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Home My WebLink About99-04658J w . ,t V 'V f ci Spear & Hoffman, P.A, BY: RICHARD M. NELSON, ESQUIRE Attorney I.D. No. 72869 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No.: 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION 1400 EAST NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 PLAINTIFF, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 94 - 1-1(..?,P ?? JOSEPH CARMINATI 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 DEFENDANTS COMPLAINT - CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (717) 249-3166 A V ISO Le ban demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dins de plazo a partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con on abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandadas en contra de so persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandato y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades o otros dereches importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIAL LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (717) 249-3166 Spear & Hoffman, P.A. BY: RICHARD M. NELSON, ESQUIRE Attorney I.D. No. 72869 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No.: 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION 1400 EAST NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 PLAINTIFF, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 9?. y65F au d 7-e'r^'"" JOSEPH CARMINATI 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION, with its principal place of business located at 1400 EAST NEWPORT CENTER DRIVE, DEERFIELD BEACH, FL 33442. 2. The names and last known addresses of the Defendants are: JOSEPH CARMINATI, PO BOX 1006, CARLISLE BOROUGH, PA 17013. 3. The interest of each individual Defendant is as mortgagor, real owner of the real property subject to the mortgage described below, or both. 4. On or about JULY 23, 1997, Mortgagors made, executed and delivered a Mortgage upon the premises hereinafter described to FAIRFIELD MORTGAGE CORPORATION, which Mortgage is recorded as follows: Office of the Recorder of Deeds in and for CUMBERLAND COUNTY DATE OF MORTGAGE: JULY 23, 1997 DATE RECORDED: SEPTEMBER 9, 1997 BOOK: 1404 PAGE: 288 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. 1019(g). A true and correct copy of said Mortgage is attached hereto as Exhibit "A" and incorporated herein by reference. 5. On or about JULY 23, 1997, in consideration of their indebtedness to FAIRFIELD MORTGAGE CORPORATION, JOSEPH CARMINATI made, executed and delivered to FAIRFIELD MORTGAGE CORPORATION their promissory Note in the original principal amount of $40,500.00. 6. Plaintiff is the legal holder of the Mortgage and Note by virtue of being either the original Mortgagee, the legal successor in interest to the original Mortgagee, or the present holder of the Mortgage by virtue of the following assignments: ASSIGNOR: FAIRFIELD MORTGAGE CORPORATION ASSIGNEE: CHASE MANHATTAN MORTGAGE CORPORATION DATE OF ASSIGNMENT: AS RECORDED RECORDING DATE: AS RECORDED BOOK: AS RECORDED PAGE: AS RECORDED The Mortgage is secured by property located at 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013, which is more particularly described in the legal description attached hereto as Exhibit "B" and incorporated herein by reference. 8. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, due JANUARY 1, 1999 and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become immediately due and payable forthwith together with late charges, escrow deficit (if any), and costs of collection including title search fees and reasonable attorney's fees. 9. The following amounts are due on the Mortgage and Note: Principal Balance $40,102.87 8.75% interest from DECEMBER 1, 1998 to JULY 15, 1999 at $9.61370 per day $2,182.31 Accrued Late Charges $106.02 Attorney's Fees $2,005.14 TOTAL AMOUNT DUE 396.29 Interest continues to accrue at the per diem rate of $9.61370 for every day after JULY 15, 1999 that the debt remains unpaid. 10. Pursuant to the notice provisions of Act 6,41 P.S. §403, Plaintiff sent a Notice of Intention to Foreclose Mortgage dated JUNE 10, 1999 to the defendants, by certified mail, return receipt requested and also by regular mail. Copies of the Notice of Intention to Foreclose Mortgage sent to the defendants is attached as Exhibit "C". Defendants have failed to cure the default. 11. Pursuant to the notice provisions of Act 91, 35 P.S. §1680.403(c), notice was sent to Defendants, dated JUNE 10, 1999. Copies of the notices to the defendants are attached as Exhibit "D". Defendants have failed to meet with the plaintiff or any of the consumer credit counseling agencies listed in the notice and/or have further failed to meet the time limitations specified in the notice and/or have been denied assistance from the Pennsylvania Housing Finance Agency. 12. Notice pursuant to the Fair Debt Collection Practices Act is attached as Exhibit "E". 3 WHEREFORE, Plaintiff respectfully requests this Court to enter judgment IN REM in favor of Plaintiff and against Defendants in the amount set forth in paragraph 9, together with interest, attorney's fees, and other expenses, costs and charges collectible under the Mortgage and Note and for the foreclosure and sale of the mortgaged premises. SPEAR & HOFFMAN, P.A. DATE: RICHARD M. NELSON, ESQUIRE VERIFICATION The undersigned, RICHARD M. NELSON, ESQUIRE, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff and that he is authorized to make this Verification on behalf of Plaintiff, and that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. THE UNDERSIGNED UNDERSTANDS THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ZG RICHARD M. NELSON Attorney for Plaintiff Exhibit "A" 3, A91't Yhan raasNN pall to PAZ us, "wrosa at 1:41PCLj1SiD)1 246 room IIDM U. 4)t1 U; t4rp> L1r4?2211LC ppnORILte, aS 0O01 J: i'I, I:A11D :cLNh •p'• isat"AN Ross pgap a1 '9'f SEI' 8 ;117 9 52 #-3(ola F- 1.0^11 PI 91382245 Ptrrsl Mllmba: ..•-isw.Aw.awcw r«IL.w4y w.l- - MORTGAGE THIS MORTGAGEC:Otcwniry lmwmanl'y la than an J!"T 23, 1991. The nronp2aru Jam" C. "41111att, " IIeNAwu2CD I.S., " HIS /DLL "a LrrAAArL PROPER" This Hcnlr11Y 14Wmcnl is ylWll. PAZ"XC D A.""" CORp<A,ja. ("BaWaw") vauliny mda W YUa 211E 52A2L DI CDVLD2tM wfwh Is apnl2ed2nd Mn 24 wh4ae1d4uh ]46 rpDLML nOMr pLD.VtfIlD. 4 24282 HMrowe. mra 4ndi Wpflncipal nlm of IOR2 2LOUpAV "w am" Al, LO/1............c... ................................................................................ Da14n (U. S. $48,508.00 ).7Aiaachtucvidmeedb2HwmwYahued.edlhculnedaln41hia5mDllylemulDmtl"Near"! WMtlI PIeNdifi lnplAhp'PNQWWNW, wN IM AIR IIIM. It. Mid Saba, IRWIN! p" m AVOUSi 1, 2021. ThD ScOr1ry IMlll,mmt 40llar as Land.; (a) the raprymm 0/the II&C nidawA by ft Hatt with h0a4L 20d 'all RalcvaIL enamnw and medi0eui,ms ad this Naa;(b) 1h. po ossr1l.(!II alhelfail, will Inlaid, advalvd undo p4Lnpb 7 u Isla. As NNmrify of this Socially Inumment; am (e) th i pedalar.a4 of LOa.wsfs aa«4 W and alalnpeu ands, this sh WitY fmllumcar am Ill. Nat.. For Wa part... Larlvwes Eta bcrvby mcvpSa. lanl.nd A. IS L.W. IM (allal.InQ do dkd Pn nrlaAYd4 'IWLLUIYD C..:Y. penaeylranu: SCL 11'r'-. Op9Cat Pttep A22ACLLD MLLASO ANC MARL A PUT ACALar which hu lbaaddn+l a! 151 Mr52 pOLtM AtPLpd, MLLIS" 11"OUCH P.nnfylwmD 1)013 Im.t ca.L f'Plotry Addron'y: Ih[.sll ITANSVINAMIA. tMMY.wilr•I MMMaI11Mr U.17.w u,"M MIST InScSASu VNYaNIrAI 0. I., YM,J0, Ma .W.4. N1 Pap)a6 pAIO[r0 • LIItLD wf coap14114PLCC 288 08-05-99 12!20 C 1. Paymoldre ecipal lad IdenW a(.W hatesslen the debt nddaawd by w Z Fronde for THAI and Lnnnece. Su OOaa dr agaalet And All cammam. appuroluncm, and mYeeNy4n Saronry lmwmwu. All Io-T.T P. 04 I roam and nonmutfara awnams Bilk limiled DawPatd. at adcrray. Imlrrra "IY, wawry brolialup roLaB apply IbA K ar a wper Ilya Eenor item. rw'ec and I.endor my air. to w411., hwro err, Fse, an einnwl aawndat oflhe Poode. dwwinK Ma !Made TIN Fun all aR plabae l n alldllwrral the saosn no& In accordance W U melenulreve nts o(applkebw few. if then alnearnl net au(Iicienl lately the 6aerw Items wbrll Arco I.ende mey n Llano' Bar a w.n are n LeMnr Ibe arrow npaearylo make uP dwe deficiency. Bortensr shift make up Coca Pormenu. al Ladcr's We di"".. Upon payment in full of all at= named by ibis Security Inwmrou Leader chall p yl<nda. If, underarelnph If. Leader hall acquire or call the Property. LerNLn, pn strait applyanyFends held by Under at Ulcdme eraopuisilbn or ele wa credit apilri It X Application of Paymanls. UMea applicable W provide olborwin, all peysne area y shall be A,Iad Ilem In Any prapymenl charters duo II dm IM Win. nerond. w In lmmece due; faunh to pnn4pal dw; aM Um a cry Ime charpa due under oho Tina a. Catarpcr; Liens. 9a(mwr shall pay all Iaae, Aaw %chon co. Mes and Am. L.M. "I moaum to Be., rfor Purr MM by Lander, At I., do. I, again,%mlRe ftlof it. Men In. Mal PrnnLlnpa.Inch In dlc L W's opinion nptnrew to prcvrnl the vdwmmnn of the lie; m (e) eccurn fnnr the holder e(Ilc lie en.,;rwmcnl aeufsnory In Lender wbordanaunC tlN 11. to this Security Inllwecm If Led., deermine del Any "M athe Peopenr i1.u1n. ut • lien wbkh may aumn prLOnry owe This Srzvnry Inarvrnm, L Isle" Initi.ltr alfN1a11rmi1nr MrnmWra Mr rr[rlefd 11 Bood,104 ace. 289 65-05-99 12:22 C ID-TIT F.H'. Ld.n g, 0710110 1. IW.N sr prulwrl> Inanna.0.nsmwr.toll Ysrp the Impronmenu IM rdninR a mauderareod e. ihr hquM Inarcd oplnsl lot by rim. lualda testator wTTMn ib Yls "alnsdd mnvage' and any aibr haul" unum iq 0" or hopoing. Far which Lander requires amruct, This IaaawdWl b nelsalnal In Ib..I. ad hl literalists chat fader rquuse TM tmurU,u carrkl poaldln6lb Iaunma aMli b shoo. by Hofrpla! abyal m Lan4r'a appraal whk6.toll ml I.pnnaanWywlhlwlJ. iftlsrmwar klkte munuln s.saapdoearrbed J..a, LnW.r e.y, .14mlcr'I ryµai4 ekainu.aaga Ie Macca All lassonveollails aN/hlo Ia Ik M.1jNIn sae ssal?ldbla MNpaynph T. and po wwd t tllb kLUWrandeMli gru eudul nanppeekes. Isder stall tore the risk gM is hneld the pllsa and rvmwab. If Lady restated, Banower call atoll prOmp111 live to Leader all stories Wplid qW prpnkm admawd.elletl. in tle.aa a till, HonOSlrralull glyspnmpl nolim rorhe Imunlsv ama aMLoMa. Lender mm Mahe prddlaa If ml nWe geu'gly by Harrasror. or praWm Urdn he 30-dry plopadaa npdra mle not Ills' due. The )Odry pulled II begs. wbn rb a units' ladder Ud Helrva.r a uharwiaa a aroo In wrW rlrnllllnwl4. also which an W. evidenced by the sons, it dins.. , but mI I1M W b. I.,.ud Wil"pallalduv Iflhbsaedrylnvementlaenakwheld,Hermµs Aaanm fa tllle to the Properly. The household ad Ile IN title atoll m 7, pmleeden.(Under'. IG1ha I. thopaparm. crBarm,vfan Seounly Innmmenl. a then ka kcal gxedinpMT roryupllkanl4 n IunYnplc7, aohele, to mndpnm Urn or folfetiura ar seasonal law Is alnanry bprelm the a.lveefThe propslyadf ardaYdphk 1. U . odbya GUS wilds has aredlyever this Smuniv histow ml. oppai nn Our pr,gavey a mega n,aln. Alooe k Lads nay ub Mb. and Any aroalols disbursed by Leader under cut paragraph 7 abell be InlnmenL Until Hmmwr and Irnder as= to other lent, of pay Jbbursrant.l Or, Net. rase ad (hall b payable. with WML auto .. Mnni.F lootteo. If Lanaer requited nunpp I...1 a laeanenl. HarrwarMnll gylhoprcminma Uslnird romalnldn Tba in.n n sox maonµe aqui rtd by Londe r lapsr er ea 1a re b in oReq & nro y egavelml w rh. monpge Imsrraan lmly in ease the mortgage let inntaunna pmimMIn HYIn a. on alternate ownsel occur. mnpRe rula maraca Is sea Available. H.nanf ahUl Pay rota Ihr Dwell of lender, dmn ourneraawpwrenp(In eppmwd by UnJer yarn mourner available and Is ab rZonfyl.vAflA IryL1'? J. J.MNe111MCL'MIInnM lnr vM1 alto' malnl )Mn,.a.. Awn4r N I page 1 or a coop 2404 PAit. 290 On IM.rAns. -05-09-19 12.29 C nr uaR.m. erw aarr •. fTamau /rwr4 • Iw r•a•M, xnll Jr rowinm•m M men4t•.Ner,ra uq, m fraNSnro rllh enY rnnan +[.a•maM fr...n lnrel•+r eN 4nMr •r wgrrp lav . f.In,prllen.lerWrrlla,[w^,Y nwlenw.rprYlr •PrenJln,pwpn,MlMYrvgrry I?.Ibr,pNl/Iw llrrv?.•r .wkc..I W bm, e!r qM w u.rlsrwn,wlMry.rrn,aro ww M ne rnrgawn. __ In. CmJarmpn. Tw proua4 M np frfN m elJn M YmfM Jlrmf sr anPyxYr1141, In wnmwlw. rn4 ,nr .r r N nM111wlwn ur eICW rover fIrJ1I M v, el rnk aruJ!.Y IwrY•r•nwl ?r we Nm, Mrlro?.r w D?irrawm', mran0ur er nW em •wwnina/eher Ynlh ••/Jw.e la. Vu b•,hu Ifllr IYe revraJ ww. s.•YnM Innrvmenl k Wv re • M. whkb. me+i..Irn aNrtr. mr n m•n nr rr ., rnnaYrY o n n.nrma Iwr..nnn e.Yr.w.. u,n.w.ynm enunYnwnr,r urrn x. Yemnrmn wr n f mn.nnw rrrrorur m Im.rvw.. r.J.r vanvemJ.rw m.w.er ?• nal a rum.•I qn.N Mm. rnuw w.wnr. LrwP mYY, w lu egr.n. r+gYln Imnxflw p,rmurl rn NU eLll mmuewrrq N.Ma fan ICnnYYr.V.vrnar YYwmua.rr.MC rMIpnN rn,rYYnCXT Inltl.l.r Y+rY JY1CN(w.nl Y•ri•w MMMwrnJ•J»I Yay.ef• ,ooxl404ri;F 291 eau[iQ^4r,[c 292 r x 05-65-99 12125 C ID-?17 I lowew.IN.W",bdl net taaemlfldy Gn4r lfea,aiw is pmWbad by e fdgal 1,01111 11 17102245 IfLndO mrcil..lnluplen, LeMaralulllMB lawalml"dalwflWaSoadl>InaNm,m. Inon !0 471 !mm the 61145 da "Ila k Mlram a ro u laaNhkaaraaenlian.7" Mka ahdl pmrWa a Prid d"t Im Inmrvmml IfBamwr fade Iapay 1111w mm/ PHa loW aplralbn111hbBaer-r Inlul pay all ww peered y Ihls Sswriry Ihn SmOyllulrvlla"xi1hM11 fw0uarwre Polsel}ndan8alona( p.6W. GlkermginmNanYlemd)aprmrnedy 11. 2nrrewer'r plghl IN Rdelbk. 11BanOwfllyalana111aiI1dL4u, 14rrewrrNll ....... law IM NIA, be DfIhllpttwlJYlMNmmadlmul.?.M _ ._.._ .. parefrde...... OM (441410 tool, lalm neGndO may aNmnabNrequlnb ••?_ ..raaminp, ON Not llndbd r, romnaNaanaNyl rpmMaTlndB enmwn Olb seln??n'a La amy In pnNrom ewmHu, Ihn INN mlhb Swedy 1Nllanbm•I+aH'a do" 'aenenl p far th' amt mNld by this saaady ININmNs.hev lenamm sraballew heap by ad Ina abllytlaN .stomp barey anal rmNin w eramn W m,srrd. Hawvea, INr dgW IN MMAW 1"11 aW sppy In Iho aw efml en H e nI Ms r Ir dfs0le w if no t. Lb afNme;Cllan11e M lam Stork or. no, Nab or a paned lph,enlO lMNma a laan/aph 17. e wW env ar"mlinb6 Wlluu Who, nbla IN Bert., A.1 9.1.U. this Saadylmbolnen) :er"IrMrrwll.ru ?..rl,.. .._ .. pal Raullmaela11O1n WeuJw M1..... .... __ law. pmnilliu a Hai; ldwl2uNUUa auul an marr,.sells pee V* 1. the pfymm, um,slfaap onihe.hwp... o(muH M1M Prepvp. S y lMradbb anpaeprlaNb damsl lasldtalW laa and m new.maa"s Isms. pall pranPlly Ili- 4nda wIIHn ruaa of alas Inwdgallalt claim, dread, lowest of -'her tepee by any pwnnamsl ar mlu4lsyatmis7 Npdnbpll"i-W-8 the Prtpny hkbBeNewerhmsnudamlrledp basaemEnrimnmmnl4Wef .I(Domwralumr,aianalfitl ae adsroHaaaNala Su sm", rtmdlakn Maly Haardmq SUkta. Ackabg Iha Pmpmesyy Y ydesrnnb M° blarrtNlaayw"y' .lmyaaewal mradid Whom In aramanee trilh EnNmNNmal LaW.a4p. Rammwr pullMmPdY lake mlmaauy N IrMd In INS pnaynph 20, '•Hw14w lanalanaa" are thou abna"es 4111-6 H hale or hazardous subaanas by EMImnnW W GW 116th, (mleaie(IYp11aYV; gasoline. hbeaenL ahWaAMN ablaalpakpHmkwplplduC4 bYkQOpCIdN an0luMieHes,wbtiklohuntr, metNbbamdldnttblloaar/anptl4nyds11110 rWaeihemabrbb. A4mdl11pbpsnlmph 10. •'Enrimlone" Law" It1ane foam, laws and Wsafthrjededkllen (Mere she Preppy If lssud that rebbb h olllh My anHrsnmmW n pr11tmle a l lAmekn IeII: nemeaa.AWTS. wraN Gud.a fuaM1sa ameNnl1,M a" as fdbw: . nmrmlam aerrarerefthe right to rdnuleMa"abntim and be right la papa b Ise Psrmlwm . aesookr abn ""blma da 611101ar-NYSherddmm m Barman, be Mosleall" anll fartelaerc H 11 Wanda. aPIII1d,GnJm.afiy epaa0, wpa0llin bnmtdbta paYmtet I. fdlefdl___ eIke asily HboaIN farther dwand and my for IM his Sradtr lrvmmlby rdk ran b71h115aady imitates ilhmt npolMa Noorred I. purwingahe rN"dbPnrided Is this PSgnp1/, IneluCilo 1,cmclor all ronee, all np Noses lllmkedeenHlbdb'AM and eab of III, arid", to that antenl Perndtled by Applicable bw, M nloralaya fm and IL Rrlaae up.pwm.l ofall amt Secured "is Ssmay INNININlL this Ssudy IeaMlmint rd IM mbrc." d flWlfermiN4alld bbero "al" Afb su,hamurm"e, Gal411 lhWI dlbha,p Asatiny this So:orly 1411malela mLhftc Charge le BeraowM. Bomsr dullW "Y rooWds!Wn raw.. 23.W.1"ot Boamwa,m IM "Um WMIRW by aps"NNe". WMl are satalu My,ner or dde11s in pmeWingsb ,NarMa ft Sempy ism.mart[ arm hereby Worn It. beWddmy P,es,N, ,lure law proH0ingfHAgo(attmllon, ealwion of lima. a"mytion Ibm m"h1Nne. Ierl Ad al,, and harranad a,mptam r,nnrr1^r1•,IyL Ieny.IxMNA1WCYmmaM inertVMIFT rMr4t(aalpnM/w1MOmIMW.a h1 PAVS06 InLtLaSar rMM U 1001404fdsE 292 P. Go 95-85-99 12:25 C FD-717 P•07 a4 Mal armaM tSTmnn scMddl u Fa1VkrMssl Prop .1hassaO( U. Rdry 1 own RauA U. totems 37. e(TwlpG<(t M saxim or a7. Wd<nuihhW O p 0 iAMt 11 07102245 11 suit mlam b am Few wun 10 IN TIKnI .1 4 IGM b Bwteuy b aagulro IlllGb IM M. ndamdnl if muted m IN Nw<w in p ColabMNum Akin p 40 pamBy M. r-, la.mod UMf DGW<)'nml Mdw pBIralOY 7*-mAldcr p Nu IMprou6mc d IOdw p Strand Nome Iudar p aFnD) pp<dirl BY SIONINO BELOW. ftro 'OCnpa.W.aroas IOtMluauam be<n.nu mnblood In ws Stotdly 11191M round in any m,af() Gatwllad by Bwroxw..d rwordrd vi1F IL W.I.an: (((JJJ IMttDYRBOtOIi GGNIwG,M0. aP C. GIW7YATf 74YAIr'M? Bdrgmdp. 15101 I lgwB&I umnmm.r Ilcddm« tlo FertFY WIN IMt III- tarR<ladtlfaaa of IM wllhln•Mmed ManpP^ la 246 Mlty. ROAD. "CONFIRM. n' 06606 Wltnae MMad 00, day nr CONMONWAALTROYRRNNSYLVANIA, ?? A?Ju ? [muY n: Onm1..'m %]J? dsY Or -J`' a t 4 17 Mroro In., UndndlnN Ohiat, p<ttonWly n'pn Frown lunN: (<I nILI(<gonly prone) IO la"M pubs xhon namc?L'?<e0acri0cJ 1<Ihe Mlliw Iwrrymsnl and atltnuxlod0<d EMI c.ecalM bC Ulm rot tlu purpona MNln canuim! IN WI7NBSS WHEREOF. i hnmmn ant m)' h.nd and Official nd. My Umnllwc. Eapm D ?.? • • , TJ .r NO MEAL 6lAL uagatu! N 0EA0ln. Nuu<puma II[MNYYI.VANLn•<yY7.iMr•.nwNnILwC VX1IC11w InMiPNMAMY LAw WrW h re,•u.w.^!?+ y p wn bW..? 1 ru.naU vNp•<II(IAll7nallw Nl. rnOAwnba s. (nO Wd .aeae OOUK14Updee 293 Exhibit "B" 65-65-99 12:27 C SCHEDULE "C" NUMORR:35aa ID-117 P.99 ALL,rHAT CSRTAIN Inc[ of land situate in Ilia Barough of Carlisle, County of Cumberland and Canmlonwealth of Pennsylvania, more particularly bounded and described u follows, to wit: BOUNDED on the South by Waal North Street; bounded on die West by property fommrly of Rica and Maggie Brown, now or formerly of Shultz; bounded on the Noah by a 12 foot alley; and bounded an the ran by property now or formerly of J. W. Handshow Estate. Containing 28 feet, mole or tat, in (rout nn West Nina It Street and extending in depth 114 feet, more or less, to the aforesaid 12 foot &I ley. Together whit the free and uninterrupted passage through said alley. Having thereon erected a two-story 11, nine dwelling known and numbered as 151 West North Street. Piece? A05-20-1799-123. BEING the same premises which Helena Davie, widow, end Sharon Alice Davis, single, by Deed dated 1720/96 and recorded 14197 :n the County of Cumberland in Record Book 151 pace 520 conveyed unm Bc,..G. l Consumer Discount Company D/B/A Beneficial Mortgage Co. of Pc nnsylvania, in fee aon114O4rlet 294 Exhibit "C" Law Offices Spear and Hoffman, P a. INIM C. spear (1922-1976) DATE: -(0 - q9 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No. 1500355595 Property: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. The MORTGAGE held by CHASE MANHATTAN MORTGAGE CORPORATION (hereinafter we, us or ours), on your property located at 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013, IS IN SERIOUS DEFAULT because you have not made the following payments Regular monthly payments for the months of JANUARY 1, 1999 through today's date. 6 Payments of $425.49 from 111199 to 611199 $2,552.94 Late Charges for the months of JANUARY 1, 1999 through today's date. $90.09 TOTAL DUE $2,643.03 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $2,643.03 1018 Laurel Oak Road / Suite I / Voorhees, New Jersey 08043 / Phunc:(609) 784-8220 Fax: (609) 784-8322 You may cure this default within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $2,643.03, plus any additional monthly payments and late charges which may fall due during this period You must contact the undersigned at 609-784-8220 to determine what additional monthly payments and late charges are due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: SPEAR & HOFFMAN, P.A. 1018 LAUREL OAK ROAD, SUITE 1 VOORHEES, NJ 08043 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the Mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. Ifyou cure the default within the THIRTY (30) DAYperiod, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheri, ff"s foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately 5 months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us or our attorneys at (609) 784-8220. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, lRichard M. Nelson, Esquire NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT Rhc Act) 15 U.S C. SECTION 1601 A AMENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting the debt. 2. The amount of the debt is stated on page I of the Act 6 letter. 3. CHASE MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 4. The debt described in the Act 6letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the named creditor is not the original creditor, and if Ure debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. Law Offices Spar and Hoffman 9 P.A. Irvine C. Spear (1922-1476) DATE: 6 -10-QQ VIA REGULAR MAIL JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No. 1500355595 Property: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. The MORTGAGE held by CHASE MANHATTAN MORTGAGE CORPORATION (hereinafter we, us or ours), on your property located at 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013, IS IN SERIOUS DEFAULT because you have not made the following payments Regular monthly payments for the months of JANUARY 1, 1999 through today's date. 6 Payments of $425.49 from 111199 to 611199 $2,552.94 Late Charges for the months of JANUARY 1, 1999 through today's date. $90.09 TOTAL DUE $2,643.03 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $2,643.03 1018 Laurel Oak Road / Suite 1 / Voorhees, New Jersey 08043 / Phune:(609) 784-8220 / Fax: (609) 784-8322 You may cure this default within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $2,643.03, plus any additional monthly payments and (ate charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: SPEAR & HOFFMAN, P.A. 1018 LAUREL OAK ROAD, SUITE I VOORHEES, N1 08043 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owning on the original amount borrowed will be considered due immediately and you may lose die chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the Mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAYperiod, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff `s foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney fees and costs connected with the foreclosure sale [and perfontt any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately 5 months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at or our attorneys at (609) 530-9520. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. if you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, Richard M. Nelson, Esquire NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the Act) 15 U.S C. SECTION 1601 AS AMENDED 1. The amount of the debt is stated on page I of the Act 6 letter. 2. CHASE MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 3. The debt described in the Act 6letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 4. If the debtor notifies the creditor's law ftmt in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 5. If the named creditor is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 6. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. Law Offices Spear and Hoffma_n_.? P.A. [Mw C. 3p=(1922-1976) DATE: & -10-,7q VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED JOSEPH CARMINATI 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No. 1500355595 Property: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. The MORTGAGE held by CHASE MANHATTAN MORTGAGE CORPORATION (hereinafter we, us or ours), on your property located at 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013, IS IN SERIOUS DEFAULT because you have not made the following payments Regular monthly payments for the months of JANUARY 1, 1999 through today's date. 6 Payments of $425.49 from 111199 to 611199 $2,552.94 Late Charges for the months of JANUARY 1, 1999 through today's date. $90.09 TOTAL DUE $2,643.03 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $2,643.03 1018 Laurel Oak Road / Suite 1 / Voorhees, New Jersey 08043 / Phone:(609) 784-8220 / Fax: (609) 784-8322 You may cure this default within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $2,64.3.03, plus any additional monthly payments and late charges which may fall due during this period You must contact the undersigned at 609-784-8220 to determine what additional monthly payments and late charges are due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: SPEAR & HOFFMAN, P.A. 1018 LAUREL OAK ROAD, SUITE I VOORHEES, NJ 08043 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the Mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attomey's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately 5 months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may rind out at any time exactly what the required payment will be by calling us or our attorneys at (609) 784-8220. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, Richard M. Nelson, Esquire NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT (the Act) 15 U S C SECTION 1601 A AMENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection. Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting the debt. 2. The amount of the debt is stated on page 1 of the Act 6 letter. 3. CHASE MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 4. The debt described in the Act 6 letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the named creditor is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. Law Offices Spur and Hoffman P A Iffim C. SPor(1922-1976) DATE: 6 -10 - qQ VIA REGULAR MAIL JOSEPH CARMINATI 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No. 1500355595 Property: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 ACT 6 NOTICE NOTICE OF INTENTION TO FORECLOSE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. The MORTGAGE held by CHASE MANHATTAN MORTGAGE CORPORATION (hereinafter we, us or ours), on your property located at 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013, IS IN SERIOUS DEFAULT because you have not made the following payments Regular monthly payments for the months of JANUARY 1, 1999 through today's date. 6 Payments of $425.49 from 111199 to 611199 $2,552.94 Late Charges for the months of JANUARY 1, 1999 through today's date. $90.09 TOTAL DUE $2,643.03 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $2,643.03 1018 Laurel Oak Road / Suite 1 / Voorhees, New Jersey 08043 / Phone:(609) 784-8220 / Fax: (609) 784-8322 r You may cure this default within THIRTY (30) DAYS, of the date of this letter, by paying to us the above amount of $2,643.03, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: SPEAR & HOFFMAN, P.A. 1018 LAUREL OAK ROAD, SUITE I VOORHEES, NJ 08043 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owning on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the Mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAYperiod, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately 5 months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at or our attorneys at (609) 530-9520. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR'I!.hNSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE, ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be resiored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Sincerely, Richard M. Nelson, Esquire NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES err h6n Aryl 15 U S C SECTION 1601 AS AMENDED 1. The amount of the debt is stated on page 1 of the Act 6 letter. 2. CHASE MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 3. The debt described in the Act 6 letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 4. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 5. If the named creditor is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 6. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. Exhibit "D" I, Law Offices Spur and Hoffman P.A. [vine C. Stmr(t922.t976) ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. IF YOU NEED MORE INFORMATION, CALL THE PENNSYLVANIA HOUSING FINANCE AGENCY AT 1 (800) 342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS 1018 Laurel Oak Road / Suite I / Voorhees, New Jersey 08043 / Phone:(609) 784-8220 / Fax: (609) 784-8322 DATE: -/Q -,?q RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No.: 1500355595 Property Address: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 TO: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 FROM: Richard M. Nelson, Esquire SPEAR & HOFFMAN, P.A. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Richard M. Nelson, Esquire Spear & Hoffman, P.A. 1018 Laurel Oak Road, Suite 1 Voorhees, NJ 08043 (609)784.8220 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $2,643.03. That sum includes the following: regular monthly payments of $425.49 for the months of JANUARY 1, 1999 through today's date, plus monthly late charges for the months of JANUARY 1, 1999 through today's date. Your mortgage is also in default for the following reasons: n/a If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call 1-800-342-2397. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, -' , x^ -? Richard M. Nelson, Esquire Attachment NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT. (the Act) 15 U.S.C. SECTION 1601 AS AMENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting the debt. 2. The amount of the debt is stated on page 2 of the Act 91 letter. 3. CHASE MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 4. The debt described in the Act 91 letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the named creditor is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NI 08043. ._. ? _.+_?. ?_ ... vrr. ?ii'. f, ? ? . .: 1 . I ` :;.?: 1 ? . o?n1?? CORRECTION Previous Image Refilmed to Correct Possible Error Law Offices Spear and Hoffman, P.A. Irvine C. year (1922-1976) ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU. READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. IF YOU NEED MORE INFORMATION, CALL THE PENNSYLVANIA HOUSING FINANCE AGENCY AT 1 (800) 342-2397. LA NOTIFICACION EN ADJUNTO ES. DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS 1018 Laurel Oak Road / Suite I / Voorhees, New Jersey 08043 1 Plione:(609) 784-8220 / Fax: (609) 784.8322 DATE: 6 -to -9q RE: CHASE MANHATTAN MORTGAGE CORPORATION Loan No.: 1500355595 Property Address: 151 WEST NORTH STREET, CARLISLE BOROUGH, PA 17013 TO: JOSEPH CARMINATI 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 FROM: Richard M. Nelson, Esquire SPEAR & HOFFMAN, P.A. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Nuance Agency. Please read all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Richard M. Nelson, Esquire Spear & Hoffman, P.A. 1018 Laurel Oak Road, Suite I Voorhees, NJ 08043 (609)784.8220 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $2,643.03. That sum includes the following: regular monthly payments of $425.49 for the months of JANUARY 1, 1999 through today's date, plus monthly late charges for the months of JANUARY 1, 1999 through today's date. Your mortgage is also in default for the following reasons: n/a If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call 1-800-342-2397. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, Richard M. Nelson, Esquite" - Attachment NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRAC'TIC'ES ACT (the Act) 15 U S C SECTION 1601 AS AMENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting the debt. 2. The amount of the debt is stated on page 2 of the Act 91 letter. 3. CHASE. MANHATTAN MORTGAGE CORPORATION is the creditor to whom the debt is owed. 4. The debt described in the Act 91 letter will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the named creditor is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. Exhibit "E" NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT (the Act) 15 U S C SECTION 1601 AS MENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit may be used for the purpose of collecting the debt. 2. The amount of the debt is stated in paragraph 9 of the Complaint. 3. The Plaintiff as named in the Complaint is the creditor to whom the debt is owed, or is servicing agent for the creditor to whom the debt is owed. The undersigned attorney represents the interests of the Plaintiff. 4. The debt described in the Complaint, evidenced by the copy of the mortgage note attached hereto, will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the creditor named as Plaintiff in the Complaint is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffman, P.A., 1018 Laurel Oak Road, Suite 1, Voorhees, NJ 08043. i' i •' t? • r -t, I n? F :.J l? ?? T ce) ^V^ ))V v/ ?r Spear & Hoffman, P.A. BY: RICHARD M. NELSON, ESQUIRE Attorney I.D. No. 72869 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No.: 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 99-4658 CIVIL JOSEPH CARMINATI DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION OF COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification to the Complaint in Mortgage Foreclosure on the above- captioned matter. SPEAR AND HOFFMAN, P.A. RICHARD M. NELSON, ESQUIRE VERIFICATION The undersigned hereby states that he/she is an authorized officer, representative or agent for Plaintiff in this action and that he/she is authorized to make this Verification on behalf of Plaintiff, and that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of his/her knowledge, information and belief. THE UNDERSIGNED UNDERSTANDS THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: 7- ?-to -qG Name: f11CLrK 5• Gocdt: Company: C kac5 Me n kaPfan f1i or710.? e- Corp . Title:414, Vice- (-esidenT _ ;`. ?? ?.. _ ;; , .?: . ,, ?. ..l I IN TI IE COt IR'I OI' COMMON 1'LGAS OI' Ct1M131iRLAND COI1N'I'Y. PENNSYLVANIA CIVIL DIVISION PRAECIPE, FOR WRIT OI' FXECU IION CHASE MANITAVI'AN MORTGAGE CORPORATION VS. ( ) Confessed Judgment ( ) Other File No. 99-4658 CIVIL Amount Due $45.771.10 JOSEPH CAR,MINATI Any's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) 151 WEST NORTH STREET CARLISLE BOROUGH PA 17013 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: December G 1999 Signature: Print Name: Richard M Nelson Esquire Address: 1020 N Kings Highway Suite 210 Cherry Hill N.J. 08034 Attorney for: Chase Manhattan Mortgage Corporation ?Mj 0 r ca >. ; i ?' ri ?? =_ ',`? D ? ? 1 ? ,J c_ ;i.. (? p ? J c'' "? ?? ? . SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, Vs. JOSEPH CARMINATI DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-4658 CIVIL CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: CHASE MANHATTAN MORTGAGE CORPORATION 1400 EAST NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 and that the last known address(es) of the judgment debtor (Defendant (s)) is (are): JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 SPEAR & HOFFMAN, P.A. BY: -- RICHARD M. NELSON, ESQUIRE } x ? _: ?? c?, F-; , wr' -?.,r 1:?:- . -c7 .,;;; ?:,. ? _ j- C :IICl U Q1 c? CJ Spear & Hoffman, P.A. BY: RICHARD M. NELSON, ESQUIRE Attorney I.D. No. 72869 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No.: 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 994658 CIVIL JOSEPH CARMINATI DEFENDANTS CERTIFICATION OF MAILING NOTICE PURSUANT TO RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to file a Praecipe for the Entry of Default Judgment was mailed to Defendant(s) and to his, her or their attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe for the Entry of Judgment. A true and correct copy of each Notice is attached hereto, sent as stated. SPEAR & HOFFMAN, P.A. $- Dated: 30 -gq BY: RICHARD M. NELSON, ESQUIRE Attorney for Plaintiff a? LLI?? '-?l (J>'- ' ? '_7c] _ ? f i)?:.. ?:L ??'J 'l c Cl ? ?? ' c C' ? i SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff' CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, VS. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY JOSEPH CARMINATI DEFENDANT(S) NO. 99-4658 CIVIL CERTIFICATE OF SERVICE We, Spear and Hoffman, P.A., Attorney for the Plaintiff, hereby certify that we have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 Date mailed: (t' C SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE CC- CX) L.I cz? a- O U o. SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755.1560 Attorney for Plaintiff Loan# 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION 1400 EAST NEWPORT CENTER DRIVE DEERFIELD BEACH, FL 33442 PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET 99-4658 CIVIL JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter Judgment IN REM in the amount of $45,771.10 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiff's Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $40,102.87 Interest at 8.75% from JANUARY 1, 1999 to DECEMBER 6, 1999 (370 days @ $9.61370 per diem) $3,557.07 Accrued Late Charges $106.02 Attorneys Fees $2,005.14 TOTAL AMOUNT DUE $45,771.10 Richard M. Nelson, ESQUIRE Attorney for Plaintiff ter u> >- CS ? r- Li c . ? ^:Q ; ?? v } AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $45,771.10 PRO PRO, '`-IY Z',CL a? a) uj? r f =?. Ul 111-- a. ;;. i U C =. 0. Lj l Spear & Hoffman, P.A. BY: RICHARD M. NELSON, ESQUIRE Attorney I.D. No. 72869 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No.: 1500355595 CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, VS. JOSEPH CARMINATI DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 994658 CIVIL NOTICE To: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 Date of Notice: g.30-4q IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (717) 249-3166 Richard M. Nelson, Esquire Attorney for Plaintiff THIS LAW FIRM MAY BE DEEMED A "DEBT COLLECTOR" UNDER THE FAIR DEBT COLLECTION PRACTICES ACT. ANY AND ALL INFORMATION OBTAINED DURING THE PROSECUTION OF THIS LAWSUIT MAY BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. v Lr. ? CC) I ?r J CL 6?: ?.: ??11`u C C.L ? U SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 99.4658 CIVIL JOSEPH CARMINATI DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 Your house (real estate) at: 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 is scheduled to be sold at Sheriffs Sale on MARCH 1, 2000 at: CUMBERLAND COUNTY COURTHOUSE 2ND FLOOR, COMMISSIONERS HEARING ROOM I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 at 10:00 a.m. to enforce the court judgment of $45,771.10 obtained by CHASE MANHATTAN MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to CHASE MANHATTAN MORTGAGE CORPORATION the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (8561755-1560. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to step the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ti YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. L If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (717)240-6390. 2 You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717)240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than APRIL 1, 2000 This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 11- YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURTHOUSE I COURTHOUSE SQUARE CARLISLE, PA 17103 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ? Ql r = a, to (_J .11 UJ (D 0? c-) l SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, VS. COURTOF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 99.4658 CIVIL. JOSEPH CARMINATI DEFENDANT(S) AFFIDAVIT OF NON-MILITARY SERVICE RICHARD M. NELSON, ESQUIRE, being duly sworn according to law, deposes and says that he is attorney for Plaintiff in the above-captioned matter, that he makes this Affidavit on Plaintiffs behalf, and that the statements in this Affidavit are true to the best of his knowledge, information and belief. Defendant, JOSEPH CARMINATI, is over 21 years of age. His last employment is unknown. Defendant is not in the military service of the United States as contemplated by the Soldiers' and Sailors' Civil Relief Act, as amended. This Affidavit is made in connection with the judgment upon a note and mortgage secured upon the premises located at 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013. SWORN TO AND SUBS RIBED BEFOREETHIS G DAY OF ?, % ?: - S BY: RICHARD M. NELSON, ESQUIRE n / - December 6, 1999 ATRICIA BONKOWSKI NOTARY PUBLIC OF NEW JERSEY ,IY COMMISSION EXPIRES 11/1012003 C; Al L IJI??i i rl„ ?1 (.IJ L.. ? ..' JJ LL L ? ' U rn U ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BOUNDED on the South by West North Street; bounded on the West by property formerly of Rica and Maggie Brown, now or formerly of Shultz, bounded on the North by a 12 foot alley; and bounded on the East by property now or formerly of J. W. Handshew Estate, Containing 28 feet, more or less, in front on West North Street and extending in depth 114 feet, more or less, to the aforesaid 12 foot alley. Together with the free and uninterrupted passage through said alley. Having thereon erected a two-story frame dwelling known and numbered as 151 West North Street. Parcel# 05-20-1798-123. BEING the same premises which Helena Davis, widow, and Sharon Alice Davis, single, by Deed dated 12/20/96 and recorded 1/2/97 in the County of Cumberland in Record Book 151 page 520 conveyed unto Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co, of Pennsylvania, in fee. of N y v w ` ILL cn m .J U SHERIFF'S RETURN - REGULAR CASE NO: 1999-04658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. CARMINATI JOSEPH DAWN L. 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 CARMINATI JOSEPH the defendant, at 15:30 HOURS, on the 6th day of August 1999 at K STREET VIDEO PIZZA EXPRESS 1548 SPRING ROAD CARLISLE, PA 17013 ,CUMBERLAND County, Pennsylvania, by handing to VICKIE EDDY (MANAGER) a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 3.10 f? Affidavit .00 /• 2 Surcharge 8.00 IT7 omas ine, eri $Z9 TO-SP AR & HOFFMAN 0809/1999 by epu y eri Sworn and subscribed to before me this ? day of 19-qf A.D. r on ary SPEAR & HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 99-4658 CIVIL JOSEPH CARMINATI DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Richard M. Nelson, ESQUIRE sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s): JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 2. Name and address of Defendant(s) in the judgment: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: BOROUGH OF CARLISLE TAX COLLECTOR CARLISLE. PA 17013 DOMESTIC RELATIONS P.O. BOX 320 13 N. HANOVER ST. CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE LIEN HARRISBURG, PA 17501 TAX CLAIM BUREAU 1 COURTHOUSE SQUARE CARLISLE, PA 17013 CAROLYN MCQUILLEN TAX COLLECTOR 1044 PINE ROAD CARLISLE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT(S)/OCCUPANT(S) 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 I verify that the statements made in this 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. §4904 relating to unswom falsification to authorities. SPEAR & HOFFMAN, P.A. Richard M. Nelson, ESQUIRE Attorney for Plaintiff %i T a i- L J O^ C? Spear & Hoffman, P.A. Richard M. Nelson, Esquire Attorney I.D. No. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NJ 08034 (856)755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPOR COURT OP COMMON PLEAS CUMBERLAND COUNTY vs. JOSEPH CARMINATI Defendant DOCKET NO. 99-4658 CIVIL CERTIFICATION OF NOTICE 7'O LIENI IOLDERS PURSUANT TO PA R.C.P. 3129.2 (C) (2) I,Pat Bonkowski, Paralegal to Richard M. Nelson, Esquire, Attorney liar Plaintiff, hereby certify that Notice of Sale was served on all persons appearing on Plaintiffs Affidavit pursuant to PA R.C.P. 3129. 1, by United States mail, first class, postage prepaid, with Certificates of Mailing, the originals of which are attached as Exhibit "A". The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SPEAR & IIOPFMAN, P.A. BY:-.?1t Pat Bonkowski PARALIi(iAL TO RICI IARD M. NELSON, FSQUIRE Exhibit "A" • J !I f `? r C?ypr ' lfl 1 t` ? LL d ?'"I ? EELkp s iS?F Y ? Y 0 HE S ° r- o oc y c o; I Q m Y ytn Y Q ? yyy C ?? ? ? F J c? no Ede m 00 t Cfi 9?fi m N U ? ? K{O <Q: c y yyy I j $a I ? m y ? L q le ?m?QQ?((yy$$ 9 .Q?Ca 7a ? ?u e?4 ? i 0 L 0 ° L ?o? _? rr °O $'e ???' ? 11 C ¢ ? o E: am ¢ r n E o 0O ^p [ ov $ ? '?Om ??°1 F v Q_UU ° 0 v Q g o L F O ° r N a° A a° • ? •y Q 0 c j ? c m a C a ? d r, r > > a+ a O m t 'Lp v`m r ` 7 (n 01 ? O °-PO 0 8 ° ? ? Q m E v `p a Z i d w _ m % o C C) O a C a C O V V! V O N H E o . 7 Y M M O °' m O Z F r V I- F- U a s s d U N ip t a2 A v Cl) g.a ` m m m e m ?y o i £ FeaN m .? n m .? in a v E r a• a a 0 a m .l° E 0 LL m Z m r m N E LE • -- 4VI ' 1I I I m ?C F.p OOH I+I a Al?l ????g r n I ? 5 H ui! `n G . y LL Q 'g ?Eifh 5 ? i Jos I I T cESa of 6 2 c @E' E 3 o = .9 a ?? a E E : g ' a ? M 35 L HI A_ E IS g a , HIM y arn?` 33 Fb c ` r0 C g ? Rpd ??°' ? o {?0 ° $ wE LL y?? . gQ?' d e ? 5 e m `s?se" Y ¢°? Ew u 0 EI E E 0 ° ? ` 9 E i mo 9 ?O °mnUu e¢SUV w c m o` (4 <° C O o CN a° N C a w Y 43 C d r j ? ? " d N 43 d o g a • 0 r 0 T g ` O w , fn CN a ?r Oi o c Q N O 0 3 ^ E _ € a w C ) X A C no O N _ z •? 0 N N d 0 CO S O ,0 N 0 0 8°_ c Y m H V E z co E_ ? z D a .. ?o d N CL ? + ip ? 8 m < ' z E a g 1? 9 E y M ^ U E .. _ .. ,.. .. m °_m m 0 LL li A m E LL STATE OF PENNSYLVANIA, C COUNTY OF CUMBERLAND J SS. I, ------ ----------------------------------------------------- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ---------------- Federal Home Ln Mtg Assco ---- •-------------------------------------------------------- is the grantee the same having been sold to said grantee on the ___].s.t---------------------------------------- day of March 2000 ---------------------------------------- A. D., 19-- ---------- under and by virtue of a writ-------------- --------- Execution---------------------------issued on the---------- 14th ---------- day of ------- --------------------- December December ----- - A. D., 19___99, out of the Court of Comman Pleas of said County as of Civil -----_-_ ---------------°-------------------------------------------------- Term, 19-- 99-- Number___ 4658 - atthesuitof__Chase Manhattan Mtg CorQ_________-_ - -------------------------------------'---------- against ----- J--o-s----eph ---- Ca------rmina-ti ------------- ----- n duly recorded in Sheriff's Deed Book No. Page____ 1029 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ------ 0-?/ ------ A. D., IJu ?{v ?J? of Deeds Recorder of D", Cumberlemf Ceuadl, CIM11, fM MF Cemsuum Erpiree the Fiat Mtmday of hn. 2W ? _ S r 1 i. f.J Chase Manhattan Mortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Joseph C. Carminati No. 99-4658 Civil Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on January 7,200 at 2:38 o'clock P.M.EDST, he posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of Joseph Carminati located at 151 West North Street, Carlisle, Cumberland County, Pennsylvania, according to law. Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on January 7, 2000 at 2:16 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Joseph C. Carminati by making known unto Joseph Carminati at 1548 Spring Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant to wit: Joseph C. Carminati by regular mail to his last known address 1548 Spring Road, Carlisle, Pennsylvania. This letter was mailed under the date of January 8, 200 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on March 1, 2000 at 10:00 o'clock A.M.EST and sold the same to James Kayer for Federal Home Loan Corporation for the sum of $ 1.00. It being the highest bid and best price quoted for the same Federal Home Loan Mortgage Corporation of 2231 Crystal Drive, Arlington, VA being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 656.35 it being costs. Sheriffs Costs Docketing 30.00 Poundage 12.87 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 6.20 Certified Mail .99 Levy 15.00 Surcharge 16.00 Law Journal 237.50 Patriot News 189.71 Share of Bills 25.08 Distribution of Proceeds 25.00 Sheriff's Deed Sworn and Subscribed To Before Me This.ln<C Day of O'Cl:1 2000, A.D. P tl onotary 26.50 $ 656.35 Pd By Any 03/17/00 So an?}vers r w•: R. Thomas KlineQe,, Sheriff By ?6k/L Real Estate Deputy Gt d710Y 14. , 93 -71y THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ret No. 587. Bsnroeed Mao 16. 1929 Commonwealth of Pennsylvania, County of Dauphin) as FrankJ.15p/er being duly sworn according to law, deposes and says: That he Is the 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 and Metro editionslssues which appeared on the 25th day of January and the let and 8th day(s) of February 2000. That neither he nor said Company is Interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. _ PUBLICATION COPY S A L E Y21 Notarial Seal Tony L. Russell, Notary Public Harrisburg, Devotion County My Comnilsslon Expires June 6.2002 this 25th Member, Pennsylvania Association 01 Nobs Commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE 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 $ 188.21 Probating same Notary Fee(s) $ 1.50 Total $ 189,71 isher's Receipt for Advertising Cost sher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have THE PATRIOT-NEWS CO. By .......................... V :, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 21, 28, FEBRUARY 4, 2000 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 BALE NO. 21 Writ No. 99-4656 Civil Chase Manhattan Mortgage Corporation VS. Joseph Carnunatl Atty.: Richard M. Nelson ALL THAT CERTAIN tract of land situate in the Borough of Carlisle. I County of Cumberland and Com- i monwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BOUNDED on the South by West North Street; bounded on the West by property formerly of Rica and Maggie Brown, now or formerly of Shultz, bounded on the North by a 12 foot alley; and bounded on the East by property now or formerly of J. W. Handshew Estate. Containing 28 feet, more or less, In front on West North Street and extending in depth 114 feet, more or less, to the afore- said 12 foot alley. Together with the free and uninterrupted passage through said alley. Having thereon erected a two-story frame dwelling known and numbered as 151 West North Street. PARCEL 005-20.1798-123. BEING the same premises which Helena Davis, widow, and Sharon Alice Davis, single, by Deed dated 12/20/96 and recorded 1/2/97 In the County of Cumberland In Record Book 151 page 520 conveyed unto Beneficial Consumer Discount Com- pany D/B/A Beneficial Mortgage Co. of Pennsylvania, in fee. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 4 day of FEBRUARY 2000 NOTARIAL SEAL' tOiS E. SNYDER, 14ctory Public CarliJa lbro. CVmb'hufld 'ounfy, PA My CommiwcO Expire, March S, 2IX1I i. v. REAL AT=- NO 21 51,000.00 Advance Costs Paid 12/15/99 Arr;. Spear & Hoffman Assessed'valuationS 4410.00 CvT%J N0, 99-4658 Civil REP.L DEBT I\TEPEST ATT'S FEES uRIT COSTS ?.TTY ESCROW LATE CH.-%RGE SHERIFF'S COSTS Docnetino Poundaee Postine Bil is Adve-isine Ackto,.vledaine Deed Auctioneer Lau Lib=; C o unr.- "'Iileasa Ccn Mail Le-,-,- Postpone Sale Surcharge Chase Manhattan Mortgage Corporation VS Joseph Carminati 151 West North Street Carlisle, PA $ 45,771.10 Le gaI Starch ' Dt'7?TI' i`:r;: Law Journal Patriot Share of Bills Distribution of P;oce_cs e= - STAMPS Pa Transfer Tax T`vp or Boro Trar._fer Taz TAYIS Sewer & Water 2000 County Library & Boro Taxes 101.10 30.00 12.87 15.00 15.00 30.00 10.00 .50 1.00 6.20 .99 15.00 16.00 237.50 129:N 25.00 26.50 147.50 291.73 r SPEAR & HOFIFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 99-4658 CIVIL JOSEPH CARMINATI DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Richard M. Nelson, ESQUIRE sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013: 1. Name and address of Owner(s) or Reputed Owner(s): JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 2. Name and address of Defendant(s) in the judgment: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 3. Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: BOROUGH OF CARLISLE TAX COLLECTOR CARLISLE, PA 17013 DOMESTIC RELATIONS P.O. BOX 320 13 N. HANOVER ST. CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE LIEN HARRISBURG, PA 17501 TAX CLAIM BUREAU 1 COURTHOUSE SQUARE CARLISLE, PA 17013 CAROLYN MCQUILLEN TAX COLLECTOR 1044 PINE ROAD CARLISLE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT(S)/OCCUPANT(S) 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 I verify that the statements made in this 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. §4904 relating to unswom falsification to authorities. SPEAR & HOFFMAN, P.A. Richard M. Nelson, ESQUIRE Attorney for Plaintiff SPEAR R HOFFMAN, P.A. BY: RICHARD M. NELSON, ESQUIRE ATTORNEY I.D. NO. 72869 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY FILL, NEW JERSEY 08034 (856) 755-1560 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 99-4658 CIVIL JOSEPH CARMINATI DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOSEPH CARMINATI PO BOX 1006 CARLISLE BOROUGH, PA 17013 Your house (real estate) at: 151 WEST NORTH STREET CARLISLE BOROUGH, PA 17013 is scheduled to be sold at Sheriffs Sale on MARCH 1, 2000 at: CUMBERLAND COUNTY COURTHOUSE 2ND FLOOR, COMMISSIONERS HEARING ROOM I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 at 10:00 a.m. to enforce the court judgment of $45,771.10 obtained by CHASE MANHATTAN MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to CHASE MANHATTAN MORTGAGE CORPORATION the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (856) 755-1560. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY S'fII.L BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHIRIPF'S SALE DOI?S TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (717)240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your properly. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717)240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than APRIL 1, 2000 This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURTHOUSE I COURTHOUSE SQUARE CARLISLE, PA 17103 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BOUNDED on the South by West North Street; bounded on the West by property formerly of Rica and Maggie Brown, now or formerly of Shultz, bounded on the North by a 12 foot alley; and bounded on the East by property now or formerly of J. W. Handshew Estate, Containing 28 feet, more or less, in front on West North Street and extending in depth 114 feet, more or less, to the aforesaid 12 foot alley. Together with the free and uninterrupted passage through said alley. Having thereon erected a two-story frame dwelling known and numbered as 151 West North Street. Parcel# 05-20-1798-123. BEING the same premises which Helena Davis, widow, and Sharon Alice Davis, single, by Deed dated 12/20/96 and recorded 1/2/97 in the County of Cumberland in Record Book 151 page 520 conveyed unto Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co. of Pennsylvania, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO.. 99-4658 CIVIL Yg_ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF nrrnhwrlanrl COUNTY: To satisfy the debt, interest and costs due Chase Manhattan Mortgage Corporation from Joseph Carlninati 151 West North Street Carlisle, PA 17013 DEFENDANT(S) (1) 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 as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If propertyof the defendant(s) not levied upon an subject to attachment is found in the possession of anyoneother 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 $45.771.10 Interest _ Atty's Comm Atty Paid _ Plaintiff Paid L.L. _ $.50 Due Frothy $1.00 Other Costs Date: December 14, 1999 Curtis R. Prothonotary, Civil Division REQUESTING PARTY: Name Richard M. Nelson. Esq. Address: 1020 N. Kings Highway. Suite 210 by' Deputy Attorney for: Chat Manhat't'an __Coi=ation Telephone: (Rcih) 799-1 un Supreme Court ID No. - REAL ESTATE SALE No.';w LL la > S .r, 4 4 Q W? J? 4.C O un tiu -""" IZ / "cj ttln Sif rllf iC'Ji°ti lij.: !} in, drt811 Vii" w interest in the real property situated in Cam' Cumberland County, Pa., known and numbared as: 16'1 AA19o,L4_..___ and more furl, ,±escriMcl on Exhibit "A" filed with .r-li 1 w N rhis welt and by this reference inccrperated herein. .i e: d p V V