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HomeMy WebLinkAbout01-2907 FX '.. , FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 ';) ';1>1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE, COLUMBUS, OH 43219-6009 TERM Plaintiff v. NO. CJI- ;lift) 7 b;d CUMBERLAND COUNTY LILLIAN E. BUCKLES CHARLES A. BUCKLES, III 424 BURGNER ROAD, CARLISLE, PA 17013 Defendant( s) C'TVTT. AC'TION - T.AW C'OMPT .ATNT TN MORTGAGF. FORF.C'T .OSTTRF. NOTIC'F. "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #: 1947067354 1-"--' ")" ,;*. --I '." 'r~ .,-, "".. ".~,~ w ~ 1. Plaintiff is: CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISIONDRNE, COLUMBUS, OH 43219-6009 2. The name(s) and last known addressees) of the Defendant(s) are: LILLIAN E. BUCKLES CHARLES A. BUCKLES, ill 424 BURGNER ROAD, CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNION MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1505, Page 694. By Assignment of Mortgage Recorded 9/16/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 624, Page 1057. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ;C,,__ __ _ I ",', ~'o "1'- I "'. ~ '~ '.f"" ,~ "~ ,_ n, ,"" " . - ; . 6. The following amounts are due on the mortgage: Principal Balance Interest 9/1/00 through 5/1/0 I (per Diem $13 .23) Attorney's Fees Cumulative Late Charges 12/11/98 to 5/1/01 Cost of Suit and Title Search Subtotal $67,796.38 3,214.89 3,389.00 146.46 55QJ]Q $75,096.73 Escrow Credit Deficit Subtotal 0.00 5l'lA3. !I; 'il<) 41 TOTAL $75,616.16 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $75,616.16, together with interest from 5/1/01 at the rate of$13.23 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ]-~~ /~/ Fnmk F~rlenn~n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "0' "I.~,,^ ,n.., ""'"'~'. ._" " " -,. I,r, ,<- ' . ---<'l~ '- . A.LL THAT CERTAIN tract of land situate in Lowc::r FrankIeI'd Township, Cumberland County, Pennsylvania., and described as fonows: BEGINNING at: a point at the northem line of the public road leading from Burgner's Bridge to Heishman's Bridge at line of property now or for:rnerly of David R. Black; thence by said property, North 09 degrees East, 500 feet: to a point; thence by property no'VJ or formerly of James W. Wogan, South 85.1/4 degrees East, 208.5 leet to a point: thence by line of property now or fonner1y of Martha E. Nickel. South 08 degrees 57 minutes West. 500 fc;:et to a point on the northern line of the said public road; thc:nce by the northern line ot said public road, North. 85 degrees West, 209 feet to the place: of BEGINNING. CONTAINING 2.396 acres. H.fo,VING..T1::IEEEON ,ERE~ED-a'one-'st.ory fr'anle dwelling house lcnown:and numbered: as- 42'4~" ~:,:::B\ji"gner Roa.d, Carlisle. ?enns!lv.~a~ < -!!J 'I' , VF.RIFlC A TION CHRISTOPHER STUMP hereby states that he/she is 4SSISTMsmnm of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take. this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her lmowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~/ DATE: s/q/P/ CHRISTOPHER STUMP ASSISTAIIT SEcmlD /-,,, , r I '-" ~ ,", ,,'" - , < ~~,~ ;11 ~ " w ,~ -.. 0 :: ~ ~ it \ ) ~ \ , ~ ~ ~, ~ ~, ~~ ~ \~ _ .S_O' (") c , ~~~'- zr-.-., ':0;:/ ~~~:-~; ?-,-, ~c'_ L::'. ~ -~,~.' , c> -:r: --.- ~ (") :-~ t -':';: ',j ""' ..,.- ",-,- ::_:\\,r: ~:-.:-\ 'G-' ~ _JII~'''!~ ,. _~~~v."~._~ "."'<. .'." 111':" ,~ !f.,l!lINffli";~"'~I~"'f;''I'.Fm;-.r,q>{if''';R'''''\'''t<J''''il;\li'1~~fflIW~~ifWiWij<'1-~~~ ~. " SHERIFF'S RETURN - REGULAR CASE NO: 2001-02907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS BUCKLES LILLIAN E ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BUCKLES LILLIAN E the DEFENDANT , at 0017:51 HOURS, on the 25th day of May , 2001 at 424 BURGNER ROAD CARLISLE, PA 17013 by handing to CHARLES A. BUCKLES 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 4.34 .00 10.00 .00 32.34 SO;?~~t R. Thomas Kline OS/29/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: C0~ ~. \61L me this l , ; 1.__ L '/.w..4-- ~ I 1] , ) , l... ~.~ CL Ihdf.,/ ~. 7 othonotary . ). ,,12 day of Deputy Sheriff A.D. ; \~, , ,1 , ' ~ f'" 'r" ,_ r "- CASE NO: 2001-02907 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS BUCKLES LILLIAN E ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BUCKLES III CHARLES A the DEFENDANT , at 0017:51 HOURS, on the 25th day of May , 2001 at 424 BURGNER ROAD CARLISLE, PA 17013 by handing to CHARLES A. BUCKLES 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 6.00 .00 .00 10.00 .00 16.00 So Answers: f!"~ vt:~t R. Thomas Kline OS/29/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: \Jcu.Jn J k Deputy Sheriff me this ""--- 2.(" - day of (l"d ;we/ A.D. fQ "'-'-.,(] ~. 4. ~thonotary W 'J'l'."~ _C_,..' ,--, ,,, ." '" . ~~_~r'. . I - . FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PAc 19103-1814 (215) 563-7000 CHASE MANHATTAN MOTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DIVISION VS. : NO, 01-2907 CIVIL TERM LILLIAN E. BUCKLES CHARLES A. BUCKLES,III 424 BURGNER ROAD CARLISLE, P A 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against LILLIAN E. BUCKLES and CHARLES A. BUCKLES,III, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 5/1/01 TO 6/26/01 $75,616,16 $754.11 TOTAL $76,370.27 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. I. J J\0J1 K :red.9JYYlM FRANK FEDERMAN, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED. . ~ DATE: .J/.I.I"'~ ;J'7:QO:>/ (1Ai~) ). . PRO PRO **THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TInS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATI'EMPT TO COLLECf A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 1 ' -~..-~..~- '1'-' " "'. ~1~~' - ~ , .-,~'"- FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563 -7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN CORPORATION MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III CUMBERLAND COUNTY NO. 01-2907 Defendant(s) TO: LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE,PA17013 DATE OF NOTICE: JUNE 15,2001 FILE C~-- THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff r" '..- , - , '-"I." ,,' , FEDERMAN AND PHELAN ~ Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563 -7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION plaintiff vs. CUMBERLAND COUNTY LILLIAN E. BUCKLES CHARLES A. BUCKLES, III :NO.01-2907 Defendant TO: CHARLES A. BUCKLES, III 424 BURGNER ROAD CARLISLE,PA17013 FILE COP" , DATE OF NOTICE: JUNE 15.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff T4,,,,",,. '~"r~ , --, . "I . ", -, U_, ~ \ '~.""" --~1 FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Attorney for Plaintiff : CUMBERLAND COUNTY : Court of Commou Pleas Plaintiff : CIVIL DMSION vs. : NO. 01-2907 CIVIL TERM LILLIAN E, BUCKLES CHARLES A, BUCKLES,III Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUlRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant LILLIAN E. BUCKLES is over 18 years of age and resides at 424 BURGNER ROAD, CARLISLE, P A 17013, ( c) that defendant CHARLES A. BUCKLES,III is over 18 years of age, and resides at 424 BURGNER ROAD, CARLISLE, P A 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to \Ulsworn falsification to authorities. :JhoJ'JK \,1 Q dormail FRANK FEDERMAN Attorney for Plaintiff , ,- ~' - -~ ^, ~.- '" I '1',rl" (Rule of Civil Procedure No. 236 - Revised) CHASE MANHATTAN MOTGAGE CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 01-2907 CIVIL TERM LILLIAN E, BUCKLES CHARLES A, BUCKLES,III Defendant(s) Notice is given that a Judgment in the. above capti~ned matter has been entered against you on JUNE ~7 ,2000. I......By4~ o.P/P-)'JA/'Jt1..IDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ." 'i':~ "" ,".., 01.. ,'" ,-- ", I ~ i i , ,< ." . -- ,-~ ~U~,,~_" t (0 (J ~ fl ~ B 0 '--"~ r c; ,- -cf;~ - ~ 92!~' ' - ......... ~ -..." " ~ ~ .-(.-_l -~ (I) ,~ --<: "' IV ...t:: w :.:~:: c - .0 ...J $ ~;~ ~ C> ()' r'-..J ,-- '.J ---I -< (n _.~__Arnfil''''~_~~iQ~,!lltit~!I;~~~~jm,.~,"';v,'",'':''"'el'""''''-'!''''l;.-,,,,,"",'_""',M_ jf . """ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C,P.3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v, No, 01-2907 LILLIAN E, BUCKLES CHARLES A, BUCKLES, III Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $76,370.27 Interest from 6/26/01 to 12/5/01 (per diem - $12.55) $2,033.10 and Costs TOTAL $78,403.37 Note: Please attach description of property.No. ,.,,,,,~, (, - . ',-' " , 'PI ~-.~~ ~~-- -', -- -" ,- ~ ,-". ~ ',,' ,..., "__' '0" '-,."",,,^"'=~'"__~~""_'_~ ~""_" ''''''=, __~, '~.."~~=~ ^"^' ,. ..".. ^ , '" ..... <:> r-- ..... ~ IilS ...:$ .... ...< .... 00 O~ .... Z .... ~ rr; 0 ~ 00> f;;l;1 .... <...< ~ Eo< f;;l;1;;.. ~ ;;;1 U -'d "'<00 ooU U Q) ll-oz ~ f;;l;1;;;1 ~'F ~ c: Zz Q) ~~ '" Q 0f;;l;1 Oz f;;l;1 = ~ Q) '" ..0 ::;:ll-o ::;:0 U< ... 0 < ::;: . ~E=: ;;;100 0" >- O~ .. f;;l;1 S 0 =:If;;l;1 Eo< ... 0 ~ 0 UZ Eo<~ .; r-l~ ;~ '" ~ i:l N ...;;;1 ~O ~~ g 00 ~= g< Eo<U =~ ~~ ;;;1 p. ~O ....U 01::: =:l j f-< ~~ ...< -.r ;;;1~ ...< ... 0 .... ::;:U .... tl6 -.r ~ 8~ ...< f;;l;1 .... '" f;;l;1f;;l;1 00 U '" < ~ .i:j Q) ==:l = Eo<::;: Q) ~ U ..... .~ Z;;;1 ll-o ~ ....U ~_'"., ~<"<J~~l~ii'<i'l\'i\i'E~"",!,,jl'i""-'.;>""F-';,";p.',> '-'''][<!ilfFf,:'r'''ril1?-ori:'fW)C\''~(W'''':'i~'W;,~'''"_;<''i!Wr~F!0i:j.l;'refm~l'ffll'tif~~ , , .... t ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, and described as follows: BEGINNING at a point at the northern line of the public road leading from Burgner's Bridge to HeisJunan's Bridge at line of property now or formerly of David R. Black; thence by said property, North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W. Wogan, South 85-1/4 degrees East, 208..5 feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and numbered as 424 Burgner Road, Carlisle, Pennsylvania. Tax Parcel #14-06-0027-066 V TITLE TO SAID PREMISES IS VESTED IN Charles A. Buckles, ill and Lillian E. Buckles, His Wife by Deed from Dorothy J. Steele, Widow dated 12/11/1998, recorded 12/14/1998, in Deed Book 190, page 1044. . '" - ~ "'.'--C~_'."_C~"_""'."-~....~' .', ^, ',1" ", '"""!.~,:,.',"~ " '-. ,/ ~. I .,.,- ~, "". , , . ~L" , ,,~r'_~", ~.~ "'-~. .,,<~, ~" _i'-~,."__.">.-<<,,, '--"''''.'' "'.~">J,.""~';y'4",-'.',~,-"".'''' "C,""","'''''''''''"O'.",', "",~,,__"__ ,~",.,.,", -^ --" .,~ -' J , 7V ~ t ~ ~ ~ ;CQ. ~ iU ~ ~ "'- k; ~ ';'- c :-0 6' "- 8 CJ (') "- ~ VI ~ -n 8 () d , g "- "- '" 8 tv -"u..: (/) _,_I (i' c,) ~ (i 0 0 fTlm f"1 --:-;"p' -0 Cv ~ 2:0 c;., () Z~ ',~~ ~ ~ ~ I f ~Z Cl 'J "-0 I (;U CO ~ )' ~ - - 0 20 -". ,~C; 0 - ... - r )>c: CO 5"" , ... * ^--, ~ ... ... Z :p.:"" :.:2 ;::"'"1 :0 , ~i? ()1 -< ... - '" '" " "- .~ , . t ~ o~~~lJ'f'llIJl~~~~'Ji_\li!'f"\"''''''~''~''':,'''''''1F,'-''''''j.,,,,.,''n;,,,,,,;''~;~J'<'M'hf""W%''-:;'''''';''''"'''Y'Wflm\~~!~~~~~ ~ \ FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY . COURT OF COMMON PLEAS v. CIVIL DIVISION LILLIAN E. BUCKLES CHARLES A. BUCKLES, 10 NO, 01-2907 Defendant(s), CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I W_" .,,<, ," , -1"- , -" I , t, ~- "'~~,""'~~~ ~ .... ~~ 1Ir" ".~ _,n -,,, -.., <~, - .~,.,'.> ^ .~,~^- .-" .'~~.=o - I Jllfnr1 t 8 0 c> -'1 s: (/) ::j ;:Ri'fi '''l ;J~, :!J Z:D '"1J ,'" ~S?: 0 ~'S)8 .:<:......:" .:::~;~.:? ~C) ~ )>'c ,,-~ J-,. ;~~~ zd 9? )>c '.~ Z :J1 s;! =< :J:J c.n -< ~~IIl'I'llJ~ ..:i;!l!!iHI,1l1..,., ~~~ffllil'ff"",'1lR!jC''f,,,~.~-><;iH'~ff-'f\''''~'~'''' "",,'0~"'" "'''' g "i11-""l'J'''i''l'W~1p~~Iilff'~'"'i''4''f,!l'''-ji!i'ii[:-'"if~!@~~~~ > .# , CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. LILLIAN E, BUCKLES CHARLES A. BUCKLES, III CIVIL DIVISION NO, 01-2907 Defendant(s), AFFIDA VIr PURSUANT TO RULE 3 129 (Affidavit No.1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD. CARLISLE. P A 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, P A 17013 CHARLES A. BUCKLES, III 424 BURGNER ROAD CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None )',e" .'- .. 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 424 BURGNER ROAD CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsi catio 0 authorities. August 1. 2001 DATE ::'"'", r" "'''' ~ ,". t.L.' < '''''1 ", , " . ,- ~ ,'" " "I ~= a: 1.J it''P ~,'RlIf!I ~ _ ~ ~""H'~~'" ",,_ ,~ ' ""~" T!lll~~c~.li"itli~f~II!'lJWH~m!i!!~"'"",!m,'!~W!10"!K'"I--'''w,II''''-'W','n''''I<\''f~'''''''''''- .. (") 0 0 C -n -~ V) "'"- -00:; rr1 ;~.~: mrr -0 -:7 ~~. , ~--,-. ZI:;'- f rjl <=> :,..c'l ~":j <.0..:::.::: ::26 ~.:. !<D ;p> -----;- ., ~o 'J: ':;;,:";',1 1---;\"") >8 co OfTl ~ :.n > tJ'I ~ CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No, 01-2907 LILLIAN E. BUCKLES CHARLES A. BUCKLES, ill Defendant(s). August 29, 2001 TO: LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, P A 17013 CHARLES A, BUCKLES, III 424 BURGNER ROAD CARLISLE, P A 17013 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 424 BURGNER ROAD, CARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. lfthe Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ',' ., ~ ':' ..,J .~.,- ',:,'I~' '.'j ,,_ ,"., ; , c. 'c' "'''''''' ,.., " You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE, I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 L~", ~ ~ '.,' , 'I, r< .. ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County,' Pennsylvania, and descnlled as follows: BEGINNING at a point at the northern line of the public road leading frO!TI Burgner's Bridge to Heishman's Bridge at line of property now or formerly of David R. Black; thence by said property, North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W. Wogan, South 85-1/4 degrees East, 20&.5 feet to a point; thence by line of property now or formerly of Martha E. Nickel, South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and numbered as 424 Burgner Road, Carlisle, Pennsylvania, Tax Parcel #14-06-0027-066 / TI!LE TO SAID PREMISES IS VESTED IN Charles A. Buckles, ill and Lillian E. Buckles, His WI!e by Deed from Dorothy J. Steele, Widow dated 12/11/1998, recorded 12/14/1998, in Deed Book 190, page 1044. . .. . ~ ii.l'.,~ .~., ""l'" --- '~: ."~ I', '~'l"'" ."'1-'1,'- , ~~ .. " !"'1~., I ,- "I , ^"" ~ II!"'"""""",,,- "_ ._'~~, _'" ~~'n ~,w~~ ._~. '"'' .. (") 0 ,', ~ -'r-'j "'- CI) -Cn:;C1 rr1 mrn -0 2:"1) ZS;: (J) , c:> -<d'': :,~j~ !;2C :t-"'" ?fC ~.~; ~:!~ C 9? ;~)n"j )>C z :.n :;:~ ~ ." en "" ~ If l;>,~~ ~~,~!';!Iwllit'l!l'f'" ", ~~~~!~"il;'l1'1!>1W>''jl'fol'f''''''~''''li''''''',"""-'''"''''''''1'''''''1lf~,,,,,"1''--"!E<';W~'11\'l~'''l;;'f,,,~'!!r,':~~W'11f~~;~'~' m AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY No.01-2907 DEFENDANT{S) LILLIAN E, BUCKLES CHARLES A, BUCKLES, III Type of Action - Notice of Sheriff's Sale SERVE LILLIAN E. BUCKLES AT 424 BURGNER ROAD CARLISLE, PA 17013 Sale Date: DECEMBER 5, 2001 SERVED Served and made known to ldI I;;;. t-J f, B..,c~\01.S (Jv~')~..~ l<,i..' 4 '00 JfJJ. at I , o'clock -t.m., at T , Defendant, on the Ca.1\.\."S k 1& if.. day of 2'.!rt<-IMIo,..., 200..!, , Commonwealth of Pennsylvania, in the manner described below: x '- \........ \<a' ^, /3" < \<.\ 'l> 31T On the ____ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me tl-jis _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, P A 19103 (215) 563-7000 1'2 _ ~." .~ -"'.'! ',1 ' .,., , >AC~ '~'~"~~~"",,"',~=,_" ",-- ",-'""." () c:: ~v -< !:: ....:-:;, =- :~; ):.... III IITJlW~ c.::~' o i':-j ,.-t 1"0 {1'1 -Cii'>m._ ~~ ".,,,~.i>_~J!l:, 1fI!J"~,",..,~I:moo-Wo/'lFJl.~:~~1"'m!~!O'li'Ml'I~MjIlli~'!IIf.lWl!r~lt"~rW"'f"~'c""''''''Y"'fF""'! j',"~""'h' ""'.''-,''''"""W<-',"r~Wi1W'!l,''iTIU~plm;R'';:'J'~\f?;,,,..)~'t~~.~?1lffl~'l!r~-m~\@ ? = J.p <r- AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY No.01-2907 DEFENDANT(S) LILLIAN E, BUCKLES CHARLES A, BUCKLES, 111 Type of Action - Notice of Sheriff's Sale SERVE CHARLES A. BUCKLES, III AT 424 BURGNER ROAD CARLISLE, PA 17013 Sale Date: DECEMBER 5, 2001 at 1:00 ,o'clock?m., at 1~'1 SERVED C~9"'\U A, e",~\t.5 ( :J1L ,Defendant, on the ~vt\5t-l..~ ~~" C-a~\\~k /(; fl-. dayof Serf't...j,~200L Served and made known to , Commonwealth of Pennsylvania, in the manner described below: ')(' Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place ofIodging in which Defendant(s) reside(s). Agent or person in charge of Defendant( s)' s office or usual place of business. an officer of said Defendant(s)'s company. Other: \ , , " \ Description: AgeJJi Height~ Weight /6S- Race I!.J(.. Sex fA, Other "M;;c" I, C )ot<-<,NCt, \.... 0<<.*1, Ji, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice .. orth herein, issued in the captioned case on the date and at the address indicated above. Notarial Seal Stacy L. Heefner, Notary Public . Chambersburg Bora, Franklin County ~ Sworn to and subscnbed My Commission Expi 5, 2002 ~ 0 be~hb~J:.#- day Member, Pennsylvania so e on of Notari of 200.!. Nota :~~.~ By: l0 u U I NOT SERVED On the _____ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire -1.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 '.'''''ll.j1'L,,,", 'I ,-- '<'" I"~' .~ - ~ 'I '. r, -~ ~ 'Al i_~~, ~ .u" ," .'~'F.'",,,,... ~'* .~ , _~",,~~~,~,Y"_._\~'~'~'" ~_"'" "..~" ,~" _, ~ () ~;; <../1." rnt-~ ' ~~~ r' -< ~5~'~ )..::C.~ z: ':<! " 11--' c;::; f'::l ;:"") "". I -rill _.~" ~~ '.. en ij~~I~~"~~"!>!"Jl~~L"i'.~iy";"r~'"",^...,,),;,.,,,.'" ','''~'c''-'F'''JJ'm'''-'lr-cW<j!~:'''~;''!7;'~~''i-t~,.'j~,f\:g'lm,<!1~jll;~~~~'i' i SALE DATE: DECEMBER 5. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHASE MANHATTAN MORTGAGE CORPORATION No.: 01-2907 vs. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa, R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 424 BURGNER ROAD. CARLISLE. PA 17013. As required byPa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required byPa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) ahd Supplemental Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached l for each notice. November 30, 2001 F FEDE , ESQUIRE A orney for PI 'ntiff i'''~''=~''1'' . ~" " . I' . . ~ ~" ~ CUMBERLAND COUNTY CHASE MANHATTAN MORTGAGE CORPORATION No.: 01-2907 vs. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.2) Plaintiff in the above action, by its attorney, Frank Federman, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD, CARLISLE, P A 17013: 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ''tf''.- ~. .l T~r,' r ""t ,'" '. I'" " ' ; I, "I - , CHASE MANHATtAN MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. LILLIAN E. BUCKLES CHARLES A. BUCKLES, III CIVIL DIVISION NO. 01-2907 Defendant(s), AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD. CARLISLE. PA 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, PA 17013 CHARLES A. BUCKLES, III 424 BURGNER ROAD CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ... ~ -1' ""',f,=~-.'~", "{ '",_ ~ " ,. . ,~.~ ". \ 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: NAME LAST Kl~OWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occnpant 424 BURGNER ROAD CARLISLE, PA 17013 Domestic Relations of Cnmberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatio 0 authorities. August I. 200 I DATE ,'~,<, .1_"" ,,~" _'___'i_~""'~ , -.' ,~ \ DATE: August 1,2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) LILLIAN E. BUCKLES CHARLES A. BUCKLES, III PROPERTY: 424 BURGNER ROAD CARLISLE, P A 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriff's Sale on DECEMBER 5, 2001 at 10:00 a.m. in Cumberland Countv Courthouse, South Hanover Street, Carlisle, P A. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH ]',,^ ,-, ., '--,,"'" , -", "~. -~ , _ "'v " ,_ I " " u. 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'1-" -"', ,1 """""'-r" ,,~, .... ," I{) I I I I I I 1 T I ;;-.-i~,~f:~?,?q "..---;-~. :i.:: ~ r 0 ::: lti":i\:;:'",i ::i --- - L. -- i ~ .';.tf ;r~ ,~ . -, ~ '"0~ _, lk. _'_"~__ ,'J.a, ,J, -"1 :; J8VlSOd'rn iY?;" ~;:'O') ~^~/ :.~ _:-._~~:17~~'k}i~~~ ,.~-~ f.i~I~/:~ ^ ' :";' '....- . :.'- .'.::->', ... -, '; , . , \ ", " f , " , <0 o ~ ~ ~ '<t I{) ~ ~ '" ~ M ~ "- co Ol - - - '0 " E- ro" z" ~'" ~o ,,- Cl.g- ..:W 20> '" C "'.- ii .~ ",1l 0" Cl.0:: ~ 1l 1l", .!!:lo Cl._ -~ 00 11'= E ro ,,'0 zj! 19 .8 0" 1-0:: <;; '0 C " '" o~ ~-g -"- g:j z~ g" 0.- I-Cl. -- STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _______________._____________________________________.._______________________Flecorderof Deeds in and for said County and State do 'hereby ccnify that the Sherifrs Deed in which ________________ Chase Manhattan Mtg Corp . ____________________________________________________________________________________ ~ thegr.antee 5th the same having been sold to said gr.antee on the ____________________________________________h_ day or Dec 01 ______________________n___________n___ A. D., ; onn' under and by virtue of a writ____n________ 10th Execution . ________________________________________________lSSued on the ________n______n___________________ Sept 01 day or __________________________ A. D., Civil --------------------------.---..-- n___ __________ ____ _____ _____ __n ____ ____ ____ ___ Tenn, : 2907 Chase Manhattan Mtg Corp ~U>Rber______________.atthesuitor-----------------______________________________________________ -----, out or the Court or Cornman Pleas of said County'as or 01 Lillian E Buckles & Charles A III ------------------ ---------- n_ ____ against. ___ - --_ __ _ ___ ____._.. _ __ __ ____.__ _ ____ ____ ________ _ is duly recorded in Sherifrs Deed Book ~o. __:_~:______, Page _________:~~.9 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ____l1_____ day of ___h~___________ A. D., ~~_L -n~-A.~--th:.i-t:lV-~-- Recorder of ~eds Retarder oIlleeds, Cumberland County, Carlisle, PA My Commission Expires the first Monday of lan, 2002 VS In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-2907 Civil Term Chase Manhattan Mortgage Corporation Lillian E, Buckles and Charles A Buckles, III Dawn Kell, Deputy Sheriff, who being dilly sworn according to law, states that on Sept. 27, 2001 at 10:21 o'clockP,M" E,D,S,T" she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lillian E. Buckles, by making known unto Charles Buckles, adult in charge, at 424 Burgner Rd" Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same, Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2001 at 10:21 o'clock P,M" E,D,S,T., she served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Charles A Buckles, III, by making known unto Charles Buckles, at 424 Burgner Rd., Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same, Shannon Sunday, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 2, 2001 at 9:09 P.M" E,D,S,T" she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lillian E, Buckles and Charles A Buckles, III located at 424 Burgner Rd" Carlisle, Pennsylvania, according to law, R. Thomas Kline, Sheriff, who being dilly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Lillian E, Buckles, by regular mail to her last known address, 424 Burgner Rd., Carlisle, PA 17013, This letter was mailed under the date of October 3, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice ofthe pendency ofthe action to one of the within named defendants to wit: Charles A Buckles, III, by regular mail to his last known address, 424 Burgner Rd" Carlisle, PA 17013, This letter was mailed under the date of October 3, 2001 and never returned to the Sheriffs Office, R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 5, 2001 at 10:00 o'clock AM" EST, He sold the same for the sum of $1.00 to Attorney Frank Federman for Chase Manhattan Mortgage Corporation, It being the highest bid and best price received for the same, Chase Manhattan Mortgage Corporation of3415 Vision Drive, Columbus OH 43219-6009 , , being the buyer in this execution paid SheriffR. Thomas Kline the sum of $660,68, it being costs, fbW;; "~41 -~'" , . ,-" Sheriff s Costs: Docketing Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Poundage $30.00 15,00 15,00 30,00 10.00 .50 1.00 7,80 4,53 15.00 30,00 242.15 169.59 25,66 25,00 26,50 12,95 $ 660,68 Sworn and subscribed to before me So Answers: This f)/'f-dayof~, ) r~"'''<'#-t' 2001, A.D, ~A.-' 12 ~, # R. Thomas Kline, Sheriff Pr onotary BY~~ R al Es te Deputy /.~:,~ ~ " -. , -, ~~ 3b'U1l ,:)1> . ~ 35/)'16 ~p.IrOO'l >- CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LILLIAN E. BUCKLES CHARLES A. BUCKLES, III CIVIL DIVISION NO. 01-2907 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiffin'the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 424 BURGNER ROAD, CARLISLE, PA 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, P A 17013 CHARLES A. BUCKLES, III 424 BURGNER ROAD CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3, Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None -:;", - ~"I' ~-~,~, ,'f 1,""" ". '",. ~- 4, Name and address of the last recorded holder of every mortgage of record: ~" NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 7, Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Tenant/Occupant 424 BURGNER ROAD CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties ofl8 Pa, C,S, Sec, 4904 relating to unsworn falsi catio 0 authorities. iff August 1. 200 I DATE ;,,",., '-.- I "_.__ ~,-.." .,,'C., '5;_~;,__r,' -- 4" ,-- , -"~ - ; CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-2907 LILLIAN E. BUCKLES CHARLES A. BUCKLES, ill Defendant(s). August 29,2001 TO: LILLIAN E. BUCKLES 424 BURGNER ROAD CARLISLE, P A 17013 CHARLES A. BUCKLES, III 424 BURGNER ROAD CARLISLE, P A 17013 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TlON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 424 BURGNER ROAD, CARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a,m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. -,~,"{ -f "'~"_',,_,,"-< _,7_. "d' . c ""~. ~ . ! You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling (215) 563-7000, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ;~ -.' -'1 ." ~- '__~< __'~''-' ~." I~ ',' I ___~ , " .^ .' ~ e ., "'" " , ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, and descn"bed as follows: BEGINNING at a point at the northern line of the public road leading frO!TI Burgner's Bridge to Heishman's Bridge at line of property now or formerly of David R. Black; thence by said property, North 09 degrees East, 500 feet to a point; thence by property now or formerly of James W, Wogan, South 85-1/4 degrees East, 208..5 feet to a point; thence by line of property now or formerly of Martha E, Nickel, South 08 degrees 57 minutes West, 500 feet to a point on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING, ", CONTAINING 2,396 acres. HAVING THEREON ERECTED a one story frame dwelling house know and numbered as 424 Burgner Road, Carlisle, Pennsylvania. Tax Parcel #14-06-0027-066 v' TITLE TO SAID PREMISES IS VESTED IN Charles A. Buckles, ill and Lillian E, Buckles, His Wife by Deed from Dorothy J. Steele, Widow dated 12/11/1998, recorded 12/14/1998, in Deed Book 190, page 1044. . -4 - ~ 1J1. "i "'~",'/'?:",~"i' .'c -~'~- -'f,,,",I-,"'., ",-"-,,,-,_,,"C~_<,__"~ <~ ~ . WRIT OF EXECUTION and/or ATTACHMENT GOMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Chase Manhattan Mortgage Corporation NO.01-2907 CIVIL CIVIL~_ CIVIL ACTION - LAW from To i llian E. Buckles PLAINTIFF(S) Charles A. Buckles, III 424 Burgner Road, Carlisle, Pa. 17013 OEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell 424 Rllrgner Road. Carlisle, Pa, 17013 (2) You are also directed to attach fhe property of the defendant(s) not levied upon in fhe 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 e~joined 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 pol>Sessionof anyone other . than a named garnishee, you are directed to notny him/herthat he/she has been added as a garnishee and is enjoined as above stated. AmountOue $7n,170.27 frrom 6/26/01 to 12/5/01 (per diem - $12.55) meresf 2,033.10 Atty's Comm % l.l. $0 <;0 Due Prothy o;;J 00 Other Costs Atty Paid Plaintfff Paid 170 14 Date: !'ipptPlTIber 10. 2001 Curtis R. Long Prothonotary. Civil Division by: 9~ Q.~ REQUESTING PARTY: Deputy Name Frank "'eO"Tm<1n, 1':"rp Ii n' Address: On" Ppnn Cpnh'r at Sllburban Station Suite 1400 Philanplphia. Pa. 19103 Attorney for: Plaintiff Telephone: Supreme Court ID No. :'f~<" 1" ~,. ~ 1-' , -, .. .- I .~"'~ REAL ESTATE SALE No. 33 On September 17, 2001, the sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA, known and numbered as 424 Burgner Road, Carlisle, and more fully {.~ cv:LI c:;jIj7 1==::2 <s:e> (iVi) described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: September 17, 2001 By: qMi JJ Jfiti.IJ;l i;al Estate Deputy .,,\6 ",\ '\;\-' C, I,' (", \'.. ' ~ \"'-<;j t-, , '<:1\'<." . .. <;,S ,. (\ ~~ \\,\\ . \'''' ;.\.'i--'~~'i. ~~"* \\ ~S ",'" " \\"" \"- (<\\~. '\ '" ;I." "~_.I!lII~...... T~~:!It'~~_~mj1I'jfj'~~!~~:m~fr'i!r;,~(,,~,-r '_t",~,,,,,c,,,, ",,'.'''''~f'~i'''fF"'-_-~,-,'~' ,~~,- '=,. ,-, ->>~ ~.~~. ~.~- -'<<--'-"<<,'~-~ ,- ,,~" "-'" I.~_~"-" -,'~ REAL ESTATE &AU: NO, 33 Writ No. 2001-2907 Civ1l Chase Manhattan Mortgage Corporation vs. Lillian E, Buckles and Charles A. Buckles, m Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in Lower Frankford Town- ship, Cumberland County, Pennsyl- Vania. and descnbed as follows: BEGINNING at a pOint at the northern line of the public road lead- Ing from Burgner's Bridge to Heish- man's Bridge at Une of property now or formerly of DaVid R. Black; thence by said property, North 09 degrees East, 500 feet to a pOint; thence by property now or formerly of James W, Wogan, South 85-1/4 degrees East, 208.5 feet to a point; thence by line of property now or formerly of Martha E. Nickel. South 08 degrees 57 minutes West, 500 feet to a pOint on the northern line of the said public road; thence by the northern line of said public road, North 85 degrees West, 209 feet to the place of BEGINNING. CONTAINING 2.396 acres, HAVING TIlEREON ERECfED a one story frame dwelling house known and numbered as 424 Burgner Road. Carlisle, Permsylva- nia. Tax Parcel #14-06-0027-066. TITLE TO SAID PREMISES IS VE8rED IN Charles A. Buckles. III and Lillian E. Buckles. His Wife by Deed from Dorothy J. Steele, Widow dated 12/1I/1998, recorded 12/ 14/1998, In Deed Book 190, page 1044, - ~. . '.. -<' .~ -_1.'..,' ," -,-'- '1 - .' 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, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: October 12, 19,26,2001 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 26 day of OCTOBER. 2001 NOTAR ~ LOIS E. SNYDER, NoI.ary Public CaI1isle Bolo, Cumberlal1d County My Commi&aIon &pilUS Marcl15. 2005 '-'''-~ ~l ,-~, ~-, ! - "I - ,. , -I -I m. :~~Rii~ESWESAliN~~33-~' wrlt No, 2001'2007 . CivllTerm . Ch.". Manhattan Mor\gageC<m>oratlon , . V$ UIDan E. BUCKles Chsrles 1\. BUcIllOs, m :, . Atty: franl< Federman DEsi:RJl'l'lON ... .. ALL 'IltA'T CERTAI.~ tract or iand situate in LOWe! Frankforcl Towm.nljl, Cumrerhu\d County, pennsy{vanla, and described as fallows: , BEGINNING at a ~nt at the nortbern line (If the publiC"' road k.adtng from Burgner'~ Bridge to ". Heisbman's Bridge al line <?f pro~cty nOW (II fcmnedy of Davtd R. 'allll:~ thence by ~aid propeny, North 09. degrees Eao..;t. 500 feel \rI a pGtnt; thence by property now ot fomwly of ")alW?S 'fl, Wogan, South a?#l!4 degrees E,a$t, 2085 feet to 4 'po~lIt;, ,thence by line of property now nr formerlv ()f Martha E. NicRel, South Qill tkgrteS 51 minutes Wc'i/., 500 feet \:0 " point on !he no~m1ineofthe said public road' \heI,Ice by Jhe ncrlhern line of said public road, Ncrtb. $5 .:degre~ West, 209 feel to lhe place of BEGlNNlNG. . CONTA1NJjlC 2,396 "",,: :rrn.E to SAID premIses h vested in Charles A. \ BUC~es, ill and tmi:ili-E, Buckle~, His Wife., by I Dee4.., from porothy ], Stede., Widow, .datr:d l2/ 'lril99S;recoroed \21\41\99S,\nDwlBookl9Q, I ':page_l044. -~---~------------- .--- 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 Th e Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 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 verity 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 Mi ellaneous Book "M", SALE #33 NOIMal Saal Teny L. Russ.". NOlary Pu HarriabwlI. Dauphin County y My Commission Expires Jun. 6, 2002 TAR PU BLlG Membar, PannsylVenle ASSOCiallon 01 No mission expires June 6, 2002 " CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement a1 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 $ 168,09 1.50 169.59 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general oirculation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.......,.,.,.,.,.,........,.,...,.,....,.,.,.....,.,.,.,.,.,.,...... ~ ,'.,1' _ _"'."^ "'''''.