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Home My WebLink About03-2762 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. DEBRA I. SCUDDER a/k/a DEBRA E. SCUDDER, Defendant. TO DEFENDANT You are hereby notified to plead to Ihe ENCLOSED COMPLAINT WITIUN TWENTY (20) DAYS FROM SERVICE HEREOF /;).:c-..2LL~y-:h{a/{ c-{ {Ox..-/ ATTORNEY FORPLAmtwF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 34t5 Vision Drive Columbus, OH 432t9 AND THE DEFENDANT IS: I 803 Walnut Bottom Road Newville, PA 1724t ~~OLG~(a~UtJ-,J A TIO NEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 1803 Walnut Bottom Road Penn, P A (CITY, BORO,(TOWNSH1~ (WARD) ,/ {,.uJUA.u)i tz<<- (.(..~ A RNEY FOR pLAINTIFF NO.: 04 -~71,A.. e,'uiLY€P-h-J TYPE OF PLEADING: CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: Plaintiff, vs. DEBRA I. SCUDDER a!kIa DEBRA E. SCUDDER, Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 Phone (800)990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CNlL DNISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, NO.: O~ - C"u~CT~ vs. DEBRA I. SCUDDER alk/a DEBRA E. SCUDDER, Defendant. CNlL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219. 2. The Defendant, Debra I. Scudder, alk/a Debra E. Scudder, is an individual whose last known address is 1803 Walnut Bottom Road, Newville, Pennsylvania 17241. 3. On or about November 30, 2001, Defendant executed a Note in favor of Plaintiff in the original principal amount of $70,443.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about November 30,2001, as security for payment of the aforesaid Note, Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $70,443.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 11, 2001 in Mortgage Book Volume 1741, Page 4224. 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. Defendant is the record and real owner of the aforesaid mortgaged premises. 6. Defendant is 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. Defendant is due for the February 1, 2003 payment. 7. Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. g16800403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12U.S.C. ggI707-1715z-18) [35 P.S. g16800401C(a) (3)]. 8. Plaintiff was not required to send Defendant written notice of Plaint iff's intention to foreclose said Mortgage pursuantto 41 P .S. g403 (Act 6 of197 4) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. g 101 and Defendant is not a "residential mortgage debtor" as defined in 41 P.S. glOl. 9. The amount due and owing Plaintiff by Defendant is as follows: Principal Interest to 6/5/03 Late Charges to 6/5/03 Escrow Deficiency to 6/5/03 Corporate Advances Attorney's fees Title Search, Foreclosure and Execution Costs $69,665.50 $ 2,085.35 $ 123.57 $ 46.00 $ 82048 $ 1,250.00 $ 2.500.00 TOTAL $75,752.90 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of$75,752.90 with interest thereon at the rate of$13.36 per diem from June 5, 2003, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. BY: ~hLac (/-yf/}..( t2~ (,( c<l7C-- Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Exhibit" A" '. . ORIGINAt . . NOTE FHA Case No 4416751628703 17902583 1179025837 November 30, 2001 0- 1803 WALNUT BOTTOM RD, CARLISLE, PA 17013 "'-"'~ I. PARTIES ~Borrower. means each person slgmng al the end of ibIS Note, and the person's successors and assigns, "Lender" means CHASE MANHATTAN MORTGAGE CORPORATION and Its successors and assigns. 2. BORROWER'S PROMISE TO PA Vj INTEREST In return for a loan received from Lender, Borrower promlses 10 pay the principal sum of Seventy Thousand, Four Hundred Forty-Three and 00/100 Dollars (U .S. $ 70 , 443 . 00 ). plus interest, 10 the order of Lender Interest will be charged on unpaid pnnclpal, from the date of dlsbursemem of the loan proceeds by Lender, at the rate of Seven percent ( 7. 000 %) per year unlil the full amowJt of pnnclpal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or surular secunty InslI11lJ1CTl.t thai is dated the same date as thiS Note and called Ihe "Security lnSln1menI.. That Security Instrument protects the Lender from losses WhIch ought result If Borrower defauhs under thIS NOIe. 4. MANNER OF PAYMENT (A) Timo Borrower shall make a paymenl of pnnclpal and mterest to Lender on the first day of each month beginning on January 1, 2002 Any principal and mterest remauung on the firsl day of December, 2031 . will be due on that date, wbtch IS called the lnlIIunly date. (B) Place Payment shall be made at 200 OLD WILSON BRIDGE RD COLUMBUS, OH 43085 or at such other place as Lender may deslgJ1llte in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in Ilie amount of U S $ Four Hundred Sixty-Eight and 66/100 468.66 This amount Will be pan of. larger monthly payment required by the Secumy Instrument, Iliat sball be applied to principal, mterest and other Items in the order described m Lhe Secunty Instrument. (D) Allonge to this Note ror Payment Adjuslments If an allonge provldmg for paymenl adjustments IS Cx.ccuted by Borrower logether with this Note, the covenantS of the allonge shall be incorporated IOta and shall amend and supplement the covenants of this Note IS if the allonge were a pan of thiS Note. 5. BORROWER'S RIGHT TO PREPAY Borrower has !he nghllo pay the debt evidenced by thiS Note, 10 whole or in part, Without charge or penalty, on the first day of any month. Lender shall accepI prepayment on other days prOVided that bonower pays interest on the amount preplld for the remamder of the mon!h to the extent required by Lender and pernutted by regulations of the Secretary. If Borrower makes a partial prepayment, there Will be no changes In the due date or in Ihe amount of the monthly payment unle" Lender agrees In wntlDg to those changes 6. BORROWER'S FAll..UR.E TO PAY (A) Late Charge tor Overdue Payments If Lender has DOt rccc:lved the full monthly payment reqUired by Ihe Security Insuument, as described in Paragraph 4(c) of this Note by the end of fifteen calendar days after the payment IS due, Lender may collect a late charge In the amount of 4% of the overdue amount of each payment. (B) Default If Bonower defaults by falling to pay In full any monthly payment, then Lender may, except as limned by regulations of the Secretary in the case of payment defaullfl, reqUire immediate paymmt 10 full of the principal balance remaining due and all accrued interest. Lender may choose not 10 exen:ue tIus oplJon without waIVing ItS nghts in the event of any subsequent default. In many circumstances regulations issued by the Sec~ary Will limit Lender's nght to reqUire unmediate p.yment 10 fulllD the case of payment defaullfl. ThiJ Note does not au!horize acc.cleration when not pennitted by HUn regulations. As used lD this Note, -Secrewy" means the Secretary of HOUSIng and Urban Development or his or her designee FHA MULTISTATE FIXED RATE NOTE C.1302(l1196)~lot'l (RqllxaII96) . . . . (C) Payment ot Costs and Expenses If Lender has required immediate payment in full, as descnbed above, Lender may requlfC Borrower to pay costs and expenses including reasonable and customary attorney's fees for enforcing this Note to the extent not prohibited by apphcable law. Such fees and costs shall bear interest from the date of disbursement at the same nte as the principal of thu Note. , . WAIVERS Borrower and any other person wbo bas obhgallons under this Note waive the righlS of presentment and notice of dishonor. "Presentment" means the righllo require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to orner persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law reqUlres a different method, tUly notice that must be given to Borrower under this Note Will be given by deli venng It or by mailing it by first class mad to Borrower at the property address above or at a wfferent address If Borrower has given Lender a notice of Borrower's different address. Any nOllce that must be given to Lender under this Note will be given by first class ttla11 to Lender at the address stated 10 Paragraph 4(8) or at a different address If Borrower IS given a notice of thai different address. 9. OBLIGATIONS OF PERSONS UNDER TInS NOTE If more lhan one person SignS thIS Note, each peoon is fully and peoonaily obiLgated to keep ail of the promises made m thiS NOle, mcludmg the prormse to pay lhe full amount owed Any person who IS a guarantor, surety or endorser of this Note is also obligated to do these thmgs. Any person who takes over these obilgalions, includlllg the obhgations of a guarantor, surety or endorser of lhlS Note, IS also obligated to keep all of the promises made in lhls Note. Lender may enforce ItS nghts under this Note against each person indivldually or agamst all signatones together Anyone person signing this Note may be required to pay all of the amounts owed under thiS Note. BY SIGNING BELOW, Borrower accepts and agrees 10 the terms and covenants contained In lhts Note. ~~1~ B E SCUDDER WIlIIOOI' IlB:llllRSE PAllO tHE 0IlIIEI Of: CHASE IIAIlIIIITAIl ~~.~~ ~ 13-. U (ZtrlG.-- FHA MULTISTATE FIXED RATE NOTE C.7:10211l196)Pqe2of2 (RI!!pIKaII96) Exhibit "B" "~._"._'"--,_.-~. --,-~..... ..--..,. Ih~' file)\- dJ( '1 ",'ORIGINAL Record and Return to: CHASE MANHATTAN MORTGAGE CORPORATION 1500 N 19TH STREET MONROE LA 71201 ATTENTION: FINAL CERTIFICATIONS GrI~. ~L ~ !':':'O,' "'_ ~ ,,;- ::::EDS "c!I.OERLMiu COUNTY-fA '01 DEe 11 AM 8 ~~, THIS MORTGAGE ("Security Instromenn is given on The: Mortgagor is DEBRA E SCUDDER, UNMARRIED November 30, State or Pennsylvania MORTGAGE whose address IS 1803 WALNUT BOTTOM RD, CARLISLE, PA 17013 ,eBorrower~) ThIS Secunty Instru.ment is given to CHASE MANHATTAN MORTGAGE CORPORATION which IS orgarnzcd and existing under the laws of the State of New Jersey ,and whose address IS 343 THORNALL ST EDISON, NJ OB837 ,("Lender"). Borrower owes Lender tbc:princ1pa1 sum of Seventy Thousand, Four Hundred Forty-Three and 00/100 Dollars (U.S. $ 70, 443 . 00 ). This debt is evidenced by Borrower's Note dated the same date: as thiS Secunty Instrument (MNoIC"), which provides for monthly payments, With the full debt, if not paid earher, due and payable on December 1, 2031 . This Security Instrument secures to Lender. (a) the repayment of the debt evuJenced by the Note, with mterest. and all renewals, extensiOns and modific:al1ons of the Note; (b) the payment of all other sums, With interest, advanced under paragraph 7 to protccltbe secunty 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 desc:nbed property located in CUMBERLAND County, Pennsylvarua: See Attached Legal Description B Fi? 0" .... .... ,'~ " ~..::- ct; I~' ,..,C)., ';:''7'1' r- : ~ . J ~C.~. 0'\..." o .."t/ S,....j: ....,.. ~Q';-' , ,.,.""-1 ;E ~ .ct> "'" <n which has the address of 1803 WALNUT BOTTOM RDt CARLISLE, PA 17013 TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenanc:es. and fUtures now or hereafter a part of the property. All replacements and additions shall also be covered by tlus Secunty Instn.unent All of the foregomg is referred to m thiS Sec:unty lnsuumem as the -Property.- BORROWER COVENANTS that Borrower is lawfully sascd of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and thai the Propeny is uDCDCUlllbcred, except for CDClImbranccs of record Borrower warrants and will defend generally the utle to the Property against all clauns and demands, subject to any encumbrances of record. PENNSYLVANIA FHA MORTGAGE C-3701 (1196) (Replaces 1196) PAGE 1 OF S BK' 741 PG4224 . . t Tlus SECURITY INSTRUMENT combmes umform covenants for national use and non-uniform covenants with linuted vanations by JurisdIction to coru;titutc II umform secunly instrument t:OVenng real property. Borrower and Lender covenant and agree as follows: UN1FORM COVENANTS: 1. Payment of Principal, Interest and Late Char1:e. Borrower shall pay when due the pnnclpal of, and mterest on, the debt eVIdenced by Ihe Note and laIC charges due under the Note 2. Montbly Payment or Taxes, ]~. and Otber CIlareeS. Borrower shall InClude In each monthly payment. together With the pnnclpal and interest as set forth In the Note and any latc charges, II sum for (a) taxes and special assessments levied or to be levied against the Propeny, (b) leasehold payments or ground rents on the Property, and (c) preanums for insurance required under Paragraph 4. In any year m which the Lender must pay II mortgage insurance premium to the Secretary of Housing and Urban Development (.Secretary~). or In any year in which such premium would have been requn-ed If Lender still held the Security Instrument, each monthly payment shall also include either: (i) a rum for the annual mortgage Insurance premium to be pll1d by Lender 10 the Secretary, or (11) a monthly charge mste2d of a mortgage Insurance premium if thlS Secunty lostrumentl$ held by the Secretary, In a reasonable amount to be deterrmned by the Secretary. Except for the monthly charge by the Secretary, tbese Items are called -Escrow hems" and the sums paid to Lender are called -Escrow Funds- Lender may, at any tune, collect and hold amounts for Escrow Items in an aggregate amount not to exceed tbe maxunum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. 12601 ~ iS9 and Ilnplcmcnting regulations, 24 CFR Pan 3500, as they may be amended from tune to tune rRESPA"), except thai. the cushion or reserve penmtted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available In the account may not be based on amounts due for the nKlrtgage InSurance premium. If the amounts held by Lender for Escrow ltems exceed the amounts pcmuned to be held by RESPA, Lender shall account to Borrower for the excess funds as requlI"Cd by RESPA If the amounts of funds held by Lender at any tunc are not suffiCient to pay the Escrow Ilems when due, Lender may noufy the Borrower and require Borrower to make up the shortage as permitted by RESPA The Escrow Funds are pledged as additional s<<unty for all swns secured by this Secunty 1nstrumcnt. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be Crediled with the balance remammg for all installment Items (a), (b) and (c) and any mortgage insurance prenuum Installment that Lender has not become obligated to pay to lbe Secretary, and Lender shall promptly refund any excess funds to Borrower. lnunedntely pnor to a foreclosUIe sale oflbe Property or its acquisition by Lender, Borrower's account shall be credited With any balance remaining for all Installments for Items (a), (b) and (c). 3. Applia.tlOD or Payments. All payments under Paragraphs 1 and 2 shall be applied by Lender as follows: FusI. 10 the mortgage UlSurance prenuum to be paid by Lender to the Secrelary or to the monthly charge by the Secretary inslead of the monthly mongage IDsurance premium, ~. to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard msurance prenuums, as required; Thud, to mtereSt due under the Note; Fourth, to amortlUtion of the prInCipal of the Note; and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard lnsunmce. Borrower shall insure all improvements on the Property, whether now In existence or subsequently erected, agll1DSt any hazards, casualues and COntlngenclcs, lDeludlng fire, for which Lender requues UlSurance. Thts Insurance- shall be IJllIlnwned m the amounts and for the periods that Lender requires. Borrower shall also lIlSW'C all unprovcmc:nts on the Propeny, whether now m existence .or subsequently erected, agllDSt lass by tloods to the extent required by the Secretary All insurance shall be carned With companies approved by Lender. The InSurance poliCies and any renewals shall be held by Lender and shall include loss payable elauses in favar of, and in a fonn acceptable to, Lender In the even! .of loss, Borrower shall give Lender irmnedlate nouce by mail. Lender may make proof of Iou if not made promptly by Borrower. Each insurance company concerned is hereby aulbonzed and drrected to make payment for such loss dtreC1ly to lender, instead of ta Borrower and to Lender Jaintly. All or any part .of the msurance proceeds may be applied by Lender, at Its .option, either (a) to the reductlan .of the indebtedness under the Note and thiS Secunty Instrument, first to any dehnquent amounts apphed In lhe .order In Paragraph 3, and then ta prepayment of prmclpal, or (b) to the restoratian or repa1t of the damaged propeny. Any apphcatlan of the proceeds 10 the pnnclpal shall nat extend or postpone the due date .of the monthly payments which are referred 10 In Paragraph 2, or change the amount of such payments. Any excess Insurance proceeds over an amount reqUired to pay all outstanding Indebtedness under the Note and this Security Instrument shall be paid to the entity leaally entitled thereto. In the event of foreclosure .of tJus Security Instrument or other transfer of title to the Property that extmgulshes the indebtedness, all nght, title and interest of Borrowt:r in and to insurance poliCIes In farce shall pass to the purchaser. 5. Occupancy, Preservation_ Maintenance and Proleetiou of the Property; Barrewer's Loan Applieatioo; Leaseholds, Borrower shall occupy. establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or Within sixty days of a later sale or transfer of the Property) and shall conllnue to occupy the Property as Borrower's pnDClpal residence for at least one year after the date of occupancy, unless Lender determines that requirement Will cause wulue bardsbip for Borrower, or unless exte.ouatmg circumstanCeS eXist which are beyond Borrower's control. Borrower shall nolify Lenders of any extenuating Circumstances. Borrower shall not commit waste or destroy, damage or substantlally change the Propcny 01 allow the Property to deteriorate, reasonable wear and tear excepled. Lender may IOSpect the Property If the Property IS vacant .or abandoned or the loan is In default. Lender may lake reasonable action to protect and preserve sucb vacant or abandoned Property. Borrower shall also be In default if Borrower, during the loan apphcation process, gave materially false or inaccurate Infarmation or statements to Lender (or faIled to proVide Lender with any marerial mfanna!tOn) m connection with the loan eVldenCed by the Note, mcludlng, but nat lunited to, representatlons concerning Borrower's occupancy .of the Property IS a principal residence. If thiS Secunty Instrument is on a leasehold, Borrower shall comply With the provisions of the lease. If Borrower acqulJ'e:S fee title 10 the Property, the leasehold and foe title shall 001 be merged unless Lender agrees to the merger in wnting.(j, Condemnadon. The proceeds .of any award or chum for damages, d1rect or consequential, in connection with any condemnat1on or other taking .of any part of the Property. or for conveyance in place of condemnation, arc hereby asslped and sball be paid to Lender to the extent of the full amount of the indebtedness that remains unpllld under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction .of the indebtedness under the Note and this Security I:nstrumenl:. first to any dehnquent amounts apphed In the .order proVided In Paragraph 3, and then to prepayment of pnncipal. Any applicauon of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which arc: referred ta in Paragraph 2. or change the amount .of such payments. Any excess proceeds over an amount reqwred to pay all outstanding indebtedness under PENNSnVANlAFHA MORTGAGE C-J701 (1196) (RepIa~, 1196) PAGE 2 OF S BK 1741 PG4225 . . th.:iN""ote and. this Secunty Instrument sball be plUd to the entity legally entitled thereto 7. Cbargelii to BolTOwef and Protection of Lender's Ripts In.he Property. Borrower shall pay all governmental or municipal charges, fines and imposillOns that are not Included m Paragraph 2. Borrower shall pay these obligations OD tune dlleclly to the entity which is owed lhe payment If failure to pay would adversely affect Lender's mterest in the Property, upon Lender's request Borrower shall promptly furnish 10 Lender receipts eVidencing these payments. If Borrower fails 10 make these payments or the payments required by Paragraph 2, or fails to perfonn any other covenantli and agreements contauled in thiS Security Instrument, or there is a legal proceeding that may sigmficantly affect Lender's rights m the Propeny (such as a proceeding m bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights m the Property, Including payment of lues, hazard InsUrance and other items mentioned 111 Paragraph 2. Any amoums disbursed by Lender under Ibis Paragraph shall become an additional debt of Borrower and be secured by this Secunry Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at lhe option of lhe Lender. shall be immecbately due and payable. Borrower shall promptly discharge any lien which has pnonty over lhis Security Instrument unless Borrower: (a) agrees m wntmg 10 lhe paymenl of lhe obhgation secured by the hen ill a manner acceptable to Lender, (b) contests lit good faith the hen by, or defends against enforcement of lhc lien in, legal proceedmgs which In the Lender's opinion operate to prevent the enforcement of the hen: or (c) secures from the holder of the lien lID agreement sallsfactory to Lender subordmating the lien to this Secunty Instroment. If Letlder deternunes Ibat any part of the Propeny is subject to a lien which may attain prionty over this Security Instrument, Lender may give Borrower a notice Identlfymg the hen. Borrower shall satisfy the lien or take one or more of the actions set fonh above Wlth10 10 days of the giving of notice. S, Fees. Lender may collect fees and charges authonzed by the Secretary. 9. Grouads for Acceleration or Debt. (8) Default. Lender may, except as limited by regulations Issued by the Secretary in the case of payment defaults. reqwre unmediale payment in full of all sums secured by thiS Securily lnstrumetlt if (i) Borrower defaults by fallmg 10 pay m full any monthly payment required by thiS Secunty Instrument pnor 10 or on Ibe due date of the next monthly payment, or (ii) Borrower defaults by fading, for a period of thlny days, to pe~onn any Olher obligations contaIned In thiS Security InstllllJlCIlt. I (b) Sale Without Credit ApproYBI. Lender sball, if permitted by applicable law (mcludiog section 34l(d) of the Gam-St Gennain Depository Instirotions Act of 1982, 12 U.S.C. 170Ij-3(d)) and with the pnor approval of the Secretary. require Immediate paymem 10 full of all sums secured by thiS SeCurity Instrument if: (I) All or part of the Property, or a benefiCial interest In a lru5t ownmg all or part of the Propeny, is sold or olherwise transferred (other than by devise or descent), and Oi) The propeny IS not OCCUpied by the purchaser or grantee as his or her principal fCSldence, or the purchaser or grantee does so occupy the Property, but bis or ber credit bas not been approved In accordance with Ihe reqUirements of the Secretary (c) No Waiver, If Circumstances occur Ibat would permit Lender to require unmed1a1e payment lit full, but Lender does not require such payments, Lender does not WlUve Its nghts With respect to subsequent events. (d) Re&uiations or HUn Secretary, In many circumstances regulatiOns issued by the Secretary wllllimill..ender's rights in !he case of paymenl defaults to require IRunediate payment 10 full and foreclose If lJOI. paid This Secunty Instrument does not authonze acceleration or foreclosure If not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if thl! Security Instrument and the Note are not determined to be ellAlble for U1SI1rance undct the National Housing Act Wlthm 60 days from the date hereof, Lender may, &IllS option require immediate payment In full of allaWllS secured by ibiS Secunty InSll\1ment. A written statemenl of any aulbonzed agent of the Secretary dated subsequent to 60 days from the date hereof, declinmg to msure thiS Security Instrument and the Note, shall be deemed conclUSIVe proof of such meligiblhty. NotwilhstaDdmg the foregolOg, thiS option may nOl be exercised by Lender when the unavatlabIhtyof insurance IS solely due to Lender's f81lure 10 remit a mortgage insurance premiwn to the Secretary. 10. Reinstatement. Borrower has a nght to be reinstated If Lender has required unmedwe payment 10 full because of Borrower's fallure to pay an amount due under the Note or this Security Instrument. This nght applies even after foreclosure proceedmgs are Instituted To reinstate the Security Instrument, Borrower shall tender In a lump sum all amounts requrred to bnng Borrower's account Currenl mcludmg, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorney's fees and expenses properly associated wllb the foreclosure proceeding. Upon remstatc:ment by Borrower, this Secunty Instrument and the obligations that II secures shall remain in effect as if lender had not reqwred immccbate payment In full However, Lender is not required to permil reinstatement If: (i) Lender has accepted reinstatement after Ihe commencement of foreclosure proceedings withm two years Immediately preceding the commencement of a current foreclosure proceedmg, (it) reinstatement Will preclude foreclosure on different grounds in the future, or (iii) Te1l1Statement Will adversely affect Ih~ prionty of the lien created by this Securily Instrument. 11. Borrower not Released; Forbearana by Lender not . Waiver. Extension of the time of payment or mochfication of amol'l1zat1On of the sums secured by thiS Security Instnunenl granted by Lender to any successor in interest of Borrower shall DOl operate 10 release Ihe hablluyof Ibe ongmal Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedmgs aglUnst any successor In interest or refuse to extend time for payment or otherwise modify amortlZltlon of the sums secured by thIS Security lnstrument by reason of any demand made by the original Borrower or Borrower's successors 10 mterest. Any foroearana by Lender 10 exercising any nghtor remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Slpers, The covenanu and agreements of this Security Instrument shall bind and benefit Ibe successors and assigns of Lender and Borrower, subject 10 the provlsioll! of Paragraph 9(b). Borrower's covenants and agreements shall be Jomt and several. Any Borrower who CO-SIgns this Secunty InslIUment but does not execute the Note: (a) is co-sIgning this Secunty lll!tnunent only to mortgage, grant and convey that Borrower's interest In Ibe Property under the terms of this Secunty Instrument; (b) is not personally obligated to pay the sums secured by thIS Secunty Instrument; and (c) agrees that Lender and any other Borrower may agree to extend. modify, forbear or make any accommoda1ions wtth regard to the terms of this Security Instrument or Ihe Note without that Borrower's consent. 13. NotictS. Any notice to Borrower provided for in thIS Security Instnunent shall be given by delivering it or by mailing it by first class mall unless apphcable law requu~ 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 mad to Lender's address stated bereio or any address Lender designates by ootice 10 Borrower Any notice proVided for in this Security Instrument PENNSYLVANIA FHA MORTGAGE C-3701 (7196) ~n 1196) PAGE 3 OF 5 BK 1741 PG4226 . . \ ...ill"; <\<<;;.. Ulba" _ ",von Ul Bonow<< 0' Lond" wheo glvon" provWod .. m" puag,aj>h. ,,-~-' --_..,,-,,-~-"~.. -'''''.-'- ..-~_...-.-._-_....- .._~..._...__...-._-_.,,_..........- -.......- .~_....-,~--_._'-"- .. -'~' -_......-.....--'~-- ". --. -..............-..-.-....... .--"'''- _..-..--~...__.- ~"'-'.--- ~.......~-_..".,....-..._'. -,....-.--..-.-..-.-........-- to","",,,,,_Ofm.?t<>P"'Y- . _.._........._-,.._--_.~....... _.__._...-.__.__._~. ....-"....-.... .-_.._.._.__.~. _....--..--_._._._.._~. -,,"" -""," ""00' itl-- wob En""'-" \.OW, ....~_...... ~- -"'" .....-' .........-' --~_.-- ~~.-.-_....--_...- -_.....~---_._--- .....- ...._~....-~--,.__._......~_._.- Of envuonllw:tlla!. prtl\ecuon. \ NON_UNIfORM CO'iE"^",S ""_ on<! '-""'" futlIt" ",v_t on<! .."e .. lo\low, ". -'- -----..........--.. - --....................-------..... -...-......-- -....-......-'............ -...-..---..---.---..-..... ...........--. --....-.-.--.'-' addll10nal SCCUntj onlY, ........-''''''- .........,.- .......-..... .........~..._.....-..__........._._-- ......,.-,-,.,--..-.....-.--......-- on ~'s 'IIrltttn~ \0 lhe teaam. _.._....-.....-..-..._..~-- 1-<Od" from .....\oing its rl&"ts under Ill" P"..""" \1. .... ~,.._...._.~_.._.__._..-..... .- _.......__.....~....-_..- ~_.- ...-....................-.......... --......-... ,"""",aI' wbontlte <lebl _"'" by m' _rllY \n~- ~ patdlnlull. .........- ._--_.~-_..--- ,~--'-"'- -.....-......--....... -_.~_..._.....-_.__.__..- petndtted by appl.\d.ble law. .."-'- .--- ............ _........-- _.~--"'''''''' -................. .--.....- --~...,-"'.."._....,._._--- .~.--_.~.-._.... -....-.-.... -~_.~--_.._--_..._- ..- --..--.........-....---... _..---~ ."'-_.---~_..._.-- _g. ,0 ""_,,, ""now" """ p'y any _,.ati.. """. .. - _..._......_~.~~--~_._.- ............----.........-.---....- ......\0. of ."e, _Ion from .._t. ''''' on<! ",.. ... _eod "".,.non. ,,_...... ...--.--.-"............-.. "'_"""".t.lbldding....betllf, """'IlI"",,p_'UlIll~-rl" \~. .. --- ........-....--.-.-........ Ul Ill' PfOI'C"" Ill" SccorilY !.,,,um"" ...",.",. pu""........, _a&" . ----. --....----....-.......... .r to .. ",... 01 UlOt\&.ge lored'''''' """ .", tlte tat. payabl. frott't.... to """ under tlte Note. . ..........-- ...----.----..... --..---.---...---........--. "'v_ on<! ~ 01 tlII' Scc.rllY ""........,.. Utlle rldo<\') w....part oltlll> Se<>trlty \0$\"'''''''' The <ollowin9 riders are attached' NO RIDERS l>TIl>cRED \ BI( \ 74 \ PG4227 \ \ . . BY SIGNING BELOW, Borrower accepts and agrees to the tenns contained in tillS Securily Instrument and In any rider(s) executed by Borrower and recorded with It. The Borrower certifies that a true copy of the mongage has been receiVed DE~~~~P COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On llus 30th day of November I 2001 subscnber, a Notary Public In and for the Commonwealth of Pennsylvania, residing in came tM above-named subscnber(s), DEBRA E SCUDDER, UNMARRIED '" ,before me. lhe "'" aoknowl<dg" the w;tlun mdenture 01 Mon..., m bo the" ro _.~. Cd to be recorded as such. WITNESS my ~and~~"F aforesaJ.d. -~ ~. rIA. f[ .~ JI'U ' NotARIA.L SEAL bile I My conunlSlllon expires CARRIE E cOOK. NO:6;'~lV ~ Ka,rt,bUlg, DOU:. Mg. I. 2002 '" MY commld1on E:lP - j, ~ ,"",",,,,,,,,,,,,,,",,Certify this 10 be recorded -.--- IC'. ",,~..,,",. J1 Ul11uerland County P A ~..--":"<"~~ ~ 'l j:::~; ,,; ~, ". Recorder of Deeds PENNSYLVANIA FHA MORTGAGE C.3701 (7M) (Rq)laccsl19(i) PAGE $ OF' BK 1741 PG4228 . . '. ALL that certain house and lot of ground situate in the Village of Centervi11e, Township of Penn, County of Cumberland and Commonwealth of Pennsylvania, ~unded on the north and east by property now or fonnerly of Arnold A. Shenk; on the south by the Slate Highway Roote No. II; and on the west by property now or fonnerJy of Holbert A. Myers, and having thereon erected improvements. the said lot of ground being more particularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (formerly State Highway Route No. ll); thence North 66 IS degrees East 3.85 pen:hes to a point on bridge; thence North 17 % degrees West 16.3 perches to. _e; thence South 70 1-\ degrees West 9/10 perches to a stake; thence North 17 % degrees West 8/10 perches to a stalce; thence South 70 IS degrees West 5.1 perches to a stake; thence South 2S ~ degrees East SA5 perches to an old stwnp; thence South 24 % degrees East 11.9 pen:hes to the Place of BEGINNING. . CONT AlNING ninety six perches, more or less. I !:'(:;~:~;:~~~~~?A:';:::\t~0~i::~~>.tr",:~~;;o",::;;c~~>~:~;:~~'~O:~\:7'~,"", ,. ~~'. 'C,,,,,: :; ':'1 '..;........",'........ ......... 'Of ~,~..". .''''., u ,'. ~ ,;..' . ~... . , '~ ..~.'....N \, " ... .~ ,', '., ..~\~"., ~ '; ,..... ~.. ". ; ,"'~" . , ''',.,.,''.'' ,",\, "\",'y\; .:',,,,,,,. .:..: \. .~\ '~"~' ".~ -. ~ .,' ;'1 h. : ;,,,. " <<-'.' '\':""\" ",'\\. ....,,\'," .)- '.\.., .~. . ... ,."". ~.: \'.', ...-' ,'1 ' . ,. ".. - . .... . .:.., : ,. '," w" :. ~ ~. " ~.' . ...,...... , ", . " ,,,. :. .......:,'i.,~,'-.-': ..~.'. ~';'::~''",'-,~:~'_~"~",'','",,:,'",:''-''','',,,_''''p,,~.....:~.,..,.-~~,_'..,.l._',','~,::....i,~_..._.,,:~,':,'- .~;.,.,,~_:.~rt;.>"_.,~.:-.,~~...:-;.~.._;.~;,~,..,,~'~.\.',-;,.,"~..:.:*".".i_".;.:".:.:.\::~;:~i '~~'~~~'~;~~;~~"~i~:~~;;..;-\~\'.~~,.", -:. ''>''~'" ~~ .' ~ . _ .' , . . " , ". ... " '.. .. ...... ,....~ ..'.,..... :~~,.~-<:'.~.'...,... .., .....,..- ~ . - . . ~._.. ~_"."__C"';'-""_"" "~,,<-:,,-..,::.,..~.-,, :,-,~.,. . ''';';.'~_'''.>.'..... .~ _ ~~. ...~...\~',/..,:c,,_:..~;.\:...:.., -: ....:.{i....\ .. ,,_".' -., .-...... .' " ~ - ',M' ,........ , .\" ~ . BK 174/ PG4229 Verification DAVID LOVETT 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 are true and correct to his information and belief. ca4~ ' DAVID LOVETT ' ssistant Secretary iVPiQ. ~i ~ '- .....:) ~ ~ II) 0 ~ lI't :c) ~f~ ~ -< '-" J- ' C) ,-- r ' , , 'J ., ',," </1 t -<. (;) , c, SHERIFF'S RETURN - REGULAR CASE NO: 2003-02762 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SCUDDER DEBRA I AKA DEBRA E SC 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 SCUDDER DEBRA I AKA DEBRA E SCUDDER DEFENDANT , at 1143:00 HOURS, on the 18th day of June at 1803 WALNUT BOTTOM ROAD NEWVILLE, PA 17241 GREG SCUDDER, HUSBAND by handing to a true and attested copy of COMPLAINT - MORT FORE the , 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.21 .00 10.00 .00 34.21 Sworn and Subscribed to before <C> me this 30 ~ day of fh:. J4J.3 A. D . n . - () 7Ju1.1h ~ ^ LatA. "- ~thonotary , -r-J So Answers: r~~4 R. Thomas Kline 06/19/2003 GRENEN & BIRSIC By: \J~ ~ Deputy Sheriff ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. ISSUE NUMBER: DEBRA I. SCUDDER alk!a DEBRA E. SCUDDER, TYPE OF PLEADING: Defendant. PRAECIPE FOR DEF AUL T JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: I hereby certify that the address of Plaintiff is: Chase Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219 COUNSEL OF RECORD FOR THIS PARTY: the last known address of Defendant is: Kristine M. Anthou, Esquire Pa. I.D.#77991 1803 Walnut Bottom Road Newville, P A 17241 GRENEN & BIRSIC, P.C. One Gateway Center 9 West Pittsburgh, PA 15222 (412) 281-7650 GRENEN & BIRSIC, P.C. J).L b.?"--"r.(),(j:ZLL~L'7L-- Atbmeys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA I. SCUDDER aIkIa DEBRA E. SCUDDER, Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Debra I. Scudder aIkIa Debra E. Scudder, in the amount of$76,485.35, which is itemized as follows: Principal Interest to 7/22/03 Late Charges to 7/22/03 Escrow Deficiency to 7/22/03 Corporate Advances Attorneys' fees Title Search, Foreclosure and Execution Costs $69,665.50 $ 2,718.86 $ 148.55 $ 102.96 $ 99.48 $ 1,250.00 TOTAL $ 2.500.00 $76,485.35 with interest on the principal sum at the rate of$13.36 per diem from July 22,2003, 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/~( (~S};(tt7 /LL,.cl~ ~~e M. Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service ofthe United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. ~ ) , ' ~ J VVLJLLWiC(lIL--C' ':7. <-- / ,'--<,,~-- Sworn to and subscribed before me this~2.nd day of JLUJj ,2003. '+lbLuk 4~LO,j~0~l~ Notary Public' ' COMMONWEALTH OF PENNSYLVANIA NOOllial Seal RebeCCa G. B1azJna, NotalY PublIC Ci1y Of Pi\lSbUrgn. Allegheny County My eommlsSion Expires June 2, 2007 Member.penns~nla_Of- . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, NO.: 03-2762 vs. DEBRA 1. SCUDDER alkla DEBRA E. SCUDDER, Defendant. TO: Debra I. Scudder, alkla Debra E. Scudder 1803 Walnut Bottom Road Newville, PA 17241 DATE OF NOTICE: July 9,2003' IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COUR TYOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DAlE OF THIS NOTICE, A JUDGMENT MAYBE 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 Avenue Carlisle, PA 17013 Phone (800)990-9108 GRENEN & BIRSIC, P.C. FIRST-CLASS MAIL, POSTAGE PREP AID By: ~O-i (/~/( U,.(.C/(' tP-~ Attdmeys for Plaintiff One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 ~~ i ~ _ _ D F ~ -J 0 ~ ~ ~ ~ @ ~ - 12 ~ --F -'" " ",J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, ISSUE NO.: vs. DEBRA 1. SCUDDER alkJa DEBRA E. SCUDDER, TYPE OF PLEADING: Defendant. Praecipe for Writ of Execution (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa.I.D. #77991 GRENEN & BIRSIC, P.C. Firm #023 One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA I. SCUDDER aJk/a DEBRA E. SCUDDER, Defendant. PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary SIR/MADAM: Please issue a Writ of Execution, directed to the Sheriff of Cumberland County, against the Defendant, Debra I. Scudder, aJk/a Debra E. Scudder, as follows: Principal Interest to 12/10/03 Late Charges to 12/10/03 Escrow Deficiency Corporate Advances Attorneys' fees Title Search, Foreclosure and Execution Costs $69,665.50 I $ 4,584.88 $ 273.45 $ 968.66 $ 133.48 $ 1,250.00' $ 2.500.00 TOTAL $79,375.97 GRENEN & BIRSIC, P.C. By: V;'y~('<2L L A..hh( a,( ( ,( [1J Atto~eys for Plaintiff ,~ ~~.~ p r ~ ~ Lb ~ ~ ~ ~ ~ ~~ l e. +- -- ~ d J r ,5l. --- ~ ~ 52. ~ ~t" t~ ~ 2:' ~ 6 ;:~); .~ /. -; ,--.- ff! :F2 ...:t:- .- c.-~~' .;;: :~ :..J Jl -." .j;-' ~< . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA I. SCUDDER aJk/a DEBRA E. SCUDDER, Defendant. 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 Debra I. Scudder located at 1803 Walnut Bottom Road, Carlisle, P A 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN PENN TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, CARLISLE, PA 17013. DBV 249, PAGE 2762, AND PARCEL #31-29-2524-001. 1. The name and address of the owner or reputed owner: Debra I. Scudder 1803 Walnut Bottom Road Carlisle, P A 17013 2. The name and address of the defendant in the judgment: Debra I. Scudder Debra E. Scudder 1803 Walnut Bottom Road Carlisle, PA 17013 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, PA 17128-0601 Commonwealth ofPA Dept. 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 : n/<ll.U,/...J/tl ~ u h..../ y: /("- Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN to and subscribed before me this?.Jk. day of Jepfr ml:JvL ,2003. wi /XU[( 9 &a ~i<{,Uc. Notary Public U COMMONWEALTH OF PENNSYLVANIA \ Nctatial Seal RebecCa G. Blazina, Notary Public CIty Of PI\lSbUlgh, Allegheny County My CornrnI:sSIOn Expires June 2, 2007 Wember, Pennsytvanla Association Of NotarieS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA I. SCUDDER aIkIa DEBRA E. SCUDDER, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Debra I. Scudder aIkIa Debra E. Scudder 1803 Walnut Bottom Road Carlisle, P A 17013 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, December 10, 2003 at 10:00 AM., the following described real estate, of which Debra I. Scudder is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA I. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN PENN TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, CARLISLE, PA 17013. DBV 249, PAGE 2762, AND PARCEL #31-29-2524-001. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Debra I. Scudder alkJa Debra E. Scudder, Defendant, at Execution Number 03-2762 in the amount of$79,375.97. 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 of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office ofthe Sheriff. This paper is a notice of the date and time of the sale of your property. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 TELEPHONE: (717) 240-6200 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection, you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service ofthe Complaint and Notice to Defend or ifthe 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 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 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. By: ~~, 0 c ( /. &?l({2tC (',,(' i:'v..-/ Kristme M. Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA 1. SCUDDER aIkIa DEBRA E. SCUDDER, Defendant. LONG FORM DESCRIPTION ALL that certain house and lot of ground situate in the Village of Centerville, Township of Penn, County of Cumberland and Commonwealth of Pennsylvania, bounded on the north and east by property now or formerly of Arnold A Shenk; on the south by the State Highway Route No. II; and on the west by property now 'or formerly of Holbert A. Myers, and having thereon erected improvements, the said lot of ground being more particularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (formerly State Highway Route No. 11); thence North 66Y, degrees East 3.85 perched to a point on bridge; thence North 17% degrees West 16.3 perches to a stake; thence South 70Y, degrees West 9/10 perches to a stake; thence North 17% degrees West 8/10 perches to a stake; thence South 70Y, degrees West 5.1 perches to a stake; thence South 25 Yo degrees East 5.45 perches to an old stump; thentte South 24Yo degrees East 11.9 perches to the place of beginning. CONTAINING ninety-six perches, more or less. BEING the same premises which Eugene C. Cromer and Nedra L. Cromer, by Deed dated November 30, 2001 and recorded in the Office of the Recorder of Deeds of Cumberland County on December II, 2001, in Deed Book Volume 249, Page 2762, granted and conveyed unto Debra 1. Scudder. GRENEN & BIRSIC, P.C. -;/-~. . /, By:L-- I. " Q U ,c(/h(c.[ A::t,{ {.)c--' Krls . e M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222. (412) 281-7650 Parcel No. 31-29-2524-001 (") C 7. C.J -:,j () 1-; '1') '1 J (=1 :.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 03-2762 Civil Plaintiff, vs. DEBRA L SCUDDER aIkIa DEBRA E. SCUDDER, Defendant. 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. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 1803 Walnut Bottom Road, Carlisle, Pennsylvania 17013 is Defendant, Debra L Scudder, who resides at 1803 Walnut Bottom Road, Carlisle, Pennsylvania 17013, to the best of her information, knowledge and belief. \/1:WU 1Lj41 a It. {,(. &K-- SWORN TO AND SUBSCRIBED BEFORE ME THIS J4l'- DAYOF }epkmmt cJ at/' Cc qjj{(/j t tAL^-- Notary Public ,2003. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rebecca G. Blazina, Notary Public CIty Of Pittsburgh. Allegheny County My CommissIon Expires June 2, 2007 Member. Penns~nia Association Of Notaries o c.;:. , ->~j -<, "0 J t:.:.~ 7;" :, ~~~ :...> J:-j -< ..r~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION CHASE MANHATTAN MORTGAGE CORPORA nON, NO.: 03-2762 Civil Plaintiff, vs. DEBRA I. SCUDDER aIkIa DEBRA E. SCUDDER, Defendant. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.I01. 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 Commonweallh, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. S 1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. SSI701-1715z-18) [35 P.S. S 1680.401 C(a)(3)J. Additionally, Plaintiff was not required to send Defendant written notice of Plaintiff's intention to foreclose said Mortgage pursuant to 41 P.S. S403 (Act 6 of 1974) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. S 101 and Defendant is not a "residential mortgage debtor" as defined in 41 P.S. S 101. SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ DAY OF y.jJlt filUM /';;!a){i1.~ ( 1-jLaN?U~ Notary Pub~c L. ~{ ,k. ur((L/u/. ex.- ,2003. COMMONWEALTH OF PENNSYLVANIA NoIaIiaI Seal Rebecca G. Bial'Jna, Notary Public CIty Of PlllBborgl, Allegheny County My CommIssIon EJcptres June 2. 2007 Member, Penne>"vania Association Of Notaries (') ;z t- c: ":h (/) " ~ J ( '::~t :.,.) .!:~. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2762 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy Ihe debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From DEBRA L. SCUDDER a/k/a DEBRA E. SCUDDER, 1803 WALNUT BOTTOM ROAD, CARLISLE PA 17013. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 1803 WALNUT BOTTOM ROAD, CARLISLE PA 17013 (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 gamishee(s) that: (a) an attachmenl has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the accounl of Ihe 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 direcled to notify him/her lhat helshe has been added as a garnishee and is enjoined as above stated. Amount Due $ $69,665.50 Interest TO 12/10/03 = $4,584.88 L.L. $.50 Atty's Comm % $1,250.00 Due Prothy 1.00 Ally Paid $116.21 Other CostsLATE CHARGES TO 12/10/03 = $273.45: ESCROW DEFICIENCY = $968.66: CORPORATE ADVANCES = $133.48: TITLE SEARCH, FORECLOSURE AND EXECUTION COSTS = $2,500.00 Plaintiff Paid Date: SEPTEMBER 10, 2003 CURTIS R. LONG (Seal) ProthO~tary JI j~ By: j~ ~~I'~ REQUESTING PARTY: Name KRISTINE M. ANTHOU , ESQ. Address: ONE GATEWAY CENTER, NINE WEST PITTSBURGH PA 15222 Attorney for: PLAINTIFF Telephone: (412) 281-7650 Supreme Court ID No. 77991 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, ISSUE NUMBER: vs. DEBRA 1. SCUDDER, a/k/a DEBRA E. SCUDDER, NO.: 03-2762 Civil Defendant. TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE CODE- FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. 1.D. #77991 GRENEN &. BIRSIC, P.c. One Gateway Center Nine West Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 12/10/03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, NO.: 03-2762 Civil vs. DEBRA I. SCUDDER a!kJa DEBRA E. SCUDDER, Defendant. Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Anthou, Esquire, Attorney 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 ofreal property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows: I. By letters dated September 18, 2003, 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 conect copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. . 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: .f{~'J L c i-;n ((1 C(A ()K/ Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Nine West Pittsburgh, P A 15222 (412) 281-7650 Sworn to and subscribed before methis~ayof ~ g<prmOP(),2003. ())d\) D'C' ; 0'>\ f] ~ o'\l. s.~)~ Notary Public COMMONWEALTH OF PENNSYLVANI,c\ O Notarial Seal PalJida A T01M1send, Notary Public City Of Pittsburgh. Allegheny County My Comrnission Expires June 2, 200.= Member. Pennsylvania Association Of Notar;; EXHIBIT A . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DMSION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER a!k/a DEBRA E. SCUDDER, Defendant. 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 Debra 1. Scudder located at 1803 Walnut Bottom Road, Newville, P A 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA I. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN PENN TWP., CUMBERLAND COUNTY, PENNSYL V ANlA. HA VlNG ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PA 17241. DBV 249, PAGE 2762, AND PARCEL #31-29-2524-001. 1. The name and address of the owner or reputed owner: Debra I. Scudder 1803 Walnut Bottom Road Newville, PA 17013 2. The name and address ofthe defendant in the judgment: Debra 1. Scudder Debra E. Scudder 1803 Walnut Bottom Road Newville, PA 17013 . . 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 ofthe 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, PA 17013 PA Dept. Of Revenue Bureau of Individual Taxes Inheritance TaX Division Dept. 280601 Harrisburg, PA 17128-0601 Commonwealth ofPA Dept. 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. ~4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. BY~~c2 C L 1'chtt1.:.. (/ ~ Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN to and subscribed before me this y-fl.. day of .:fed anbu..... - , KtWil( 9 f!i~!ftU<- Notary Public ~ COMMONWEALTH OF PENNSYLVANIA NoIartal Seal Rebecca G. Blazina. Notary Public CIty Of Pittsburgh, AJlegheny County My Commission Expires June 2. 2007 Member, Pennsytvanla Assodslion Of Notaries .2003. u.s. POSTAL SERVICE CERTIFICATE OF MAILING Afflx fee heritptstal1lPS or mste,r POS~fl and postl!!8rk.ln~of Postmaster fot!:~rrent Ie.. MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE POSTMASTER B!'iceivedFrom: GRENEN & BIRSIC ONE GATEWAY CENTER, One piece of ordinary mail addressed to: CvM \?\:?1Z-U\i00 C.OvlVl'! j2.ELAT\ ())J <; r.o. 00'1; ::>20 CAILU'SLE, PA I '10\ ~ (fQ:) PS Form 3817, January 2001 '1'7y'1?8" ~ NDS u.s. POSTAL SERVICE CERTIFICATE OF MAILING 'Affjxfee"are'~_stamps orme~~and postri'llirk. Inquire of Pos~ter for~curtenl fee. ' Received From: ,"~ '"' MAY BE USED FOR DOMESTIC AND INTERNATIONAl MAil, DOES NOT PROVIDE FOR INSURANCE POSTMASTER c PA Department of Revenue Bureau ofIndividual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, PA 17128-0601 - ... " PS Form 3817, January 2001 'l?'-17?~ ~ A)D S @ u.s. POSTAL SERVICE CERTIFICATE OF MAILING Aff!x fe~hore in;slamps onneter stage and pqstmartt..nquireof PoslmasteF-for current re~. ' RElceivedFrom: GRENEN & BIRSIC ONE GATEWAY CENTER, --... 000 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, P A 17105 PS Form 3817, January 2001 ~ '1'5-'-175'3 ~ NDS ~ c. c.~ ;P' -r) !" lT1 f, 2::,1-' 7:::1, (1.\, -<:., " t;::C ~ .:c:~ f" L,;...,. 110"-' )?~,. /" -'-j ...< C," L: :.; "- C) -II , ,I'" \..0 r. f,.J ~'t~l ::..1': r:? :..:> .::- .~; c:') ;;_;\1'1 .~.., ~ -<.. Chase Manhattan Mortgage Corporation VS Debra 1. Scudder a/k/a Debra E. Scudder In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2762 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Kristine Anthou. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Law Journal Patriot News Law Library Prothonotary Postpone Sale Share of Bills 30.00 12.07 15.00 15.00 15.00 20.00 17.94 260.75 179.17 .50 1.00 20.00 28.90 $ 615.33 paid by attorney 03/01/04 Sworn and subscribed to before me So Answers: This 3M.... day of'Jna.uv r~ ~ 1'< ~.:c.;. !I fl. ' R. Thomas Kline, Sherifr ...-..- 2004, A.D.l-)uf< l..4. ~ I ~BY Jrr-AJAi,~, i.f.-L Prothonotary Re~ i;lt:;;;;.. '- 'v \ ,~ .\~ 4c\I-IS .;> VV . 'I) Q2w. \ ~ 'I j. . ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin l ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assl. Controller 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..Ibe... Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verity this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#63 .....~............ ~this 19thdaYV~ ~RY PUBLIC '\";!i~'... .: 1jt,I!..__"1ll~1iIlIiIe iA'\IIo_!if'~'ll!WIiIlIlI,*"'" tf..Jc ~,~~,4/.\of .":JI~~ ..~,w .lIIlliool.... .........-..... of ." ....~I"I.rJ.r!;~F _'W..~ ...~t1~"'~=~ Publisher's Receipt for Advertising Cost ~~~~.~4il't~,.,...,.I:JO., publisher of The Patriot-News and The Sundav Patriot-News. newspapers of general ~':~~:J...t== Ige receipt of the aforesaid notice and publication costs and certifies that the same have ..N.iih li:ll~:' &110 pelclIes t<l a .~. ,',.;if1..'~" '~~~I"J!'*=.:.lI.J By "'. -,.. .................................................................... ilos!'.~/!i....1<lllll""'_ .,,' . . .llaRIO~lIi..PlI<o<if "',' .....:'....,..'.:.i", .... .,':_ ,_....'., ~~~..lIa. ..IIIl'\lfIII:<d!i!Il',.... c. l+r:r~.IlY_~ . ... 71 n-&~ 'i!f:!lliiil......,....~. .1""~....~l ..,' .. ,"",', .. ;1lo\;3j'2f.~I.. Sworn to ds s r Notana Seal Teny L. Russell, Notary. PubliC City Of Harrtsburg. DaUf:A1in CouOIy2Q06 My Qlmll1iSSiOn Expires June 6. . Member. PennsyNania Assodation 01" Notaf1eS My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 179.17 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2,1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17,24,31,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 63 Writ No. 2003~2762 Civil Chase Manhattan Mortgage Corporation VS. ~-Ih~ tv. (j~ Marie COyne~i;Or Debra 1. Scudder. a/k/a Debra E. Scudder Atty.: Kristine Anthou LONG FORM DESCRIPTION ALL that certain house and lot of ground situate in the Village of Cen- terville, Township of Penn. County of Cumberland and Commonwealth of Pennsylvania, bounded on the north and east by property now or formerly of Arnold A Shenk; on the south by the State Highway Route No. 11: and on the west by prop- erty now or formerly of Holbert A. Myers. and having thereon erected improvements, the said lot of grotmd being more particularly bounded and described as follows: BEGINNING at a stake in the W~lnllt Rottt"\JT1.RoacLlfnrf'l2('1,"l'l..&&!e North 17 3/4 degrees West 16.3 perches to a stake; thence South 70 1/2 degrees West 9/10 perches to a stake: thence North 173/4 degrees West 8/10 perches to a stake; thence South 70 1/2 degrees West 5.1 perches to a stake; thence South 25 1/4 degrees East 5.45 perches to an old stump; thence South 24 1/4 degrees East 11.9 perches to the place of beginning. CONTAINING ninety-six perches, more or less. BEING the same premises which Eugene C. Cromer and Nedra L. Cromer. by Deed dated November 30, 2001 and recorded in the Of- fice of the Recorder of Deeds of Cumberland County on December 11 ?/l/ll '- ~ . SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER 2003 ~~i. J~ hAmA SEAl. f/ LOIS E. SNYDER, Notary PWlIc CI1lfis\& BolO. Cumbe~and CountY 5 My commission ~l9S MaICh 5, 200 ~- ..-"....,.-;;~--=::~ ';;;"".,; of Pennsylvania. U\JU....A.....~ north and east by property now or fonnerly of Arnold A. Shenk: on the south by the State Highway Route No. 11: and on the west by prop- erty now or formerly of Holbert A. Myers. and having thereon erected improvements. the said lot of ground being more particularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (tormerly State Highway Route No. Ill; thence North 66 112 degrees East 3.85 perched to a point on bridge: thence North 17 3/4 degrees West 16.3 perches to a stake; thence South 70 1/2 degrees West 9/10 perches to a stake; thence North 173/4 degrees West 8/10 perches to a stake; thence South 70 1/2 degrees West 5.1 perches to a stake: thence South 25 1/4 degrees East 5.4~ perches to an old stump; thence South 24 1/4 degrees East 11. 9 perches to the place of beginning. CONTAINING ninety-six perches. more or less, BEING the same premises which Eugene C. Cromer and Nedra L, Cromer, by Deed dated November 30, 2001 and recorded in the Of~ nce of the Recorder of Deeds of Cumberland County on December 11, 2001. in Deed Book Volume 249. Page 2762. granted and con- veyed unto Debra 1. Scudder. Parcel No. 31-29-2524-001. J My CommissiOll l:."l"'~. . , - .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND coUNTY, PBNNSYL VANIA CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, aIkIa DEBRA E. SCUDDER, Defendant. NOTICE OF SHERIEF'S SALE OF REAL ESTATE TO: Debra 1. Scudder, aIkIa Debra E. Scudder 1803 Walnut Bottom Road Newville, P A 17241 TAKE NOTICE that by virtue of the above Writ of Execution issued out ofthe 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 September 7, 2005 at 10:00 A.M., the following described real estate, of which Debra 1. Scudder, aIkIa Debra E. Scudder is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER, aIkIa DEBRA E. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TOWNSHIP OF PENN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PENNSYLVANIA 17241. DEED BOOK VOLUME 249, PAGE 2762 AND PARCEL NUMBER 31_29-2524-001. ... .. The said Writ of Execution has been issued on ajudgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Debra 1. Scudder, a!k/a Debra E. Scudder, Defendant, at Execution Number 03-2762 in the amount of$90,573.50. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. B . \../ C;1<' u( (i..JX(J.( (<.:?'<-. y. , Kristiiie M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (4]2) 281-7650 - .... ...... . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, DBV 249 Page 2762 ParceI31-29-2524-001 GRENEN & BIRSIC, P.C. BJ'y'" ~-0L'-0a.,(..-c..c."L,U Kristine . . Antliou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. LONG FORM DESCRIPTION ALL that certain house and lot of ground situate in the Village ofCenterville, Township of Penn, County of Cumberland and Commonwealth of Pennsylvania, bounded on the north and east by property now or formerly of Arnold A. Shenk; on the south by the State Highway Route No. 11; and on the west by property now or formerly of Holbert A. Myers, and having thereon erected improvements, the said lot of ground being more particularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (formerly State Highway Route No. 11); thence North 66Y7 degrees East 3.85 perched to a point on bridge; thence North 17% degrees West 16.3 perches to a stake; thence South 70Y7 degrees West 9/10 perches to a stake; thence North 17% degrees West 8/10 perches to a stake; thence South 70Y7 degrees West 5.1 perches to a stake; thence ,South 2514 degrees East 5.45 perches to an old stump; thence South 2414 degrees East 11.9 perches to the place of beginning. CONTAINING ninety-six perches, more or less. BEING the same premises which Eugene C. Cromer and Nedra L. Cromer, by Deed dated November 30, 2001 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11,2001 in Deed Book Volume 249, Page 2762, granted and conveyed unto Debra 1. Scudder. - (") ....' c=' ;;::;:~ 0-' '-, ~Tl :? .-"" c~} ~~,~: \.0 L<.) c..n ~ CO\.l1,n:'l', 1>J3,~S'{1...'l ~ ;t0~ l'LEfr...S Of C~BERl-fr...1ID rO~i. O~ ceO' -O'fGfr...GE C~lL D~lSlO~ i.v..~ v ~ '''' ~ ~~i.i. cv..~~~ ~i.\0~' Co~O ,?\'/>.\-r.\\\\' ~O:. 03-2162 Civil 'l: -' lSS\.lE ~o:. ,,<0' JER, alkia 0DER, ~<p~ "Q ~ "Q~<P311t. 'f'{l'E Of l'LEp.J)1NG: l'raeci-pe for -Writ of Execution (Mortgage foreclosure) flLED O~ BEBALf Of l'LNN'flff', Chase Manhattan Mortgage Corporation COU~sBL OF ",,"oFD FOR t\l'" AI< 1(ristine M. NltbOU, Esquire l'a.l.D. #1199\ GF,B~~ & BlRS\C, l' .C. One Gatewa'f center ~inth floor l'ittsburgb, l' fr... \5222 (4\2) 2\\\_1650 " CNIL DNISION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, Ys. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. NO.: 03-2762 Civil PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary SIR/MADAM: Please issue a Writ of Execution, directed to the Sheriff of Cumberland County, against the Defendant, Debra 1. Scudder, a!k/a Debra E. Scudder, as follows: Principal Interest to 9/7/05 Late Charges to 9/7/05 Escrow Deficiency to 9/7/05 Corporate Advances Attorneys' Fees Title Search, Foreclosure and Execution Costs TOTAL $69,221.85 $10,190.28 $ 323.07 $ 2,564.90 $ 4,523.40 $ 1,250.00 $ 2.500.00 $90,573.50 GRENEN & BIRSIC, P.C. :/1]" 1.)' . " /1,/{', .. By: -- '-('//'--' l.-L_^--,_{':"~I'_ _c,,-_c/,--.&'-'--L,_ Kristine M. Anthou, Esquire Attorney for Plaintiff tzJ ~ ~ ,- ~ 6"- ~ (<) p -(Q, ..... y\-{"J-- S? ..... :-:t "'..()Vtlr)-t~ \l~ \) . . . .. . C> g 8 CI) It.l lUC) ~ ()- -l:: l>Cv - D f , (fl - - I I I I ~-J a- C) ~ t -e: D ,0 p=.. G"'- ~ :: ~ - - !:t. lJ ~ , CY - ':. tt::) b p. '-.t::. , ':. ::. - - W+:.. -r .~ ~ ~ n r--... ~~ CJ ,,;-:;:) -", crl -". :~J :";.1' ~'j'l -: C,) ;:;., '...0 (.') C:'~ COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2762 Civil CIVIL ACTION - LAW WRIT OF EXECUTION and/or ATTACHMENT TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff(s) From DEBRA I. SCUDDER A1KJ A DEBRA E. SCUDDER (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of 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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,221.85 Interest TO 9/7/05 - $10,190.28 Arty's Comm % Due Prothy $1.00 Atty Paid $744.04 Other Costs LATE CHARGES TO 9/7/05- $323.07 - ESCROW DEFICIENCY TO 9/7/05 - $2,564.90 - CORPORATE ADVANCES- $4,523.40 - ATTORNEYS' FEES - $1,250.00 - TITLE SEARCH, FORECLOSURE AND EXECUTION COSTS - 2,500.00 L.L. Plaintiff Paid Date: MAY 31, 2005 CURTIS R. LONG (Seal) ~ Proth7~ Bv: -Q. 77zOlAf1-< ~ Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, P.C. ONE GATEWAY CENTER NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 -'" .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of Debra 1. Scudder, a!k/a Debra E. Scudder, located at 1803 Walnut Bottom Road, Newville, Pennsylvania 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TOWNSHIP OF PENN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PENNSYLVANIA 17241. DEED BOOK VOLUME 249, PAGE 2762 AND PARCEL NUMBER 31-29-2524-001. Debra I. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, PA 17013 1. The name and address of the owner or reputed owner: 2. The name and address of the defendant in the judgment: Debra 1. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, P A 17013 ,. '" 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 GRENEN & BIRSIC, P.C. 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 P A Department Of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, P A 17128-0601 Commonwealth ofPA Dept. 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. ~4904 relating to unsworn falsification to authorities. 4') ,~ ~, 1/'/</;1' '}7'{,1" BY:.,'.M..VCl.A'--" I s--.,(,c/__l~ Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE METHIS~DAYOF (HeLLI ,2005. ) - .' /' ,j . .' "'-kP Jy ('I' (, ( l5{{~ i [(<<- Notary Public t ( COMMONWEALTH .9f..PENNSYlVANIA Notanai &:~Ji Rebecca G. BlazIna, Notary Public CllyOf PltlsbLlfgh, AJIegheny County My Commisslon Expif8S June 2, 2JXJT -. Penns~ AssoclatIon OfNolarfeo .~ /"'-,-'1 e::~ c:.:. <-" - ..~ -< c.) ~: \D <.." U, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYL VANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 1803 Walnut Bottom Road, Newville, Pennsylvania 17241 is Defendant, Debra 1. Scudder, a!k/a Debra E. Scudder, who resides at 1803 Walnut Bottom Road, NeWVille, Pennsylvania 17241, to the best of her information, knowledge and belief. '-:C/ ~ V( u, L)j( (f'i. < I. &' ~ SWORN TO AND SUBSCRIBED BEFORE ME THIS 24/~ DAY OF 1ft flU ) . . , .. I c Ck'J J.Yi (It, i j)ia~tu c'- Notary Publ"c . ,2005. COMMONWE'.AL TH OF PENNSYLVANIA ~ Notar1aISeaI Rebacca G. Blazina, Nolary PublIc CIty Of PIttsburgh, Allegheny Qx.IIIy My Coo,........, ExpiIes June 2. 2fXJ1 "M""'''W' Q""~'l'^-'1.,rt;l A8SOCIatIon OfNocarias - - p ...., 0 <-:::::'/ .,.;;:;) -n --- c.n -. =--== , :I:; 10 --", G.) ~~, \f) c...J Cr-; IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ) BANKRUPTCY ) CASE NO.: 1-03-BK-07176-MDF ) ) CHAPTER 13 ) ) ) ) ) ) ) ) ) ) ) ) IN RE: Debra I. Scudder a/k/a Debra I. Wilson Debtor. Chase Home Finance, LLC, Successor by Merger to Chase Manhattan Mortgage Corporation Movant, vs. Debra I. Scudder a/k/a Debra I. Wilson, Debtor, and Charles J. DeHart, 111, Trustee Respondents. ORDER OF COURT - Upon consideration of the foregoing Certificate of Default, filed on behalf of Chase Home Finance, LLC, Successor by Merger to Chase Manhattan Mortgage Corporation, it is hereby ORDERED, ADJUDGED, and DECREED that the Default is granted and the automatic stay is terminated as it affects the interests of Movant in the real property and improvements thereon commonly known as 1803 Walnut Bottom Road, Newville, Pennsylvania, 17241. Date: March 28, 2005 BY THE COURT, !2~~fJ~ 9- This electronic order is signed andjiled on the same date. - .-, C':...~ ,::::-) C;J' o .TJ ::j [::;"1 (.,.) ....() c.) (.II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101. 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. Anthou, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that Plaintiff was not required to send Defendant written notice pursuant to 35 P.S. ~1680A03C (Homeowner's Emergency Mortgage Assistance Act of 1983 _ Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 V.S.C. ~~ 1701-1715z-18) [35 P.S. ~ 1680A01C(a)(3)]. Additionally, Plaintiff was not required to send Defendant written notice of Plain tift's intention to foreclose said Mortgage pursuant to 41 P.S. ~403 (Act 6 of 1974) prior to the commencement of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. ~101 and Defendant is not a "residential mortgage debtor" as defined in 41 P.S. ~ 101. ME THIS 24.;1,- DAY OF < ~ij)a (' A. t; Notary Public I SWORN TO AND SUBSCRIBED BEFORE J}tCUl /"-). I /:51t(-j {Hk /:1 ),1' ./J~//'. d , J y; vc (J, < ,,:v' I( (.1.,(. (;{ 0--<..-/ '- I ,2005. COMMONWEALTH OF PENNSYLVANIA NoIarIaI Seal Rebecca G. Blazina. NclaIy PuIJIIc OIyOf_rgh.~~ 'II\' (""""""<"7 "'Pires June 2, 2Oll7 !IMmbar, (o);ru';;.')/~'i:'.;'"a AssocIaticr- Of Notaries . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CNIL DIVISION Plaintiff, ISSUE NUMBER: vs. NO.: 03-2762 Civil DEBRA 1. SCUDDER a!k/a DEBRA E. SCUDDER, TYPE OF PLEADING: Defendant. Pa. R.C.P. RULE 3129.2(c)(2) PURSUAI\rT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE CODE- FILED ON BEHALF OF PLAINTIFF: Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. 1.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, P A (412) 281-7650 SALE DATE: 9/7/05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION, CNIL DIVISION Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER a!k/a DEBRA E. SCUDDER, Defendant. Pa. R.C.P. RULE 3129.2(c)(2'l LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Manhattan Mortgage Corporation, being duly sworn accoTding 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 25, 2005, 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 r1espective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are trule and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BY: :..-.~().{<..,<.'{~l}{a.L(A..tf7J Kristme M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Sworn to and subscribed before me this~ay of~Iu ,2005. n (\ g \)~~~ .i-6-I~ No Public COMMONWEALTH OF PENNSYLVANIA Notartal 8GB1 Elizabeth M. Palano. Notary Public City Of PI\\9burgh, Anegheny County My Commission Expires Jan. 6. 2008 Momw. \=lennsylvanl8 Association Of Notaries . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information was of record' concerning the real property of DebTa I. Scudder, a!k/a Debra E. Scudder, located at 1803 Walnut , Bottom Road, Newville, Pennsylvania 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TOWNSHIP OF PENN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PENNSYL V ANL<\. 17241. DEED BOOK VOLUME 249, PAGE 2762 AND PARCEL NUMBER 31-29-2524-001. 1. The name and address of the owner or reputed owner: Debra 1. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, PA 17013 2. The name and address of the defendant in the judgment: Debra 1. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, P A 17013 . . 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, PA 17013 PA Department Of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, I'A 17128-0601 Commonwealth ofPA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 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. ~4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. /~ ,~ ~. . .,' ':", I .I . . By: /}(>Je,-^-;"'--"h t~{...(?,----- .... I Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME T~I~..~ DAY ~F/~ It! UJ. ,2005. 't!!;:~~:i~ f /~~i ~~ COMMONWEALTH Q!: PENNSYlVANA Nolana! Seal Rebecc:a G. BlazIna. Notary Public CIly OIP111sburgh, Allegheny ColI1ly My CcnwnIs$lon ExpIres June:z. 2JX11 "' I!! E II: c 0 - c "' e ! - II) ~ ~ .. > 'C II. "' "' II) 0 0 0 0 M M f'Il r<\ c " ll. .... .... 0 a " M M ..l;) ;f ~ .. lD ~ 0 >< .E '" ., - >< <=, 0 I ., 0 "" E-<..... 0 '" I ~iT i-I ......... co ., > N o N 1"1 ;::I'r-! - ~ .~ ,"', ""''''' .... -1,1 ..... - ., - > >< ... i ..... ., ...: ~ ~'~ 1:i ""'E-< Po. <= - ........ H "0 . .,,,,,. i I~I """ ~-N 00 4-l.t::.o I-ol 'H >< ~~1 0 C'tL co ;:I .u,(".,J ..c o,8~3 3,' I "..... '" ., ... ...... . ..... 13 ., ., OJ ... .u . ,..q<\ ~ ~ ..c:: Q.1r-l ~O"'G ~, l", I ::I s:: Q,lcIj ., .., o<l H ""::t: ""Po.::t:":':< '<.' '" -, '" o/<~."... -;. "', -'a '" ;\ r-"--~'-~-'i~-~'il H!-;! I I { ,~ I" ~ iHH Cj ~:; ~~!;i Ln i:" . 1':.,', U:'~~~;:~i; co ['J ~ ". l2,. J,." H f' C.,H .8 ,<(- ~ 0 ~ 0 0 I~' () \GJ Y.l :t:: I~"':;; ;: ~ ~, :-</d ~l >" ~n "'" <'" h ~ ti. -gal ~ClItlii'g::i!D Q.1J)li; 8== ctl16 E CD ~~ ~Q:: ~~f-. ~~ ~1; $ ~~ ~Gl~~ U. ::;:~ ~ l&<!l o K\ " c:- a 1!I <=> " . <'(\ . ~ ~ . '6 .. c . E h Il ,g. ~ .!! ~ . a'!! ! ~ ~i18 i tt: e ill illE" .. .w :::1_ tl:I ll'- c i a:.a:.~g '" 0000 B a ;; I c:- u c .~ ,B a " ~ ! N1:: . ~ 'E= r>, .~ H I J'.-J E jofn '5 j ~ ~8c~~ ~ 0000 <)~ ~ u " . . .c c, () '-' . d 31. fl ., ~ N I- " 1; i~ <= J~ OJ ~ > t ~ OJ S2~~ ~ ...: !l:. - ~-t;i Po. l~ .,.z... 'H '" ~I!~ .l! ' 0 'H 0 i J~ 0 0 '" OJ a ~ ".. if <= ..c:: ~ '" w ili~ OJ OJ .l; EI .... ~ OJ ., HLl\ '", u. i~ ... OJ ,.: ., ~ ~ t1 ~CD~~ "" ... OJ 0 co "" ~ M .. W C, .;, '" E ~ z ,"$ ...: 0 .,) Qq 0 '-'Q Po. U ',--.l U. .. 0 ...: N M ... on co '" z a. S! .-' c.:::J ~ <'> o Q. -' ~:-n ,-r\ z:: -4\\.' ~') "(-) \_~\l~} "}: ,'..;. l~i~J';; ~~ --.- -,"~ ~' --..\ fC' <"" ~2. r.J\ C) 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 Deed in which Chase Home Finance LLC is the grantee the same having been sold to said grantee on the 7th day of Sept AD., 2005, under and by virtue of a writ Execution issued on the 31 st day of Mat, AD., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 2762, at the suit of chase Manhattan Mtg Corp against Debra I Scudder aka debra E is duly recorded in Sheriffs Deed Book No. 271, Page 237. IN TESTIMONY WHEREOF, I have hereunto set my hand cf~r ..21 tfld7J) day of and seal of said office this ,A.D. ~y Recorder of Deeds Aeeonlet- '" Deeds, Cumb.""'"d gounty, Cortlole PA My Commission El<pIres 1Ile Flrot MondilrgfJorl.'ilIIl6 Chase Manhattan Mortgage Corporation VS Debra 1. Scudder a!k/a Debra E. Scudder The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2762 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2005 at 4:40 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Debra 1. Scudder a1k/a Debra E. Scudder, by making known unto Greg Scudder, husband of Debra Scudder, at 1803 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2005 at 3:37 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Debra 1. Scudder a1k/a Debra E. Scudder, located at 1803 Walnut Bottom Road, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Debra 1. Scudder a!k/a Debra E. Scudder, by regular mail to her last known address of 1803 Walnut Bottom Road, Newville, PA 17241. This letter was mailed under the date of July 05, 2005 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 Courthouse, Carlisle, Cumberland County, Pennsylvania on September 07, 2005 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Kristine Anthou for Chase Home Finance, LLC slblm/t Chase Manhattan Mortgage Corporation. It being the highest bid and best price received for the same, Chase Home Finance, LLC slblmlt Chase Manhattan Mortgage Corporation of3415 Vision Drive, Columbus, OH 43219, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $874.40. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 17.15 15.00 15.00 30.00 10.00 1.00 19.20 4.25 15.00 20.00 347.00 268.10 18.20 25.00 39.50 874.40 Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ Sworn and subscribed to before me So Answers: r~ !~!:?ttr~ R. Thomas Kline, Sheriff BY \.)ofHj; ~ Real Estate eputy This '/ 'fU day of iJi-- 2005, AD. ary ~~ J{),vV V j.lJO en ~p3l- (2,.v. / L '{(,Il IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information was of record concerning the real property of Debra 1. Scudder, a!k/a Debra E. Scudder, located at 1803 Walnut , Bottom Road, Newville, Pennsylvania 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TOWNSHIP OF PENN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PENNSYLVANIA 17241. DEED BOOK VOLUME 249, PAGE 2762 AND PARCEL NUMBER 31-29-2524-001. 1. The name and address of the owner or reputed owner: Debra 1. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, P A 17013 2. The name and address of the defendant in the judgment: Debra I. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville,PA 17013 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, PA 17013 PA Department Of Revenue Bureau of Individual Taxes Inheritance Tax Division, Dept. 280601 Harrisburg, PA 17128-0601 Commonwealth ofPA Dept. 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. ~4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. ~-I _ ,,' If /~ By:C/ ~/){v<... cA,-h( {?kZ--< ,,--- Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS.2!tt. DAY OF I HaLl ,2005. "~}jYf'I't, ( is2c~ t~uz. Notary Public t C COMMONWEALTH 0..1:. PENNSYLVANIA Notaliar SeCJi Rebecca G. BlazIna. Notary PullIic CIty QfPIttsbUIgh, Allegheny C<ully My CanmIsslon ExpIres June 2. 2fXJT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHA Tt AN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: '03-2762 Civil vs. DEBRA 1. SCUDDER, aJk/a DEBRA E. SCUDDER, Defendant. NOTICE OF SHERIFF'S SALE OF REAL EST ATE TO: Debra 1. Scudder, a!k/a Debra E. Scudder 1803 Walnut Bottom Road Newville, PA 17241 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 September 7, 2005 at 10:00 A.M., the following described real estate, of which Debra 1. Scudder, a!k/a Debra E. Scudder is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TOWNSHIP OF PENN, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1803 WALNUT BOTTOM ROAD, NEWVILLE, PENNSYLVANIA 17241. DEED BOOK VOLUME 249, PAGE 2762 AND PARCEL NUMBER 31-29-2524-001. The said Writ of Execution has been issued on ajudgment in the mortgage foreclosure action of Chase Manhattan Mortgage Corporation, Plaintiff, vs. Debra 1. Scudder, a!k/a Debra E. Scudder, Defendant, at Execution Number 03-2762 in the amount of$90,573.50. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. ] l //; By: L"" IF-"k '- i.~';;t<LiA. U..I"L.-. Kristiile M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, P A 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CNIL DNISION CORPORATION, Plaintiff, NO.: 03-2762 Civil vs. DEBRA 1. SCUDDER, a!k/a DEBRA E. SCUDDER, Defendant. LONG FORM DESCRIPTION ALL that certain house and lot of ground situate in the Village ofCenterville, Township of Penn, County of Cumberland and Commonwealth of Pennsylvania, bounded on the north and east by property now or formerly of Arnold A. Shenk; on the south by the State Highway Route No. 11; and on the west by property now or formerly of Holbert A. Myers, and having thereon erected improvements, the said lot of ground being more particularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (formerly State Highway Route No. 11); thence North 66\1, degrees East 3.85 perched to a point on bridge; thence North 17% degrees West 16.3 perches to a stake; thence South 70\12 degrees West 9/10 perches to a stake; thence North 17% degrees West 8/10 perches to a stake; thence South 70\1, degrees West 5.1 perches to a stake; thence South 25Y- degrees East 5.45 perches to an old stump; thence South 24Y- degrees East 11.9 perches to the place of beginning. CONTAINING ninety-six perches, more or less. BEING the same premises which Eugene C. Cromer and NedraL. Cromer, by Deed dated November 30,2001 and recorded in the Office of the Recorder of Deeds of Cumberland County on December 11,2001 in Deed Book Volume 249, Page 2762, granted and conveyed unto Debra 1. Scudder. DBV 249 Page 2762 ParceI31-29-2524-001 GRENEN & BIRSIC, P.C. , Bf.( C)li.A:x...L~a/-.-<x....if,J Kristin~. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-2762 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 DEBRA I. SCUDDER AlK/A DEBRA E. SCUDDER (I) You are directed to levy upon the property of the defendant (sland 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 gamishee(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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,221.85 Interest TO 917/05 - $10,190.28 Atty's Comm % Due Prothy $1.00 Atty Paid $744.04 Other Costs LATE CHARGES TO 917/05 - $323.07 - ESCROW DEFICIENCY TO 917/05 - $2,564.90 - CORPORATE ADVANCES- $4,523.40 - ATTORNEYS' FEES - $1,250.00 - TITLE SEARCH, FORECLOSURE AND EXECUTION COSTS - 2,500.00 L.L. Plaintiff Paid Date: MAY 31, 2005 CURTIS R. LONG (Seal) ProthO;iry ~ ~y: AO/lI?2. 'l?~ Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, P.C. ONE GATEWAY CENTER NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 Real Estate Sale #75 On June 17, 2005 the Sheriff levied upon the defendant's interest in the real property situated in Penn Township, Cumberland County, P A Known and numbered as 1803 Walnut Bottom Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 17,2005 By:JeciA{~h Real Estate Deputy ~ o 0' b I :8 "i/ Z - Nnr ~aal ': , ~id Ali ,11-.,' , JJIU-" ".,'-, .';' .,:jf"l~ .:.;"-;1 iJ ',_,'1,1;"".',:.'.,1 .=l.iu ~ . \ . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 COlnmonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday! Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently dnly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneons ook "M", Volume 14, Page 317. NOTA Y PUBLIC My commission expires June 6, 2006 COpy S ALE #75 befoMs 16th day of PUBLICATION Sworn to and subsc 'b CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 268.10 REALw.V=:I~lI CIvlI~ ChMei....~~.. ..It~ If Ccqlordan V. QebnlI. ScucIItsr eNa QebnI eo ScuddIor A\ty:~""""u Dl!S(;IlIPI1ON ALL TIII3: CI!II:WII_lIIlIlot 01 ground .- ill Iii ViIIoF oi CoalorviIlo. Township 01 """'.Cl>uolJ oiCbolbodood,aDd,-weaIlh oIJWsy\......bola!doI...........ODd cast by ~.... \Xr..mty oIAmoIda. Sbeok; 011 lIIc _ by lIIcSqjo,1fi8my ~ No. 11; and ontbe_byIllOPO'll'DOWor~yol lIolliott A. Ml"i, ... having..... """'" ~~~~~?a: Rood (l\lrmq' _ IfiIbw1y _ No. H); _ NIXIMo5 depees Iloit 3.85 pe<clled to a poiDlllll bridp:'_ _17 JS depees W<st 16J~toa..._SooIlI70.sdegrees WestWI0 ~to a slake; __17.75 depees WestIlIlO~toalbke;_SooIlI 7O.sdegreesW<st5,.l~toa_;_ SouIIl25~,""" East SA5 ~ to an ,old __; lhoaii'lflluoh 2425 degrees East 119 ~""_OUI''''''', ' .Cll'IfAJNINGDil>elY-oix~._\XloIs. ()~~t".'c.::..~:r ~ _JIl,3XlIIllll"""'*lmlllcllllicool lIIc _0I~ ocCuoi>edand,Coul!lY lIIl ~1l.llJ6Jill____,249, PltF~i'- '"", .....,...DoI>ill. _. 118V249 PltF2762 1'an:<1JI-<9-2524-W1. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z; July 15, 22, 29, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. TO AND SUBSCRIBED before me this 29 day of Julv. 2005 NOT L LOIS E. SNYDER, Notary Public Carlisle 8oro. Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 75 Writ No. 2003-2762 Civil Chase Manhattan Mortgage Corporation VS. Debra I. Scudder a/k/a Debra E. Scudder Atty: Kristine Anthou LONG FORM DESCRIPTION ALL that certain house and lot of ground situate in the Village of Centerville, Township of Penn, County of Cumberland and Com- monwealth of Pennsylvania, bound- ed on the north and east by prop~ erty now or formerly of Arnold A. Shenk; on the south by the State Highway Route No. 11; and on the west by property now or formerly of Holbert A. Myers. and having thereon erected improvements. the said lot of ground being more par- ticularly bounded and described as follows: BEGINNING at a stake in the Walnut Bottom Road (formerly State Highway Route No. 11); thence North 66 1/2 degrees East 3.85 . perched to a point on bridge; thence North 17 3/4 degrees West 16.3 perches to a stake; thence South 70 1/2 degrees West 9/10 perches to a stake; thence North 17 3/4 degrees West 8/10 perches to a stake; thence South 70 1/2 degrees West 5.1 perches to a stake; thence South 25 1/4 degrees East 5.45 perches to an old stump; thence South 24 1/4 degrees East 11.9 perches to the place of beginning. CONTAINING ninety-six perches. more or Jess. BEING the same premises which Eugene C, Cromer and Nedra L. Cromer. by Deed dated November 30. 2001 and recorded in the Of~ nee of the Recorder of Deeds of Cumberland County on December 11, 200 1 In Deed Book Volume 249 Page 2762, granted and conveyed unto Debra I. Scudder. DBV 249. Page 2762. Parcel 31-29-2524-001.