing the Sheriff of Cumberland County to post the real property, being 4162 Kittatinny Drive, Mechanicsburg, PA 17055, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by first class mail, postage pre-paid at 4162 Kittatinny Drive, Mechanicsburg, PA 17055. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. BY THE COURT: z,.. w 0 iv .` ` , tf l hl??i?ln?P?? Pi .? c? i ?"+, } i I ?: v1 1`.? 1- .? SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-05674 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M 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 SANDERSON JOHN M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND as to the within named DEFENDANT SANDERSON JOHN M UNABLE TO SERVED PRIOR TO EXPIRATION, ALTHOUGH NUMEROUS ATTEMPTS WERE MADE. Sheriff's Costs: Docketing 18.00 So answ Service 13.80 Not Found 5.00 / Surcharge R• Thomas Kline 10.00 Sheriff of Cumberland County 00 46.80 GRENEN & BIRSIC 02/03/2003 Sworn and subscribed to before me this 7---- day of Zbis,3 A . D . Px onotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, Vs. JOHN M. SANDERSON, Defendant. NO.:02-5674 ISSUE NO.: TYPE OF PLEADING: PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE CODE - FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. Nine West One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE ) CORPORATION, ) NO.:02-5674 Plaintiff, ) VS. ) JOHN M. SANDERSON, ) Defendant. ) PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO:PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: Attorneys for Plaintiff ?. e_= e_. .? -- _?, .... , ?, f , , ;.. G' ?_^.4? _:- ??"? f_ 'i- -T, ?- t _. > I: -, r? ?'? n, SHERIFF'S RETURN - REGULAR CASE NO: 2002-05674 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SANDERSON JOHN M DEFENDANT the , at 1823:00 HOURS, on the 25th day of February , 2003 at 4162 KITTATINNY T)PTVF. MECHANICSBURG, PA 17055 Dlnerru I nn/lnnnmv T m by handing to 4162 KITTATINNY DRVIE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.97 Posting 6.00 Surcharge 10.00 .00 42.97 Sworn and Subscribed to before me this day of -2003 A.D. Prothonot r So Answers: R. Thomas Kline 02/26/2003 GRENEN & BIRSIC By: ? Deputy eriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, CIVIL DIVISION NO.: 02-5674 VS. JOHN M. SANDERSON, Defendant. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH43219 the last known address of Defendants is: 4162 Kittatinny Drive Mechanicsburg, PA 17055 GRENEN & BIRSIC, P.C. Attorneys for Plaintiff ISSUE NUMBER: TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D.477991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA (412) 281-7650 `! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, vs. Plaintiff, NO.: 02-5674 JOHN M. SANDERSON, PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Defendant. Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, John M. Sanderson, in the amount of $57,449.88, which is itemized as follows: Principal $ 49,859.96 Interest to 4/1/03 $ 3,012.37 Late Charges to 4/1/03 $ 259.07 Escrow Deficiency to 4/1/03 $ 400.16 Corporate Advances $ 168.32 Attorneys' fees $ 1,250.00 Title Search, Foreclosure and Execution Costs $ 2.500.00 TOTAL $ 57,449.88 with interest on the principal sum at the rate of $9.90 per diem from April 1, 2003, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. Sworn to and subscribed before me this day of 12003. Notary Public Notarial Seal Patricia A. lbwnseW, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2003 Member, Pennsylvania Association of Notaries ON PLEAS OF CUMBERLAND CO, PENNSYLVANIA COURT OF COMM IN THE CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 DATE OF NOTICE: March 21, 2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 PHONE (800)-990-9108 GRENEN & BIRSIC, P.C. By: Atto s for Pl intiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID W N M --4Z V CA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, Plaintiff, NO.: 02-5674 vs. JOHN M. SANDERSON, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on aDC ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: $57,449.88 with interest on the principal sum at the rate of $9.90 per diem from April 1, 2003, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. Deputy , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV CIVIL DIVISION ANIA PRAECIPE FOR WRIT OF EXECUTION Caption: Chase Manhattan Mortgage Judgment Corporation ( ) Other File No. - John M. vs. Sanderson Amount Due Interest Atty's Comm TO THE PROTHONOTARY OF THE SAID COURT- Costs 2002-5674 A57,449.88 $1,721.40 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession Of judgment, but if it does, it is based on the a Pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6pof1 amededeeding filed, 974 as Issue writ of execution in the above matter td the. Sheriff of for debt, interest and costs, updn.,the'folloiving -described proper{y of the defendant(s) County, Please see atta11-A - PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland costs, as above, directing attachment against the above-named County, for debt, interest and estate, supply six copies of the description; supply four copies of lengthy personalty list) Please see attached description garnishee(s) for the following property (if real. and all other property of the defendant(s) in the possession, custody or control of the said (Indicate) Index this writ against the garnishee(s). garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date r'12 4,3 Signature: _ ?Lr eJC.C i• }i?S Q ?C G.? e?7?... Print Name: Kristine ?tbwi Address: One Gateway Center Nine West Pittsburgh, PA 15222 Attorney for: Plaintiff Telephone: (412) 281_7650 Supreme Court ID No.: 77or (over) r- w h p r T noh?o;? ooo?p -moo .? p e PL, 1 1 ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; Thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; Thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-way of record. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16,1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. GRENEN & BIRSIC, P.C. By; ?T l(G?',t C? E ?v Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Tax Map No.10-15-1285 Parcel 113 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of John M. Sanderson located at 4162 Kittatinny Drive, Mechanicsburg, PA 17055 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DR., MECHANICSBURG, PA 17055. DBV 164, PAGE 572, AND TAX MAP NO.10-15-1285 PARCEL 113. 1. The name and address of the owner or reputed owner: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 2. The name and address of the defendants in the judgment: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation [PLAINTIFF] Hampden Township 5001 Park Mechanicsburg, PA 17055 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Bureau of Individual Taxes Commonwealth of Pennsylvania Department of Welfare Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. GRENEN & BIRSIC, P.C. SWORN to and subscribed before me this 3rd day of a UAL -" 12003. Notary Public COMMOnnN` 1.TH Op PSMSYLVANIA f ri SPgI Reber' 6, al una 2 r`?. ?rypahlC OfPltrt ,rgh 114 Ih°nvCq?l4r Ommtssla+?,?r?^?2.2007 Membgr, Penneyiwnia AssocisLw' a -Wades Kstine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 4162 Kittatinny Drive, Mechanicsburg, PA 17055 is Defendant, John M. Sanderson who resides at 4162 Kittatinny Drive, Mechanicsburg, PA 17055, to the best of her information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS r'? DAY OF ?d/((J L ( 2003. t. Notary Public COMMONW_EG,LTF'._:',4 7NNSYLVAMA Rebecca, v £ti.. ., : ?lic CRYOfPftbucgn •, t^ty MYC seion Exc,u OT Mertiber. ftnMyflw. ASe ,to. OI Noierbs { `? f`l ? e"' _i ?- 3» .f a ?'. , ?Y .,,?! " --? .,'? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M.SANDERSON, Defendant. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101, ET SEQ. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. § 1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title H of the National Housing Act (12 U.S.C. §§1701-1715z-18) [35 P.S. §1680.401C(a)(3)]. Additionally, Plaintiff was not required to send Defendant written notice of Plaintiffs intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101 and the Defendant is not a "residential mortgage debtor" as defined in 41 P.S. §§/101. SWORN TO AND SUBSCRIBED BEFORE ME THIS Yr?DAY OF JC, 2003. Notary Public COMMONWEALTH OF PENNSYLVANIA NofeAal Seal Rebeooa O.5larlna, Notary Public Cry Of PitlaburM. Aft*wry County My Commlae w Expires June 2,2W? We bn. PennWmnm A690*11oh Of Notann CJ C:. _.. 't: r_ r f_'.. _. ,__, ?. fir' '.J ?I -?. ? I' _ d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2"d Floor 1 Courthouse Square Carlisle, PA 17013 on September 3, 2003, at 10:00 A.M., the following described real estate, of which John M. Sanderson is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DR., MECHANICSBURG, PA 17055. DB V 164, PAGE 572, AND TAX MAP NO.10-15-1285 PARCEL 113. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. John M. Sanderson, Defendant, at Execution Number 02-5674 in the amount of $59,171.28. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Court Administrator 4" Floor, Cumberland County Courthouse Carlisle, PA 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By. a! l6 ? tiC? f'K? Kristine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; Thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; Thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-way of record. BEING the same premises which Sandra L. Reber, by Deed dated September 12,1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. GRENEN & BIRSIC, P.C. zi? c u C Lk. By: Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Tax Map No.10-15-1285 Parcel 113 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5674 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOHN M. SANDERSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $57,449.88 L.L. $.50 Interest - $1,721.40 Arty's Comm % Due Prothy $1.00 Arty Paid $217.71 Other Costs Plaintiff Paid Date: JUNE 10, 2003 CURTIS R. LONG Prothonotaa (Seal) By: Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, NINE WEST PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, Plaintiff, ISSUE NUMBER: Vs. NO.: 2002-5674 JOHN M.SANDERSON, Defendant. TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS CODE- FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D.#77991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 9/3/03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, Plaintiff, V5. JOHN M. SANDERSON, Defendant. NO.: 2002-5674 Pa RCP RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on September 3, 2003as follows: 1. John M. Sanderson is the owner of the real property and has not entered an appearance of record. 2. On February 13, 2003 this Court entered an Order authorizing Plaintiff to serve Defendant, John M. Sanderson, by posting the property and serving the Defendant by certified mail return receipt requested and first class mail to addresses sett forth in the Order, with service to be valid upon posting and mailing. A true and correct copy of the Order is marked as Exhibit "A" attached hereto and made a part hereof. 3. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on June 11, 2003 and June 13, 2003 the undersigned counsel served Defendant, John M. Sanderson, with a true and correct copy of Plaintiffs notice of the sale of real property by certified mail, return receipt requested, and regular U.S. mail postage prepaid, addressed to 4162 Kittatinny Drive, Mechanicsburg, PA 17055. A true and correct copy of the U.S. Postal Service form 3800, Article Numbers 7003 0500 0001 7588 6653, and the Certificates of Mailing, evidencing; service by certified mail and first class mail on the identified Defendant, are marked Exhibit "B", attached hereto and made a part hereof. 4. On June 23, 2003, Sheriff s Office of Cumberland County posted the property located at . A true and correct copy of Sheriffs return of Service: is marked Exhibit "C", attached hereto and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. GRENEN & BIRSIC, P.C. BY: -T Kristine M. Anthou, Esquire Attorneys for Plaintiff Nine West, One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 SWORN rr TO AND SUBSCRIBED BEFORE ME THISSI DAY OF , 2003. ., but t ? lG ? 1?.?1 GL Nota Public CRO O"rE L' NNSYWANI A GBla r. ry ZO u?c pr Ple ur_ "Oegy 200 c_xpres June 2, 2007 gyy9elbn of Notaries uyr, FenroyNaMe Exhibit "A" FEB 1 1 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, N0.:02-5674 Plaintiff, VS. JOHN M.SANDERSON, Defendant. ORDER OF COURT AND NOW, to wit, this 43?- day of 3 2003, upon consideration of the within Motion for Special Service of the Complaint and all subsequent pleadings in Mortgage Foreclosure Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, John M. Sanderson, with a true and correct copy of Plaintiff's Complaint, by causing the Sheriff of Cumberland County to post the real property, being 4162 Kittatinny Drive, Mechanicsburg, PA 17055, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by first class mail, postage pre-paid at 4162 Kittatinny Drive, Mechanicsburg, PA 17055. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. BY THE COURT: ?4 /L J. t?: c r , ;/E', s S .it#'a( ?.td-v LyFU iE ?? Pa. Joi93 PrrltESi',?fRC.t;3PJ CFRTIFICAIt yr m•.. postmaM squire at U.S. POSTAL SERVICE . AAY BE USED FOR DOMESTIC AND W 7FRNATIONAL MAIL, DOES NO Posaster for current T fee... Received From: One Ga MY Center one piece of ordinary mail addressed to JV I l ? U Mec ni` S. OS //,^,p - an rsDn tW ?r1a1o; PS Form 3817, January 2001 ?'- y?W 1 1 '• r M Irel , % ., CO ? r 6 r, U , Lrl M1 Postage @ ? C3 ee Certified F M Postnark O Return Redept Fee (Endorsement Required) Xr7 Here O O Restricted DeliveryFee (Endorsement Required) Lr) M 8 F -2 ees Toal Postage M p o en, To ---------- john M1 F n O Box ptNNo. . `/ /0,f O ------------- - r/ ?. -_..-._... , Stele, ZIP?4 e I n/?? r t1 ' O? Exhibit 11 C" 0 Chase Manhattan Mortgage Corporation VS John M. Sanderson 40, in The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5674 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2003 at 7:23 o'clock P.M., she served the within Writ of Execution, Notice of Sheriff s Sale and Description upon the within named defendant to wit: John M. Sanderson, by posting the premises pursuant to court order at 4162 Kittatinny Drive, Mechanicsburg, PA 17055, according to law. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2003 at 5:48 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John M. Sanderson located at 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the martion to one of the within ail to his last known address named defendants, to wit: John M. Sanderson, by regular of 4162 Kittatinny Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of July 07, 2003 and returned to the Sheriff s Office on July undeliverable, addressee moved and left no forwarding address. 10, 2003 as Swom and subscribed to before me This day of 2003, A.ll.? Prothonotary 10 R. Thomas Kline, S enff Re al Esta eputy C-) CD O C7 r cn _ ? .< Y Y1 -c Chase Manhattan Mortgage Corporation In the Court of Common Pleas of VS Cumberland County, Pennsylvania John M. Sanderson Writ No. 2002-5674 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Kristine Anthou. Sheriff's Costs Docketing 30.00 Poundage 16.57 Posting Handbills 15.00 Advertising 15.00 Mileage 19.32 Levy 15.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Postpone Sale 20.00 Law Journal 367.70 Patriot News 309.88 Share of Bills 28.90 $ 864.87 paid by attorney 12/04/03 Sworn and subscribed to before me So Answers: / This ?o day of 7t_, /-? R. Thomas Kline, Sheriff 2003, A.D. 00 '' BY 1C Prothonotary Real s to Deputy sp 42.k y.368D P, I ISY 3 S' 66 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of John M. Sanderson located at 4162 Kittatinny Drive, Mechanicsburg, PA 17055 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DR., MECHANICSBURG, PA 17055. DBV 164, PAGE 572, AND TAX MAP NO.10-15-1285 PARCEL 113. 1. The name and address of the owner or reputed owner: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 2. The name and address of the defendants in the judgment: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation [PLAINTIFF] Hampden Township 5001 Park Mechanicsburg, PA 17055 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Bureau of Individual Taxes Commonwealth of Pennsylvania Department of Welfare Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. SWORN to and subscribed before Yd ?ti me this ? day of , 2003. a Notary Public COMMO-MAJ= --i!.Ttl OF PENNSYLVANIA LL, cayot PIas'xfgh.All,xlhenv ou* & br=is? x;.,r•. .. rs. 2. 2007 Msml?er, Pon reyl ,;? fssoaacxx, Of Nc>Wm u r. .2,e-( 6?. f Kristine M. Anthou, Esquire Attorney for Plaintiff r •? o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2"d Floor 1 Courthouse Square Carlisle, PA 17013 on September 3, 2003, at 10:00 A.M., the following described real estate, of which John M. Sanderson is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DR., MECHANICSBURG, PA 17055. DB V 164, PAGE 572, AND TAX MAP NO.10-15-1285 PARCEL 113. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. John M. Sanderson, Defendant, at Execution Number 02-5674 in the amount of $59,171.28. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Court Administrator 4' Floor, Cumberland County Courthouse Carlisle, PA 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff s Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By: Kristine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; Thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; Thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-way of record. ? Y BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. GRENEN & BIRSIC, P.C. Y Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 Tax Map No.10-15-1285 Parcel 113 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5674 Civil CIVIL ACTION - LAW TO 'THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOHN M. SANDERSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the ga:rnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is 1Found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $57,449.88 L.L. $30 Interest - $1,721.40 Atty's Comm % Due Prothy $1.00 Atty Paid $217.71 Other Costs Plaintiff' Paid Date: JUNE 10, 2003 CURTIS R. LONG Prothonotary (Seal) B ???? Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, NINE WEST PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 TRUE 00PY FROM REWRD TVs ay 1A A.) Real Estate Sale # 48 On June 12, 2003 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 4162 Kittatinny Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 12, 2003 By: Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. S before me this L.OIS E. Slit DER, I3 y' Pub1c L My Condon E*M Mwch 5, 1 day of AUGUST, 2003 REAL ESTATE GALS NO. " Writ No. 2002-5674 Civil Chase Manhattan Mortgage Corporation Vs. John M. Sanderson Atty.: Kristine Anthou LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hamp- den Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kit- tatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right- of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; Thence by line of land now or for- merly of J.P. Roth, South 82 de- grees 02 minutes 02 seconds East 20.00 feet to a point; Thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BE- GINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to cer- tain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cum- berland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, NEVERTHELESS, to easements, restrictions, reservations, conditions and rights-of-way of record. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on Septem- ber 16, 1997, in Deed Book Vol- ume 164, Page 572, granted and conveyed unto John M. Sanderson. Tax Map No. 10-15-1285 Parcel 113. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company, and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ................. ................ COPY Sworn to nd ubscri is 13th day o?-Augu 03 A.D. S A L E #48 axial Seal Terry L. Russell. Notary PCY City a Harrisburg, Da OMn My Corrxrwssion Expires June 6, 2006 NO ARY PUBLIC Merntxar, PennsyWn2 1on Or Notaaes My commission expires June 6, 2006 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 $ 308.13 Probating same Notary Fee(s) $ 1.75 Total $ 309.88 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By ......................................................... REAL ESTATE SALE No. 46 VWrlt. No. 2606874 Glvli Term Chase Manhattan Modger Corp. Vs John M. Sanderson Atty.: Krlstlne Anthou DESCRtPTtQN ALL THAT CERTAI lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, set fbrth on the final Subdivision Plan for Mountain View Village, Phase N, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as, follows to wit: BEGINNING at a point on the northern right-of- way line of Kittatinny Drive (64'wide private), at the dividing line of Lot #2 and #63; said point. also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02seconds West 20.00 feet to a point; Thence by line of Lot #64 and passing through the center of a partition wall North,07 degrees 57 minutes 58 seconds East 100.00 feet to a point; Thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; Thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way fine of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of ?!eds in and for Cumberland County, Pennsylvania in Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. ALSO UNDER AND SUBJECT, nevertheless. to easements, restrictions; reservations, conditions and tights-of-way of record. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in peed Book Volame 164, Page 572, granted and conveyed unto John M. Sanderson. TAXMAPN0.:10-15.1285 Parcel 113. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment Chase Manhattan Mortgage Corporation vs. John M. Sanderson TO THE PROTHONOTARY OF THE SAID COURT. (xx) Other File No. 2002-5674 Amount Due $57,449.88 Interest $9,286.32 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) SEE.ATTACHED.DESCRIPTION PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description;' supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. C.hC?trt?x? Date Signature: Print Name: Kristine M. Anthou. Esquire Address: One Gateway Center, Ninth Floor Pittsburgh, PA 15222 Attorney for: Chase Manhattan Mortgage Corporation Telephone: 412-281-7650 Supreme Court ID No.: 77991 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. c CI, ti N??4 ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5674 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOHN M. SANDERSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $57,449.88 L.L. Interest $9,286.32 Atty's Comm % Due Prothy $1.00 Any Paid $1,095.08 Other Costs Plaintiff Paid Date: JUNE 7, 2004 CURTIS R. LONG Prothonotary (Seal) OzlxerIt Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania 17055 is Defendant, John M. Sanderson, who resides at 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania 17055, to the best of her information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS N DAY OF Not Public , 2004. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2008 Member. Pennsyivenla Association 01 Notaries - , <a ? ; ,_. ;,,_ _,. ;?> ?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974,41 P.S.101, ET SEO. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. § I680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1701-1715z-18) [35 P.S. §1680.401C(a)(3)j. Additionally, Plaintiff was not required to send Defendant written notice of Plaintiffs intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. § 101 and the Defendant is not a "residential mortgage debtor" as defined in 41 P.S. §101. SWORN TO AND SUBSCRIBED BEFORE duA 2004. ME THIS &DAY ? 4?1?H1nA Rotary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2008 Member, Pwipvivivonia Ae5ociatioo Of Notaries rv r,? < i ca =fi t ..? 1 ') ?? t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of John M. Sanderson located at 4162 Kittatinny Drive, Mechanicsburg, PA 17055 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. DEED BOOK VOLUME 164, PAGE 572, TAX MAP NO.10-15-1285 AND PARCEL 113. 1. The name and address of the owner or reputed owner: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 2, The name and address of the defendants in the judgment: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 The name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation PLAINTIFF 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation PLAINTIFF 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. SWORN to and subscribed before me this day of 2004. Not Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commisalon Expires Jan. 6, 2008 IVIOM-tsof. Pennsvlvanla Association Of Notaries By. C_cX c Kristine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2"d Floor 1 Courthouse Square Carlisle, PA 17013 on September 8, 2004, at 10:00 A.M., the following described real estate, of which John M. Sanderson is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A D WELLING BEING KNO WN AND NUMBERED AS 4162 KITTATINNY DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. DEED BOOK VOLUME 164, PAGE 572, TAX MAP NO.10-15-1285 AND PARCEL 113. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, VS. John M. Sanderson, Defendant, at Execution Number 02-5674 in the amount of $66,736.20. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Court Administrator 4`h Floor, Cumberland County Courthouse Carlisle, PA 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the j udgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or ifthe judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By: (?C .G LIf Ck Kristi$e M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest comer of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. GRENEN & BIRSIC, P.C. By:?Lt.? CC9?. Kris6e M. Anthou, Esquire DB V 164 Attorney for Plaintiff Page 572 One Gateway Center, Ninth Floor Tax Map 10-15-1285 Pittsburgh, PA 15222 Parcel 113 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, Vs. JOHN M. SANDERSON, Defendant. ISSUE NUMBER: NO.: 2002-5674 TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS t ' CODE- FILED OIV BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281..7650 SALE DATE: 9/8/04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, Plaintiff, VS. JOHN M. SANDERSON, Defendant. NO.: 2002-5674 Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on September 8, 2004 follows: 1. John M. Sanderson is the owner of the real property and has not entered an appearance of record. 2. On February 13, 2003 this Court entered an Order authorizing Plaintiff to serve Defendant, John M. Sanderson, by posting the property and serving the Defendant by certified mail return receipt requested and First-Class mail to addresses set forth in the Order, with service to be valid upon posting and mailing. A true and correct copy of the Order is marked as Exhibit "A" attached hereto and made a part hereof. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on June 4, 2004, the undersigned counsel served Defendant, John M. Sanderson, with a true and correct copy of Plaintiffs notice of the sale of real property by certified mail, return receipt requested, and regular U.S. mail postage prepaid, addressed to 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7003 3110 0004 4621 0158, and the Certificate of Mailing, evidencing service by certified mail and First-Class mail on the identified Defendant, are marked Exhibit 'Brr, attached hereto and made a part hereof. 4. On July 13, 2004, the Sheriff's Office of Cumberland County posted the property located at 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of Sheriff's return of Service is marked Exhibit "C", attached hereto and made apart hereof. I verify that the facts contained in this Affidavit are tme and correct based upon my personal knowledge, information, and belief. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS IO41DAY OF 2004. Notary Public C01.4 d.CfB_NE%\'.-T f-i OF ??NNSYLVANIA n q al -l Eliz-ob 4f ,,,nn Jr t=ry Public C y U Pittrir! c P ?.!r aheny County My Cu ,p r Jan E, 2008 Member, F"- f,( s Y!?' o a Aboclat,on Of Notaries • •. Exhibit "A" • FEB 1 1 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:02-5674 Plaintiff, vs. JOHN M.SANDERSON, Defendant. ORDER OF COURT AND NOW, to wit, this /3 day of ,? 2003, upon consideration of the within Motion for Special Service of the Complaint and all subsequent pleadings in Mortgage Foreclosure Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendant, John M. Sanderson, with a true and correct copy of Plaintiffs Complaint, by causing the Sheriff of Cumberland County to post the real property, being 4162 Kittatinny Drive, Mechanicsburg, PA 17055, and Plaintiff is permitted to serve Defendant, by certified mail, return receipt requested and by first class mail, postage pre-paid at 4162 Kittatinny Drive, Mechanicsburg, PA 17055. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. BY THE COURT: U.S. Postal $erviceTM CERTIFIED MAILTM RECEIPT joomesticMaii only" NO surance Coverage J rov d) .. ..__..rr..e.,, iefarmetlon visit our vtebstte at www.usps.co .D L F05 ?e . 5 L- I H I o ti S %eriitied Fee L ?._.? Po?Vnark ED O Return ReL'lept Fee i doreement Regwretl) g 1 C Here 1 --I ( n I"` Fee li j ???? Q C3 ra very Restricted De (Entleree ON Required} l / m t.] Fosisge 8 Fees ' o Isa i°3CHN M SAN17?1 0 - - ` ?6? 1?1 I IATi?vN 17121V? r`- i §rraet Adt No, L1 to(POenr No _,_ - 1 I IC, jX4 , EC YJ <Vv (C ? V V cdr, sm :?r O 3 w V y m. c m N °o N A m F » 0 c S a-1 1 _ I ,., Ol 1 a 1 1 1 29 m n ?? rt ? m g no' ? w C' rt c n b F rL ro M ? r r n ? N n-? e t m ? A -L Pd tv j ? ?? ?IF o O j ? ?- rt K rt'mm N DOD 0 5 i ? I? N W td W ry o W r+ C C7 @ m m F` 7 r 2 C m C:ONO W 2 $¢ 6S? ? m iF s O+ N V H O N H r p C r. yy 2' u £ ???? rd M ro H W A r a g m ? M x< r < o a ?, o w c w DODO co m J, C7, 0 W m ?? ?. iyy 8 E Vj W W V' Q 8? o o ? a ? c; ? c A a a m ?m aq z p ? @ 3 a y m? c 9 m A? R< co 7 ATF * '.o 6 z ? ° •d USA i `? . ii g 0 Exhibit "C" 0 Chase Manhattan Mortgage Corporation VS John M. Sanderson Q In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5674 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: John M. Sanderson, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description, as NOT FOUND, as to John M. Sanderson. Several attempts at service were made at 4162 Kittatinny Drive, Mechanicsburg, PA, but defendant was not at home. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2004 at 6:48 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John M. Sanderson, located 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania, according to law. Sworn and subscribed to before me So This day of R. Thomas Kline, Sheriff 2004, A.D. Prothonotary BY 0((j???1L V Real Estate Deputy r-? C-D i`4 COMMON PLEAS OF CUMBERLAND CONY PENNSYLVANIA IN THE COURT OF CIVIL DIVISION MANHATTAN MORTGAGE CHASE MANO' CORPO? ISSUE NUMBER: Plaintiff, NO.: 2002-5674 Vs. JOHN M. SANDERSON, PLEADING: TYPE OF PLEAD Defendant. Pa. R.C.P. RULE 3129.2(c)(2) PURSUOL E WLE 3129.1 TO I LIENH R AFFIDAVIT OF ' SERVICE CODE- FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GgENEN & BIRSIC, P.C. one Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 9/8/04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 2002-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. Pa R. RULE 3129 2(cl(2? LIENHOLDER AFFIDAVIT OF SERVICE 1, Kristine M. Anthou, Attorney for Plaintiff, Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of plaintiff s Affidavit Pursuant to Rule 3129.1 as follows: 1. By letters dated June 4, 2004, undersigned counsel served all persons (other than the plaintiff) named in Paragraphs 3 through 7 of plaintiff s ,Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit marked Exhibit 3129.1 and Certificates of Mailing and any letters, if returned as of this date, "A", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BY: QC L a-'te /'t2' Kris me M. Anth , Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Sworn to and subscribed before me this 1'r day of 2004. Notary blic PENNSYLVANIA Fi a r ? i J'. "ub'dc Ct??i i r??oIlly Myr i ,t h,2008 N7ember. ?enrsylvenlr; Aaeuast?un 01 1"arie5 E??1Bl? • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE NO.: 02-5674 CORPORATION, Plaintiff, VS. JOHN M.SANDERSON, Defendant. AFFIDAVIT PURSUANT TO RULE 3129_I COMMONWEALTH OF PENNSYLVNNL\ SS: COUNTY OF ALLEGHENY Corporation, plaintiff in the above action, sets forth as of the Chase Manhattan Mortgage information was of record date the Praecipe for the Writ of Execution was filed the following Drive, concerning the real property of John M• Sanderson located at 4162. Kittatinny Mechanicsburg, PA 17055 and is more fully described as follows: SANDERSON OF, ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLL OWING DESCRIBED REAL ESTATE SITUATED IN TH PENNSYLVANIA. HAVING TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, NUMBERED AS 4162 ABM ERECTED THEIR OE A DWELLING BEING KNOB KITTATINNY MECHANICSB OG,OPENN 85 AND P 7705.IDBED BOOK VOLUME 164, PAGE 572, TAX MAP 1. The name and address of the owner or reputed owner: 4162 Kittatinny Drive John M. Sanderson Mechanicsburg, PA 17055 2. The name and address of the defendants in the judgment: 4] 62 Kittatinny Drive john M. Sanderson Wiechanicsburg, PA 17055 0 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: PLAINTIFF Chase Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations PA Dept. Of Revenue Commonwealth of Pennsylvania P.O. Box 320 Carlisle, PA 17013 Bureau of Individual Taxes Inheritance; Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false; statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. SWORN to and subscribed before me this day of 2004. Nctal Public CCNIfVrvNWEA,! hi ,F PENNS: VANIA '- --JrLrm' Seal GI L P'ar No--'.'r Dc liegheny 00011V r n f" jai! 6, ?r By: Kristine M. Anthou, Esquire Attorney for Plaintiff 0 r? RJ - .r , ?N °$E5 m? ? O `? O 0 J J 8 m co > ?OO? -H ca m y N ? 'C H. w + --I w Fn P. „'I I0 1 E {? r7 ( 10 p m - W O N p H ZI E i tlN q O w% 7? 0 ?I 1 16 41 N 10 0 0. ?y U Cd }+ . rl rl i J? i ti' D 0000 , t ,- ? 0) 'awx ?5 ? Tj yi 7s I I U - y G ? cNV J y a ? ;l ?. g $ i J O 0 y °r i ++ 4 3 ?J v ? a a J V Y m ' d O a. .: ?=:.. . I E N z a • m N la `o 3 c N a_ $ m m I? o ? N m z li e s9 n Am N m F {... n,) 4, _ ?Ii LL' ?, i ?? - '1 C.. 1'? -- .-... _.:::: •i:.' (.a ? I r. "j 1 ? i7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Steven C Buysse is the grantee the same having been sold to said grantee on the 8th day of Sept A.D., 2004, under and by virtue of a writ Execution issued on the 7th day of June, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 5674, at the suit of Chase Manhattan Mtg Corp against John M Sanderson is duly recorded in Sheriff's Deed Book No. 265, Page 4012. IN TESTIMONY WHEREOF, I have hereunto set my hand Z?t and seal?/of said office this z 9 day of 6?Z , A.D2004 Recorder of Deeds djm =& = A Chase Manhattan Mortgage Corporation VS John M. Sanderson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5674 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: John M. Sanderson, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description, as NOT FOUND, as to John M. Sanderson. Several attempts at service were made at 4162, Kittatinny Drive, Mechanicsburg, PA, but defendant was not at home. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2004 at 6:48 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John M. Sanderson, located 4162 Kittatinny Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 8, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $90,000.00 to Steven C. Buysse. It being the highest bid and best price received for the same, Steven C. Buysse of 1858 Hunter Drive, Mechanicsburg, PA 17050, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $94,098.78. Sheriff s Costs: Docketing $30.00 Poundage 1800.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 28.86 Levy 15.00 Surcharge 20.00 Law Journal 358.40 Patriot News 347.89 Share of Bills 30.49 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 2766.14 Sworn and subscribed to before me So_ sw s: This aF day of ?r R. Thomas Kline, Sheriff C,j."f 2004, A.D. (? P o onotary BY 4EstDeputy Real a)p 30'e 6D CJL4 7 (0("0 K,.., ;6? SLG SCHEfiULE OF DISTRIBUTION SALE NO. 48 Date Filed: October 08, 2004 Writ No. 2002-5674 Civil Term Chase Manhattan Mortgage Corporation VS John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 Sale Date: September 08, 2004 Buyer: Steven C. Buysse Bid Price: $90,000.00 Real Debt: $57,449.88 Interest: 9,286.32 Attorney Costs: 1,095.08 Total: $67,831.28 DISTRIBUTION: Receipts: Cash on account (06/15/04): $ 1,500.00 Cash on account (09/08/04): 9,000.00 Cash on account (09/23/04): 85,098.78 Total Receipts: $95,598.78 Disbursements: Sheriff s Costs Legal Search State Transfer Tax Local Transfer Tax Attorney Grenen & Birsic Chase Manhattan Mortgage Corporation John Sanderson Total Disbursements: Balance for distribution: So Answers: $ 2,766.14 200.00 1,049.39 1,049.39 1,500.00 67,831.28 21,202.58 ($95,598.78) 0.00 R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 48 Held Wednesday, September 8, 2004 Date: September 8, 2004 TAXES: Receipts for all taxes for the years 2001 to 2003 inclusive. Taxes for the current year 2004. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2004, and recorded , 2004, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Sandra L. Reber, single woman, by deed dated September 12, 1997 and recorded September 16, 1997 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania, in Deed Book 164 Page 572, granted and conveyed to John M. Sanderson, single man. OTHER EXCEPTIONS: The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbeds of Kittatinny Drive and Tussy Court. 6. Building and use conditions, setbacks and restrictions as shown on or set forth on the Final Subdivision Plan for Mountain View Village, :Phase IV, recorded in Plan Book 60, Page 87. 7. Building and use restrictions, covenants, easements and conditions as imposed by the Declaration of Covenants, conditions, restrictions and easements for Wyndham Place recorded in Miscellaneous Record Book 392, Page 787. As amended by First Amendment, to Declaration recorded in Miscellaneous Record Book 393. Page 557 and further amended by Second Amendment to Declaration recorded in Miscellaneous Record Book 414, Page 1102. Building and use conditions and restrictions as imposed by Deed recorded in Deed Book "U," Volume 34, Page 870, Deed Book "V," Volume 33, Page 384, Deed Book "F," Volume 26, Page 493, and Deed Book "O," Volume 34, Page 239. 9. Mortgage in the amount of $85,500.00 given by John M. Sanderson to Eastern Mortgage Service, Inc. dated September 12, 1997 and recorded September 16, 1997 in Mortgage Book 1405, page 208. Said mortgage was assigned to Chase Manhattan Mortgage Corporation by instrument recorded March 27, 1998 in Miscellaneous Record Book 572, Page 232. Complaint in mortgage foreclosure filed by Chase Manhattan Mortgage Corporation as Plaintiff, against John M. Sanderson, as Defendant, on November 25, 2002 in the Office of the Prothonotary of Cumberland County to File No. 2002-5674. Judgment in the amount of $57,449.88 entered April 4, 2003. 10. Private rights in party wall forming a portion of the property line for the subject premises. 11. Rights granted to the Pennsylvania Power and Light Company by instrument recorded in Miscellaneous Record Book 181, Page 936. 12. Rights granted to United Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 356, Page 307. 13. Rights granted to the Pennsylvania Power and Light Company by instrument recorded in Miscellaneous Record Book 383, Page 863. 14. Rights granted to UGI Corporation by instrument recorded in Miscellaneous Record Book 521, Page 497. 15. Utility and sanitary sewer easements as shown on Plan Book 70, Page 47, and Plan Book 62, Page 88. 16. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 17. Satisfactory evidence to be produced that advertisement of the sale was sufficient despite the lack of any reference to improvements on the subject premises. 18. Real estate taxes accruing on and after January 1, 2005 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be valid or bi until countersigned by an authorized signatory. REAL ESTATE SALE NO. 48 Writ No. 2002-5674 Civil Chase Manhattan Mortgage Corporation VS. John M. Sanderson Atty.: Kristine Anthou :LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erect- ed thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase W, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in <cnd for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kit- tatinny Drive (64' wide private), at the dividing line of Lot #2 and #63: Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; MiENCE by the northern right- of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; thence by line of land now or for- merhr of J.P. Roth, South 82 de- grees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot: #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BE- GINNING. CONTAINING 2,000 square feet. U114DER AND SUBJECT, to cer- tain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cum- berland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. DBV 164. Pale 572. Tai: Map 10-15-1285. Parcel 113. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, VS. JOHN M. SANDERSON, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of John M. Sanderson located at 4162 Kittatinny Drive, Mechanicsburg, PA 17055 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. DEED BOOK VOLUME 164, PAGE 572, TAX MAP NO.10-15-1285 AND PARCEL 113. 1. The name and address of the owner or reputed owner: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 2. The name and address of the defendants in the judgment: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation PLAINTIFF 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation PLAINTIFF 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Dept. Of Revenue Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswern falsification to authorities. GRENEN & BIRSIC, P.C. SWORN to and subscribed before me this day of '2004. Not Public COMMON(WEAi_Tt-? -JF PENNSYLVANIA Notanal Seal I Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Comrr155lon Expires Jan. 6, 2008 n? in(arr t €rir;e.V v an a Association Of Notaries By: - Kristine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. NOTICE OF SHERIFF'S SALE OF REAL, ESTATE TO: John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2"d Floor 1 Courthouse Square Carlisle, PA 17013 on September 8, 2004, at 10:00 A.M., the following described real estate, of which John M. Sanderson is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOHN M. SANDERSON OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF HAMPDEN, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 4162 KITTATINNY DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. DEED BOOK VOLUME 164, PAGE 572, TAX MAP NO.10-15-1285 AND PARCEL 113. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, VS. John M. Sanderson, Defendant, at Execution Number 02-5674 in the amount of $66,736.20. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Court Administrator 4`h Floor, Cumberland County Courthouse Carlisle, PA 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff s Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service.of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriff s Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff s Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. By: Kristine M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 02-5674 Plaintiff, vs. JOHN M. SANDERSON, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN lot or tract of land with the improvements erected thereon, situate in Hampden Township, Cumberland County, Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at a point on the northern right-of-way line of Kittatinny Drive (64' wide private), at the dividing line of Lot #2 and #63; Said point also being located 441.28 feet west of the northwest corner of Kittatinny Drive and Tussey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point; thence by line of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point on the northern right-of-way line of Kittatinny Drive, the place of BEGINNING. CONTAINING 2,000 square feet. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 392, Page 787, Miscellaneous Book 393, Page 557, and Miscellaneous Book 414, Page 1102. BEING the same premises which Sandra L. Reber, by Deed dated September 12, 1997 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 16, 1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. GRENEN 1 BIRSIC, P.C. By: Kris{yne M. Anthou, Esquire DBV 164 Attorney for Plaintiff Page 572 One Gateway Center, Ninth Floor Tax Map 10-15-1285 Pittsburgh, PA 15222 Parcel 113 (412) 281-7650 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5674 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOHN M. SANDERSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $57,449.88 L.L. Interest $9,286.32 Atty's Comm % Due Prothy $1.00 Atty Paid $1,095.08 Other Costs Plaintiff Paid Date: JUNE 7, 2004 CURTIS R. LONG Prothonota y (Seal) Deputy REQUESTING PARTY: Name EMSTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone : 412-281-7650 Supreme Court ID No. 77991 Real Estate Sale #48 On June 15, 2004 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 4162 Kittatinny Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 15, 2004 By: 111jo Real Estate eputy ?nf OR) c= THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 27th day(s) of July and the 3rd and 10th day(s) of August 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin, in Miscellaneous Book "M", Volume 14, Page 317.. PUBLICATION COPY SALE#48 ,P ....... ?? ............... day ofAugust 04 A.D. i anlaAsscclattonotNotari TARY PUBLIC My commission expires June 6, 2006 Terry L. Russell, City of Harrisburg, ly Commission Fxi CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 347.89 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... REAL ESTATE SALE No. 40 Jolt `I Atty: K. led. Antes DESCRIPTION ALL THAT CERTAIN lot or tsar of land with the imptove- i erectod thereon, situ* in Hampden Township, Cumberland County, Pennsylvania, era, set forth on the Final Subdivision Plan- for Mountain View .Village Phase N, also known as Wyndham Place, dated June 1, 1989 and recorded May 7, 1990 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as fblkrws to wit: BEGINNING at a point on the northern right-of-way line of Kitpaieny Drive (64'wide pri-vane), at the dividing Ike of Lot #2 and #63; Said point also being ioc*d 441.28 feet west of the northwest cornea of Kittatinny Drive and Tossey Court; THENCE by the northern right-of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to a point; thence by line of Lot #64 and passing through the center of a partition wall North 07 degrees 57 minutes 58 seconds Bast 100.00 feet to a point; them byline of land now or formerly of J.P. Roth, South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point; thence by line of Lot #62 and passing through the center of a partition wall South 07 degrees 57 minutes 58 seconds West 100,00 feet to a point on the northern fight-of--way line of Kittatinny Drive, the place of BEGINNING. CONTAINING z,ooosqume feet. UNDER MD SUBJECT, to certain restrictions and cations as of record in the Office of the Reeder of?s in and for Cumberland County, Pennsylvania in Miscellaneous Bank 392, Page_ 787, Miscellaneous Book 393, Page 557, and Miscellaneous book 414, Page 1102. BEING the same which Sandra L. Reber, by Dail September 12,1997 and recorded in the Office of the Recorder of Deeds of Curnberland County on September 16,1997, in Deed Book Volume 164, Page 572, granted and conveyed unto John M. Sanderson. DBV 164; Pane 572; Tax Map #1015-1285: Parcel 113. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, dE itor SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 NOTARIAL SEAL v LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County MY Commission Expires March 5, 2005 REAL ESTATE SALE NO. 48 Writ No. 2002-5674 Civil Chase Manhattan. Mortgage Corporation John M. Sanderson Atty.: Kristine Anthoi LONG FORM DESCRIPTION ALL THAT CERTAIN lot nr tract of land with the improvements erect ed thereon, situate in Hampden Township, Cumberland County- Pennsylvania, as set forth on the Final Subdivision Plan for Mountain View Village, Phase IV, also known as Wyndham Place, dated June I 1989 and recorded May 7. 1990 Iii the Office of the Recorder of Deeds in and for Cumberland Coiini.V. Pennsylvania in Plan Book 60, Page 87, more particularly bounded and described as follows to wit: BEGINNING at i point on the northern right-of-way line of Kit tatinny Drive (64' wide private.). at the dividing line of l,oi #2. =uid #63 Said point also being located 441.28 feet west of the northwest cnrntr of Kittatimiv DrjvC- and T issev Court: THENCE by thi: northern right- of-way line of Kittatinny Drive North 82 degrees 02 minutes 02 seconds West 20.00 feet to :1i point; Lheoce by line of Lot 464 and passing through the center of a partition wall North 07 degree-, 57 minutes 58 seconds East 100.00 feet tc; ;i pc- r011_, thence by line of land now fir- 1w merly of J.P. Roth. South 82 dc- grees 02 minutes 02 second,, E;is1 20.00 feet, to a point: ihence by line of Lot #62 and passing through the center of a partition wall South 07, degrees 57 mini h,s 58 sec cu do - West 100.00 tc c + ,i pout tlur northern r,ha. vzt` Kittatinny Drive, the place of BF, GINNING. CONTAINING ::,000 square irct UNDER AND ` 1-JE3JE(T r r, r tain restrictions ;wd coiidinoiis a.- appear of record in the Office cJ thi, Recorder of Deeds in and 1C)i i'tw! berland Cnmmu Pennsvlvani,i Miscellaneous Book 192. f'ac?e 78'"r` Miscellaneous Book 393. Pat -, 557, and Miscellancoiis Book -t 1=i, Pa {c 1102. BEING ihe swine preiiii9e? which Sandra L. Robe: !)v 1'aeed d,iiecl September 12 1997 and rpCord-i in the Office of the Recorder r., Deeds of Ciiinhoilaud t'ouw,,, .. September 16 1997. in r? c i P;<nY? Volume 164. Pa:;e 572,rantrri _,nc conveyed unto Jolm M. Suuir°scii; DBV 161 Page, 57:I "fax Mali 1+) ' Parcel I