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HomeMy WebLinkAbout01-1702 FX .. I FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE lDENTIFICATIONNO.12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (? 1 'i) 'i1i1- 7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRlVE COLUMBUS, OH 43219 Plaintiff TERM NO. 01- /7" ~ Cu~( 'r~ v. CUMBERLAND COUNTY JOHN M. SANDERSON 4162 KITTATINNY DRlVE MECHANICSBURG, PA. 17055 Defendant( s) CTVTT, ACTTON - I.AW rOMPT,A TNT TN MORTGAGF, FORF,CT,OSTTRF, NOTTCR **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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 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 DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 1922026608 c,,~_ ,_~. I ... .~~~=. ~<.-.~ In - ( 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known addressees) of the Defendant(s) are: JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, P A. 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/12/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1405, Page 208. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 232. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. "'--1 ,~" ,'~- I.rn~ 1-' I,' .,-- .~ 6. The following amounts are due on the mortgage: Principal Balance Interest 10/1/00 through 3/1/01 (Per Diem $11.35) Attorney's Fees Cumulative Late Charges 9/12/97 to 3/1/01 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $57,121.52 1,725.20 2,856.00 116.56 55.O.JlQ $62,369.28 133.36 0JlQ (!I> 111,(;) $62,235.92 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $62,235.92, together with interest from 3/1/0 I at the rate of $11.35 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. iO:"'r ,.' I,",: ^ 1<' , !}~~ /,,/ Fr:mk Fp.tip.rm~n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff . . "'!"' .'0 ,=_~ ~~ .<.., ,~. J\.Lx., 'rH..,"r C!i:RTAXN ~ot. or tra.ct ot: land w:it.h t:.h~ .improvem~nl:s eret;;t:ed thereon, sir:.uate i.n Hampden To,^onship. Cumber~and County, Ptn/u1fl.y.i.v;,u.d..:::', as Gel:":. foreh on t.:.he Final Sl,tbdi.vi.sion Plan fol:'" M(,)tJl"1t:?d.n View Vi.~lage, 1?haFJe IV, alao known as Nyndham P1.ace, clal~-:ed .June 1., 1989 and racorcl.ec1 Mal' 7, J.990 :in the Of:fi.ce of ehe Rec':H.:der or: Deeds i.l'l and for Cumberland COUl1t;y, l?ennsyJ.van:i.a in PJ.ai"l, Book 60, page 87, mor.e particl..l,1.cu:).y l')ound~d and described as [~':...:!..ows t.a ....'.it:: Bl~G1'NN'XN'G fl.!:. a J;joint:. ()n th~ nort:.hern r:.ghe-oe..w~y l. in2 ot fCt.I::t;.:;JI.;j.r..nj-' prio.r.s- (64' wJ.de pr1var;e), aC :".he dividi.ng ~i))e 1:)1:' Lot fifi: ~nd 1163; ~aid point a1ao being 10cated 441.28 feet w~st of ~:"he I10rtrH...t:~~3t co.r.:n-er of r.::ittat::i.nny Drive and TUafiey Cou=t:.; T1!!-';'U(:B by t.l1.......! nox.8t;he.1:'r~ :righe-of-way ~i.ne c.f. K~,t.\:.:t.l::i.nny Drive Nc..)r!:h 82 degrees 02 mir~utl:"!9 02 seconds t<lest 20" 00 feet: t.o a point.,' Thence by line of LC".It #54 and passing through. the cent:.er. or :t pa:r"l:iticn. \o1""J.J. UO.r.C~' 07 de::grep..tc S7 m.inut.>2l!:1: sa eeconds East. 1,00.00 L'HP.t. tn ;1, point:; 'l'hancf! by ~ine of: l.and now or :eorfl'le.c1y of oJ, I?, not.h, South 92 degrer!;s 02 m:i.ntJtea Q.2 Gecon.ds East- 20.00 .tesL: 1:0 ill p.:>Jrd:; 'I'h6!n<.:e by' 1.lne of i"at:. #62 and passi,ng through t:.he I;:Oilt.e:c: o.e a part:.3.tiou ~"'a.:l.l Boul:.ll 07 degrees S7 rnj.llu!:es 58 gF.!~onds \flr~,.,/p;. 1.00.00 feec. 1:'0 .:J. pcd.nt: C'Lt ::he northern right-o.f-way ~j.ne of Kiceacinny Drive, the place of BEGINNING. CONTAINING 2,000 square feec. BEING Lot. #63 on Fina~ SUbctivision P~an of Mountain View V~11age Phase IV Recorded in Plan 600k 50, Page 875. UNDER AND SUBJECT, to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for CUmber1and County, Pennsy~vania in Miscellaneous Book 392, Page 787, Misee1.1aneous Book 393, Page 557, and Misce~1aneous Book 414, Page ~102. ALSO UNDER AND SUBJECT, reStrictions, reservations, NEVERTHELESS, to easements, conditions and right.s-of-way of record. BE~NG THE SAME PREMISES WHICH Yingst Homes, Inc., a pennsylvania Corporation, by Deed dated December 8, 1994 and recordect December 1.4, 1.9.94 in che R.ecorder of Deeds Office in and for Cumber~and County, pennsy~vania, in Peed Book ~1b, Page 21.7, granted and conveyed unto sandra L. Reber, single woman. PREMISES ON: 4162 K;ITTATINNY DRIVE ~" ~~~ ., . VERIFICA nON FRANK FEDERMAN. ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: :3/;11/6/ ;t',\""l~;"'Ti'JlI",~ -~, r-""""" " r~ J--~ '" ". ~~ . -~ . " ~" ~~, - 'u" ,.. '""", '.",.,.'. ',. .''"'''''''iI'".'''''''~'''''~'lli~ll;:rI'' t('Tf"" " i9 ~ -'9 ~ 0 C:Jo ~ c:: Ii. < - ~ :::: ~ -... "-'~, 0 rXr!'! ]:~ a . ;;:::<~- :':;J ~~ ...... .... B 0 0~~:: 0,) ,--,.-, 0- ~ '''-..; ,..,j 8 c:= t.~; -.-}(S -0 I I j;:, -- =-"2 ' i"1 tj -;:.>- (.I (-5~ }J r {P ~() ry -,,::"P',,; c: csrn ~ h? ~ ....- =t;t ...,.. :< '" :n ~t -< '.nL s~- . -or- . r, ~~~ ~~:...: ~-1: ! I : T: :;;: O' 1: i': -1 : o >-~ :;;' ;~~J ;;0 O' -<: -. ~ .. ,~ _~_~,_~ 11!1._ " ,..lg.i~~~ - ,. ,-'-" f""-"'''''-'0,E'':R",;,H:'''i'='<-~;''l;''~;v]-<;;;;);l<f~roe\~'!i'~~ft\f ~~jijllii-<!'!l'",",1':""Wi1"WL~~'" SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01702 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 PAPER EXPIRED BEFORE SERVICE WAS MADE Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 ~~ . Thomas Kllne Sheriff of Cumberland County FEDERMAN & PHELAN 04/24/2001 Sworn and subscribed to before me this ") IrA day of 7~7J ~{; 01 A.~. ~Lij~ ,prothonbt~y (:T c><Jr(J -'-:!i"i<r' ,"" 1-' 1< """-1 ' , -.', '. . '. FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 One Penn Center Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 01-1702-CIVIL JOHN M. SANDERSON DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. ~!lMJc 1-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: May 16, 2001 ,~, 1- " -" , -I ,- " I," .. .. . ~ .. , VF,RIFWATI0N RYANL.REmwEll,SR. hereby states that he/she is -'SSlSiAIIT SRmAlf of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her mowledge, information and belief. The undersigned Wlderstands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~ tf 0-~/1-.- '- RYANL.REITMAIEIl,SR. MSlSTAIff SfCmm DATE: 5-10-01 ~~ -. FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for plaintiff CHASE MANHATTAN CORPORATION MORTGAGE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JOHN M. SANDERSON Cumberland County Defendants NO.01-1702 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: June 6, 2001 :''\f~HI , . ,,--- _1>1 ~_.""" """'."" ,~.,a,"",,",,","-,.v_,~,V'""'I'~" [I "Jm iLl.r"i1i"f'f ." 0 0 C'J c: ~ ~1 ;;;: '-- -~". '"00:; C ,_'c:Ti ITln') ~~ Z::JJ ~- "'r zr;:: ' '" -jO S2~.: (~(:) r-;r" '<~ "'0 "l~ll PC' :l: ;~~ Zc. 'i! PC: z ~ ~ =< 0 :Q ~ Pr1 ",,,,,,~JIjI iJU ~,,~"" "1fiIi!'!"l"_!I!'i'!.'jl.""1"""""" _'~'''''.''',",~ ~"""""" ,~_,.~.~Mlffi"","-~~--''''N~''' -"",;:,."-1 V'i,',,_'. . "'i!iJrr!)""-'-"""'1~<;";i'~"~"~"JH".,"j",\';r-'H~if;H~WIW,~~fl SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 200i-01702 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 and inquiry for the within named DEFENDANT , to wit: SANDERSON JOHN M but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE 20th , 2001 , this office was in receipt of the On June attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 25.50 .00 62.50 06/20/2001 FEDERMAN & PHELAN S~.~~~ R.Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 2i5''t:' day of ~ (f'l~1 A.D. fl~ prothonotar~ <""""1 ~~,-,-- ,~ 1-' j " - <*+~:f::;K8fi2;t"Y;.~ @ffit~ of tlrt ~4triff William T. Tully Solicitor 1. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 1710 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania CHASE MANHATTEN MORTGAGE CORP vs County of Dauphin SANDERSON JOHN M Sheriff's Return No. 1624-T - -2001 OTHER COUNTY NO. 01-1702 I, Jack Lotwick, Sheriff of the County of Dauphin, state of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for SANDERSON JOHN M the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, June 15, 2001 DEFENDANT IS ~O LONGER EMPLOYED BY BELL ATLANTIC PER SECURITY GUARD. --------. Sworn and subscribed to before me this 15TH day of JUNE, 2001 r\ .. ) C-. ( fj();~ So Answers, Jf~ Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $25.50 PD 06/14J2001 RCPT NO 150992 / -"~~-"I-' .~-~" ,~ - 'I. I~ - ~~_. ,~:,ym'~lltt'.(::~.fK,~~ In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mortgage Corp. VS. John M. Sanderson John M. Sanderson SERVE: No. 2001 1702 civil Now, June 12. 2001 , I, SHERIFF OF CUMBERLAND COUNTY,P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~ Sheriff of Cumberland County. P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made lrnown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ '"~I <, '1 ". , , ~) " ". " ",",c"' ,.,..~_ ~, E,\:' :8 .. ~ ~- ""~" . V .._ o~. oW no -.O""l -, , I ":) ''\ ~l 1-1 "; , ",. ",' \\".J ,-,I ..' C'\i:'Y\f1 (; 1\' ,I ,. , -: c; ~ '.' "I n ....\ ;;)':;: :/ ,~~:;~",);,~ ::; -",,1 ~..tn S ,:.,.JI ,J -' --, jJ'i<r:;....... l,;',!_i .jn"'f'C _~.1 ~" j i,' J j',. .' jii\' I~ . ".~!&~irZ'4~f,jlo] ~ .,~".,. ''''''''''''''. ~,u."",.~~ ,~,~__,~, ~~, "~_~.;,."'lIC"'-.'f~\r'_'i"j_""~,,., - - - -,-, "I'r"P\";1!""N~!;'!!O['!m1Ir,-'1ll~If~~f,i!;"~"~h't~!PJ!\i[,'!r!9:!~'ll~~~~WJ>; ,. . ~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 () l~) ~1i1. 7000 ATTORNEY FOR PLAINTIFF o Cc ~" c COURT OF COMMON PLE~S - -OC_ :;-~:; CIVIL DIVISION g;:'~-~ CHASE MANHATTAN MORTGAGE CORPORATION tiS \~~ 3415 VISION DRIVE ";,,,- \/'--~. -0 COLUMBUS, OH 43219 ~7 C TERM jj; 2 r:~ ',~ NO. DI-I7()~ C,~tC01~ Plaintiff v. CUMBERLAND COUNTY JOHN M. SANDERSON 4162 KITT A TINNY DRIVE MECHANICSBURG. PA. 17055 NOTWF /I:J ~b~ 4ljj ~t't ~ ~1IVi1t";1; "'9'J'j' ~ ~ t).o ~ 1;1<: Z~ :y~. Iz/ (0)) ~!.1t ~V y Defendant( s) CIVIl. ACTION - l.A W COMPT ,A TNT TN MORTGAGF FORFCT OSTTRF "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE 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 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 DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP WE! hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE. PA 17013 (717) 249.3166 ~ <l~~~-4. 'i!-().(,~'\,J 'i!-'iP-~~V~~~ ~~#..~~ ~~ ~~~~~$-S TRUE COpy FROM RECORD II T~ wmw\\lOl, I 00i'1l !,Iilto S4It f<<I/ hand ... .. .. .. &aid Ooul't it Carlisle. Pl. -?1?~~~ ~:r~ Loan;;: 192.202660;-; '--- -'-'1'~"";IH_!\IlI~'" I'~ r ' ~ " <~~ ~ . =,,~~- ~ - FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE ~ IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F..KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (?1 'i) 'i61.7000 COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 TERM Plaintiff v. NO. CUMBERLAND COUNTY JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA. 17055 Defendant(s) f:TVTT ACTTON - I.A W COMPLAINT IN MORTr.Ar.F FORFC'T.oSTJRF NOTTCF **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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 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 DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 1922026608 '~1 ,., ,~ -r 'f . L Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 432]9 2. The name(s) and last known address(es) of the Defendant(s) are: JOHN M. SANDERSON 4162 KITT A TINNY DRIVE MECHANICSBURG, PA. 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/12/97 mortgagor(s) made. executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES INC. which mortgage is recorded in the Office oflhe Recorder ofCUMBERLAi'<O Coun[~. in .'clortgage 80c'!-- No. ]405, Page 208. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572. Page 232. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 1111/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ~~~ roo, ~ ., ~~- -' 6. The following amounts are due on the mortgage: Principal Balance Interest 10/1/00 through 3/1/01 (Per Diem $11.35) Attorney's Fees Cumulative Late Charges 9/12/97 to 3/1/01 Cost of Suit and Title Search Subtotal $57,121.52 1,725.20 2,856.00 116.56 5.5flJl.Q $62,369.28 Escrow Credit Deficit Subtotal 133.36 lLllil (I\; l111h) TOTAL $62,235.92 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8, This action does not come under Act 6 of 197..+ because the original llwrtgo.ge .1l1h'Hlnt exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $62,235.92, together with interest from 3/1/01 at the rate of $11.35 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. /c;/ Fr~nk Feoeornum FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - '~ r1" --'I' ~"" , ..,....~ . " , ALL 'r.fl..",,:r CERTAIN loot. or t:ract. of lane.! wit.h t.he i.mp:ro""emp-nts el:ect:ed thereon, sir:.uate in Hampden To.....nsh.ip, Cumber1.and County, P...:'llnny-i.var.d...'::"'l, as oet torch on t:.he Fi.nal Subdivi.sion Plan .tOl: 14t;"JUll';"".i.n VLew Vi.11age, PhaF.le IV, a).Go known as i-Iyndham Place. dal~,,==d .June 1.. 1.989 Dnd 1:ecorced Maj" 7', ~!J9a .ill the Office of t:he Rec.';)rder 01'. Deeds in and ~or Cun1.berland county, Pennsylvania in Plan Book 60. page 97. more part:.iculcu:J.y bounded and desC':ribp.d as (~~:tow::; t.O ,,"'it: Bl'=G:l:Ni'J)"Nc; at. a po.int:. ()n t~H'~ not;"t:.haL'n r:.ght: -of..way 1 irl2 of ~(:tr:t;.:;l.'.:;.r.ny [')r:t-JE" (64' w;.de pri.~J'at.e). nc ::.he d:i.vidlng 1.i.1l~ '::If Let flli: and f~GJ; ~aid poin~ ~1.no b~ing 1oc~t~d 441..~9 feet W~3t:. of '.:.l'~ Ilorth~'H.~'3\: co:=n~"'!r of r.:.1.etat:i.nny Drive &nd T'...t!ist::''}' Cou=t:: 'nl!-~!T(:H by t.lv~ n.ol:'th~.':"r~ :right.-of-.....ay ~ir.e r;.f K1.t.l,;~!..:inny Drive Nurl:h U2 dE~gJ;.'ees 02 rninucl?!3" 02 seconds tiesl:: 20. 00 .e~et to a po:\.n!:.: ':n~.oencCl! by li.nc cf .L('"Jt #54 and p;:lsGi.'.'la t.:"lr-::Jugh the cent.er c.r .:a Pi::l.t'^tit:.icn ~lal.l. Uo.r.l;h 07 deg.::eAlt 57 mi,J"lut>?l'I 58 $~conds E~st 'l()0. 00 t'f~P.t tn i1 po.tne; 'l'hencf'! by J.iae 0_1: land now or fc'rrrop.r.ly 0:; J. P. not:h, SQuth 82 degre~HJ 02 m.lnutt.~.s Q.2 Gecond:::: East:. 20.00 1:eel: 1:0 i'l po.i.r.t:; Thence b:' J.i.ne ~E i~(.;,- :t{~2 and pass::.ng through t.he f':snt.e.r of << part.{t:ion ~"'n~.l Sout.h 07 degrQes 57 m3.Ilu!::es 58 GF:!~onds \tl~~(.;t. 1.0<Loa f~C?1:. I:() .:!. pc.j tll: C'Il ;:lle no:=-t.hero ::-ight-o!-W3:.r ~jne of Kict.a~inny Drive, t.he pJ.aee of BECI~~!NG. CONTAINXNG 2,000 square feec. BEING Loe #63 on Fina~ Subd~v~s~on Pla~ of Moun~ai~ V~~~ Vi.~l.age Pnase IV Recorded in plan Soak 60, Page B79. UNDER A..."1D SUBJECT, to certain restri.ct-ions and conditions as appear of record in the O~fi.ce 0= the Record~r of Deeds in ar.d for 0~~erl.and Count.y, Pennsylvania in M~gcellaneous Sook 39:, Page 787, M~sce11aneous Book 393, Page 557, and Misce:~aneouS Book 4l4, Page ~~02. ALSO UNDER AND SUBJECT, rescric:i.on$. reserva~ions, N~VERTHELESS, to easemenC5, conditions and rights-or-way 0= reco:=-d. SEING THE SAME PREMISES WHICH Yingst Homes, Inc., a Pennsylvani.a Corporation, by Deed dated December B, 199~ and recorded Decenmer 14, 1994 in ~he Recorder oe Deeds Of=~ce i~ ~nd for Cumberland County, penn5y~va~ia, in Peed Soak 110, Page 217, granted and conveyee uneo sandra L_ Rebe~, s~ngle woman. PREMISES ON: 4162 ~ITTATINNY DRIVE L< , ~'I__~ 7' ~"!.,,. .' , VERIFICATION FR.'\NK FEDER;YIA~, ESQl'IRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in :vlortgage Foreclosure are true and correct to the best of his knowledge. information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to uns\\om falsification to authorities. r~ J--~ D.-HE: ,:)//1(/0/ --'l'i'I~.,. ...~ . . " 1 ~ t_. c. ,,\\? Co ......:f""'1'!.'.'-','...:.\ ,\\\" " ,. ~ "l ".. I':' t\~\\~ ~: \'.'...\ C't. 0 '. '-\k'l;.. . r\,' \\J' \\",,\: t\\:) . ,~,J\ I"~ ,\~') 1'0' . ~)..~~:~~~ .~\\\. ;..' ~~\\I:" " '-' =-~~!'&!'~, ~~:ut .. o,J!JI!f" ~~'\F.iif?~~"~{,,,,,?;r,!'" ~- -..'~~ ~~ "i-. tif't i'\''l."'''''> ,. ;"'''''~'T .... "~-"n" ill ~[f.' PI "iN " "0 ~ . Z ~. -I. j~f ~: ~ : V>. . -I? -1~ :>.: :> ;;:I' ~ Q~ ( 1: ) ."~:-o,""''!fj'7jI'!1'''';<_-::;:8'-G;m'''~t",<i0~\Wljf1_'lW1!:liifJ'~~m FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff CHASE MANHATTAN CORPORATION MORTGAGE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JOHN M. SANDERSON Cumberland County Defendants :No.01-1702 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. F~~ Attorney for Plaintiff Date: July 13, 2001 ':~I ~~ , I'~" ,~~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-01702 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M DAVID MCKINNEY , 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 the DEFENDANT at 0017:51 HOURS, on the 13th day of Auqust 2001 at 4162 KITTATINNY DRIVE MECHANICSBURG, PA 17055 by handing to JOHN SANDERSON a true and attested copy of COMPLAINT - MORT FORE together with REINSTATED WITH NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 26.00 .00 10.00 .00 54.00 So Answers: ~~ ~-,~/-( R. Thomas Kline 08/14/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~4n~ //// if~Cll,1~:l Deputy Sherirf me this /? -e:- day of n {' r"'/ .)011 ( A. D. 'Ctr~ Q. ~ ~~ othonotary ," 7 ' '~. '- 'I" I' ", ""*"'1 ,~'." .. FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Court of Common Pleas CUMBERLAND County No. 0l-1702-CIVIL vs. JOHN M. SANDERSON Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. '1-1'-0) lr~I4bA/YXJ ) Frank Federman Attorney for Plaintiff Date ,,''''''~''-''',' ',' - -^~. ~~""l" "-+'~" 1'-_' --I 1",- "' , , . ;c_,- ,~..~ .,^,- <. ~ " a_ ~ ~~,~. .~- ,-, _' ~~~~~IIiIJ"~~~_I<11.~'%"!:~1'J" <~ P""" ,_ " _<_~ >~ - ----lJ .. 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