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HomeMy WebLinkAbout03-1646FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Vo Plaintiff JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE 707 2ND STREET GRANTHAM, PA 17027 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DIVISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FlRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgrnent 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 DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Loan #:1504717950 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. I. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE 707 2ND STREET GRANTHAM, PA 17027 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 2/14/01 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERICAN RESIDENTIAL MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1673, Page 1. By Assignment of Mortgage recorded 4/27/01 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 673, Page 200. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 10/01/2002 through 04/07/2003 (Per Diem $21.85) Attorney's Fees Cumulative Late Charges 02/14/2001 to 04/07/2003 Cost of Suit and Title Search Subtotal $118,161.95 4,129.65 850.00 191.21 $ 750.00 $124,082.81 Escrow Credit 0.00 Deficit 183.49 Subtotal $ 183.49 TOTAL $124,266.30 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $124,266.30, together with interest from 04/07/2003 at the rate of $21.85 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: .,~/s/Francis S. Hallinan ~// FR~ FEDERMAN, ESQUH~ LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ~ ~a~ oert;s~n ~ac~ oF ~o~ o~ ~ound s~ua~e ~Fan~h~m, Upper Allan ~ownah~ ~ ......... ~n She v~la e of oounde~ and d,nscr~bsd .aa fol~r~,-~%~nd ~ounc~, Pennsylvania, BB~NNXMG a~ ~ po~n~ marked by an iron pin ~n Middle $~ree~ (30 fee= w~ds), which in be~wee~ Lo~ ~s. 1 and 3 ..... - P ks in on sa~d alan ,~----~ , _. ~s~on ~ne be~ ........ one hundred ~]1£ ~_L ..... ~_.) ~egraea ~or~--£~ve ;4 .... L~ and 3 mTnt~on.d Plan of ~s'~L°t Nos. 3 and --~' ~ aha 2 on sa~d P~an a~d a~o~ ~h~ e~hk (08) d~'gFo~s foR~--f~ye .... B~ a~d ~onn M. Bart. Sou~h ~h~r~y--t~ (13:~) feet ko ~ ~ron ~_~u~s. Wef~ one hundred Stree~ a~orosa'td; ~ ~ ~nm ~as~ ~tne North e~gh~ (08) degrees t~nty--four (24) m~nu~es West ~en (~0) ' £ee~ ~c an 4ran pin ~n ~he dlv~sion llne between Lo= Nos. i and 3 on ~he hereinafter mentioned Plan of Lo~s B=r, hasband and wife, which Plan Is ~corded in the O~fice o~ the Plan Book 50, page Bm=r, htJmbmnd and wi~*, by deed dated Sc=shat 29, ~986 and recorded County, P*nnsy~van~a ~n Du~ Book H, Volvo 32, page 80, granted Grnn~ors heroin. ~ac~ 2: ~ ~T :~N ~t of ~, t~ with t~ ~~nts ~ ~, ~ of L~ f~ly of-~ ~t~t ~ n~ ~ ~e of ~k ~. Win~. with f~C ~:,. ~th O0 ~ 45 ~ut~ ~t 132 f~t tO · t~ ~ da~ A~ll 1~, 1986 ~ ~dd ~ t~ Office of ~ ~ ~ f~ C~~ Co~ty. Pm~yl~ia. ~ ~ ~k v 31 at Pa~ 181. ~t,~ a~ ~flve~ ~to ~v~ E. ~ ~ J~ M. ~ h~ w~e the PREMISES 0N 707 2~ .STREET VERIFICATION JOE KOONC~ hereby states that he/she is All~ta~.t ,~l'~ of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) ~63-7(}00 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. JOHlq WOLFE A/K/A JOHN D. WOLFE TPJtCY WOLFE A/K/A TP~ACY A. WOLFE Defendants COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No. 03-1646 C.T. PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURv TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: June 19, jrh,SVC DEPT 2003 ~P~ANK FEDERMAN, ESQUIRE Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-01646 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND CHASE MANHATTAN MORTGAGE CORP VS WOLFE JOHN ET AL R. Thomas Kline duly sworn according to law, says, that he made inquiry for the within named DEFENDANT WOLFE JOHN A/K/A JOHN D WOLFE unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being a diligent search and but was He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 707 2ND STREET GR3kNTHAM, PA 17027 DEFENDANT'S NEW ADDRESS IS , NOT FOUND , WOLFE JOHN A/K/A JOHN D WOLFE PO BOX 501 CAiqAL FULTON, OH 44614. as to Sheriff's Costs: Docketing 18.00 Service 8.97 Not Found 5.00 Surcharge 10.00 .00 41.97 R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 06/19/2003 Sworn and subscribed to before me this 30- day of J0gl3 A.D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-01646 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS WOLFE JOHN ET AL R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , WOLFE TRACY A/K/A TRACY A WOLFE but was unable to locate Her in his bailiwick. deputized the sheriff of LACKAWANNA County, serve the within COMPLAINT - MORT FORE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, to On June 19th , 2003 attached return from LACKAWAIxrNA Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Lackawanna Co 30.20 Notary 2.00 57.20 06/19/2003 FEDERNUtN & PHELAN Sworn and subscribed to before me this ~o~ day of ~uU3 A.D. ~Pro~honota~y this office was in receipt of the Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mortgage Corporation John Wolfe aka John D. Wol£e et al SERVE: Tracy Wolfe a/k/a Tracy A. Wolfe No. 03-1646 civil Now, April 23, 2003 hereby deputize the Sheriff of , I, SHERIFF OF CUMBERLAND COUNTY, PA, do Lackawanna Coullty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County~ PA ~IOW~ upon at by handing to a and made known to Affidavit of Service ,20 ,at o'clock copy of the original So answers, M. served the the contents thereof. Sworn and subscribed before me this day of ,20__ Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA SHERIFF' S RETURN - REGULAR CASE NO: 2003-00201 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF LACKAWANNA CHAE MANHATTAN MORT. CORP. VS WOLFE TRACY A/K/A DONALD STETS , County, Pennsylvania, says, the within COMPLAINT MORT. WOLFE T C A/K/A DEFENDANT , at 0009:50 Hour, at 9A JOYCE ST MOOSIC, PA 18507 Deputy Sheriff of Lackawanna County who being duly sworn according to law, FORE. was served upon on the 5th day of May by handing to HER PERSONALLY AT 200 N WASHINGTON AVE SCR/~NTON PA a true and attested copy of COMPLAINT MORT. FORE. the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing ~.'~,~ .00 Service ~ ~ .00 Affidavit ~ .00 Surcharge .00 .00 .00 Sworn and Subscribed to before me this ~-~ dav of kc Not~m 8em ~ So Answers: John ~Szyra~nski, Sheriff ~puty Sheriff 00/0o/00o0 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 1215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 03-1646 JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JOHN WOLFE A/K/A JOHN D. WOLFE and TRACY WOLFE A/K/A TRACY A. WOLFE, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 4/08/03 to 7/24/03 TOTAL $124,266.30 $ 2,359.8O $126,626.10 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/KIA TRACY A. WOLFE Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION CUMBERLAND COUNTY : NO. 03-1646 CIVIL TERM TO: JOHN WOLFE A/K/A JOHN D. WOLFE P.O. BOX 501 CANAL FULTON, OH 44614 DATE OF NOTICE: .HYL¥ 14, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATflSMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ll~PORTANT NOTICE You are in default because you have faded 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 (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important fights. 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: CLrMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENLIE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?1~) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. JOHN WOLFE A/Y-dA JOHN D. WOLFE TRACY WOLFE A/KJA TRACY A. WOLFE Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CLrMBERtAND COUNTY : NO. 03-16a6 CML TERM TO: TRACY WOLFE A/KJA TRACY A. WOLFE 9A JOYCE STREET MOOSIC, PA 18507 DATE OF NOT/CE: JIFL¥ 14, 200'~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAI2qST PROPERTY. 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 (I0) days fi.om the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other in~ortant 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 CLrMBERLAND COI. YNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff _ FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?lC) 56%7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. JOHN WOLFE AflK/A JOHN D. WOLFE TRACY WOLFE A/K]A TRACY A. WOLFE Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY : NO. 03-1646 CIVIL TERM TO: JOHN WOLFE A/K/A JOHN D. WOLFE 707 2ND STREET GRANTHAM, PA 17027 FiLE COPY DATE OF NOTICE: JUI,Y 14, 200'~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 (10) days fxom the date of this notice, a Judgment may be entered against you without a heating 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 flae following office to find out where you can get legal help: CUMBERIAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQLrIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (915) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. JOHN WOLFE A/KdA JOHN D. WOLFE TRACY WOLFE AdK/A TRACY A. WOLFE Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CML DMSION : CUMBERLAND COUNTY : NO. 03-1646 CML TERM TO: TRACY WOLFE A/K/A TRACY A. WOLFE 707 2ND STREET GRANTHAM, PA 17027 DATE OF NOTICE: ,~lI,V 14, 200~ THIS FIRM 1S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. I~[PORTANT 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 (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN CASE NO: 2003-00201 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF LACKAWANNA CHAE MANHATTAN MORT. CORP. VS WOLFE TRACY A/K/A - REGI/LAR DONALD STETS County, Pennsylvania, says, the within COMPLAINT MORT. WOLFE T C /K/A DEFENDANT , at 0009:50 Hour, at 9A JOYCE ST · Deputy Sheriff of Lackawanna County who being duly sworn according to law, FORE. was served upon on the 5th day of May MOOSIC, PA 18507 by handing to HER PERSONALLY AT 200 N WASHINGTON AVE SCRANTON PA a true and attested copy of COMPLAINT MORT. FORE. the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing B~ .00 Service ~_[ ~ .00 Affidavit ~6.~ .00 Surcharge .00 .00 .00 Sworn and Subscribed to before me this ~ ~'\ day o~ So Answers: John Siymanski, Sheriff ~</~puty Sheriff oo/oo/oooo FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Attorney I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE Attorney for Plaintiff COURT OF COMMON PLEAS C1VIL DIVISION CUMBERLAND COUNTY NO. 03-1646 CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE PIIR,qllIANT TO Pn.R.C.P. 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Complaint in Mortgage Foreclosure was made by sending a true and correct copy by certified mail to Defendant, JOHN WOLFE A/K/A JOHN D. WOLFE at P.O. BOX 501, CANAL FULTON, OH 44164 which Complaint was received by Defendant, JOHN WOLFE A/K/A JOHN D. WOLFE on April 2.~, 2003 as evidenced by the attached Return Receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date: An~l~It 6, 2003 erman, Esquire Attorney for Plaintiff 7160 3901 9844 4120 9127 TO: JOHN WOLFE A/K/A JOHN D. WOLFE P.O. BOX 501 CANAL FULTON, OH 44614 SENDER: REFERENCE: JRH/SVC PS Form 3800, June 2000 RETURN Postage 34 RECEIPT Certified Fee SERVICE Return Receipt Fee 1 .'~0 Total Po,*ag, & Fee, ...... 3.74 Receipt for Certified Mail Article Number 711.Xl 39~i 9~44 2424 6034 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra F~e) [~Yes 1. Article Addressed to; JOHN WOLFE A/K/A JOHN D. WOLFE P.O. BOX 501 CANAL FULTON, OH 44164 PS For~ 3811, July 2001 Domesti~ Return Receipt JAMES HELLINGS PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE Defendant(s). No. 03-1646 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 7/24/03 to 12/10/03 (per diem -$20.82) TOTAL $126,626.10 $2,893.98 and Costs $129,520.08 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. DESCRIPTION ALL THAT CERTAIN tract or lot of ground situate in the Village of Grantham, Upper Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point marked by an iron pin in the Eastern line of Middle Street (30 feet wide), which pin is in the division line between Lot Nos. 1 and 3 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lot Nos. 1 and 3 on said plan, North eight (08) degrees forty-five (45) minutes East one hundred thirty-two (132) feet to an iron pin in the Western line of a fourteen (14) feet wide alley; thence along the Western line of said fourteen (14) feet wide alley, South eight (08) degrees twenty-four (24) minutes East ten (10) feet to an iron pin in the division line between Lot Nos. 3 and 2 on the hereinafter mentioned Plan of Lots, at the corner of other land now or formerly of David E. Bart and Joan M. Bart; thence extending along the division line between Lot Nos. 3 and 2 on said Plan and along the line of said other land of David E. Barr and Joan M. Bart, South eight (08) degrees forty-five (45) minutes West one hundred thirty-two (132) feet to an iron pin in the Eastern line of Middle Street aforesaid; thence along the Eastern line of Middle Street, North eight (08) degrees twenty-four (24) minutes West ten (10) feet to an iron pin in the division line between Lot Nos. 1 an 3 on the hereinafter mentioned Plan of Lots first above mentioned at the point and place of beginning. Being designated as Tract No. 3 on the Final Subdivision Plan of Frederick K. Bart and Doris E. Barr, husband and wife, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 50, page 83. IT BEING the same premises which Frederick K. Bart and Doris E. Barr, husband and wife, by deed dated October 29, 1986 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book H, Volume 32, Page 89, granted and conveyed unto David E. Barr and Joan M. Bart, husband and wife, Grantors herein. TRACT 2: ALL THAT CERTAIN lot of ground, together with the improvements thereon erected, situate in the Village of Grantham, in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING AT A POINT in the line of land formerly of Anna Rothert, now or late of Mark L. Winger, said point being also at the point of intersection of said line of land formerly of Anna Rothert and now or late of Mark L. Winger, with the Eastern line of Middle Street; thence along the Eastern line of Middle Street, North 08 degrees 24 minutes West 115.6 feet, more or less, to a point in the center line of a 14 foot alley; thence along the center line of said 14 foot alley, North 80 degrees 45 minutes East 132 feet to a point in the Western line of said other 14 foot alley or avenue, South 08 degrees 24 minutes East 90.25 feet, more or less, to a point in the line of land formerly of Anna Rothert and now or late of Mark L. Winger, aforementioned; thence along the line of said land formerly of Anna Rothert and now or late of Mark L. Winger, South 70 degrees 58 minutes West, 135 feet, to a point in the Eastern line of Middle Street, first above mentioned, at the point and place of beginning. HAVING thereon erected a one-story frame and aluminum siding, ranch-type dwelling, and now known as 707 Second Street, Grantham, Pennsylvania. TOGETHER with the right in said Grantees, their heirs and assigns to use said 14 foot avenue mentioned above in common. Tax Parcel# 42-31-2151-107 TITLE TO SAID PREMISES IS VESTED IN John D. Wolfe and Tracy A. Wolfe, husband and wife by Deed from David E. Barr and Joan M. Bart, husband and wife dated 10/25/1996 and recorded 10/31/1996 in Record Book 148, Page 312. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/FdA TRACY A. WOLFE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 03-1646 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied (X) vacant (~ Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE Plaintiff, JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1646 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JOHN WOLFE A/K/A JOHN D. WOLFE is over 18 years of age and resides at 707 2Nn STREET, GRANTHAM, PA 17027. (c) that defendant TRACY WOLFE A/K/A TRACY A. WOLFE is over 18 years of age, and resides at 9A JOYCE STREET, MOOSIC, PA 18507. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff · CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE AflCJA TRACY A. WOLFE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-1646 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for thc Writ of Execution was filed the following information concerning the real property located at 707 2ND STREET, GRANTHAM, PA 17027. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JOHN WOLFE A/K/A JOHN D. WOLFE P.O. BOX 501 CANAL FULTON, OH 44614 TRACY WOLFE A/K/A TRACY A. WOLFE 9A JOYCE STREET MOOSIC, PA 18507 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nallle None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address caunot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 707 2ND STREET GRANTHAM, PA 17027 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 24, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JOHN WOLFE A/K/A JOHN D. WOLFE TRACY WOLFE A/K/A TRACY A. WOLFE Defendant(s). TO: JOHN WOLFE A/FJA JOHN D. WOLFE P.O. BOX 501 CANAL FULTON, OH 44614 CUMBERLAND COUNTY No. 03-1646 July 24, 2003 TRACY WOLFE A/K/A TRACY A. WOLFE 9A JOYCE STREET MOOSIC, PA 18507 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 707 2ND STREET, GRANTHAM, PA 17027, is scheduled to be sold at thc Sheriffs Sale on DECEMBER 10, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $126,626.10 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherifi's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney% fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract or lot of ground situate in the Village of Grantham, Upper Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point marked by an iron pin in the Eastern line of Middle Street (30 feet wide), which pin is in the division line between Lot Nos. 1 and 3 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lot Nos. 1 and 3 on said plan, North eight (08) degrees forty-five (45) minutes East one hundred thirty-two (132) feet to an iron pin in the Western line of a fourteen (14) feet wide alley; thence along the Western line of said fourteen (14) feet wide alley, South eight (08) degrees twenty-four (24) minutes East ten (10) feet to an iron pin in the division line between Lot Nos. 3 and 2 on the hereinafter mentioned Plan of Lots, at the corner of other land now or formerly of David E. Bart and Joan M. Bart; thence extending along the division line between LOt Nos. 3 and 2 on said Plan and along the line of said other land of David E. Bart and Joan M. Barr, South eight (08) degrees forty-five (45) minutes West one hundred thirty-two (132) feet to an iron pin in the Eastern line of Middle Street aforesaid; thence along the Eastern line of Middle Street, North eight (08) degrees twenty-four (24) minutes West ten (10) feet to an iron pin in the division line between Lot Nos. 1 an 3 on the hereinafter mentioned Plan of Lots first above mentioned at the point and place of beginning. Being designated as Tract No. 3 on the Final Subdivision Plan of Frederick K. Barr and Doris E. Ban', husband and wife, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 50, page 83. IT BEING the same premises which Frederick K. Bart and Doris E. Bart, husband and wife, by deed dated October 29, 1986 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book H, Volume 32, Page 89, granted and conveyed unto David E. Bmr and Joan M. Bart:, husband and wife, Grantors herein. TRACT 2: ALL THAT CERTAIN lot of ground, together with the improvements thereon erected, situate in the Village of Grantham, in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING AT A POINT in the line of land formerly of Anna Rothert, now or late of Mark L. Winger, said point being also at the point of intersection of said line of land formerly of Anna Rothert and now or late of Mark L. Winger, with the Eastern line of Middle Street; thence along the Eastern line of Middle Street, North 08 degrees 24 minutes West 115.6 feet, more or less, to a point in the center line of a 14 foot alley; thence along the center line of said 14 foot alley, North 80 degrees 45 minutes East 132 feet to a point in the Western line of said other 14 foot alley or avenue, South 08 degrees 24 minutes East 90.25 feet, more or less, to a point in the line of land formerly of Anna Rothert and now or late of Mark L. Winger, aforementioned; thence along the line of said land formerly of Anna Rothert and now or late of Mark L. Winger, South 70 degrees 58 minutes West, 135 feet, to a point in the Eastern line of Middle Street, first above mentioned, at the point and place of beginning. HAVING thereon erected a one-story frame and aluminura siding, ranch-type dwelling, and now known as 707 Second Street, Grantham, Pennsylvania. TOGETHER with the right in said Grantees, their heirs and assigns to use said 14 foot avenue mentioned above in common. Tax Parcel//42-31-2151 - 107 TITLE TO SAID PREMISES IS VESTED IN John D. Wolfe and Tracy A. Wolfe, husband and wife by Deed from David E. Bmr and Joan M. Bart, husband and wife dated 10/25/1996 and recorded 10/31/1996 in Record Book 148, Page 312. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-1646 Civil COUNTY OF CUMBEKLAND) 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 WOLFE A/K/A JOHN D. WOLFE, TRACY WOLFE AfK/A TRACY A. WOLFE, (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 tha 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 garfflshee(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 possessiun 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. AmountDue $126,626.10 L.L. $.50 Interest FROM 7/24/03 TO 12/10/02 (PERDIEM - $20.82) - $2,893.98 AND COSTS Atty~s Comm % Due Prothy $1.00 Arty Paid $181.17 Other Costs Plaintiff Paid Date: JULY 25, 2003 (SeaD CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Chase Manhattan Mortgage Corporation VS John Wolfe a/k/a John D. Wolfe and Tracy Wolfe aJk/a Tracy A. Wolfe In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1646 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing 30.00 Poundage 23.79 Posting Handbills 30.00 Advertising 30.00 Mileage 6.21 Levy 30.00 Surcharge 40.00 Law Library .50 Prothonotary 1.00 Certified Mail 8.17 Out of County 9.00 Lackawanna County 30.20 Notary Public Fee 2.00 Law Journal 651.35 Patriot News 294.33 Share of Bills 28.90 $1215.45 paid by attorney 12/17/03 Sworn and subscribed to before me This 3 I~-day ofi~.~J,~ R. Thomas Kline, Sheriff Pro~onot~ Real Esta~ 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: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authofizea 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 tree. REAL ESTATE ~ALE NO. 27 Writ No. 2003-1646 Civil Chase Manhattan Mortgage Corporation VS. John Wolfe, a/k/a John D. Wolfe and Tracy Wolfe, a/k/a Tracy & Wolfe Atty.: Frank Federman DESCRiPTION ALL THAT CERTAIN tract or lot of ground situate in the Village of Grantham, Upper Allen Township, Cumberland County, pennsylvai~ia, bounded and described as follows, to v~t: BEGINNING at a point marked by an iron pin in the Eaaiem line of Middle Street (30 feet wideL which pin is in the division line betlveen Lot Nos. I and 3 on the hereinafter mentioned Plan of Lots; thence ex- tending along the division line be- tween Lot Nos. 1 and 3 on said plan. North eight [081 degrees forty-five (451 minutes East one hundred thirty-two (1321 t~et to an iron pin in the Western line of a fourteen [ 141 feet w~de alley: thence along the Western line of said fourteen (141 /fLisa Marie Coyr]e, Editor SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER, 2003 LOIS E. SNYDER, Noisy Pub~ C~isls Boro, Cumberland Courtly My Commission ~i~ I~ S, 200S feet wide alley, South eight (081 de- grees twenty-lbur (241 minutes East ten [10) feet to an iron pin in the division line between Lot Nos. 3 and 2 on the hereinafter mentioned Plan of Lots. at the corner of other land now or formerly of David E. Bart and Joan M. Barr: thence extend lng along the division line between Lot Nos. 3 and 2 on said Plan and along the line of said other land of David E. Bart and Joan M. Barr. South eight (08) degrees forty-five (451 minutes West one hundred thirty-two (1321 feet to an iron pin BE~INNINt~ at a 1~ by an iron pin in the Eastern line Middle Street 130 feet wide), which pin is in the di~sion line ~t Nos. I ~d 3 on the herein~ter mentioned PI~ of ~ts; thence ex- tending ~ong the di~sion hne ~een ~t Nos. I ~ld 3 sn s~d North eight (081 degrees forW-five [45) minutes East one hundred thirW-~o (132] i~et to ~ iron pin in ~e Western hne of a iburteea [ 14) I~et wide ~ley; thence ~ot~g the Western line of said fourteen (14) feet wide alley, South eight (08} grecs ~wenty-four (241 minums East ten (10) feet to azl iron pin in the division line between Lot Nos. 3 and 2 on (he hereinafter mentioned Plan of Lots, at the comer of other land uow or formerly of David E. Bart and Joan M, Barr; thence ex~end- South eight 108) degrees forty-five (45} minutes West one hundred line of Middle Street. North eight at the point *aid place of beginning. plan Book 50, page 83. TRACT 2: of Upper Allen, County of Curet bounded and described as folk merly of Anna Rothert an( land formerly of Anna Roi beginning. ranch~type dwelling, and or' Lots, at the corner of other l~a~ now or £'ormerly of David E. and Joan M. Bart; thence exffem( TRACT 2: of Upper Allen. County of land formerly of Anna Rc land formerly of Anna ranch-type dweilLr~g, dated 10/25/lc' 1.0/31./1996 in page 31.2.