HomeMy WebLinkAbout01-1994FX
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01994 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE MORTGAGE COMPANY-WEST
VS
DICKEY SHIRLEY A
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
DICKEY SHIRLEY A
the
DEFENDANT
, at 0012:48 HOURS, on the 9th day of April
, 2001
at 6 LOCUST LANE
MECHANICSBURG, PA 17055
by handing to
SCOTT HAKE (ROOMATE)
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
6.20
.00
10.00
.00
34.20
S;i2~~~
R. Thomas Kline
me this
04/10/2001
GRENEN & BIRSIC
By: ~
Sworn and Subscribed to before
day of
Deputy Sheriff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,)
flk/a MELLON MORTGAGE COMPANY, )
) NO.: Ot - /99'(
)
)
) ISSUE NO.:
)
)
) TYPE OF PLEADING:
)
) CIVIL ACTION - COMPLAINT
) IN MORTGAGE FORECLOSURE
)
)
) CODE-
)
)
) FILED ON BEHALF OF PLAINTIFF:
)
) Chase Mortgage Company - West, flk/a
) Mellon Mortgage Company
)
)
) COUNSEL OF RECORD FOR THIS
) PARTY:
)
) Kristine M. Faust, Esquire
) Pa. I.D. #77991
)
) GRENEN & BlRSIC, P.C,
)
) Firm #023
) One Gateway Center, Nine West
) Pittsburgh, P A 15222
) (412) 281-7650
Plaintiff,
CIO~ty-~
vs.
SHIRLEY A. DICKEY,
Defendant.
kton
I HEREBY CEIITIFY lIE ADIlA!S8 OF1M! 1
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CER"F1CAlE OF LOCA1lON
I HEI1EBY CERTIFY 'lHl.TlIE UlCA1lOll OF
'!HE RE l ESTATE AFfECIED 1IY1HB1BI B
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST, )
f/k/a MELLON MORTGAGE COMPANY, ) NO.:OI-1994
)
Plaintiff, ) ISSUE NUMBER:
)
vs. )
) TYPE OF PLEADING:
SHIRLEY A. DICKEY, )
) PRAECIPE FOR DEFAULT JUDGMENT
Defendant. ) (Mortgage Foreclosure)
)
)
) CODE-
)
)
) FILED ON BEHALF OF PLAINTIFF:
)
) Chase Mortgag.e Company-West, f/k/a
) Mellon Mortgage Company
)
) COUNSEL OF RECORD FOR THIS
I hereby certify that the address ) PARTY:
of Plaintiff is: )
3415 Vision Drive ) Kristine M. Faust, Esquire
Columbus, OH 43219 ) Pa. I.D, #77991
)
) GRENEN & BIRSIC, P.C.
) Firm #023
the last known address of ) One Gateway Center
Defendants is: ) Nine West
6 Locust Lane ) Pittsburgh, P A 15222
Mechanicsburg, P A 17055 )
) (412) 281-7650
GRENEN & BIRSIC, P.C.
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Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
flkla MELLON MORTGAGE COMPANY,
NO.:Ol-1994
Plaintiff,
vs.
SIDRLEY A. DICKEY,
Defendant.
PRAECIPE FOR DEF AUL T JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant, Shirley A. Dickey, in the amount of $67,938.99, which is itemized as follows:
Principal
Interest through 5/11/01
Late Charges through 5/11/01
Other fees
Attorneys' fee
Title Search, Foreclosure
and Execution Costs
TOTAL
$62,822.63
$ 2,484.94
$ 87.32
$ 244.10
$ 800.00
$ 1.500.00
$67,938.99
with interest on the Principal sum at the rate of$12.91 per diem from May 11,2001, and additional
late charges, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the
mortgaged premises.
GRENEN & BIRSIC, P.C.
BY:
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Kris' 'M. aust, Esquire
Attorneys for Plaintiff
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AFFIDA VII OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYL VANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in lllld for said County lllld
Commonwealth, personally appeared Kristine M. Faust, attorney for lllld authorized representative
of Plaintiff who, being duly sworn according to law, deposes lllld says that the Defendllllt is not in
the military service of the United States of America to the best of her knowledge, information lllld
belief lllld certifies that the Notices ofIntent to take Default Judgment were mailed in accordllllce
with Pa. R.C,P. 237.1, as evidenced by the attached copy.
~ju/
Sworn to lllld subscribed before me
this 24flday of J11.Ct~
I~J~~to qfjOif~
[ Notary Publ"
,2001.
Notarial Seal
Rebecca G, Blazina, Notary Public
Pittsburgh, Allegheny County
My Commission Expires June 2, 2003
Member, Pennsv1vaflla Association of Notartes
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IN THE COURT OF C~ON PLEAS OF CUMBERLAND cmlv, PENNSYL V ANlA
-
.
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST, )
f/kla MELLON MORTGAGE COMPANY, ) NO.: 01-1994
)
)
Plaintiff, )
)
vs. )
)
Sf!lRLEY A. DICKEY, )
)
Defendant. )
TO: Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 17055
DATE OF NOTICE: May 1,2001
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 TIllS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANTRlGHTS. YOU SHOULD TAKE TIllS NOTICE TOALA WYER 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:
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
By:
GRENEN & BIRSIC, P.C,
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Attorn s for I?laintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
FIRST CLASS MAIL, POSTAGE PREPAID
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
NO.:OI-1994
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
NOTICE OF ORDER. DECREE OR mDGMENT
TO: Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 17055
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the
above captioned proceeding on ~ ,2q, JH; /
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $67,938.99
with interest on the Principal sum at the rate of $12.91 per diem from May 11, 2001, and additional
late charges, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the
mortgaged premises.
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Deputy .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
Plaintiff,
NO.: 01-IOR4
vs.
SHIRLEY A. DICKEY,
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.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
(717) 240-6200
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k1a MELLON MORTGAGE COMPANY,
NO.: ,,2fXj/_ ;qtf,/
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Chase Mortgage Company - West, fi'kla Mellon Mortgage Company, by its attorneys,
Grenen & Birsic, P,C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Mortgage Company - West, fi'kla Mellon Mortgage Company,
which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219.
2. The Defendant is Shirley A. Dickey, an individual whose last known address is 6
Locust Lane, Mechanicsburg, Pennsylvania 17055.
3. On or about September 9, 1997, Defendant executed a Note in favor of First United
Mortgage Services, Inc. ("First United"), in the original principal amount of$64,966.00. A true and
correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof.
4. On or about September 9,1997, as security for payment of the aforesaid Note,
Defendant made, executed and delivered to First United a Mortgage in the original principal amount
of$64,966,OO on the premises hereinafter described, said Mortgage being recorded in the Office of
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the Recorder of Deeds of Cumberland County on September 17, 1997, in Mortgage Book Volume
1405, Page 446, A true and correct copy of said Mortgage containing a description of the premises
subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof.
5. First United assigned all of its right, title and interest in and to aforesaid Note and
Mortgage to Plaintiff pursuant to a certain Assignment of Mortgage recorded in the Office of the
Recorder of Deeds of Cumberland County on September 17, 1997, at Mortgage Book Volume 557,
Page 443.
6, Defendant is the record and real owner of the aforesaid mortgaged premises.
7. Defendant is in default under the terms ofthe aforesaid Mortgage and Note for, inter
alia, failure to pay the monthly installments of principal and interest when due. Defendant is due
for the December 1,2000 payment.
8. Plaintiff was not required to send Defendant written notice pursuant to 35 P .S.
gl680,403C (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 (12U.S.C.
ggI707-1715z-18) [35 P.S. g1680.401C(a) (3)].
9. Plaintiff was not required to send Defendant written notice of Plaintiffs intention to
foreclose said Mortgage pursuantto 41 P .S. g403 (Act 6 of197 4) prior to the commencement of this
action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. g101
and Defendant is not a "residential mortgage debtor" as defined in 41 P.S. glOl.
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10, The amount due and owing Plaintiff by Defendant is as follows:
Principal
Interest through 3/27/01
Late Charges through 3/27/01
Other fees
Attorneys' fees
Title Search, Foreclosure
and Execution Costs
TOTAL
$62,822.63
$ 1,906.20
$ 65.49
$ 64.47
$ 800.00
$ 1,500.00
$67,158.79
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $67,158.79, with interest thereon at the rate of $12.91 per diem from March 27, 2001, and
additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale ofthe mortgaged premises.
GRENEN & BIRSIC, P.C.
BY: ~~d06
Kris eM, Faust, Esquire
Attorneys for Plaintiff
One Gateway Center
Nine West
Pittsburgh, P A 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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M"IIistate
LJAN NO. #675810
NOTE
FHA Cn~c Nn.
~
441-549718-0
SEPTEMBER 9
IOakl
199'
6 LCCUST LANE
MECI ANICSBURG, PA 17055
IPrnpCrlY Atldr~~!>1
f. l'ARTIES
"Borrower" means each perl'ion signing at th end of this Note, and the person's SllcceSSOfR ttmJ assigns. "Lender" me,,"s
FIRST UNITED MORTGAGE SERVIC S, INC.
and ill-' l->llCCeSSors ami assigns.
2. BORROWER'S PROMISE TO PA Y; INTE~ EST
In return for a 1m," received from Lender. Be rrower promises to pay the rrincir:11 SUIll of
SIXTY-FOUR THOUSAND NINE IUNDRED SIXTY-SIX AND
00/100
Dollars (U.S. $ 64,966.00 ). pill' il1kr~sl. 10 the flnh~r or Lender. Inlcresl will he ch:.rged on unr;lid principHI,
fwmlhe dilte of dishllr~el1lent of the loan prm.:eed. hy Ltmder, at the nile of SEVEN AND ONE HALF
percent ( 7 . 500 %) per year IIlti! Ihe filII al110llnl of principal has heen paid.
3. PROMISE TO PA Y SECIIREn
Borrower's promise to pay is securell hy ~l III lrtgage. dt'-t'.d of trust or simi\;,r sel~l1rily instrument that is dated the same lhlte
(f,l.; ,hi.l.; Note and c;llIed th~ "St'-curi,y Inl"lrumenl." ~nle St'.curity Jm;lfllnw,nl prnit'dl" the Lendt:'.r from los.r.;t'$ which might result if
Borrow~r defaults lindeI' this Note.
4. MANNER OF PA "MENT
(A) Time
Borrower shall nmke a payment or PI' neirml <lnd interest to Lender on the tirst day of el-H.:h month he~inning on
NOVEMBER 1 .1997 . Any p incipal and inlerest remaining on the first day or OCTOBER 1
2027 . will he dlle on thai dale, which is c: lied Ihe "Malll1'ily Dale,"
(R) Place
Paymenlshallhemadeal 4931 CAILISLE PIKE, MECHANICSBURG, PA 17055
or HI such rhtce as Lender may. desigllClte in writing
hy notit..:e to Borrower.
(C) Amount
Each monthly payment of prillcipltlllllll illkrl~st will he ill the amount of U.S. $ 454 . 26 . This amount
will he part of a larger monthly payment require hy the St'.curity Instrument. that shall he applied to principal, interest and
olher il~l11s in the order descrihed in the Security I strlll11t'.nt.
(n) AIIIIIl!!e IlIlhis Nllle 1'111' paymenl mlj. ,h'wllls
If an allon,ge providing for payment fll ;lIstments is eXljr.;ukd hy Rorrower together with this Note. the c'ovenants of
the illlonge shall he incorporated into and shall an end <111(1 supplt:'.Il1~llt the coVellllnts of this Note itS if thlj al1ong~ w~r~ a part of
Ihis Note. ICheck app!icahle hox I
DGradtlHted PilYll1ell1 Allonge DGrowi, g Equity ^"11ngt'; DOthe.r Ispt'.cifYI
5. BORROWER'S RIGHT TO I'REPA Y
Borrower has the right to pay the d~hl t';vide H;~d hy this Nole. ill whole or in part. without chHrge or penalty. on the first
dHY of Hny ll1onth. Lender shall accept rrep<lymt'.n Oil ntht>,!' dilYS rrnvidt>.d that horrower PClYS interest on the <ImOlll1t prepaid f()r
tht'; remainder of" the monlh to the extent required 'y Lendt'.r and perrnitll:'.d hy re.gulations of the Secretary. If B()rrnwer makeH ,I
Pill"tial prepayment, there will he 110 ch<tn,gt~s in II e due d:tt.e or in the. amount of tilt:". ll10llthly payment lInleHI' Lel1d~r llg~ees in
writing 10 those changt."$.
IliA )\1JJllt..lllll' Fix",) Unit. Nllft. _ 11IJt,~
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. ,_, ~ II. Lemler 11lt:' Ilql n:.celvlJd I Ill', 11111 111C1llhly paYIIIL~llt n:qulled hy lhe Seetlnl nstrulIltlllt. dS UeSl;lIhl!.d III r .t1<I,bI<lph
....:11 ~') of this Note, hy tilt: t~l1d tJl firken cale.ndar lays "fter lhe payment is dUe. LelHler Ilmy coiled a late charge in (he amount
() FOUR petcenl ( 4.000 %) of the oven.lue amount of each payment.
(II) IJcl'a,,1l
If Borrower defaults hy 1~liling 10 p.1Y il full any monthly payment. thell Lcnuer may. except as limiteu hy regulations
o Ihe Sc:crc:t<ny in the ca,....(j of payment dd~H11t.'i. 'cqu;re immeJi.llc: p.tymcnt in full of the prim.:hm) hidant:t: fCIl1i1inin.g due Ilnd
HI i flt:crued interest. Lemler lllay choose not 10 e ercise this option wilhout wnivin,g its rights in the event of 1my suhsequent
Jd"ault. In many cin;ulllstances re!iul.atiolls issue hy the Secretary witt limit Lender's rights to relluire immediate payment in
hill in the case of paYIllt::l1l dd~lttlls. This Nole do s not authorize accderatiol1 when not penniUeu hy HUD regulations. As used
in this Note, "Secretary" means the Secretary of ~ ollsing und Urhan Development or his Of her designee.
(C) Paymenl of Cost." and Expense...;
If Lem.ler has required immediate paYIll~nt ill rull. as descrihed ahove. Lemler may n:~quire Borrowe.r to pay costs anti
expt::nses indutling reason<lhle Hnd customary aile fIleys' fees Ii". entilrcing this Note to the extent not prohihited hy applic.ahle
law, Such fees Hlld Costs shetll hear interesl from tl e dale of dishursement al the same rate as the principal of this Note.
7, WAIVERS
BorroWer :'lIlt] HflY other (JefSOI1 who Iw.<; lhliglllions U1uJt:r thi... Noh:: waive the rights of presentment anu notice or
dishonor. "Pr~s~ntlllent" 1llt::IIlS the right to rt:quir Lender to demand p:'IYIl1~nt of amounts du~. "Notice of uishol1of" Illeans the
right to relluire Lender to give notice to other per. OilS that illllounts tlue have not heen paid.
S. GIVING OF NOTICES
Unless .applicahle law requires a dilkrent III thod, any notic.e that must he given to Borrower untler this Note will he given
hy delivering it or hy Illuiling it hy first c1Hss I mil to Borrower <It the property Clc.kJress ahove or at .a c..lifl~rent ,u..ltlress if
Bon-ower has ,given Lender a noti~e of Borrower'. llin~rt:nt address.
Any notice that must he given to Lenuer LInd r this Note will he given hy tirst class maiJ to Lelltler at the atlures!"; staled in
Paragraph 4(13) or at a different mJdress if Borrow r is given H notice of that din~rent audress.
9. OHLlGATIONS OF I'ERSONS UNDER TH S NOTE
If mort:: than one person signs this Note, em.: 1 person is fully mlu personnlly ohJigaleU to keep all of the promises made in
this Note::, including the promise to pay the full nil olln( owed. Any pt:rson who is a guarantor. surety or ~nJorser of this Nol~ is
:.tlso ohligated to do these things. Any penmn wh( lakes over these ohligations. including the ohligations of a guar.antor, surely
or enuorser of this Note. is also ohligated 10 keep III or the promises nmde in this Notlj. Lt:muer may enforce its rights tlnuer this
Not~ MgMinst ~~lch ptmmn individulllly Ill" Hguinsl ~ lI:--igl1Httlries together. Anyone person signing this Note may he rt:qllire<.l to
pay all of the amollnts owed under Ihis Note,
BY SIONJNG BELOW, Borrower accepts aI U agn.-:t:,o; to the term... anu covt:na.nl.o; conta.ineu in this Not~.
~,aJl~_
C SHIRL A. DICKEY
(Seal)
~Btl,.rtlWcr
(Selll)
-BtllTtlwo:r
(Selll)
-Btlfl'UWo:r
PAY vIITHOUl' RECOURSE, TO THE 0
T UNITED MORTGAGE SERV ES
ER OF MELLON MORTGAGE CO.
INC.
(Selll)
-BtllTt\WCr
Wi'lHOUTRECOURSE PAY TO THE ORDER OF
MELLON MORTGAGE COMPANY
!/1vvspf-
CYNTHIA L. GRESSETT, ASST, VICE PRES
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WHEN RECORDED RETURN TO
FIRST UNITED MORTGAGE SERV CES, INC.
4931 CARLISLE PIKE
MECHANICSBURG PA 17055
'97 SEP 1'1 Ar110YO
rSp Ice Ahnvc Thi:-: Lin.: Fur Rcr.:llrdinl! DUllll
State flf" Pennsylvania
LOAN NO. #675810
I FHA Case Nfl,
441-549718-0
MORTGAGE
THIS MORTGAGE ("Security Instnunent ') is given on SEPTEMBER 9, 1997
SHIRLEY A. DICKEY
. The mortgagflr is
(" Borrower").
This Security In~trl1ment is given to
FIRST UNITED MORTGAGE SERV CES, INC.,
which i~ organized and existin~ under the laws Jf COMMONWEALTH OF PA. . .md whose address is
4931 CARLISLE PIKE
MECHANICSBURG, PA 17055 ("Lender"),
Bnrrnwer nwesLender the principal sum nf" IXTY-FOUR THOUSAND NINE HUNDRED SIXTY-SIX
AND 00/10'0 Dnllars(U.S. $ 64,966.00).
This deht is evidenced oy Borrower's note da cd the same dak as this Security Instrument ("Note"), which provides for
monthly payments. with the f"ull deht. if" nnt pa d earlier. ulIe anu payahle nn OCTOBER 1, 2027
This Security Instrument secures tn Lender: ( ) the repayment nf" th<, deht evidenced hy the Note. with interest, and all
renewals. extensionr-; and moditications of th Note: (h) the pilyment of .lIlI other slims, with interest, advanced under
paragraph 7 to rrot~ct the ~'dcllrity of th;~ S ~uriry In~rrllm~nt: and (e) tht: r<::rteJrlnanCe of Borrower's covenants and
agTcclllt'.nts under this Security Instrument an I the Note. For thi~ purrost'., Borrower does ht';rehy mortgagt';, grant and
(,;ollvey to Lem.lt';r the t()lInwing d~scrihed prop rty !ol.<tted in
CUMBERLAND Counly. Pennsylvania:
SEE ATTACHED DESCRIPTION
which has th~ addr~.ss of
6 LOCUST LA E, MECHANICSBURG
/Slr....q
ICilyl
Pennsylvania
17055
("Pro)'<,rly Address"):
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TOGETHER \VITH ~tJllhc improvcmtinls now or ht:r~;lncr t:rt:~h::J_on 11 c propc:rty. auu all casemc:nts, appuftc:nancc:s.
.anu tix[urc::s noW or hc:rc:aftc:r a purl of the: properly. All rc:pla~C:IIl~nts aill! a Jitions shall also be: covc:rc:u by this Security
Instrumc:nt. All of the:: forc~oilH.! is rde:Ht:J to in this Security Instrumc:nt as lh "Propc:rty."
BORROWj;:R COVENAN-TS IhatBi,ri'llwer is lawfully seiseJ of the slale herehy cllnveyeJ anJ has the right 10
mortgage:. gran\f 'anJ 'l:oilv~y the: PrupdrlY' ~uuJ that the:, Propc:rly is UIl~nl,;lI nhc:rc:ll, c:xct:pl f()( c:ncumbrances of rc:con.l.
Borrower' warnuilS -anJ- will Jc:fc:nll gc:nc:rally the: title: to the: Propc:rty agit'I1S{ all claims 1.U1J ucnu\nus. suojt::ct 'to any
c:ncumbrances of rc:con.l.
THIS SECURITY INSTRUMENT combinc:s uniform COVt:I1i.Ults tl'f n ttiollal lISe ami non-unitorm cuv~nants with
limitt:u variations by juri~uiction to constitule: a unifonn s~curity in~lrument c( ve:ring re:al prope:rty.
Borrower anu Lel1l.ler covt:nant anu agrt:e as tl.)lIows:
UNIFORM COVENANTS.
I. Payment tit' Principal, lnten~."t and Late Charge. Borrowe:r sh~dllnty whe:n Jue: the:: principal of. and int~re::.st on, the
Jcbt e::viJe::n..:e::u hy the Notl:: and Ii.ttc:: charge::s oue:: unJe::r lhe: Note:.
2. J\'JlJnthly Puymcllt of Ta.\:cs, 1u.\"unUlcc. alld OI,hcI" Chal"gt:.\". BOlT HVc:f ."ihaJJ indllJc: in c:....:h monlhly paymc:nl.
together with the principal anu inte:re:::il Ct~ Sd ll.)Ilh in tht: Note:: unJ any Iltt: ch;.trge::s, a sum It)r (u) taXe:S unJ spc:..:ial
assc:ssme:nts h::vi~u or to he:: Ie:vie:d against the: Prope:rty, (h) Ie:Hse:hoIJ paym nls Of grounJ fe:nts on the: Prupe:rty. anJ (c)
pre:miums f()f insuranL-C fCllujrc:J undc:r P.lIru,gmph 4. In any yemr in whid the:: _Le:nJe:r lllllsl puy a mortgage: insur~nce
premium to the: Se:crdary of Housing unJ Urban [)e:vc:lopllle:nt ("Se:..:rdary"), or in any ye:ar in whi..:h such pre:mium woulu
have heen re'iuireJ if LenJer slill hdJ the Security 'nstrumenl. each mUlllhly ,ayment shall also induJe either: (i) a sum for
the: annllal Illl}rtgage insianul~e: pr~mium to he: paiJ hy Le:nJe:r to the: Sccrt::htry, or (ii) a munthly ~hargc instead of a mortgag~
insuranc~ prc::mium if this Se:l.:urity Jnstrumc:nt is hdJ by tht:: St::cre:htry. in . re:asonahle: amount to be: ude:rmine:J by the::
Sc:cre:tary. Exce:pt tc.J( the:: monthly charge hy the: Sccrc::lary. thc:se: ite:l11s afe: r.:allcu "Escrow Ite:ms" ami the sums paid to
Le:nue:r arc calle:J "Es..:row Funus."
Le:nUcf may, at any time:. ..:olle:..:t unJ holJ amounts for Escrow Ilt:m. in an aggre:gate:: amount not to cxcce:u the
maximum amuunt that may he: re:ljuire:J for Borrowe:r's e:scrow i:I\:culInt lIlH.le:f the: Real Estah: Se:ttle:mc::nt Proce:uure:s Act uf
1974. 12 U.S.C. ~ 2601 ~t Se:ll. uno imple:me:nling regulations. 24 CFR Part 3500, as they may be:: amc:ndeu from time:: to
time: ("RESPA"), eXCe:pt that tht: cushion or rc::sc::rve: pcnniHe:J hy RESPA tl'( unancicipatdu Jishurse:ll1c::nts or _uisburscll1cnts
bdurc:: tht: Burruwer!s payme:nts art: available' in the: m::cuunt may not be hase: un amuunts Jue: tor the: murtgage: insurance
pre::l1l1l1lll.
If Ihe amounls hdJ by LenJer tur Escrow Ilems exceeJ Ihe amounls p rmiueJ to he hdJ by RESPA, LenJer sball
account to Borrow~r for th~ e:x":~ss funJs as r'Cl.luireJ hy RESPA. If the amOll ts of funds he::IJ by Le:nd~r at any time is not
sufticie::nt to pay the: ESl;row Itc::ms whe:n Jue::. Le:nde:r may notify the: Bormwe:r anJ rC:lluir~ Borrowe:r to mak~ up the shortag~
as pe,milleJ hy RESPA.
The: Escrow Funds art: pkJge:J as auuition.tl se::curity fur all sums se::cure:: by this Sc:curity Instrume:nt. If the: Borrowt:r
te:mlers to Lc:nde:r the:: full p;.tyme::n[ of ctll sw.."h sums. Borrower's w.:t.:llunt shall he:: crc::Jite:u with the halance:: re::maining tl.)r all
installment ite:ms (a), (h). anu (..:) anJ .my" ll1ort,gi.lge:: insuf<lnl.:e:: premium installme:nt that Le:nJe::r has not be:cmne obligate:d to
pay 10 the:: Sc::crc::tary. anJ Le:nde:r slmll promplly re:funu any e:x,,:e:ss funJs to Borrowe:r. Inul1e:diatdy prior to a forc::dosure:
sale:: of Ihe:: Propc::rty or its ;'K"Iuisitioll hy Le:nuc::r. Burrowc:r's W.."l.:oUllt shall c:: cre:uitcJ with any halulll.."e: rc::maining fl.)r all
inslitllme:nts for ite:ms (<I), (b) anu (C).
3. Applicutitul uf Payment". Ail pi.tYll1e1US unJe:r Paragruphs I and 2 slud
Fjrst. to the mortgage:: insurance: pre:mium to he: paid hy Lc::nJe:r to th
Sccr~tary inst~au of thc:: l11ol1lhly mortgage insurance: pre:mium;
Sc::conJ" to any ta,'(cs, spc::cial a."scs.""nc::nls. le::aseholJ paymc:nts or gro mJ n:ols, aoJ firc:, tl()()(..l aou mhc:r huZitnl
insurance pre:miums, as re:l.Iuircd;
ThinJ, tu interest uut: unuc:r the Note:;
Fourth, to amortiz;.(tiun of the: principal of the: Note; ami
Fifth, tu late chargel; JUe unucr the Note:.
4. Fire, Fluud and Other HU:I.ard Insurullce. Borrower ~hall insure all i lproveme::nts on the Prope:rty. wh~the:r now 'in
e::xistenc~ ur suhse:llucntly e:re:de:u, against any h"Zl:lrJs, l.."asualtie:s, anJ con inge::nci~s, incluuing tire, for which L~nu~r
re:quires inslIranc~. This inslIran..:t: shall h~ maintaine:d in th~ amounts and f( r the: periods that LcnJ~r rt:quircs. Borrow~r
shall also insure all improvelllents on Ihe Properly, wh<lher nuw in exislence Jr subse'iuently erect<:J, againslloss by HooJs
to the: exte:nt rCl.llIircu by thc Se:..:rctary. All insurance:: shall he:: l.:arrioo with c Hl1panie:s appruve:u by Lc:::nder. The inSllranl.:t:
poHcic::s anu any re::ncwals shaH he: hdJ hy Le:nJe:r anu shall incluue: loss payah e c1ause:s in favor uf, and in a form acceptable:
tu, Lcnucr.
he applieu by Lenuer as fulluws:
Se::crc:tary or tu the: monthly charge:
by Ihe
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In th~ event of loss. Borrower .shall give Lend~r immediate notice hy mail. Lender may make proof of lo.s.s if not made
promptly hy Borrower. Each insurance company concerned is herehy lwthorized and directed to make payment for such loss.
directly to Lender. insltllld of to Borrower and to Lender jointly. All or any part of the insurance procoods may he applied hy
Lender. at its option. either (a) to the redll~tio of the indehtedness under the Note and this Security Instrument, tirst to any
ddin(lUent amounts applied in the order in Pt ragraph 3. and th..:-n to prt:payrnent of principal. Of (h) to the r~st()ration or
repair of the damaged Property. Any arrlicati< n of the proceeds to the principal shall not eXh:md or postpone the due date of
the monthly payments which are referred to iT Parugraph 2. or change the amount of such payments. Any excess insurance
proceed$-; over an amount required to pay a(l C t1(~(:tnding indehtedness under the Note and this- Security lnstrument !'hall he
paid to the entity legally entitled thereto,
In the event of foreclosur~ of this Security Instrllment or other transfer of title to the Property that ~xtinguishes the
indehtedness. all right, title and int~rest of 80 rower in and to insurance policies in torce shall [Jass to the purchaser.
5. Occupancy, Preservatinn, J\1aintellll1t"e ulld Protectiun of the Property; Borrower's Lmm Applic~ltion;
Leaseholds. Borrower shall occupy, estahlish. and use the Property as Borrower's principal residence within sixty days after
the execution of Ihis Security Instrument (or w thin sixty days of a ",ter sale or transter of the Property) and shall continue to
occupy th~ Property as Borrower's principal residence for at least one year after the date of occupancy. unless Lender
determines that requirement will calise undue hardship for Borrower. or unle."is extenuating circllmstances exist wh,ich are
heyond Borrower's control. Borrower shall olify Lender of any ,extenuating circumstances. Borrower shaff not commit
waste or destroy, damage or suhstantially cha ge the Property or allow the Property to deteriorate, rtmsonahle wear and tear
excepted. Lender may inspect the Property if he Property is vacant or ~hClndoned or the loan il' in default. Lender may take
r~asonahl~ action to protect and pre:-;erv~ such V:'lcant or :'Ihamloned Property. Rorrower shall also he in rJdault if Borrower.
during the Im-m aprlic~tion process, gave m:.l erially fctb~ or inclccurale inti:lfmation or st<ltemel1t~ to Lender (or tailed to
provide Lender with any materi<il inti:\rmtltion) in connedion with the loan evidenl,,'t;".d hy the NClte. including. hut not limited
to, representations concerning Borrower's occ Ipaney of the Propert)' as a princ.;ipal residence. If this Security Instrument is
on a leasehold, Borrower shall comply with t e provisions of the lease. If Rorrnwer acquires fee title tn the Property. the
leasehold and fee title shall not he merged unl ss Lendt'.r itgrc'c's to the merger in writing,
6. Cnndemnntinn. The proceeds of any Iward or claim for d:'lmages. direct or consequential. in connection with any
condemmltion or other taking of any part of tl e Property. or t(lr conveyance in place of condemnation. are herehy as~i,gned
and sh~1I he paid to Lender to the extent of th full ~mOllnt of the indehtedness th<it re111liins unpaid under the Note and this
Sc:curity Instrument. Lender shall apply Slh.:h rnceeds to the rc:dudion of the indehtedness under the Note ami this Security
Instnunent. tirst to any ddinquent amollnts 'IPrlied in the order provided in PClragraph 3, and then to prepayment of
principal. Any application of the proceeds t l th~ principal shall not extend or postpone the uue date of the month.ly
rHyments. which are rd"erred to in Para!!rap 2. or chan!!e the ClmOllllt of stl~h paYIl'\ents. Any exces~ proceeds over Mn
amount required tn pay all olltshmding imleht dness IInder the Note and this SCL'urity Instrument ~h<lll he pitid to the ~ntity
JegHII y ~ntitled thereto.
7. ChurJ::es tn Rorrn\Il.'t"r and P..utt"ctinll .r Lendt>r's RiJ:hts in tht" PI'upt'rty. Rorrower ~hl-lll rl-lY all governmental or
municipal charges. tines and impo~itions th<it ' re not included in Panlgl1lrh 2. Borrower shall PllY these ohligHtions on time
directly If) the entity which is owed the paym ol. If failure tf) pay wl\uld adVersely anect Lender's interest in the Property.
upon Lender's request Borrower shall promrtl furnish to Lender re.ceirts evidc:nt...illg these payments,
If Borrower fails to make the,=e pay men s or the payments required hy Paragraph 2, or tail~ to perform any other
c()venant~ and agr~mcnt." cont~lincd in this S curity In...trumcmt. or there i... :t leg,a! rmc~cding that Il'ltly signiticantly ..neet
Lentler's rights in the Propcrty (such us a pre ceeding in hankruph:.y. tClr condemnation or to entclrce laws or regulations),
then Lender may do and PHY whatever is nece. s.lry to protect the v<llne of the Property mul Lender's rights in the Property,
including payment of Saxe..... hazard insllntnce ~ nd other ifem.... J11cmtioJlC'd in P(tnl~rarh 2.
Any amounts dishur~cd hy Lender under this P:.tnlgn1rh sh:tll hn'ome <In l.Iddition:.11 dt:ht of Borrower amI he secur~cJ hy
this Se~urity Instrument. These al110unts ~h<lll lear interest from the dale of dishursement at rhe Note rate, and at the option
of Lender ~halJ he in1JHeuiardy due .Iml !,myanl '.
B()rrow~r shall promptly dischnrge any lie 1 which has priority ov!:'.r this SC:I.~lIrity Instrument lInl~ss Borrower: (a) agrees
in writing to the payment of the nhligatinn st". lIred hy the lien in iI manner HlTeptahl~ tn Lender: (h) contests in good faith
thd lien hy. or ademd,.. again,.., ent(m::emellt of he lien in, leg~" rrot:ccdjng~ whidt in the Lendc,.'s opinion operate -to prevent
the enf(lrCtlment of the lien: or (c) secures frO!, the holder of-the 'lien an al!rcel11~.nt s:.tti,sfactory to Lender_ suhordinatinc the
lien to this Security Instrument. If Lender d termines thHt any part of the Propc:rty is su~iect to " lien whkh may ;ttain
priority OVdr this Security Instrument. Lende may give Rorrower it notke identifying the lien. BorroWer shall satisfy the
lien or take ond or more of the actions set fort ahove within 10 d:IYs of the givim.. of notice.
S. Fee.'i. Lender may coiled t~es amI c.har,'es authorizt"d,_l:y t.he Secretary. ...
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9. Gruunds fur Accclcnlliull HI' Ucht.
(a)' Default. Lenuc:r lIlay. cx.t.:cpl a:-; limikJ hy rcgulHliulls issueu by Ltc Sc;;:~rdary in the: I.:asc vI paymc:nt uefaults.
rClluirc:: imll1t:piatc:: paymcnt in full of all SlIll1:-i secureu by this St:~lIrity II strulllcl1t if:
(i) BorroWer uc.faults hy failing to'pay'in full any monthly paYl11clU quirc::u hy this Security lnstrul11~nt priur to or
<n1 th~ UUe Jat~ of the: next monthly pltymc::nt. or
(ii) Borrowa lh:::faull:-; by t~liling. hJr a pcrim! or thirty L1ays. to pc tonn any 01hl::f ohligatiuns containc::u in this
Sc::curity Instrulllent.
(h) Sal~ Withllut Cr~dit App....val. Lemler shall. if permilled hy ap ,Iieahle law (including section 341(d) Ill' the
Garn-St Gerlllain Del""itllry Instilutions Act of IY82, 12 U,S.c. 17 1j-3(d)) and with the prillr appruval of the
Sc::crt:lary. fcl)uirc immeuiate p;,tYIllt:111 in full of all slims st::curc::u hy this Security Instnune::nt if:
(i) All or part of the:: Prop~rlY. Of i.l he::ndi~i,ll il1te::f~st in a trust 0 vning all or part of the:: Prope::rty. is sold ur
othe::rwise:: tmllst"c;:rre::d (oth~r th,U1 hy de::vise:: or ue::s~~nt). <lIlU
(ii) The:: Prope::rty is not ()~~uJlieu hy the Jlun:hase::r or grunke:: as his 'I" her prin~ipi.tl re::siue::n~e, ur th~ purchas~r or
,grantl:':e:: UOI:':S so O~Cllpy the Property. hut his ur he::r creuit hus nut hec:n upprovc:u in accoruancc with the
rCI.Juirements of thc Secretary.
(c) No \Vaiv~r. If ~ircumstances o~cur thut Wlluld permit Lc:nder to r 1..Iuire immc:di<1te payment in full, but LenJcr
docs not require :-:;u..:h paymc::nts. Le/1l.Je:r does not wHive: its rights with r spect to slIbsellue::nt eVentS.
(d) ReJ.:,ulalions of HUn S~cr~tary. In many cin:ulllstances regulatiol s issued by the SCI,;fetary will limit Lender's
rights, in the ~as~ of payment dd,utlts. 10 re"uire imllledillle paYIll~nt i full and loreclose if not paid. This S.,.;urily
Instlllme:nt uoes not authorize: accde:ratioll or fUfc:dosufe if not pe:nniue hy re:gulations of the Se:cre:tary.
(e) J\'JurtgllJ.:e Nut In...;ured. Borrowcr u~rl:':e,'i that jf this Se~urjty Instr IInc::nt anu the: Nute: are nut uetennineu tu be:
eligible for insurance unJer the N,ttional Housing Ad within 60 DA S from the date hereof,
L~nJe:r may. at its option require immedia(~ puyment in full tlf "I( Slims 'cl..:ureu by thi:-i SCl..:urity In~trument. A written
,..;t.itr~menr uf any authorized a~t:Jl[ of the SC::l..:rdMY Lht1eu ,,,;uhsl:':l..llIeJltlu 0 DAYS from the:
Jale he::re:of. uedining 10 insure this Se~llrity Instrulll..:nt anJ the: Nol . sh...1I he: Jee:l1leJ ~ondusive pruof of sut.:h
ineligihility. NotwithstanJing the ftlregDing, this option muy not he:: e. e:rcis~u by Lc:nder when the: unavailability of
in.')ll(ancc is soldy Jue to LcnJcr's htilu(c to remit a mortgage: ;11...;lJn.lJ1C premium to the: Sc:cretary.
10. RdIL"lal~m~nt. Borfowe:r has a right tu hc reinstatcd if Lenuc:c has r quireJ imllleJiatc: payment in full because: of
Borrower"s faiI'urc: to pay an amuunt JUe lUluef the Note or this Se:l..:urity lnsfrllllent. This right applies eVen after foreclosllrc
proce:c:dings afe: instituteu. To rt:instate: the: Se::clIrity Instrull1c:nt. Burruw~r shal tcnuer in a lump sum all amoUnts rC4uireJ to
hring Borrower's aCl.:ount CUfr..:nt induuing, to the: cxtent they arc ohligation, of Borrower unuc:r this Security Instflllll..:nt.
tore:dosure: I.:osts ano reasonahle anJ I.:ustomary atturneY's :t~es ano expc:n 'e:s properly associated with 'the foreclosure
procc:c:Jing, Upon rc:institlell1t:O[ hy BorrowC:f. this Sel.:ur~ty Instrumc:nt anu Ie ohligations that it St:CUfeS shall remain in
dl~t as if Lenucr haLl not r~l..luired il1ll1l~Jial..: paymcnt in: full. Howc::v..:r. L~I uer ix not f":l..lUireJ to pc:rmit r~instat~ment if:
(i) Lc:nuer hl-l.s acc..:ph::u r..:instatel1le:nt ah~r thl:': ~UI1HneI1C~nh:mt uf furl:':doslI I:': pro!.:c:c:uings within two years illlJ11et.liatdy
rrc:ce:Jing the comm~lh.:c::mcr1C of a I.:llrrl;:fH {(,reduS'lIre prdcec::uing, (ii) rC'insl'tellle-llt will preduud ti.,r..:dosure: un dift~rcnt
grounus in the: future. Of (iii) re::ins(atC::l1lel1t will aLlvl:':rsdy i.ln~clthl;: priorit)' ot the lien crl:':.ded by this Se:(,,:urity lnstrullle:nt.
11. Burrow~r Nol Released; Furheurullce B.y LClld~l~ Not a \Vaivcr. Ex ~nsion of th~ time of paYIll~nt or llluJitil.:aliun
of amurtization of tht: SUiIIS S":CUfeu hy this Security lustfUlII..:nt grdnt~J hy L micr to any SLl~~cssur in intere:-;[ of Burruwer
shall not operate to r~lcast: the liability of th~ original Borrower or Borrow r's succcssor in int~rest. Lcmuer shall nut be
requireu to commence proce~Jings against any sucCt:ssor in inte:rest or ref Se to e:xt~nu time: for payment or utheIWis~
mudify amortization of the sums sdcureu by this Sel.:urity Instrumc:nt by r ason uf any ue:mand made by the original
Borruwer or Borrower's succes:mrs in intert:st. Any forbearance by Le:nuer in eXC:fcising any right Or remc:uy shall not he a
waiver of or precltu.le the: exc:rcise or any right or reme:uy.
12. Successurs and Assigns Buund; Juint and Several Liability; Cu-si'llurs. The Cuvenants anu agrecme:nts of this
Sc:curity Instrument shall hinu anu benefit the SUl.:l.:l:':ssors anu assigns of Lend r anu Borrowc:r. subject to the provisions of
Paragraph 9(b). BorroWer's COVenants anu agreelUents shall he: joint anu SeVe al. Any Borrowc:r who co~signs this Security
Instrumc:nt hut uoes nut eXecute: the Note: (a) is co-signing this SC:l,;urity Instr me:nt only to mortgage, grant anu conv~y that
Borrower's interest in the Property unuer the terms of thi:-; Security Instrum nt; (b) is not personally obligated to pay the
sums secureu by this Se~urity Instrument; aoLl (t.:) agrees that Lemler anu any ther BurroWer may agree to extend. mouify,
forbear or make any at.:collunoJatiuns with regard tu the term of this Set.:urity I strulUent ur the Nute without that Borrowc:r's
consent.
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13. Nfllices. Any nolice to Borrower proyided li>r in this Security Inslrument shall he given hy delivering it or hy
Illailing it hy lirsl class mail unless applicahlt law "'quires use of ,mother method. The notice shall he directed to Ihe .
Property Addre."is or any other address Borrowel d~signah~s hy notice' ~o Lemler._ Any notice to Lender shall he given by first
cla~s mail to Lender's addreSf; stated herein or a y addr~c.;s Lender designates hy notice to Borrower. _Any notice provided for
in this Security Instrument shall he deemed te have hetm given to BorroWer or Lender when given as rrovided in this
paragraph.
/4. Gnverning Law; Severllhi/ily. This: ecurity In,strument shall he governed hy Federal law and the law of the
jurisdiction in which the Property is located. Tn the event that any provision or clause of this Security lnstnlment or the Note
conllicls wilh applicable law, such conllicl sha I not affecl olher provisions of this Securily Inslrument or the Note which
Can he given effecl withoulthe cOlltlicting provision. To this end the provisions of this Security Instrument and the Note are
declared 10 he severable.
15. Bflrrower's Cnpy. Borrower shall he g ven flne conli>rmed cnpy of Ihe Note and flf Ihis Securily Instrument.
16. HU7Jlrdflus Suhstunces. Borrower shall nfll cause or permit the presence. use. disposal, slorage or release of any
Hazardous Substances on or in the Property. flrrflwer shall nol do. Ilflr allow anyone else to do, anything affecting the
Property that is in violation of any Environm~nt I Law, Th~ precedin~ two sentences shall not apply to the presence. use. or
~tnrage on the Property of small quantities of Hazar<1ou~ Suhstancel" thut are gt:menilly recognized to he appropriate to
normal residential USeS and to maintenance of th Property,
Borrow~r shall promptly give Lender writt n notice (~f any investi!!i1tion. claim. demand, hlwsuit or other action hyany
governmental or regulatory agency or private p tfty involving the Prnpt',rty l:md any HOizardnm: Sunstance or Environmental
Law of which Borrower has actual knowh:~dg , If Borrower Itmrm:. Ill' is notified ny any governmental or regulatory
aUfhority. that any removal or other remediatin of any Hazardolls Suhsf:ances affecting the Property is n~essary, Borrower
8ltall promptly take all neces.l;ary remedial actio.. in C1ccnrdam.:e with Env;rnnmc:ntal Law.
As used in thi:-: Paragraph 16, "Hazardolls '- uhstances" arc thnsc suhsf<lnces ddined as toxic or hazardou:-: suhstances hy
Environmental Law and the f()lIowing suh:-:htnl' .s: gOisoline, kerosene, other fl.lmml:lhle or toxic petroleum products, toxic
pesficiues and herhicides, v(llatil~ solvents, mi krials l,;ontaining n:-:he.stos Of tflrl1l<tlddhyde. and radioactiv~ materials. As
ul-:c::d in the paragntph 16. "Environmental La " mc::ans ti:od~ral laws and htws of th~ .i"risdiL~tion where the Property is
!oL"akd that relate to health, safdy or environl11d ltal protection.
NON-UNrFORM ,COVENANTS. Borrowe .mtl Lendtlr furthtlr covenunt and agretl as tf)IIows:
17. A~~iJ:nnlent of Rents. Bo'rrower uncon litiomllly assi,gnt: Hnd tran!4fers to Lender all the rents and reVdnlle.~ pf the
Property. Borrower authorizes Lender or Lt'mde ':-: agents to coiled the rent:-: <tnd ttwt:mUtlS and herehy directs el:tch tenant of
the Property to pay, the rents to Lender or Len er's Hgents. However, prior to Ltmder's notice to Borrower of Borrower's
hrtlach of any covenant or agreement in the StlCl rity Instrument. Borrower sh<lll collec;t and rec;eive all rents and revenues of
the Property as trustee fflr the henetit of Lende and Bnrro\Ve:r. This assignment of rents con:-:titutes an ahsolute: assignment
and not an assignment for additional security on y.
If Lender gives notice of hreach to Borrower (Oi) all J"tlnts rtlctlivt:d hy Bormwer shall he held hy Borrower as tru~tee t{lf
hendit of Lender only. to he applied to the sun s seclIred hy the Security Instrument: (h) Lender shall be entilled to collect
a~d receive all of the rents of the Property: and (c) each tenant of the Property shall pay alf rents due and unpaid to Lender
or Lender's agent on Lenuer's written demand tl thtl tenan!.
Borrower has nof executed any prior <Issignn ~nt of the rents nnd has not Imd will not pert{)fIn any act that would prevt!:nt
Lender from exercising it:-; right:-; under this p.mt ~raph 17.
Ltlndt::;r shall not ht::; r~qllin:ld to t::;nftlr upnn, takt::; control of or maintedn the Proptlrty hefortl or after giving notice of
ht~aeh to Borrow~r. However, L~nder or a ,iu li.cially l:Crpoint~d rtlceiver may do ~o at itny time there is a hreal~h. Any
af'lplication of rent~ shall not ClIrtl or waivtl any (. timlt or invalidate any nthtlr riuht or rellltldv of Ltlnder. This assiunl11ent of
rents of the. Property sl1311 tcrmimde whtln thtl de t !'tlcured hy the Secu~rity Instf'l~ment is paid- in full. '-'
IR. Fnrec1nsure Procedure, If Lender relJu rtls il11l11t'diatc payment in full lIndtlr Paragraph 9. Lender at its option may
require iml11~uiate paymtlnt in full of all slIms:-:tl ured hy this St'curity InstrUI11~l1t without further ut::;l11and and may ffm;~close
fhis S~cllrifY ~nstn~l11ent hy judichtl proceeding Lemler shall he entitled to collect all expen~ef; incurred in pursuing the
re:meUlc... provlileu III this,paragr,'ph 18, inchu.lil1', hut nor limited to, attomey~' tde~ and costs of title evidence to the extent
permitted hy applicanle law.
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Bood405PAGE, 450
.-
.-
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if the Lc:ndc:r's interest in this SCl.:urity Instrul11clH is hdJ hy the: Sc:::...:rdar and the:::: Sct.:rdary rC:l{uirc::::.s inunc::::Jiatc payment
. in full under Paragraph 9, the: StA.:rctary nmy invoke the nonjlU..Iit..:ial powc::::r ( f sale:::: proviJcJ in the Single Family Mortgage
Fo'eclosu'e Act of 1994 ("ACl") (12 U.S.c. 3751 ct seu.) hy 'eyuesling a !,"eclosure commissione' designated unde' the
Act to C0l1l111c:ncc foreclosure anu to sdl the: Property as proviuc:J in th~ A..:l. Nothing in the preceding sentence shall deprive
the Secretary of any rights olhcrwi~c av.lilahJc to a Lc:nuc:r undc:r this Paragra.,h 18 or applicahlc:::: laW.
19. Release. Upon paymc:::nt of all sums Sc\..'UfcU oy this SC:l.:urity Insll IInent. this SCl.:urity Instnlll1cnt anu the: cst~h:~
convc:yc:d shaff tc:::rminate and hccolllc voiJ. Att..:r Slh.:h OC..:UffC:IlCc, Lei cf shall Jis~hargc anu satisty this Sc:curity
Instrulllt:nt without charge: to Borrow~r. BOfrow~r shall pay any nxon.Jation Jsts.
20. \Vuivel"s. Borruwt::f. to tht: ~x.t~nt p~rmillt:J hy appficuhl~ taw, waiv..::s anu rd..::as..:::s any e::rrur ur Ud~l:ts in
pruct:t:cJing~ to e::nt4.Jrce:: this Security Instrumc:nt. anu he:rlO::hy wuive::s the: hc:n tit of any prc:scnt or future: laws proviuing tor
stay uf t::xe:cutiul1, e:xt~nsion of time:. eXemption from i.1tt;,u.:hme:llt. h::vy anu sa c:. HnJ homestc:aJ eXemptlun.
21. R~instattlUent Period. Borrowc::r's time:: to rdnstl.lh:: proviJe::u in pa . graph 18 shall e:xh::nu tu one:: hour prior to the:
COlUl1k:nce::l1lent of hiJuing at a ::ihcriff's :-;ale Of othc:r sale:: pursuant to this St:c Irity Instrument.
22. Purchase l\10I1CY J\lortgugc. If allY of the:: uc:ht se::cur~J by this Sc:c Irity Instrument is Ic:nt to Burrowc::r tu acquire
title tu the Property, this St::curity Instrum..::nl :-;hall he a purdm.'ie muney mort 'age:.
23. Inkrest Rute After Judgment. Borrowc:r agrc:c:s that the: il1lc:rt:st att: payahle: aftt:r a juJgme:nt is t:ntt:rc:u un the
Nute: or in an action of ll1ort~agc: forc:closure: shall he the: ral~ ,myahle: from ti He: tu time: unut:r the: Note:.
24. Riders tu this Security Instrument. If une: ur more: riJt:fs ar~ e:XC:L:U J by Borrowe:r anJ rt:corucu tu~eth~r with this
Se:curity Instrument, tht: covc:nants ano agre~l11c:nts of Cl.lL:h sllch riue:r sh II be: im.:orpor'd.te:u into aou shall am~nd ami
sllppl~me:nt the cove:nants anti agreC:l1lents uf this Sel.:urity Instrume:nt as if the: riucr(s) we:r~ a part of this St:curity
Instrul11t::nt. IChe:ck appliL:able hux(c=s) I
D Condominiulll RiJc:r
D Plannt: Unit Dt:vdupmcnt Riucr
D GraUUl.tt..::u Paymc:nt Riuc:r
o Growi,g Elfuity RiJ~r
D Non-Owner OCCllpl.UlI.:Y Riu..:r D AJjusta Ie: Rate: RiJe:r
o Olhe" ISpecifYI
Bood405 PAGE .451
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BY SIGNING BELOW. Borrow~r accepts ,Inti agrees to th~ terrns:and covenants contained in this Security lnstnlment
and in any rider(s) executed hy Borrower and re orded with it.
/
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(Seal)
.8nrrowcr
(Seal)
. Borrower
(Seal)
- Borrower
(Seal)
. Borrower
IS!, It.:'~ Ild..\\' 'l1li" r .in.~ 1:,,1' ^d;n.,wl<,tfr;l1ll"lltl
STATE OF PENNSYLVANIA
countYOf~
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On this ~ day of
Puhlic in and for said County. persona"
me. the undersigned. a Notary
Witness my hand and ofticial seal.
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My Coml11ission expires:
Notarial Seal pu lie
Deborah 0, Barnhart, NO~IX nty
~ower paxl1 o~onTWPx'pI' ~:~an. 2. 001
My Comm os' I el
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Exhibit "A"
.
ALL THAT CERTAIN piece or parcel of land, situate in the Silver Spring Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on th western line of Locust Lane, at the corner of Lot No. 7I as
shown on the hereinafter mentioned Ian of lots; thence along the line of said Lot No. 71, south 56
degrees 12 minutes west, 150 feet to point in the center line of a 20 foot utility easement; thence
along the center line of said utility asement (other land of George W. Walker and Mary Alice
Walker, his wife), north 33 degrees 4 minutes west, 71 feet to a point on the southeastern line of
Hillcrest Drive, as shown on the here 'nafter mentioned plan of lots; thence along the southeastern
line of Hillcrest Drive, north 34 degr es 24 minutes east, 161.55 feet (erroneously set forth in prior
recorded deed as 124.63 feet) to a po'nt on the western line of Locust Lane aforesaid;; thence along
the western line of Locust Lane, sout 33 degrees 48 minutes east, 131.00 feet (erroneously set forth
in prior recorded deed as 95.08 feet) to a point at the corner of Lot No, 7I aforesaid, the place of
BEGINNING.
BEING Lot No. 70 in the plan of\ots of George W. Walker and Mary Alice Walker, his wife,
known as "White Birch Farms Devel pment", Tract No.2, as recorded in the Recorder's Office in
and for Cumberland County in Plan ook 17, Page 61.
BEING THE SAME PREMIS S that Edward E. Stansfield and Marianne L. Stansfield, hfw,
by their deed dated October 1, 1996 and recorded October 15, 1996 by the Recorder of Deeds in
and for Dauphin County in Record B ok 147, Page 535, granted and conveyed unto Gary P. Hanlin
and Kathleen E. Hanlin, h/w G ORS herein.
State of pennSylvania}
County of Cumberland 88
Rac. ad in~the office for, the recordlnll of Deeds
eCI I and f r ~Iand Count'{. "-.f '4
In 80 ~v(~_page~ /.p
wiln,e y h~nd Adl I of offj . D. "'l
CarlisI . IS I 11" d 9l.!
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BDoK1405r4GE 45.3
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VERlFICATION
IW~ !- ~!:mMJE~ereby states that he is ASSIST ANT SECRETARY of
CHASE MANHATTAN MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in
this matter, that he 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 knowledge, infonnation and
belief. The undersigned understands that this statement is made subject to the penalties of 18 pa; C.S, Sec.
4904 relating to unsworn falsification to authorities,
\:Yo-- 01, 0- 0 ~ ,
f?'(AALF;E~
;\SS1STAIIT SHJIETAIi'\'
DATE:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Mortgage Company. West, f/k/a Mellon Mortgage Company, 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 Shirley A. Dickey located at 6 Locust
Lane, Mechanicsburg, P A 17055 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF SHIRLEY A. DICKEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN SILVER SPRING
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 6 LOCUST LANE, MECHANICS BURG,
P A 17055. DBV 164, PAGE 686, AND PARCEL #38-14-0848-046.
r i. "'" 'e
~~:;'f-y;~;~:,j;_;~~,,-
,
1, The name and address of the owner or reputed owner:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 17055
2. The name and address of the defendant in the judgment:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 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 Mortgage Company - West,
f/k/a Mellon Mortgage Company
[PLAINTIFF]
4, The name and address of the last record holder of every mortgage of record:
Chase Mortgage Company - West,
f/k/a Mellon Mortgage Company
[PLAINTIFF]
American General Finance, Inc.
3120 Parkview Lane
Harrisburg, PA 17111
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, P A 17013
PA Dept. Of Revenue
Bureau ofIndividual Taxes
Inheritance Tax Division
Dept. 280601
Harrisburg, PA 17128-0601
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'-'~ , mll'J, = n'" "~"~
1-
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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. 94904 relating to unswom falsification to authorities.
GRENEN & BIRSIC, P.e.
BY:~
Kristi . F a1ist, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this 'l#\ day of \ li ( 111\
;Q f:!,r H fJ ~ ()tl~
Notary Public ~
,2001.
Notanal seNal \ary public
G Blazina, 0 ti
Re~~;~rgh, A~~grr:~~~n~~, 2003
My commission "ot Nolanes
her Pennsylvania ASSQC\auon
Mem" ,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MORTGAGE COMPANY-WEST,
f/klll MELLON MORTGAGE COMPANY,
CIVIL DIVISION
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.10L ET. SEO.
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. Faust, 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 II of the National Housing Act (12 U.s.C. ~~1701-1715z-18) [35 P.S.
~ 1680.40 I C( a)(3)], Additionally, Plaintiff was not required to send Defendant written notice of Plain tift's
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 Defendant is not a "residential mortgage debtor" as defined in 41 P,S. ~101.
~
SWORN TO AND SUBSCRIBED BEFORE
ME THIS rtlDA Y OF Ju.Jv-..
/"l
,; ~a
/~)QUfl ., blIj~(;[;L{'--
Notary Public
,2001.
Notarial Seal
Rebecca G, Blazina, Notary Public
Pittsburgh, Allegheny COunty
My Commission Expires June 2, 2003
Member, Pennsylvania Association of Notaries
"""'-~ ~llll!", ~."~ ~',~
I~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
flk/a MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYL VANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that the owner of the property located at 6 Locust Lane,
Mechanicsburg, Pennsylvania 17055 is Defendant, who resides at 6 Locust Lane, Mechanicsburg,
Pennsylvania 17055, to the best of her information, knowledge and belief.
~.@<{~
SWORN TO AND SUBSCRIBED BEFORE
METHIS~DAYOF dLU1Q
~ I ~il' .
/ t ').1 ~ Ll, (J.;~VUL.-
f Notary Public
,2001.
Notarial Seal
Rebecca G, I3lazina, Notary Public
Pittsburgh, Allegheny County
My CommlsSlo~ Expires June 2, 2003
Member, PennsylVania AsSOCIation 01 Notaries
'"'.."__~l ~,~_
IlIIIII ~
'.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 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 at the
Cumberland County Courthouse
Commissioners Hearing Room, 2nd Floor
1 Courthouse Square
Carlisle, PA 17013
on Wednesday, September 5, 2001 at 10:00 A.M., the following described real estate, of which
Shirley A. Dickey is the owner or reputed owner:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF SHIRLEY A. DICKEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN SILVER SPRING
TWP" CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 6 LOCUST LANE, MECHANICSBURG,
PA 17055. DBV 164, PAGE 686, AND PARCEL #38-14-0848-046.
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The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Mortgage Company-West,
f/k/a Mellon Mortgage Company,
Plaintiff,
vs.
Shirley A. Dickey,
Defendant,
at Execution Number 01-1994 in the amount of $69,479.70.
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
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
TELEPHONE: (717) 240-6200
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary.
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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
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.
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By:v' , ,
Kri . eM. Faust, Esquire
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
f
PRAECIPE FOR WRIT OF EXECUTION
vs.
( ) Confessed Judgment
( x ) Other
File No. 01-1994 CIVIL
Amount Due $67,938.99
Caption:
Chase Mortgage Company - West,
f/k/a Mellon Mortgage Company
$ 1,540.71 (5/11/01 to Sale)
Shirley A. Dickey
Interest
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
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
for debt, interest and costs, upon the following described property of the defendant(s)
Single-family Dwelling at 6 Locust Lane, Mechanicsburg, PA 17055
County,
PLEASE SEE ATTACHED LEGAL 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).
o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date
y /7 1M
Signature:
Print Name:
Address:
~~
Kr~stine M. Faust
Grenen & Birslc, P.C.
One Gate'.'.lay Center, Nine West
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: (412) 281-7650
Supreme Court 10 No.: 77991
(over)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MORTGAGE COMPANY-WEST,
f/kla MELLON MORTGAGE COMPANY,
CIVIL DIVISION
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
LONG FORM DESCRIPTION
ALL that certain lot of ground situate in the Township of Silver Spring, County of Cumberland and
State of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the western line of Locust Lane, at the comer of Lot No. 71 as shown in
the hereinafter mentioned plan oflots; thence along the line of said Lot No. 71, south 56 degrees 12 minutes
west, 150 feet to a point in the center line ofa 20 foot utility easement; thence along the center line of said
utility easement (other land of George W, Walker and Mary Alice Walker, his wife), north 33 degrees 48
minutes west, 71 feet to a point on the southeastern line of Hillcrest Drive, as shown in the hereinafter
mentioned plan of lots; thence along the southeastern line of Hillcrest Drive, north 34 degrees 24 minutes
east, 161.55 feet to a point on the western line of Locust Lane aforesaid; thence along the western line of
Locust Lane, south 33 degrees 48 minutes east, 131,00 feet to a point at the comer of Lot No. 71 aforesaid,
the place of beginning.
BEING Lot No. 70 in the plan oflots of George W, Walker and Mary Alice Walker, his wife, known
as "White Birch Farms Development," Tract No.2, as recorded in the Recorder's Office in and for
Cumberland County in Plan Book 17, Page 61,
UNDER and SUBJECT to all and any easements and restrictions as set forth in prior record.
BEING the same premises which Kathleen E. Hanlin, by Deed dated September 9, 1997 and
recorded in the Office ofthe Recorder of Deeds of Cumberland County on September 17, 1997, in Deed
Book Volume 164, Page 686, granted and conveyed unto Shirley A. Dickey,
GRENEN & BIRSIC, P.C.
BY:~
Kristme M. Faust, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, P A 15222
(412) 281-7650
Parcel No. 38-14-0848-046
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
flk/a MELLON MORTGAGE COMPANY,
Plaintiff,
vs.
SHIRLEY A, DICKEY,
Defendant.
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)
) NO.: 01-1994 CIVIL
)
) ISSUE NUMBER:
)
) TYPE OF PLEADING:
) Pa. R.C.P. RULE 3129.2(c)(2)
) LIENHOLDER AFFIDAVIT OF
) SERVICE
)
) CODE-
)
) FILED ON BEHALF OF PLAINTIFF:
)
) Chase Mortgage Company-West, fi'k/a
) Mellon Mortgage Company
)
) COUNSEL OF RECORD FOR THIS
) PARTY:
)
) Kristine M. Faust, Esquire
) Pa. I.D, # 77991
)
) GRENEN & BIRSIC, P.C.
) One Gateway Center, Nine West
) Pittsburgh, P A 15222
) (412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs,
SHIRLEY A, DICKEY,
Defendant.
Pa. R.C.P, RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Faust, Attorney for Plaintiff, Chase Mortgage Company-West, flk/aMellon
Mortgage Company, 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 Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows:
1. By letters dated June 12,2001, undersigned counsel served all persons (other than
the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs 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 Pursuantto Rule 3129.1
and Certificate of Mailing and any letters, if returned as of this date, are marked Exhibit "A",
attached hereto, and made a part hereof.
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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:
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Kristine M, Faust, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me this ?+hday OChA q IA 1+ ,2001.
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Reb Notarial Seal
Pros G, Blazina. Notary Public
My CO:bu, rgh, Allegheny County
In sslon Expires June 2 2003
Msmbe' Pe .
, nnsylvanla ASSOCIation Of NOIaIIes
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/kla MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Mortgage Company-West, f/kla Mellon Mortgage Company, 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 Shirley A. Dickey located at 6 Locust
Lane, Mechanicsburg, P A 17055 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF SHIRLEY A. DICKEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN SILVER SPRING
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 6 LOCUST LANE, MECHANICSBURG,
PA 17055. DBV 164, PAGE 686, AND PARCEL #38-14-0848-046.
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1. The name and address of the owner or reputed owner:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 17055
2. The name and address of the defendant in the judgment:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 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 Mortgage Company - West,
f/k!a Mellon Mortgage Company
[PLAINTIFF]
4. The name and address of the last record holder of every mortgage of record:
Chase Mortgage Company - West,
f/k!a Mellon Mortgage Company
[PLAINTIFF]
American General Finance, Inc.
3120 Parkview Lane
Harrisburg, P A 17111
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 ofIndividual Taxes
Inheritance Tax Division
Dept. 280601
Harrisburg, PA 17128-0601
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
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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. 94904 relating to unsworn falsification to authorities.
GRENEN & BIRSIC, P.C.
BY:<~~~
Kristi '. Faust, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
~: this ~-H\ day of \J I \ /, \ (
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Notary Public ,
,2001.
Nolanal seal ry public
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One piece of ordinary mail addressed to:
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, ______________________________________________________________________________Ilecorderof
Deeds in and for said County and State do 'hereby certify that the Sheriff's need in which ________________
Chase Mortgage co-West fka Mellon Mtg Co .
____________________________________________________________________________________ ~thegrantee
the same having been sold to said grantee on the ______:_:~_____________________________________ day of
Septembe'r
________________________________________ A. n., ; _Q!__, under and by virtue of a wriL_____________
. 11th
Execut10n .
_________________________________________ _______ ISSued on the __________ _ __ ___ __ ____ ____ __ __ _______
day of ___________3.!!.'.!~_________ A. D.,
Civil
------------------------------., -- ----- --- -- --- - - -- ----___ --_______ ____ ____ _______ Tenn, :
1994 Chase Mtg Co-West fka Mellom Mtg Co
Number ______________, at the suit of _______________________________________________________________
01 '
-----, out of the Court of Cornman Pleas of said County as of
01
-------------------------__________agau.st_________~~~:_~:~_~__~~:~_::________________________ ~
duly recorded in Sheriff'. nero Book No. ______!_~~__, Page ___~=:!_____.
IN TESTIMONY WHEIlEOF, I have hereunto
set my hand and seal of said office this __1:______ day
of -.t2~~c______________ A. D., ~L
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Ilecorder of Deeds
llteonleI oI1leed5. CuIIlberlllld County. CItlls1t, ~
&Iv CGmmlssion ElpiNllht filii Mot1dQ 01_ 200f
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Chase Mortgage Company-West
Flk/a Mellon Mortgage Company
VS
Shirley A. Dickey
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-1994 Civil Term
Robert 1. Fink, Sr., Deputy Sheriff, who being duly sworn according to law,
states on July 09, 2001 at 11:10 o'clock A.M., EDST, he served a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of
the within named defendants, to wit: Shirley A. Dickey, by making known unto Shirley
Dickey, at 6 South Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania
17055 its contents, and at the same time handing to her personally the said true and
attested copy of the same.
Shannon Sunday, Deputy Sheriff, who being duly sworn according to law, states
on July 02, 2001 at 10:46 A.M., EDST, she posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action upon the property
ofShirley A. Dickey, located at 6 south Locust Lane, Mechanicsburg, Cumberland
County, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the within Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency of the action by regular mail, to one of the
within named defendants, to wit: Shirley A. Dickey, at her last known address of 6
Locust Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of July
13,2001 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Pennsylvania, on September 5, 2001 at 10:00 o'clock A.M., E.D.S.T., and sold the same
for the sum of$1.00 tb Attorney Steve Feino~ (for .f\ttorney Kristine Faust) for Chase
Mortgage Company-West, flk/a Mellon Mortgage Company. It being highest bid and best
price received for the same, Chase Mortgage Company- West, flk/a Mellon Mortgage
Company of3415 Vision Drive, Columbus OH 43219, being the buyer in this execution,
.
paid SheriffR. Thomas Kline the sum of $822.69, it being costs.
Sheriff's Costs:
Docketing $ 30.00
Poundage 16.13
Posting Handbills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1. 00
Mileage 11.70
Certified Mail 1. 70
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Surcharge
Legal Search
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriffs Deed
Sworn and subscribed to before me
ThisMdayof ~
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15.00
20.00
316.55
262.95
25.66
25.00
26.50
$822.69 paid by attorney
09-26-01
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So Answers:
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.
R. Thomas Kline, Sheriff
BY~~-S~
Re Estate Deputy
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
flkla MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Mortgage Company-West, flkla Mellon Mortgage Company, 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 Shirley A. Dickey located at 6 Locust
Lane, Mechanicsburg, P A 17055 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF SHIRLEY A. DICKEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN SILVER SPRING
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 6 LOCUST LANE, MECHANICSBURG,
P A 17055. DBV 164, PAGE 686, AND PARCEL #38-14-0848-046.
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1. The name and address of the owner or reputed owner:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, PA 17055
2. The name and address of the defendant in the judgment:
Shirley A. Dickey
6 Locust Lane
Mechanicsburg, P A 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 Mortgage Company - West,
f/kla Mellon Mortgage Company
[PLAINTIFF]
4. The name and address of the last record holder of every mortgage ofrecord:
Chase Mortgage Company - West,
f/kla Mellon Mortgage Company
{PLAINTIFF]
American General Finance, Inc.
3120 Parkview Lane
Harrisburg, P A 17111
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, P A 17013
P A Dept. Of Revenue
Bureau ofIndividual Taxes
Inheritance Tax Division
Dept. 280601
Harrisburg, P A 17128-0601
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
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I veritY 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, S4904 relating to unsworn falsification to authorities.
GRENEN & BIRSIC, P.C.
BY:~~~
Kristi . Faust, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
methis ~+h dayofjl \ HZ
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/d<i bu I' (L YL--13t (j t(;~[V
Notary Public ,
, 2001.
Notarial sa~~tary Public
Rebecca G, BlazIna. County
Pi\lsburg~, A~~8rr:~YJuna 2, 2003
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MORTGAGE COMPANY-WEST,
f/k/a MELLON MORTGAGE COMPANY,
NO.: 01-1994 CIVIL
Plaintiff,
vs,
SHIRLEY A. DICKEY,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Shirley A. Dickey
6 Locust Lane
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 at the
Cumberland County Courthouse
Commissioners Hearing Room, 2nd Floor
I Courthouse Square
Carlisle, PA 17013
on Wednesday, September 5, 2001 at 10:00 A.M., the following described real estate, of which
Shirley A. Dickey is the owner or reputed owner:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF SHIRLEY A. DICKEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN SIL VERSPRING
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 6 LOCUST LANE, MECHANICSBURG,
PA 17055. DBV 164, PAGE 686, AND PARCEL #38-14-0848-046.
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The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Mortgage Company-West,
f/kla Mellon Mortgage Company,
Plaintiff,
vs.
Shirley A. Dickey,
Defendant,
at Execution Number 01-1994 in the amount of $69,479.70.
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 Sheriffno 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
4th Floor, Cumberland County Courtho\llse
Carlisle, PA 17013
TELEPHONE: (717) 240-6200
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In
of{ler to exercise those rights, prompt action on your part is necessary.
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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 rightto 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 rightto 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 RlGHT TO HAVE THE SHERlFF'S SALE SET ASIDE
IF THE PROPERTY IS SOLD FOR A GROSSL Y INADEQUATE PRlCE OR, IF THERE ARE
DEFECTS IN THE SHERlFF'S SALE. TO EXERCISE THIS RlGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERlFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERlFF WILL DELIVER THE DEED
IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (1 0) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRlBUTION IS FILED IN THE OFFICE OF THE
SHERlFF.
GRENEN & BIRSIC, P.C.
~~
By:'J " ~
Kri . eM. Faust, EsqUire
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MORTGAGE COMPANY-WEST,
flk/a MELLON MORTGAGE COMPANY,
CIVIL DIVISION
NO.: 01-1994 CIVIL
Plaintiff,
vs.
SHIRLEY A. DICKEY,
Defendant.
LONG FORM DESCRlPTION
ALL that certain lot of ground situate in the Township of Silver Spring, County of Cumberland and
State of Pennsylvania, bounded and described as follows, to wit
BEGINNING at a point on the western line of Locust Lane, at the corner of Lot No. 71 as shown in
the hereinafter mentioned plan oflots; thence along the line of said Lot No. 71, south 56 degrees 12 minutes
west, 150 feet to a point in the center line of a 20 foot utility easement; thence along the center line of said
utility easement (other land of George W. Walker and Mary Alice Walker, his wife), north 33 degrees 48
minutes west, 71 feet to a point on the southeastern line of Hillcrest Drive, as shown in the hereinafter
mentioned plan of lots; thence along the southeastern line of Hillcrest Drive, north 34 degrees 24 minutes
east, 161.55 feet to a point on the western line of Locust Lane aforesaid; thence along the western line of
Locust Lane, south 33 degrees 48 minutes east, 131.00 feet to a point at the corner of Lot No. 71 aforesaid,
the place of beginning.
BEING LotNo. 7{) in the plan oflots of George W. Walker and Mary Alice Walker, his wife, known
as "White Birch Fanns Development," Tract No.2, as recorded in the Recorder's Office in and for
Cumberland County in Plan Book 17, Page 61.
UNDER and SUBJECT to all and any easements and restrictions as set forth in prior record.
BEING the same premises which Kathleen E. Hanlin, by Deed dated September 9, 1997 and
recorded in the Office of the Recorder of Deeds of Cum her land County on September 17, 1997, in Deed
Book Volume 164, Page 686, granted and conveyed unto Shirley A. Dickey.
GRENEN & BIRSIC, P.C.
BY:~~
Kristine M. Faust, Esqurre
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh,PA 15222
(412) 281-7650
Parcel No. 38-14-0848-046
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF 'pJ::NIlJS'lLVANIA)
COUNlY OF CUMBEI1Il;~No} .' "
NO. 01-1994 CIVIL 15X TERM
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNlY:
To satisfy the debt, interest and costs due Chase Mortqage Canpany - West, f/k/a Mellon
Mortgaqe Canpany PLAINTlFF(S)
from Shirley A. Dickey. 6 Locust Lane, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are als$) directed to attach the property of the defendant(s) not levied upon in the possession of
, GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof; .
(3) If property of 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 $67.938.99 L.L. $.50
Interest $1 '>40 71 ('>/l1f01 to !,;",1,,) Due Prothy S1.00
.
Atty's Comm % Other Costs
Atty Paid
Plainmt Paid
S106.20
Date:
June 11, 2001
Curtis R. Long
Prothonotary, Civil Division
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.a~ 0 [] 7J>>/lA'lt,;--
Deputy
REQUESTING PARlY:
Name
Address:
Kristine M. Faust!, Esq.
Grenen ~ elrS1C, p.c.
()(:}e <;at~~.~~/ r'e-n+~r,~ N;'nlO W,::u::d-
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: 412-281-7650
Supreme Court ID No. 77991
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REAL ESTATE SALE No. 3~
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un JlM'l.I. /5,JOOI the sheriff levied ~pon theaerenoank
Interest in the real property situated in --0~~ ~
Dumberland County,Pa., known and numberedas: (p ;(fXWJl:dtL~
fJJ.t.t.It4l1'~ and more fully described on Exhibit' 'A" filed wit~
this writ and by this reference incorporated herein,
'18te: JLI-^L I~ .)o/)} By: ~~ C/a..h...-._
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REAL ESTATE SALE NO. IY1
Writ No. 2001-1994 Civil
Chase Mortgage Company-West,
flkl a Mellon Mortgage Company
vs,
Shirley A. Dickey
Arty.: Krtstine M. Faust
WNG FORM DESCRIPTION
ALL that certain lot of ground
situate in the Township of Silver
Spring. Connty of Cwnberland and
State of Pennsylvania. bounded and
described as follows, to wit:
BEGINNING at a point on the
western line of Locust Lane. at the
corner of Lot No. 71 as shown in the
hereinafter mentioned plan of lots;
thence along the line of said Lot No.
71. south 56 degrees 12 JIIinutes
west. 150 feet to a point in the cen-
ter line of.a 20 foot utility easement:
thence along the center line of said
utility easement (other land of
George W, Walker and Mary Allee
Walker. his wife), north 33 degrees
48 minutes west. 71 feet to a point
on the southeastern line of Hillcrest
Drive. as shown lri tlie hereinafter
mentioned plan of lots; thence along
the southeastern line of Hillcrest
Drive. north 34 degrees 24 minutes
east. 161.55 feet to a point on the
western line of Locust Lane afore~
said; thence along the western line
of Locust Lane. south 33 degrees
48 minutes east, 131. 00 feet to a
point at the comer of Lot No. 71
aforesaid. the place of begi11nlng,
BEING Lot No, 70 in the plan of
lots of George W. Walker and Mary
Alice Walker, his wife, known as
*White Birch Farms Development,"
Tract No.2. as recorded in the Re-
corder's Office in and for Cumber-
land County in Plan Book 17. Page
61.
UNDER and SUBJECT to all and
any easements and restrictions as
set forth in prior record.
BEING the same premises wWch
Kathleen E, Hanlin. by Deed dated
September 9, 1997 and recorded
in the Office of the Recorder of
Deeds of Cumberland County on
September 17. 1997. in Deed Book
Volwne 164. Page 686. granted and
conveyed nnto Shirley A. Dickey,
Parcel No. 38-14-0848-046,
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regnlarly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
JULY 20, 27, AUGUST 3, 2001
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.
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
~;.
LOIS E. SNYDER, -'PublIc
CarlisleBoio. ~ County
My CommluIon Ellphs MarcI15. 2005
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11 -'1
, , REAL esTATE SAtE No. '1fT,
"."." Wr.it.Nq.. :?001~1:994
. Civli Term
. . ., Chase Mortgage
',,' ,,<;ompaflY-West, ,IMa
!.lellon Mortgage CompaflY
. vs .
o,Shi,n\3:Y A. Dickey
Atty::KrlstlneM, Faust
. . . .OESvR~PT10N
ALL that cerrain i~f of ground si,tualC in the
:,.To}'iU~hip. oL .s~J~r. Snt:ing, Co.unl,y- of
:Cu:m\)(;dand, (,l,att:: of Penni'y1vunia,
"bO.Olldoo 'jlid dcSl."ified 3S follows, to wit:
. "BEGINNiNG (!ta pOlnt on the western line
"-o.LLocuSl Lanc;'at the comer of Lot No. 7\
.;a.<;:'ShOWrl in the 'nt:reinafter mentioned plan
":nfl.9ls; thence '3.long the line of said Lot No.
: :,:'7.l...".wuth S6.dc,grcc~ r::'.mlnlit~w~st, 150
'"fed iO"3 pOlnr in the Ct.-'1lter line of a 2O-foot
,o,tility ea.-;cm<;..'tlt; thence along the ce!'lIer
, .,Hne of ;,aId utillt)' easement (other land of
:G-wrg.e w, W:ilkcr artd Mary Alice \\-all..er.
''hb wlfc1, norlll 33 degree!> .~t; minute" v.e>>t,
, :.ry 1 ket to a point on tht: ;,(lutnea....tJ:m 1hlC 1]1
Hillcrest Driye. as shown in the hdcinafter
.jTibwkrncd phI" of. iot\: tncrice a\oog. the
, :.sootbe<lSlcm Hne o~ Hillcre~t Drive... north
.~ de1!r'ecs 24 .minutl.=~ ca~t, 161.55 j\.'Ct 10 a
poini~oll-th<i.w~tl"i'n line of Locust Lane
" "s.fore.'<iiu; thence a:long the \\:e"tern hne of
, ,Locu~\ Lane. south 33 degrees .\.~ minut~
, :ea.o;l., DUll) feet t~) a pomt"at the C(lI"er (If
':I..l.lt" 'No. 71 : aforesaid.. the place (If
BEGINNING.
. HblNG ult No. 70 In the pian 01' lot!; of
..:pct1rge w.. \Val'Ker ,1I,1I! Mary Alice Walker,.
..,ht:>. wife, kn<w,n a~ "\Vhitc Birch Fanns
',pevdopment;' Tract No.2, as recorded in
'""the . Rt.=corocr'i Office in <lnd for
".Cumbcrland Coullty In pian Book 11. Page
,61.
UNDER. AND 5.JBJECT to <Iii and any
e;ls/..'1ll(..'T1ts anJ fl;$trictlons as sef forth in
''Pn\irrecOfd. .
BE;lNG tbe ~ame' premlse.<; . which Kllthlecn
E_ Hamlin. by ~d dated St'plt:,mber 9,
1997 ".md rec(ltded IU the Oftiee- 11( the
'R.ecorder ,of Del'.(\" 01' Cumberland County
()n St-p[o.;:mbt."'f 17, 1997, In [xed Bo()\...
'Voluml.' 1M, P'Jgi: 6l:'.6. granted ::.nd
:O;;OlWe-yed uriCO Shirk) A.. Dkk.:}'
p~l No. 3S.14"08-l,,'~,-(AA.
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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
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co" a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot,News and The Sunday Patriot, News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot,News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily andlor Sundayl Metro editions which appeared on the 24th and 31 st day{s) of July and the 7th
day(s) of August 2001. 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 MisZlaneous Book "M",
';:~~;;:: ;.;;;;;~~;;;;:;;;;~~~;~;;;~~;;;;:~
S ALE #37 Nota~al Seal
Tony L. Ru...II, Notary Pu
Harrlsbuog. Dauphin Coun
My Coinllllsslon Ellplros June 6. 2002 NO RY PUBLIC
Mambal, Pennsylvania Assoclation at NoWIl,ocommission expires June, 6, 2002
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA, 17013
\
Statement of Advertising Costs
To THE PATRIOT, NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
261.45
1.50
262.95
Publisher's Receipt for Advertising Cost
The Patriot News Co" publisher of The Patriot-News and The Sundav 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....................................................................
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