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Home My WebLink About01-03083 ~ ;0 ,""_-1<,1 . 0- .-L ~~9,,..! ... ~. ~! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. TO YOU ARE HEIIEIlY NOTIFIED TO PWD 10 THE ENClOSED r.f) will leU Vi-\-. ~ TWENTY .CID). DAYS.FROM..... ~. I HEREBY CERTIFY THE ADDRESS OF THe 6" ~ .f'J.AINTIFF IS ~';)~\\I. ~..,V\ ~~ 'I ":,>a\'1= .... ...... fJr\~ CERTIFICATE OF lOCATION I HEAEBY CEIlllfY lHAT lIfE LClCA1tON OF lItE REAL mATE ""..lr:u fit 1HI LI8J . ..... BY CIVIL DIVISION ) ) NO.: 01- .10(3 ) ) ISSUE NO.: ) ) ) TYPE OF PLEADING: ) ) CIVIL ACTION - COMPLAINT ) IN MORTGAGE FORECLOSURE ) ) CODE- ) ) FILED ON BEHALF OF PLAINTIFF: ) ) Chase Manhattan Mortgage Corporation ) ) COUNSEL OF RECORD FOR THIS ) PARTY: ) ) Kristine M. Faust, Esquire ) Pa. J.D. #77991 ) ) GRENEN & BIRSIC, P.C. ) ) Firm #023 ) One Gateway Center, Nine West ) Pittsburgh, PA 15222 ) (412) 281-7650 O,tJ~L~~ ,- I - .. ,-- i' I,; ~ . -,-, ,- <-" .'0" - ,-~ ,_ 'iI&!!:''" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave Carlise, P A 17013 Phone (717) 249-3166 800-990-9108 -".. , ~ 1_ _1, L~ .-' ,-'.,'-, ,.~ - ~,_l<,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 0/- 36~3 ~ --r~ Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: I. The Plaintiffis Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219. 2. The Defendants are Richard D. Bartlett and Sarah Bartlett, individuals whose last known address is 12 Rockaway Drive, Camp Hill, Pennsylyania 17011. 3. On or about December 29, 1999, Defendants executed a Note in favor of Patriot Bank, in the original principal amonnt of $98,900.00. A true and correct copy of said Note is marked Exhibit" A", attached hereto and made a part hereof. 4. On or about December 29, 1999, as security for payment of the aforesaid Note, Defendants made, executed and delivered to Patriot Bank a Mortgage in the original principal amonnt of $98,900.00 on the premises hereinafter described, said Mortgage being recorded in the "..~ I~J " ~ I -" _0";';_, _0-_ '-~. Office of the Recorder of Deeds of Cumberland County on January 4, 2000, in Mortgage Book Volume I 590, Page 620. 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. Patriot Bank 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 March 8, 2000, in Document Number 639-959. 6. Defendants are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the October 1,2000 payment. 8. On or about December 5, 2000, Defendants were mailed combined Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974,41 P.S. S101, et seq. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal Interest through 5/14/01 Late Charges through 5/14/01 Escrow Due through 5/14/01 Attorneys' fees Title Search, Foreclosure and Execution Costs TOTAL $ 98,444.73 $ 6,135.83 $ 249.63 $ 388.89 $ 850.00 $ 1.500.00 $107,569.08 , ,..'r :J< - ", ,;-',,"-,.;,, , A ~ *l1ij WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $107,569.08, with interest thereon at the rate of $ 23.94 per diem from May 14, 2001, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. BY: /~~~ Kristine M. Faust, Esquire Pa. J.D. #77991 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. , . i I _ ~ ,-~- ,-"" ,! ,-'0' , Exhibit" A" ,"'.,",-'" ",- -~j~ ., " .- J:.j . ~ NOTE 'THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. Dece~r29.1999 [Date) POTTSTOWN, ICilyl Pennsylvania (Slalel 12 Rockawa)' Drive, Camp Hill, PA 17011 IPropertyAdtJre.o;...j I. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 98,900.00 (this amount is called "principal"). plus interest. to the order of the Lender. The Lender is PATRlOTBANK I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder," 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 8.875 %. TIle interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monthly payments on the 1st day of each month beginning on February 1, 2000 I will make these payments every month until I have paid all pf the principal and interest and any other charges described. below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, on January 1. 2030 . I still owe amounts under this Note. I will pay those amounts in full on that date, whicb is called the "Maturity Date." I will make my monthly payments at HIGH AND HANOVER STREETS POTTSTOWN. PA 19464 or at a different place if required by the Note Holder. (B) Amount of Montbly Payments My monthly payment will be in the amount of U.s, $ 786.90 4. BORROWER'S RIGHT TO PREPAY I bave the right to prepay at any time, without premium or fee, the entire debt evidenced by tins Note. or any part thereof not less than the amount of one installment, or $100.00. whichever is less. Any prepayment in full of the debt shall be credited on the date received. and no interest may be charged after that date. Any partial prepayment made on any day other than an inslallment due date need not be credited until the next following installment due date or 30 days after the date of the partial prepayment. whichever is earlier. MULTlSTATE FLXED RATE NOTE - Single Family - Unlronn Inslromcnl 1TEM34181.1(Q51l) (Page J /If J pcJges) GREATlAND . TDDm,(:aIl:I.80I,t.530-9393D'ax616-191-1131 -._-;:.-:~- -:'-... 'f: " ...'.- :~.... "- -: . --)-:' --. ".. '~.'-- .,....',. 1:1 ~o ^" ~j" -~ - ._ .. ,,' ,c' ~: .1 ",-,I .~.,..--:..," . w' 5: LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges. is finally interpreted so that the interest or other loan charges collected or to be collected in connection wilh tins loan exceed the penniued limits, then: (i) any such loan charge shall be redl,lced by the anlount necessary 10 reduce the charge to the penniued limil; and (ii) any sums already collected from me which exceeded penniued linnls will be refunded to me. TIle Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making.a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge Cor Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the cnd of Fifteen days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be afmy overdue payment. I will pay this late charge promptly but only once on each lale payment. (B) Derault If I do not pay the full amount of each monthly payment on the date it is due, I will be in default (C) Notice of Default If I am in default, the Note Holder may send me a wriuen notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the dale on which the notice is delivered or mailed to me. (0) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay illmledialely in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay inunediately in fuU as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibiled by applicable law. Those expenses include, for example. reasonable attorneys' fees. calendar 4.000% 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given La me under tJns Note will be given by delivering it or by mailing it by ftrst class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the Notc Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS m' PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personal.ly obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Nole is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, . sureLy or endorse{ of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. TIlls means that anyone of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of presenbnent and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" means the right to require Ute Note Holder to give notice to other persons that amounts due have not been paid. lTEM3418L2 (96111 (puge2 fijJj1<lge.l) GAEATLANO. TDOnlnCaIl: l.llOO-S3().9393O'u61tH91.1131 .:;. , '~ , -, ~ " ,., , 'l"-t" (.- "-I , '- t.'~" Ail .' ~ 10. ALLONGE, RIDER, ADDENDUM, ATTACHMENT OR OTHER MODIFICATION (HEREINAFTER REFERRED TO AS ALLONGE) TO THIS NOTE If an allonge providing for payment adjustments, or for any other supplemental infomlation, is ex.ecuted by me together with this Note. the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box..] o Graduated Payment Allonge 0 Other [specify] . o Other Ispecify J II. UNIFORM SECURED NOTE lbis Note is a uniform instrument with limited variations in some jurisdictions. In addition to (he protections given to the Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. 'That Security Instrument describes how and under what conditions I may be required to make immediate payment in fun of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property. This loan may be declared immediately due and payable upon transfer of the Property securing such loan to any transferee, unless the acceptability of the assumption of the loan is established pursuant to Section 3714 of Chapter 37, Title 38, United States Code. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. Borrower has executed and acknowledges receipt of pages I through 3 of this Note. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED, ~ (Seal) -Borruwer s~ (Seal) -BulTOwcr (Seal) -Burrower (Seal) -Borrower [Sign Original Only] "Payable without recourSJ to QfASE MANIfATTAN MORTGAG~ CORi'OIlATION' ~w::rF:~ APRIl: M$T. ~AflY ITEM3418L3 (95111 (puge j III j lI<Jge.f) GAEATLAND . TollnlelCaIl: l-llOO-53G-!:I393[Ju61&-191-1131 i"- '-". .. . ;','.> ;- ~; - '; ~'. ".-'.k:1;., ,'- ., , ". .- "'-~ i.ta~hivi Exhibit "B" " "' I 1~'1" "_ ..,;., ~ '~r~ . /lc2 . e..-., .s ('J . . 'R08E~T i'. ZIEGLER RECORDEr; Or DEEDS CUMBERU:lJ COUNT'!-P~ 'DO jAN ~ AI'! 9 20 X,j )037307 fS l.\79do) {Space AOOl.e This Line For Recording Duta) MORTGAGE THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. TIiIS MORTGAGE ("Security Instrument") is given on TIle mortgagor is Richard Bartlett and Sarah Bartlett December 29,1999 ("Borrower"). This Security Instrument is given to which is organized and existing under the laws of PATRIOT BANK THE STATE OF PENNSYLVANIA , and whose address is HIGH AND HANOVER STREETS, POTTSTOWN, PA 19464 ("Lender"). Borrower owes Lender the principal sum of Ninety Eight Thousand Nine Hundred Dollars And No Cents Dollars (U.S. $98.900.00 ). This debt is evidenced QY Borrower's nole daled the same date as lhis Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on January 1, 2030 . lbis Security Instrument secures to Lender: (a) the repayment of the debt evidenced by lbe Note, with interest. and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with intereSt. advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located in Cumberland County, Pennsylvania: Pennsylvania 17011 tZipCl1l.le] 12 Rockaway Drive, ISl/'eet! ("Property Addrcss~); Camp Hill, ICilyl which has the address of PENNSVLV ANIA -- Single Family -- Unironn Inslnlment rTEM~10l1 (9511) (Puge J of6puge.f) GREATLANO. ToOrd!/CalI. 1.1lOO-53G-9393CJa616-791-1131 Bod590 rAGE ~20 ...- 1_ J_ .. . .. . TOGElHER wrrn all the improvements now or hereafter erected on the property. and all easements, appurtenances, and ftxtures now or hereafter a part of the pro~rty. All replacements and additions shall also, be covered by this Security Instnunenl All of the foregoing is referred to In this Security Instrument as the "Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and conv~y the Property and that the Property is unencumbered, except for encumbrances of record. Bonower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS 'SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdict,ion to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: . 1.. Payme~t of Principal and I~terest; Prepayment a~d Late Charges. Borrower shall promptly pay when due the pnnclpal of and mterest on the debt eVidenced by the Note and any prepayment and late charges due under the Note. 2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay 10 Lender on the day mont~y payments .are ~u~ under the. Note, ~til the Note is paid in full, a sum ("Funds") for: (a) yearly taxes and assessments which may attam pn~nty over this Secunty Instrument as a lien on the Property; (b) yearly leasehold payments or ~und ~nts on the P1:operty, If any; (~) yearly hazar~ or property insurance premiums; and (d) yearly flood lDSurance prenuums,lf any. These tlems are called Escrow Items. Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estale Settlement Procedures Act of 1974 as amended from time to time, 12 U:S.C. ~ 2601 et seq. ("RESI;'A"), unless another law that applies to the Funds sets a lesser amount. If so, Lender may, at any tIme, collect and hold Funds m an amount not to exceed the lesser amount. Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or olherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentaIily, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account., or verifying t,he Escrow Items, unless Lender pays Borrower interest on the Funds and applicable Jaw pennits Lender to make such a charge. However, Lender may require Borrower 10 pay a one-time charge for an independenl real estate tax reporting service used by Lender in connection with this loan, unless applicable Jaw provides otherwise. Unless an agreement is made or applicable law requires interest to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender may agree in writing, however. that interest shall be paid on the Funds. Lender shall give to Bonower, without charge. an annual accounting of the Funds, showing credits and debits to the FWlds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security InsIIUmenL If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender lhe amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument. Lender shall promptly refund to Borrower any Funds held by Lender. If, under paragraph 23, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at lhe time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: fllSt, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third. to interest due; fourth, to principal due; and last. to any late charges due under the Note. 4. Chargesj Liens. Bonower shall pay all taxes. assessments. charges, fmes and impositions attributable to the Property which may attain priority over this Security Instrument. and leasehold payments or ground rents, if any. Borrower shall pay these o~ligations in the manner provided in paragraph 2. or if not paid in that manner, Borrower shall pay them on time directly to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this pamgraph. If Borrower makes these payments directly, Borrower shall promptly furnish 10 Lender receipts evidencing the payments. Borrower sball promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) conlests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operale to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines lhat any part of the Property is subject 10 a lien which may attain priority over this Security Instrument., Lender may give Borrower it notice identifying the lien. Borrower shalf satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. S. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against Joss by fire, hazards included within the lerm "extended coverage" and any other hazards, including floods or flooding. for whic~ Lender requires insurance. This insurance shall be maintained in the amounts and Bod590 PAG{ .621 ITEt.42410L2(ll5l1j (Puxe 2 of6puge$) GREAH.ANO . ToOrd8rCa~: 1-600.S3IHI393D':u.61&791-1131 ". 'j':. u.Srllif1\j -- _,J ,< , ~ .' .'='>> C~, " , "~'''''-r~i ~ , .' . for the periods that Lender requires. The insurance carrier providing the insuram:c shall be chosen by Borrower subjel.:t to Lender's approval which shai! not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may. at Lender's option. obtam coverage to protect Lender's righls in the Property in accordance with paragraph 7. All insunmce Wlicies and renewals shall be acceptable to. Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance procc;:eds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not ecQDomically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then' due, with any excess paid to Borrower. If Borrower abandons the Property. or does Dot answer wit.hjn 30 days a notice from Lender that the insurance carrier haS offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 3O-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall' not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of the payments. If under paragraph 23 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent of lhe sums secured by this Security Instrument immediately prior to the acquisition. 6.. Ottupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy. establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shaU not destroy, damage or impair the Property, allow the Properly to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding. whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeitwe of the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest Borrower may cure such a default and reinstate, as provided in paragraph 17, by causing the action or proceeding to be di<i:mi~c:ffi with a ruling that, in Lender's good faith determination. precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including. but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property. the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenanls and agreements contained in this Security Instrument, or there is a legal p~g that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate. for condemnation or forfeiture or to enforce laws or regulations), then Lender may do a,nd pay for whatever is necessary to protect the value of the Property and Lender's righls in the Property. Lender's actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 7. Lender does not have to do so. Any amounls disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounls shall bear interest from the date of disburseD,lent at the Note rate and shall be payable, with interest. upon notice from Lender to Borrower requesting payment S. Iospectioo. Lender or ils agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 9. Condemnation. The proceeds of any award or claim for damages. direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then duel with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property inunediately before the taking. Any balance shall be paid to Borrower. .In t!te event of 3 partial taking of the Propeny in which the fair market v:uue of the Property immediately before ~e taking ~s les~ ~ the amount o~ the sums secured immediately before the taking, unless Borrower and Lender otherwise agree m wntmg or unless apphcable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. BOOK1590 PAG( .622 ITEM~lOl.3 (9Ml) (p/Jgt 3of6pagt!sJ GAEATLAND . To {lrd.r Call: 1.llOO-S3lI-93!13[Jax61li-791-1131 " ~y. " :;,,-~' -:-. ;.. --t'--:_ . "":::.....;.:,::.;}.:::=:.-- ..-~'...,...'"!':.,.~_.,;;:- .:. ~ ~~;-~~?~~.---~: ~-:: .,,":' ~: ~ ."-'." o ~ .. . If the Property is abandoned by B()ITower, or if, after notice by Lender to Borrower lhallhe condemnor offers La make an award o.r setde ~ claim for damages, Borrower fails to respond to Lender wilhin 30 days after the date the notice is given, Lender IS autbo~ to co~ect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Secunty Instrurm:nt. whether or not then due. Unless Lender and Borrower otlK:rwise agree in writing,. any application of proceeds to principal shall not extend or postpone the due date of the monl.hJ.y payments referred to in paragraphs 1 and 2 or change the amount of such payments. 1,0. ~orrowe[' N.ot ,Released; For-bear-ance By Lender ,Not a Waiver. Extension of the time for payment or modificabon of amortlZaUon of lh.e SUms secured by this Security Instrument granted by Lender 10 any Sllccessor in interest of Borrower shall not operate to relctlse the liability of the original Borrower or Borrower's successors in interest. Lender shall n?t be Ie9uired to .co~ence pJ:'OCeedings against any, successor in interest or refuse to extend time for payment or O~lse modify amortlZal1on of tl.1e sums secured by this.,Security Instrument by reason of any demand made by the ongmal Borrower or Borrower's SUCCessors in interest. Any forbearance by Lender in exercising any right or remedy shall nOl be a waiver of or preclude the exen;ise of any right or remedy. 11: Successors and A~igns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Secuoty Instrument shall bmd and benefit the successors and assigns of Lender and Borrower. subject to the provisions of paragraph 16. Borrower's covenants tmd agreements shall be joint and several. Any Borrower who co.signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in lhe Properly under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify. forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 12. Loan Clbarges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges. and that law is fmally interpreted so that the interest or other loan charges coUected or to be coUected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded penniued limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal. the reduction wiH be treated as a partial prepayment without any prepayment charge under the Note. 13. Notices. 1\1.1y notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by f!CSt class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. If the indebtedness secured hereby is guaranteed or insured under Title 38, United States Code, such Title and ~guIations issued thereunder and in effect on the date hereof shall govern the rights, duties and liabilities of the parties hereto, and any provisions of this or other instruments executed in connection with said indebtedness which are inconsistent with said Title or Regulations are.hereby amended to conform thereto. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of (his Security Instrument or the Note which can be given effect without the conflicting, provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Transfer of the Property. This loan may be declared immediately due and payable upon transfer of the Property securing such loan'to any transferee, ultless the acceptability of the assumption of the loan is established pursuant to Section 3114 of Chapter 31. Title 38, United States Code. If Lender ex~ses this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than' 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 17. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the propeny pursuant 10 any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument. including, but not limited to. reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Sa::urity Instrument. Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security lnslrl.lment shall continue unchanged. Upon reinstatement by Borrower. this Security Instrument and the obligations secured hereoy shall remain fully effective as if no acceleration had occurred. However. this right to reinstate shall not apply in the Case of acceleration under paragraph 16. 18. Sale of Note; Change of Lom Servicer. The Note or a partial interest in the Note (together witll this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also n~241OL4{1l51l1 W"X(! 4 of 6 flUXe,f) GAEATLANO. ToOldelCal1: 1-8O(l-530-9J9J[JilI616-191'l1Jl Bo0K1590 fAGE .623 ,,----, - : -~.i ~ - -',," . ;'':~-..'-~>- _:"..-:..~:'~~..-:.'- ~',_':'.::.,:~ ". - ~. :-, '-'~ . {&;;f~~~':' ;-~~':. '?;f~~~r ~ . ~,--,; c. ~ -,-,~:::~__~- -~.~ "" -..--. --._-,/ ~f':7.? ~ .:;;....- . :S-:~'0:G;~~' '._- :;~{., ',.'~. .'-."-:'-' .--::::-,.. ." ',",- .i." -~ " mwI ~ '~"' ~~, " ,.. .. . " may be one or more cbanges of the Loan Servicer unrelated to a sale of the Nule. If there is a change of the Loan Servicer. B?nower will be given written notice of the change in accordance with paragraph 13 above and applicable Jaw. The notice will staCe the name aJld address of the Dew Loan Servicer and the address LO which payments should be made. The notice will also contain any other information requiraj by applicable law. 19. HazatdoU$ Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of smaU quantities of Hazardous Substances that arc: generally recognized to be appropriate to normal residential uses and to maintenance Qf the Property. Borrower shall promptly give Lender written notice of any investigation, claim; demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any: Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 19, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 19, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. 20. Funding Fee. A fee equal to one.half of one percent of the balance of this loan as of the date of transfer of the Property shall be payable at the time of transfer to the loan holder or its authorized agent, as trustee for the Department of VelenU1S Affairs. If the assumer fails to pay this fee at the time of transfer, the fee shall constitute an additional debt to that already secured by this instrument, sball bear interest at the rate herein provided, and. at the option of the payee of the indebtedness hereby secured or any transferee thereof. shall be immediately due and payable_ This fee is automatically waived if the assumer is exempt under the provisions of 38 U.S.C. 3729(c). 21. Processing Charge. Upon application for approval to allow assumption of this loan, a processing fee may be charged by the loan bolder or its authorized agent for determining the creditworthiness of the assumer and subsequently revising the holder's ownership records when an approved transfer is completed. The amount of this charge shall not exceed the maximum established by the Department of Veterans Affairs for a loan to which Section 3714 of Chapter 37, Title 38, United States Code applies. 22. Indemnity Liability. If this obligation is assumed, then the assumer hereby agrees to assume all of the obligations of the veteran under the terms of the instruments creating and securing the loan. The assumer further agrees to indenmify the Department of Veterans Affairs to the extent of any claim payment arising from the guaranty or insurance of the indebtedness created by this instrument. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 13. Acceleration; Remedies. Lender shall give nolice to Borrower prior to acceleration following Horrow~r's bceach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 16 unless applicable law provides otherwise). Lender shall uotify Borrower of, among other things: (a) the default; (b),the action required. to cure tbe default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further infonn Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration 'and foRdosu.re. If the default is not cured as specified, Lender at its option may, require immediate payment in full of aU sums secured by this Security Instrument without further demand and may foreclose tbis Security Instrument by judidal proceediDg. Lender shall be entitled to collect all expenses incurred m pursuing the remedies provided in this paragraph 23, including, but not limited to, attorneys' fees and costs of title evidence to tbe extent pennitted by applicable law. 24. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. . 25. Waivers. Borrower, to the extent penniued by applicable law, waives and releases any error or defects 10 proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or f~ture laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemptJon. 26. Reinstatement Period. Borrower's time to reinstate provided in paragraph 17 shall extend Lo one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 27. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 28. Interest Rate After Judgment. Borrower agrees that the interest rale payable after a judgment is entered on the Nole or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. lTEM2410l.S (9611) (pIJge5f1/6pugesJ GREATLAND . TO OrderCaiI' 1-600"530-9393CFax&16-791-1131 Bo0K1590 rACE .624 .-' ,~ o' I I .. . 29. Riders to Ibis Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrwnent. [Check applicable box(es)J o Adjustable Rate Rider 0 Other(s) [specify] o Graduated Payment Ri~er BY SIGNING BELOW, Borrower accepts and agrees to the lerms and covenants contained in pages Security Instrument and in any rider(s) executed by Borrower and recorded with it ~ chard ert I through 6 of this (Seal) .BOlTOWer ,~~ Sa arUett (Seal) -Borrower (Seal) -B~ (Seal) -Borrower Witness: Witness: COMMONWEALlH OF PENNSYLV ANlA. roU~~COUnlY '" Onthis,the 29th day of December, 1999 ,before me, the undersigned officer, personally appeared Richard Bartlett and Sarah BartJett proven) to be the person whose name are that they executed the same for the purpose herein contained. known to me (or satisfactorily subscribed to the within instrument and acknowledged IN WITNESS WHEREOF, I hereunto set my hand and official My Commission expires: NOIARIAL SEAL CARRIE E cOOK. Notary PubliC HQ"\lb~rg. oauPhln..~gounaty2002 IIaIOn ExPk81 ~ . , I, Lorraine M. Wisely do hereby certify that the correct address of the within named lender is High and Hanover Streets~ Potts town, PA 19464 WitnesS my band this 29th day of December. 1999. ~4":'~ # J~ Agent of Lender BOOK 1590 fAG{ .625 ITEM 241016 (~1') (Puge 6 '116 puges) GREATLAND . rQOrdIICarl:'.500'S30.9393aa~6'6-79H13' -:0: - '. , !.-;-: ~-:.~~:::'.-. ~-' ' . ,.':c.-..::_";.-,:-' \-:' . ,- '-. '-:". - c__ '., -~ ~JW~w" '. , I- " ' .:"A~L THA~ CERT~.1 or parcet of land with improveme.hmon erecled, sllu.te in . Lower Allen Tow/lship, C\lmbcrl~nd County, l'ennsylv.nia, more pal1ieulorly bounded and desenoed as follows: BEGINNING at a point on Ine ..sterly line of Rockaway Drive which poinl is 501.04 fe.' North of lb. northe..tetly comer of Rockaway Drive and Palmer Drive al . dividing Une between Lots Nos. !91l1ld 20, Block H on the horeihafterIllClltionedPlan ofLots; thence along Ihe easterly line of Rockaway Drlve North 42 degr... 20 minutes Wut 80 fact to a point at lbe dividing line belween Lots Nos. 20 and 21, Block H in said Plan; thence along said dividing line Nortn 47 degrees 40 minutes Easl125 feet to . point on .the wcslerly.line of Lot No.5, Block H on said plan; thence along tho westerly line of Lots Nos. 5 and G,Block H on said Plan South 42 degrees 20 minut.. East 80 feet 10 a point at dividing lina .b.:rween line .berween LoIS Nos, 19 and 20, Bloek Ii aforesaid; thence along s.me Soulh 47 dogr... 40 minutes Wesl125 feet 10 . point, lhe place ofB:EGINNING. HAVING THBREON I!RECTEJ:> a singl. brick and frame r.nch typo dWelUng, saia premises being known and numbered as l211.ockaway Drive. AND BEING Lot No. 20, Block H in the Plan oecoualry and Town Home" Inc., whie!> Plan is recorded in theCuwherl.nd County Roeorder's Office in 00e4 Book 7, Page 41. UNDBR-AND SUBJECT, N5VERTHELESS,ro oasemoms, restriclion" resorvalions, condil'ons and righlS oeway oflocord. BEING 1HE SAME PREMISES WHICH James W. Gutshall and Setina S. Sweger, by deed dated December 29, 1999 and recorded in the office of the Recorder of Deeds in and for the County of Cumberland. granted and conveyed unto Ricbard Banlett and Sarah Bartlett, in fee. ". vi.1tr.of Pn C',.ir:my of C;nS1'h'ania ' r, :'.",. ":;r}' ,J,01Jberlaod} 86 ;" c.~~'nl'l!lr'ff; . . 'lId',.... -. .~e for the 11 '-',-,' h, r . f.. _. _ B t- O'7l,..e'![Jr,rr C eCOrdlng of D w:. '. :~ n il -<_ \/01__ -al/nrY~a. eads Ce..." . Y 'iin~'J~ ---P;lQ .~ this 'if'.,,! of 0/1" '.. f - /<c d ?;COO - BOOK 1590 fAGE .626 ':":-'-':':-,,':". "":':~'~'~;::,' -o-:"--::-~~:;: ,-.......- ~." ,~,:' !: . .,:.-. ,-v' i't " , ,,' > LI "-~MiM: STEPHEN smas. , Assistant Secretary, and duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint in Mongage Foreclosure are true and correct to his information and belief. y ,Assistant Secretary STEPHEN STR<:lIla Grenen & Birsic, P.C. Verification ~al!~~~ifiit~8~1>""~.I1:};~.w",_mm!"al!.''i)k'i,,,,;''''h''''i--,*W2~fti#ffil8'h;''ii'R.:~"',,,;o,l!;''6i''''''''' ')I...jJ f:j{J ~t <: ~ ..0 ..... ...~ ~"~allilil'~ :t Iq h ~~ ~B~ I I il!h \" t J , ... ..... ~ o ;4,.lJl"Lt?f;L~Lk~.,'!~'~ ,.^."_"~~JL ;~,,~ ._.,~J~W,~,Jj':',_~r,~ ,,,,,,-,,,,,,,\~,,'._'9.""~"',I,~,',;.;!'~-,_ f. ," ,~_n'-.^- _,' '" ^'~ "~. ,"""" ,~_, " ',.-, d ,_ "-5. ,-",' ~, ',~-. -. ^., ' ." 'I'-'^~..~ ~.""~~." ilWIlIIiilll -jl ~t: i." ' / (/' -, ~:: - ~S:~; ~; <'- --I -<. -- "~-> ,,~"'~- <=- '--. ., r~.) c...) L" / t~)m :'.1 ,J":>' 7J -< (n ~i Q -'c'--, ~-::' .U ,~,- '- ; ,;/ . ~ - ~ > >~ , I I ' ~ '" "'""r-"~"iOi.i, . SHERIFF'S RETURN - REGULAR CASE NO: 2001-03083 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS BARTLETT RICHARD D ET AL DEP DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE BARTLETT RICHARD was served upon the , 2001 DEFENDANT , at 1950:00 HOURS, on the 23rd day of May at 12 ROCKAWAY DRIVE CAMP HILL, PA 17011 RICHARD BARTLETT by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.44 .00 10.00 .00 35.44 Sworn and Subscribed to before me this 10 ~ day of ~ ~I "A.D. ~~ 7Yr ,pg,"1 ~ P honotary S;;;J2~_~~ R. Thomas Kline OS/24/2001 GRENEN & BIRSIC By: Go.wn ~. \(Jt Deputy Sheriff --- , ~I ~ _0;' -;.,' t 7 , SHERIFF'S RETURN - REGULAR . \ CASE NO: 2001-03083 P \ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS BARTLETT RICHARD D ET AL DEP 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 BARTLETT SARAH the DEFENDANT , at 1950:00 HOURS, on the 23rd day of May , 2001 at 12 ROCKAWAY DRIVE CAMP HILL, PA 17011 by handing to RICHARD BARTLETT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavi t Surcharge 6.00 .00 .00 10.00 .00 16.00 S;;~~_~~ R. Thomas Kline Sworn and Subscribed to before OS/24/2001 GRENEN & BIRSIC By: (\ ~ \/^^ k)o..u.m 1-- \4.fLJL ...., me this :30 --- day of Deputy Sheriff ,;2..1101 A.D. q~%,,(2 fuJI,,~, 11~~:- rothonotary .,~~ '.- , '-.1- =.-L.""o -l~-i:' . N . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE ) CORPORATION, ) NO.:01-3083 ) Plaintiff, ) ISSUE NUMBER: ) vs. ) TYPE OF PLEADING: ) RICHARD BARTLETT and ) PRAECIPE FOR DEF AUL T JUDGMENT SARAH BARTLETT, ) (Mortgage Foreclosure) ) Defendants. ) CODE- ) ) FILED ON BEHALF OF PLAINTIFF: ) ) Chase Manhattan Mortgage Corporation ) ) COUNSEL OF RECORD FOR TillS I hereby certify that the address ) PARTY: of Plnintiff is: ) 3415 Vision Drive ) Kristine M. Faust, Esquire Colmnbus, OH 43219 ) Pa.I.D. #77991 ) ) GRENEN & BIRSIC, P.C. ) Firm #023 the last known address of ) One Gateway Center Defendants is: ) Nine West 12 Rockway Drive ) Pittsburgh, P A 15222 Camp Hill, PA 17011 ) ) (412) 281-7650 GRENEN & BIRSIC, P.C. ~~ ,,,~- d -. -"'"I ," ,. ~-- - , "'" -~'h-, . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:01-3083 Plaintiff, vs. RICHARD BARTLETT and SARAH BARTLETT, Defendants. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Richard Bartlett and Sarah Bartlett, in the amount of $108,757.23, which is itemized as follows: Principal Interest through 6/25/01 Late Charges through 6/25/01 Escrow Deficiency Attorneys' fee Title Search, Foreclosure and Execution Costs TOTAL $ 98,444.73 $ 7,127.22 $ 285.39 $ 549.89 $ 850.00 $ 1.500.00 $108,757.23 with interest on the Principal sum at the rate of$23.94 per diem from June 25, 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: ~~Uk/ Kristine M. Faust, Esquire Attorneys for Plaintiff i" , "..1, t I , '" ',,- .~, ''''{~1>' ~ AFFIDAVIT 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 and for said County and Commonwealth, personally appeared Kristine M. Faust, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendants are not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notices ofIntent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. ~~' Sworn to and subscribed before me this 3d day of Juij ,2001. Ho billA- qn(ag~CL Notary Public Notanal Seal Re~~ba G. Blazina, Notary Public ~r!l.h, Allegheny COunty My COmmission Expires June 2, 2003 Member, Pennsylvania ASSOCIation of Notaries , I-.'~ "-< ,'~" ,;.., ;-"""' '-;;iIiiilliIIl.lllis\t(,; IN THE COURT OF CItMON PLEAS OF CUMBERLAND co!ft" PENNSYLVANIA CIVIL DIVISION .. CHASE MANHATTAN MORTGAGE CORPORATION, Defendants. ) ) NO.:O 1-3083 ) ) ) ) ) ) ) ) ) Plaintiff, vs. RICHARD BARTLETT and SARAH BARTLETT, TO: Richard Bartlett 12 Rockway Drive Camp Hill, PA 17011 DATE OF NOTICE: June 13,2001 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 THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Ave Carlise,PA 17013 Phone (717)249-3166 800-990-9108 By: GRENEN & BIRSIC, P.C. ,~~-ilu~<- Attorneys for Plainti One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID ,.- , ~ ! . , I '.111. , ~ . . '- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, ) ) NO.:01-3083 ) ) ) ) ) ) ) ) ) Plaintiff, vs. RICHARD BARTLETT and SARAH BARTLETT, Defendants. TO: Sarah Bartlett 12 Rockway Drive Camp Hill, PA 17011 DATE OF NOTICE: June 13,2001 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 THIS NOTICE, A mDGMENT 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. IFYOUDO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Ave Carlise, PA ]7013 Phone (717)249-3166 800-990-9] 08 By: GRENEN & BIRSIC, P.c. 11 ~ Atto for PIa ntiff One Gateway Center, Nine West Pittsburgh,PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID -.-'- """""'~ill''J{T" . .,,=-- -' , , ~. . L J; I"" "-~ ~~L, ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:01-3083 Plaintiff, vs. RICHARD BARTLETT and SARAH BARTLETT, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Richard Bartlett 12 Rockway Drive Camp Hill, PA 17011 ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on 9. P,/ 4, 2/)(J L ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: $108,757.23 with interest on the Principal sum at the rate of $23.94 per diem from June 25, 200 I, and additional late charges, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. 9'1" O. 7tuCPL.'.J Deputy j I --. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.:01-3083 Plaintiff, vs. RICHARP BARTLETT and SARAH BARTLETT, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Sarah Bartlett 12 Rockway Drive Camp Hill, PA 17011 ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on 0. R> ts ;200 I. ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: $108,757.23 with interest on the Principal sum at the rate of$23 .94 per diem from June 25, 2001, and additional late charges, plus costs (including increases in escrow deficiency) anp for foreclosure and sale of the mortgaged premises. L4.yr. /J 'nu.Ph/ Depu .-- ~;f~_ " ,:).;j,~~"'"\9Ii',)Olhi'l1l1J#J.,-*I"fj,~';i,-;"",,,_;,,~,,,, ,,,,~:",,,&ii"'-"'_"".!_,,j,,~,,;'J,hr o"_:,,,c,~,--,'_,,',", .".;\_;",ltk'''''''''<;.if'4.hl:;fi,r",'i~filiIIl.iiJill~Wi''ilip~'~ffi-W~Oi'!IWl!.lU~l"W.iUili"i-li..'iI...~Jd'";;!J!imL~iiffl;<L'"""""_ r~' ~ .c: .... ~ v ~ " ~ \ "t(;: :~}J(~,'.~.1..".JJ[J.mJ!L'_"i!-,"~J. C'-, .,,--,-.~,~.!h,., k..- ;F ".\~;t ",<_, e'\'";_'<,:o."l,=r"'_~,~_,,_,,,"~~_,",~',',~ .. ,_,'" _le', '. ._~_'"'^'_,~_ ,,~o ,. ., -"'~. !:~ ~~:--~ a:''--;; ;-j:',_. r-:-2',,- C-l ',.-" .L ~ C t..' :::J "(' , " If I ... \~ It " , Ii'- , <:)- ...... c::) - ~- >- ~~ \,) .{:-- -'--' -~] -",,' ~ ft '" ~ d ~ , J j I ^ ' ~" " - ,-, ,-~~ "":1 . ~ .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION f PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment (XX) Other Chase Manhattan Mortgage Corporation File No. 01-3083 Civil Term vs. Amount Due $108,757.23 $ 13,638.13 (from6/25/01 to Sale) Richard D. Bartlett and Sarah Bartlett 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) 12 Rockaway Drive, Camp Hill, PA 17011 (see attached legal description) County, 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 05/..[4/02 I l Signature: Print Name: /~~ Kristine M. Faust Address: 1 Gateway Center, 9 West Attorney for: Telephone: Pittsburgh, PA 15222 Plaintiff (412) 281-7650 Supreme Court ID No.: 77991 (over) I '. , i. I I . I ""~~" I ..- , "'~ ..... r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. LONG FORM DESCRIPTION ALL that certain tract or parcel ofland with improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Rockaway Drive which point is 501.04 feet North ofthe northeasterly comer of Rockaway Drive and Palmer Drive at a dividing line between Lots No. 19 and 20, Block H on the hereinafter mentioned Plan of Lots; thence along the easterly line of Rockaway Drive North 42 degrees 20 minutes West 80 feet to a point at the dividing line between Lots No. 20 and 21, Block H in said Plan; thence along said dividing line North 47 degrees 40 minutes East 125 feet to a point on the westerly line of Lot No.5, Block H on said Plan; thence along the westerly line of Lots No.5 and 6, Block H on said Plan South 42 degrees 20 minutes East 80 feet to a point at dividing line between Lots No. 19 and 20, Block H aforesaid; thence along same South 47 degrees 40 minutes West 125 feet to a point, the place of beginning. HAVING thereon erected a single brick and frame ranch-type dwelling, said premises being known and numbered as 12 Rockaway Drive. AND BEING Lot No. 20, Block H in the Plan of Country and Town Homes, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Deed Book 7, Page 41. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. ~,,~~W ~"_ ~ ~ __ - u" ~ _lJ 1. ,I_~. .~ ,j "=' ... BEING the same premises which James W. Gutshall and Betina S. Gutshall, fi'k/a Betina S. Sweger, by Deed dated December 29, 1999 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 4, 2000, at Deed Book Volume 214, Page 439, granted and conveyed unto Richard D. Bartlett and Sarah Bartlett. DISTRICT 66 PARCEL NUMBER 13-25-0022-167 TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, right, title, interest, property, claim and demand whatsoever of the said grantors, as well at law as in equity, of, in and to the same. GRENEN & BIRSIC, P.C. BY:V~~L~~ Kris' M. Faust, s,quire Attomeys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 ,_"_,,' ""':c"",-o:.;",,-.~\f;:,h1rJ..;}u..."'~:c[bh.%,,,;j;~~Hmi;:#~k"ll.il!E!!ii!l!,jl::,A -- ~ -~ U j f~._.-itiilliiillti t ;-'t""'<.i~1IiU~ Hi" "'llWill!h_ ~ i ~ () T". '- ~ <.v '6q" ~ -iQ. Jl> - "- ~ (j'- 7' tv . ~ ~ ~ 6' if) 0 -<: 6 0 ~ C> (") 0 D 0 0 c ~ C) C f''0 () "t < ""D if~ ~-{l I ::r. f'- 6"- , I :::-"" ,-- 9f-;~1 -0 lv ~ [;J r f! zi2:"i -..< 0' 0 1'-,,) , , (r) )- '.0 ~ ... ...--'-. ::- ~ ~ ~'... .,~ , , ['...::-c, . --- (:) ~2~ 'T; , VI ::u: ()~ - .::. ~ b ;__"\.f -, , , ~.,J (jfll ... - .YLt- )~ ",-c... :;! r" 0'" ::0 -< ~" - "- -- ~~, -~--"~" , -, ~ ~-. - _"I ~~'-< - - ~,;".~ " ~~ - - ':~"j:; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-3083 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From RICHARD D. BARTLETT AND SARAH BARTLETT, 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011 (I ) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property ofthe 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 $108,757.23 Interest FROM 6/25/01 TO SALE - $13,638.13 Atty's Comm % Atty paid $123.44 Plaintiff Paid Date: MAY 29, 2002 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division Jly: A~ 0 . tl. 71f-)M-'V. r;-J)~ REQUESTING PARTY: Name KRISTINE M. FAUST, ESQUIRE Address: 1 GATEWAY CENTER, 9 WEST PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ill No. 77991 ~~ - - __ 1,_ '0' I :"i~ J ~~- ~ -',--. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D, BARTLETT and SARAH BARTLETT, Defendants. 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 on December 5, 2000, Defendants were mailed combined Act 91 and Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of1983 and Act 6 of1974, 41 P.S. 9101, et seq. ~ SWORN TO AND SUBSCRIBED BEFORE ME:HIS~DAYOF 1Yt~t IcJx;t)1jllR fu f2j1Uav~ Notary Public ~ ,2002. Notarial Seal bl' . Notar)' Pu Ie Rebecca G. Bla:tlOa, n County City of Ph"burg~. i\lI.g~~n~ 2. 2003 My commIssIon .wxptres . '__;.l\SSOCiationotNotanaa Mamoel,?aT\f\$~\'~- , . ~,,~~~~Jr~'~fu',t!I<J;,"j';\;ct:&,.;t~.,,'8ilI;11.",',;".b"'_"'ht,,~k"'J"-, cUL"U!L "j "';"_'~,"c,<l'.d!iio,,,_,h, A";"";'-'1""_,,,1j,frn@;iJtk~If.Ulliimil*lililti@<~~'"' ". ~_'.~'J_~ ~. ,,~" ~ ~," .' ,;- ,,-~, , ~lfi~" -'ItW:d~~'''''''''''''''''iIIll~,!Oi<'i~ .-.....'jj,~ o c ~~_ri !"111T i~ :-...:l -( c' r'J () -n _'u.. "~'l' --< ~= N \.0 -,"jfT1 ---'-1'~; ~~~~ %:1 >:~.'2 ~51;j ~~! ~..:: :J.'J -< ~,J ......;.~ N .'.....J. (~'\ . - ......... . ~ ""- '. ~ j- I""""",,,;, ~ "" ~'-.::.~{- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Faust, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 12 Rockaway Drive, Camp Hill, Pennsylvania 17011 are Defendants, Richard D. Bartlett and Sarah Bartlett, who reside at 12 Rockaway Drive, Camp Hill, Pennsylvania 17011, to the best of her information, knowledge and belief. ~Wjjl~ SWORN TO AND SUBSCRIBED BEFORE M~'fHJS~DAY OF ~ ,(11! //l ~fl / oK 1.;:;0 jI II..-' fJJol/1;UA- L Notary Public ,2002. Notarial Seal . Rebecca (3. Blazina, Notary Pubhc City of Pittsburgh. AlIegheoy ~o~~3 My Commi~slon Explres June, . Member, penl1sytvaniaAssociation ot NotaneS ,~.J~;~I5}~.t.~ll'~'Wfi"')_Mi",,-,:;&j&J.:c;:,;)\'L\Ftc!lk~fu~8.":ij.;:it;~m'~';L"A",'-"_I"V'''''"',"''';'''''_'<H-'''L!';--'ic'i"",*,!B;;~ia,;~WIIl1i11i~~- .,,;;' ,"'l_~:s_",RL.L~." ~, ""I""",,,,,,,",, ~ "~"c'.,?"'~, _'__<~"~__._'n"=_,,_"'-' '_~"".. "___,~.,, '",8 "" " _ -k_". ,,8 ~,~~ ~1!li!IlIM~!lll1liB:lt 1lf<<'1~~'I( 1> -,i_Ii:i)>;QI'" .." () CO () c: l",) --'-I ,) S':. 3': .., r.r:' ';,''> m n -'~ I"'!'; " Z :r i';;:': Z C N " (""l Ci] . \.0 \.~~ ~~\:~; - C) .. ~-D ,= -~, , ''', " .. " 0::':-[--", ~~ CO:. rSl ;.:J Ii"'; '" ~ -,-, :0 -< <n -< " ,- "" ",~",~",-.."~~" "" '--,- . : I , ' '" -, "< 'lWllt\c I. .. '~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiffin the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record conceming the real property of Richard D. Bartlett and Sarah Bartlett located at 12 Rockaway Drive, Camp Hill, PA 17011 and is more fully described as follows: ALL THE RIGHI, TITLE, INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY,PENNSYL V ANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, P A 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-]67. 1. The name and address of the owners or reputed owners: Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, P A 17011 2. The name and address of the defendants in the judgment: Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, P A 17011 'J .... ~h " .. & "' "J L I.~ . .~ . .,".J""ili."'fl;'. . f 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation [PLAINTIFF] 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, P A 17013 PA Dept. Of Revenue Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, P A 17128-0601 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. B~ Kri' M. Faust, squire Attorney for Plaintiff SWORN to and subscribed before me}hiS~day of ~ LLt ,2002. /~JJxU1( ,/1/ f)[~/iWU-- [ Notary Public J Notarial Seal _a G. Blazina. Notary Public City of Pittsburgh. Allegheny County My' Commission Expires June 2. 2003 Member, PennsylvamaAssoclellonolNotartes ;~ii>:~>l-liiI~t\ii.(l~i~"i""'i-:""'l>ji,'I&.jl',,;,"ii&","i~..i;~,l;o&.","0~:.",j.-,-~);,-<,:''''-cJi'''' :-~i,>-,,,,,"'"W,'h:ljh'f,,.,,,",,_,,,;,;a""'hi~.~W!m!. .H "",,'""""''''''''' . ." _.'" ~.' ~- ""."."'. , . .. _ H~ .0 - ~~ --- .'"~ '""-~'~-.~'I~'i4&L-..:>;~~ ~ ~i'j .' .. 0 ,~ 0 C ,".,) .-;1 --;;.'>' ., ;;:..,.. _i'" 92~!~.: ',"U ~ ::.....r;: ~1 i'v :TI ;::: :c (n '.0 C) 0< , r- ,- '. T_,\> ...-0::; ):~ -', c~ ~~ "'- s> S7'~ 0) (::) t,; -, :':3 '-' Y' (,' :..} -', -', ~ --,........." ~,. . 'I ,~ . < ,- -. "~' ___,;:1 -~_~~~i 't IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARDD. BARTLETT and SARAH BARTLETT, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Richard D. Bartlett 12 Rockaway Drive Camp Hill, P A 17011 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 he exposed to Public Sale at the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on Wednesday, September 4,2002 at 10:00 A.M., the following described real estate, of which Richard D. Bartlett and Sarah Bartlett are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-167. Ji~" " . _.l.,.,;.J , " J' _J, ^. J < '"~"-''''-::t- , , The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Richard D. Bartlett and Sarah Bartlett, Defendants, at Execution Number 01-3083 in the amount of$122,395.36. Claims against the property must be filed with the Sheriff before the above sale date. Claims to proceeds must be made with the Office ofthe 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 ofthe 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 WRlT 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, Cumberlaud COUlllty 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. ~ ,.~~"",,' - - '" I,~., - =-1 , [,I " " J"r'tn:il..*;i v 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. Ifthe 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 ifthe Sheriffhas not made a valid return of service ofthe Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOUMA Y 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 IDS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. BY~~ "'e F ,squire Attorney for Plaintiff L . II .-,' ...; ~-_@~i_ . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. LONG FORM DESCRIPTION ALL that certain tract or parcel ofland with improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Rockaway Drive which point is 501.04 feet North of the northeasterly comer of Rockaway Drive and Palmer Drive at a dividing line between Lots No. 19 and 20, Block H on the hereinafter mentioned Plan of Lots; thence along the easterly line of Rockaway Drive North 42 degrees 20 minutes West 80 feet to a point at the dividing line between Lots No. 20 and 21, Block H in said Plan; thence along said dividing line North 47 degrees 40 minutes East 125 feet to a point on the westerly line of Lot No.5, Block H on said Plan; thence along the westerly line of Lots No.5 and 6, Block H on said Plan South 42 degrees 20 minutes East 80 feet to a point at dividing line between Lots No. 19 and 20, BlockH aforesaid; thence along same South 47 degrees 40 minutes West 125 feet to a point, the place of beginning. HAVING thereon erected a single brick and frame ranch-type dwelling, said premises being known and numbered as 12 Rockaway Drive. AND BEING Lot No. 20, BlockH in the Plan of Country and Town Homes, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Deed Book 7, Page 41. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. , , ,I ,,',- d" l'_i I '.- ~ ~- ,'" ,'-~;; )' 'f BEING the same premises which James W. Gutshall and Betina S. Gutshall, ti'k/a Betina S. Sweger, by Deed dated December 29,1999 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 4, 2000, at Deed Book Volume 214, Page 439, granted and conveyed unto Richard D. Bartlett and Sarah Bartlett. DISTRICT 66 PARCEL NUMBER 13-25-0022-167 TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, right, title, interest, property, claim and demand whatsoever ofthe said grantors, as well at law as in equity, of, in and to the same. GRENEN & BIRSIC, P.c. BY:V~OLL~~ Kris' M. faust, squire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 _.i ,;jJi;W\\~IJ,Jij,*fi,~fliil~!J>1~".,-,~;;iii1"",".:l$",!i";~,;JrrliJ\;l~",,,;,.;'''_''i''''''llil&.ti;~_ .1"!-'~'.';;Wd_\~<:"i,"-.;\'';;;)&',''':'-ii'''~ill3B.'''~fJii'i!~I'.i:i<~W.llr>'~ [(11lAQ ~ .~~~_!tJllo<'.""'"="'~,\l.~~'<l"~~'< ,,%L ~-J OC __.~. ~:~"'~A'",~ ,,,_=, .c,~,,,-,,_~_ " '''^.-' ,""'-'~"" c. .."_,,-,, ^,,,,,"~,' C) Cl n C f--....) _o"h :~ ::;r: ~-;J -UU_-" .'CO "Tl n' ~:i '1 ," ""'" ,- "':'-... , ;-.,.) :--n Z '- ;::J (j) '.D -<. -~';~) ~--~. u ' " " ,:,--;:: c -"'~ (J,~(' ,,(..- ( " , 5> ( - :"...) -,.,. ::'1 0.) 5J -< 0' -< ,-, I. ' '_J~ .^,~, ~_, ~_ . .-..~ " -itl: " '. , '( oz .. ~~"~.,j~~, - / COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deeti in which Secretary ofVererans Affairs is the grantee the same having been sold to said grantee on the 6th day of No v A.D., 2002, under and by virtue of a writ Execution issued on the 29th day ofMav. A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 3083, at the suit of Chase Manhattan Mtg Com against Richard D Bartlett & Sarah is duly recorded in Sheriffs Deed Book No. 254, Page 4284. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 5' day of t19 fJ.r..) . A.D. 2002 ~fuA G. ~I ,.,..-.() . , ~J, Recor er of Deeds =C!I~~__. ~__"~ L -- L_, , -I-I ~~ ""'~ ~~.,,-' - 'I!. j;"",-~,,~i@!c,1 Chase Manhattan Mortgage Corporation VS Richard D. Bartlett and Sarah Bartlett In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3083 Civil Term Brian Barrick, Deputy Sheriff, who being dilly sworn according to law, st~tes that on June 13,2002 at 7:30 o'clock PM, he 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: Richard D. Bartlett, by making known unto Richard Bartlett, personally, at 12 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly swom according to law, states that on June 13,2002 at 7:30 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sara Bartlett, by making known unto Richard Bartlett, husband of defendant, at 12 Rockaway Drive, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 9,2002 at 3:15 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard D. Bartlett and Sarah Bartlett located at 12 Rockaway Drive, Camp Hill, Pennsylvania, according to law. 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 marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Richard D. Bartlett, by regular mail to his last known address of 12 Rockaway Drive, Camp Hill, P A 17011. This letter was mailed under the date of July 16, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being dilly swom according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Sarah Bartlett, by regular mail to her last known address of 12 Rockaway Drive, Camp Hill, PA 17011. This letter was mailed under the date of July 16, 2002 and never returned to the Sheriff s 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, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on November 6, 2002 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Kristine M. Faust for The Secretary of Veterans Affairs. It being the highest bid and best price received for the same, The Secretary of V eterans Affairs of 1240 East Ninth Street, Cleveland, OH 44199, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of$I,047.70, it being costs. ~~., -,'..... Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed ,-, " .J "~ L!OiiM,~"" 1,,-1 ~ ~~ , $ 30.00 20.54 15.00 15.00 30.00 10.00 .50 1.00 19.32 9.59 15.00 30.00 20.00 423.50 318.55 25.20 25.00 39.50 $ 1047.70 paid by attorney 11/27/02 Sworn and subscribed to before me So..~~: _ ~ This qlt! dayof AO,,,~ ~~,f~ ~ 2002, A.D. C1uL2. l1A,,,L,14' B'K. JtJ~ ~M~+lf) ro onotary Real Estate eputy (~ wP 3D .[JD ~I,~ U<:- 3'i' 0/3 &. /323G? - L_~. , I_I - ~.- \ ;,fiC,,;; , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiffin 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 Richard D. Bartlett and Sarah Bartlett located at 12 Rockaway Drive, Camp Hill, P A 17011 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY,PENNSYL V ANIA. HAVING ERECTED THEREON ADWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-167. 1. The name and address of the owners or reputed owners: t Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, PA 17011 2. The name and address of the defendants in the judgment: Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, PA 17011 "~-~ "~, ," -, 'I " ~"":;'lliIiUIil~--, . , 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation [PLAINTIFF] 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, P A 17013 PADept. Of Revenue Bureau of Individual Taxes fuheritance Tax Division Dept. 280601 Harrisburg, P A 17128-0601 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. ~ B : - . Kri' M. Faust, squire Attorney for Plaintiff SWORN to and subscribed before methiS~daYOf-.lYl,fl.~/ ,2002. , ///~, ~ 12' , / d<(tb&Ul(, / uLo/~ L Notary Public Notarial Seal Re\le<:Ca G. Blazina. NotaIy PubHc Ci!y of Pittsburgh. Allegheny Coun!y My-' Commission Expires June 2. 2003 Member. pennsylvenlaA9sociationotNotarIes ., ~- I LI , Jr&.iilM!j:~~" ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Sarah Bartlett 12 Rockaway Drive Camp Hill, PA 17011 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, P A 17013 on Wednesday, September 4,2002 at 10:00 A.M., the following described real estate, of which Richard D. Bartlett and Sarah Bartlett are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-167. _L~ U.~i \ . The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Richard D. Bartlett and Sarah Bartlett, Defendants, at Execution Number 01-3083 in the amount of$122,395.36. 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 Sheriffbefore 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 ofthe 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 TmS 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 Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. , I ........' 4;....rlUia~~~ , . 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 ofthe 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 ofthe 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 Sheriffhas not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution of service or demonstrate any other legal or equitable right. YOU MAY ALSO HAVE THE RIGHT TO HA VB THE SHERIFF'S SALE SET ASIDE IF THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE SHERIFF. GRENEN & BIRSIC, P.C. BY~ ,Kri . e M. a , squire Attorney for Plaintiff ",= j,,1 . ~"~h' , . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. LONG FORM DESCRIPTION ALL that certain tract or parcel ofland with improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Rockaway Drive which point is 501.04 feet North of the northeasterly comer of Rockaway Drive and Palmer Drive at a dividing line between Lots No. 19 and 20, Block H on the hereinafter mentioned Plan of Lots; thence along the easterly line of Rockaway Drive North 42 degrees 20 minutes West 80 feet to a point at the dividing line between Lots No. 20 and 21, Block H in said Plan; thence along said dividing line North 47 degrees 40 minutes East 125 feet to a point on the westerly line of Lot No.5, Block H on said Plan; thence along the westerly line of Lots No.5 and 6, Block H on said Plan South 42 degrees 20 minutes East 80 feet to a point at dividing line between Lots No. 19 and 20, Block H aforesaid; thence along same South 47 degrees 40 minutes West 125 feet to a point, the place of beginning. HAVING thereon erected a single brick and frame ranch-type dwelling, said premises being known and numbered as 12 Rockaway Drive. AND BEING Lot No. 20, BlockHin the Plan of Country and Town Homes, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Deed Book 7, Page 41. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. }~ O~ _ ;-.1 ~~- I. BEING the same premises which James W. Gutshall and Betina S. Gutshall, f/k/a Betina S. Sweger, by Deed dated December 29, 1999 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 4, 2000, at Deed Book Volume 214, Page 439, granted and conveyed unto Richard D. Bartlett and Sarah Bartlett. DISTRICT 66 PARCEL NUMBER 13-25-0022-167 TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, right, title, interest, property, claim and demand whatsoever of the said grantors, as well at law as in equity, of, in and to the same. GRENEN & BlRSIC, P.C. BY:V~L~~ Kris' M. Faust, squire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 J~ 1'1 ~- ~- ~'1G.Iai~" 't ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Richard D. Bartlett 12 Rockaway Drive Camp Hill, PA 17011 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 4,2002 at 10:00 A.M., the following described real estate, of which Richard D. Bartlett and Sarah Bartlett are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-167. .'~ - " "-'''''''f'I~~'' I . The said Writ of Execution has been issued on ajudgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Richard D. Bartlett and Sarah Bartlett, Defendants, at Execution Number 01-3083 in the amount of$122,395.36. 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, PA 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. ,-- ~ J '- ,.1 <iRilW l I . You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to hav:e the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriffhas 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. YOUMA Y ALSO HAVE THE RIGHT TO HA VB 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 DELNERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELNER 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. B~wL- , . .ne F ,squire Attorney for Plaintiff ^,~.."~" - "J - ....LI '_iif~i ~ \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. LONG FORM DESCRIPTION ALL that certain tract or parcel ofland with improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Rockaway Drive which point is 501.04 feet North of the northeasterly comer of Rockaway Drive and Palmer Drive at a dividing line between Lots No. 19 and 20, Block H on the hereinafter mentioned Plan of Lots; thence along the easterly line of Rockaway Drive North 42 degrees 20 minutes West 80 feet to a point at the dividing line between Lots No. 20 and 21, Block H in said Plan; thence along said dividing line North 47 degrees 40 minutes East 125 feet to a point on the westerly line of Lot No.5, Block H on said Plan; thence along the westerly line of Lots No.5 and 6, Block H on said Plan South 42 degrees 20 minutes East 80 feet to a point at dividing line between Lots No. 19 and 20, Block H aforesaid; thence along same South 47 degrees 40 minutes West 125 feet to a point, the place of beginning. HAVING thereon erected a single brick and frame ranch-type dwelling, said premises being known and numbered as 12 Rockaway Drive. AND BEING Lot No. 20, Block H in the Plan of Country and Town Homes, Inc., which Plan is recorded in the Cumberland County Recorder's Office in Deed Book 7, Page 41. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. . I '~! . BEING the same premises which James W. Gutshall and Betina S. Gutshall, f!kIa Betina S. Sweger, by Deed dated December 29, 1999 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 4, 2000, at Deed Book Volume 214, Page 439, granted and conveyed unto Richard D. Bartlett and Sarah Bartlett. DISTRICT 66 PARCEL NUMBER 13-25-0022-167 TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues and profits thereof; and all the estate, right, right, title, interest, property, claim and demand whatsoever of the said grantors, as well at law as in equity, of, in and to the same. GRENEN & BIRSIC, P.C. ~~~ - , By: v ' Kris' M. aust, squire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 ,~ \ , =. ~. __~" ,~.o " I 1 ~ . ,-. ~ ~,I ~'"'- .-c , ~, ~'-"-1f.,/; WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3083 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff(s) From RICHARD D. BARTLETT AND SARAH BARTLETT, 12 ROCKAWAY DRIVE, CAMP HILL, PA 17011 (J) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $108,757.23 L.L. $.50 Interest FROM 6/25/01 TO SALE - $13,638.13 Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid. $123.44 Plaintiff Paid Date: MAY 29, 2002 CURTIS R. LONG Prothonotary, Civil Division -Bv: ~o.....,..,p Q. 77('JMJV'~ % REQUESTING PARTY: Name KRISTINE M. FAUST, ESQUIRE Address: 1 GATEWAY CENTER, 9 WEST PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 . 6~,ftij{_~~1~+':l'11""j<.Ih.",j-'c'!;iJ"i"",wk)~Hlll"1M~iIY;;"t.jf~""40/."'~;';'''~'''! ,~'l":il~J:Iiii;;!'!W"ili:;!;!;.w::\iIllli:':C < - 1IlIIiII!I'&1oliOIli't &J;] I!ldil.Ll!Ilill,ltiltll(-"';'d"'''-'''~i "' '"' . i ~ t ~'"'~OtJ~aMlMil.~,~g,"" "~-~ t'! ( Real Estate Sale # 37 On June 6, 2002 the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A known and numbered as 12 Rockaway Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 6, 2002 By: J od.J-( J~ Real Estate Deputy ~ ~ ~. ~ ~ '.- \ " I ',i ~, -'1 'TI~' 3d 'I -" ~"",c ;;2;: V, ;,( \ \ OE kU\~ HII",., lljt\l;).W' ',' ",,(in;) '..".H" ... ,t ~~ "t',' ~;J.aV ,~:~fcl~;gJ;::;)!. - ~;,.'f"p, ""'""",""". '","~+,re~,".-_!,:v" ,j';!;,,-, "_,,,~ '" ,. .',", ~-?'H,""""?-" ?""""""".",- ,~, _ ",,' ,C" '. ~ ,,,. "" ,", ,. m lkti_~li!IlIl;i':-. , ... " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : 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: JULY 26, AUGUST 2, 9, 2002 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 , . . stateP"''1ts as to the, place and ch<p p' '1'>lication are true. ~tm SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 LOIS E~ NotIIyI'ldlllc C8rIlsI& 8010. Cumber\8nd CountY My CIlIM Inl~ ExpiIIG Mm:h S. 2005 J "-!!iti_~!iliiiiI""ill'illH'iHjI;.",~\$J'-#.;H;4.,<W"oI.1Ill0llft(lt_,J;H~"-<-,~S';i'",,,)!'i''';;,~J.-~i!#''''''''-;~V'll'~OliJ~1iiiH~- ~ 'I:-,':I\.!..- ~'_'" l': -,1_~/E NO. 37 Writ No. 2001-3083 Civil Chase Manhattan Mortgage Corporation vs. Richard D. Bartlett and Sarah Hartlett Atty.: Kristine M. Faust LONG FORM DESCRIPTION ALL that certain tract or parcel of land with improvements thereon erected. situate in Lower Allen Town- ship. Cumberland County. Pennsyl- vania. more particularly bounded and described as follows: BEGINNING at a point on the easterly line of Rockaway Drive which point is 501.04 feet North of the northeasterly comer of Rocka- way Drive and Palmer Drive at a dividing line beDiveen Lots No. 19' and 20, Block H on the hereinafter mentioned Plan ofl.ots: thence along the easterly line of Rockaway Drive North 42 degrees 20 mlnutes West 80 feet to a point at the dividing line between Lots No. 20 and 21. Block H in 'Said Plan: thence along said dividing line North 47 degrees 40 minutes East 125 feet to a point on the westerly line of Lot No.5, Block H on said Plan; thence along the westerly line of Lots No. 5 and 6, Block H on said Plan South 42 de- grees 20 minutes East 80 feet to a point at dividing line between Lots No. 19 and 20. Block H aforesaid; thence along same South 47 de- grees 40 minutes West 125 feet to a P.Qwt tbe, oJace of beginning. , ... ~ HAVING-thereon erected a single brick and frame ranch-type dwell- Ing, said premisoIllilelng known a1)d numbered as 12 RockaWay Drive. AND ","JNO w( No. 20, Block H Iu me Plan of Country and Town Homes, Inc.. which Plan is recorded in the Cumberland County Record- er's Office in Deed Book 7. Page 41. UNDER and SUBJECT. never- theless. to easements. restrictions, reservations, conditions and rights of way of record. BEING the same premises which James W. Gutshall and Betina S. Gutshall. f/k/a Belina S. Sweger. by Deed dated December 29. 1999 and recorded in the Office of the Recorder of Deeds of Cumberland Couniy on January 4. 2000, at Deed Book Volume 214. Page 439. grant- ed and conveyed unto Richard D. Bartlett and Sarah Bartlett. DlSTRlCf 66 PARCEL NUMBER 13-25-0022-167. TOGETIJER with all and singu- lar the buildings, improvements, ways, streets, alleys, driveways, pas- sages. waters. water-courses, rights, liberties. privileges. hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging. or in anywise appertain- ing, and the reversions and remain- ders. rents, issues and profits there- of; and all the ""state, right. right. title. interest. property, claim and demand whatsoever of the said grantors, as well at law as in eq- uJiy. of. in and to the same. '-J~ ~ , " ~ ""'~il~iM~_ -, I - THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controiler 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 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 ail 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 July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that ail of the ailegations 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 severaily 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 Misceilaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#37 ..,,'....~.....~................................................. Sworn to and sub Nolanal Seal Terry l. Russell, Notary, Public City Of Hamsburg, Dauphm Coo My Commission Expires June 6, 2006 NOT- RY PUBLIC Member.pennsyivaniaAssociationOfNota~y commission expires June 6, 2006 CUMBERlAND COUNTY SHERIFFS OFRCE 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 $ 316.80 1.75 318.55 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.................................................................... ~~ . ~ ~~^' .~,> " r, -~ \ " '1.,"" ," , , REAL ES'rATE SALE No. 37 Writ No. 2001-3083 . Clvll Term Chase Manhattan Mortgage Corp. .. vs Richard D. Bartlett and . Sarah' Bar:tlett AttY: Krlst'ne M. Faust DESCRIPTION -' ' ALL THAT certain tmct or parcel of land with impro1,'cmeut.s tbert:uu e.rected, !.ituate in Lower Allen Town~p, Cumberland ('Qunty, Pellll.~ylvania, niore particularly bounded and de.<;eobcd as follows: BEGINNiNG :;1"a ~oint on (he easterly line of R9:Cka.\lf~'_D[i.~'J whIch pointi; 501.04 feet N~ ot the nO~terly comer cir Rockaway Dnve Olnd,Palmer Hrive at a divjdi~ line between Lots No.. t9 and" 20, Block: H"Q11 the hereinafter mentl.bnedPJ'lll of Lots; thence along the easterly Ible of Rockll'way Drive North 42 degree5 20 mil:mtesWest 8fAfeetlo a poinlat the dividing linc. l:1ctween Lol~ N(.\ 20 and 21. Block H ill ~aJd Plan; theucc aIM, ~aJd dh'iding line North-l.7 degrees 40 minute! i.ast j25 feef to apoinl on the 'i':~'ltetly line of 1 ~.,jt);5. Block if on o,:a.ld Plan; . lbencealong lhc +rly linenfLot)NI. 5 and 6, Block, H 011 ':1Ud " _, ,1 'Sooth 42 :rlegre~ 20 " ,niitUlt.es East Jru...fec. to :i {Klint at dividing H,ne bel\;.'een Lots No. 19 and 20, Block H aforesaid; 1h~n(,_~_~ong ~ame S",jI.l'~ j7 d~ 4O.mlnlltes, We~1 125 teet to . ',1.,d,nl,...,the place ox BEGINNING. ,. HAVING thereon metet' j a 5~lDpe lineK and frnme rnnch-type dWE'~:ling, sa id...gremise$' being known al:Jdnumbereda~12Rc . ViOlvDrive.- AND BE}1\;G Lot No -'lcK 1-1 'iD.tbe Plan of CoUlltry and Town .",Y~lch Pian is recorded In the C, '!4,y R~rder's Office in Deed1300k r " . UNDER 'AND Sl, ieles~. to 'w'ement", restrictions, midi'lions ami rights of way of eeeOl- B,EING the Mme premL Gutshall and B~tirla s. G.u~ , 'S'v.'ege!; by Deed datr:d Dect. rerordedinlhe0fl1ceof!he& Olmberland County on JanuarY -, ~,~\:;.. \fI;iurpe ,-214, ,P~p 43'7.. .,''''',U;U; ,,"... ':""0m:~.Y~(L unto Ri~hard D. BarlJett mid Sarah ':,:Ba41~t!,... """"""""."."."."...:.",,,.,,...,,::',:,,. , ',', JmiTRICfMp,iRO'L NUMllER 13-25-0022- ~')q1~.." ',' \: :A',' , :,:::, .. ':, " ' :,~~1fER, with all .'l1Id singular the bl.1ildtng.~J ''i~prq~:emellts., Ways, ,~Ireet~ alleys, driv"'Ii~~'!i,. :tla~sages, waleffi, water~{}u(ses, righL~, lJbeill\'~, "prlvileges, hercditanlen~ and appUrtenariccs, wha!!ioever unto the hereby granted pre'mise; befonging, or in atIYWlre appemining, and the , reversions and remaindc!s,rents, issues and profits thereof; and all lhe estate, right, right, title, interest, property, claim and demand wh:tt"lM,\'e, cl the siiif grnnlors, as well lit law a:; In equity, of, JrtuamUo1he~EJ!lC:._______ __ __u_ ___,_______ , ..-c_" --... ~ ""'8'"" .. , ~- I "' " 'O"~ - _ -," t.ll'ii:i~i!k!, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA / CHASE MANHATTAN MORTGAGE C0RPORATION, Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. Sale Date: 9/4/02 CIVIL DIVISION ) ) NO.: 01-3083 ) ) ISSUE NUMBER: ) ) TYPE OF PLEADING: ) Pa. R.C.P. RULE 3l29.2(c)(2) ) LIENHOLDER AFFIDAVIT OF ) SERVICE ) ) CODE- ) ) FILED ON BEHALF OF PLAINTIFF: ) ) Chase Manhattan Mortgage Corporation ) ) COUNSEL OF RECORD FOR THIS ) PARTY: ) ) Kristine M. Faust, Esquire ) Pa. LD. # 77991 ) ) GRENEN & BIRSIC, P.c. ) One Gateway Center, Nine West ) Pittsburgh, PA 15222 ) (412) 281-7650 ) ) ) ) ) ) ) " . .., '__I ~-, ","" -'&"""""'Waiwi.' ".. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. Pa. R.C.P. RULE 3l29.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Faust, Attomey for Plaintiff, Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows: 1. By letters dated May 30, 2002, 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 Pursuant to Rule 3129.1 and Certificate of Mailing and any letters, if returned as of this date, are marked Exhibit nAn, attached hereto, and made a part hereof. --~-~ j'l '-""- ',' ~ ,-.:~o, " .JI. 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: Kris me M. Rust, Esquire Attomeys for Plaintiff Nine West, One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIs~i- DAY OF () 1 I ff)f-f ,2002. /adkt!J rj 1ii~hL Notary Public" Notarial Seal Rebecca G. Blazina, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2. 2003 Member, PennsylvanIa AsSOCiation of Notanes , -L-L. Q '.... Exhibit n An. .'" ~_ "'-1. ~ '\~"L , I.. ~, , , ~~ ~ ~~ ..""....J~;;~ . '. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 01-3083 Plaintiff, vs. RICHARD D. BARTLETT and SARAH BARTLETT, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiffin 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 Richard D. Bartlett and Sarah Bartlett located at 12 Rockaway Drive, Camp Hill, P A 17011 and is more fully described as follows: ALL THE RIGHT, TlTLE,INTEREST AND CLAIM OF RICHARD D. BARTLETT AND SARAH BARTLETT OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN LOWER ALLEN TWP., CUMBERLAND COUNTY, PENNSYL V ANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 12 ROCKAWAY DRIVE, CAMP HILL, P A 17011. DBV 214, PAGE 439, AND PARCEL #13-25-0022-167. 1. The name and address of the owners or reputed owners: Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, PA 17011 2. The name and address of the defendants in the judgment: Richard D. Bartlett Sarah Bartlett 12 Rockaway Drive Camp Hill, PA 17011 .li " '~-J. .&~,,' . . . 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Manhattan Mortgage Corporation [PLAINTIFF] 4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland County Domestic Relations P.O. Box 320 Carlisle, P A 17013 PA Dept. Of Revenue Bureau ofilldividual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. ~ B : ~ . Kri' M. Faust,- squire Attorney for Plaintiff SWORN to and subscribed before me}hiS~day of.-1Yl ny, 2002. /J ' / d<JhtUlt ,0/ f)L{f/~ I..- Notary Public ~ Notarial Seal Rebe<:<a G. Blazina. Notary Public City of Piu,burgh, ,,!lIegheny CoonI)' My-- CommISSIon Expires June 2. 2003 Memller, PennsylveOlaASSllCiationolNolanes ", ~-",,:._.., u.s. POSTAL SERVICE ~ J., I . . - . ""~ - - J~~ !i1:i'tI:,; CERTIFICATE OF MAILING ," .. .. MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE POSTMASTER Received From: GRENEN & BIRSIC. PC ON GATEWAY CENTER NINE WEST , One piece of ordinary mail addressed 10: ' I , C-~ m~\orrl (!Dunn j ~m~nG ela ., emS p..O. 06)( ,3:;lD Co I'A PS Form 3817. January 2001 1\66 l5-cVlfll tiJr+teH u.s. POSTAL SERVICE CERTIFICATE OF MAILING Affix fee here in stamps meter pos.tage and marl(.lnql:iireof 1 ~erfor._current ~ i..:'-, ~_: MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: GRENEN & BIRSIC. PC ONE GATEWAY C u.S. POSTAL SERVICE CERTIFICATE OF MAILING Affix fee here in stamps 'or mete! J)osta~ and postm<!lI<.lnqUire'"af ;' , ostml:!sler for Current . ;fee. . MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT _ PROVIDE FOR INSURANCE POSTMASTER Received From: GRENEN & BIRSIC, PC ONE GATEWAY CENTER NINE WES DI PS Form 3817, January 2 t:( Cs'lb lo-:' CVlF71 i:;l\i1djl,*iilliO!lkiiMi,.il!.illlli!&;t.&ci.H~~~~~iollillil!l.,df.l!ll>.illj;h~,..~..,~!.sJ""&'i''''lliilll~~ll'!ifT r ~."d""""""lliIil<'.-~'o.""'~i:!ll,,~\ai,ll<!l;;~_~__ .- 0 C:r 0 c: f"..) "7) ~ > :.:::.! -0 no n; C(; c.'") ~l r~! Z 2-': f;c I rn W)> CO :2'''''''' _.~~ :~ C) " r;-l.> _n.' ~~~ " -" (!~~ .>->,,--.. ::t~ Z'~.,<' S;:;",-! c,.) "'--~rn f..J --'7 "--1 4- >- -,~ ....< 10 :D -< sAJ,.LJ ~lj!!lJ""","N'.,., ,__c~~~ . c.", ,,,,,,,n,L"'!'i'M7.'''',,''.,,,,- .'.'. ,,' .-8" ,",1'_,_, .,",-;: '.'~".,~,,-, " '''' '~."'h ". _,( ,,~.,"" ,',.'_~~ ~ , 'H. '0"'__"'-'0' ".~ ,~'" .'" ,"tfr.'.'C'.._" >e. - ., -I I , i I 1 ~~,.~,~ -.