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HomeMy WebLinkAbout03-3216FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANI-IATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff JENNIFER L. GRAY 105 HILL STREET MOUNT HOLLY SRPINGS, PA 17065 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DIVISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintift: 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 76525 IF THIS IS THE F/RST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEEENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WR/TING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAlL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. File #: 76525 Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: JENNIFER L. GRAY 105 HILL STREET MOUNT HOLLY SRPINGS, PA 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 04/19/1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST PREFRENCE MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1535, Page 593. By Assignment of Mortgage recorded 4/20/1999 the mortgage was assigned to PLA/NTIFF which Assignment is recorded in Assignment of Mortgage Book No. 610, Page 435. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 76525 The following amounts are due on the mortgage: Principal Balance Interest 02/01/2003 through 07/07/2003 (Per Diem $ l 0.40) Attorney's Fees Cumulative Late Charges 04/19/1999 to 07/07/2003 Cost of Suit and Title Search Subtotal $84,356.79 1,632.80 1,250.00 113,92 $ 550.00 $ 87,903.51 Escrow Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $ 87,903.51 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 87,903.51, together with interest from 07/07/2003 at the rate of $10.40 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: FEDERMAN AND PHELAN, LLP /s/Francis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #; 76525 gLO. ?NAT CERTAIN tract of land with improvements thereon created situate in the Borough of Mount Holly Spr/ngs, Cumberland County, Penns3qvania, bounded and described according to a surv~ by Rolmrt I. Fredricg .Ir., P.L.S, dated $,,ly 19,1991, (copy altached hereto) as follows, to wit: BI~GI~INING at a point in the center line of Hill Street at the northwestern comer of land now or formerly ofRodney C. Keckler; thence along said land ot'Redney C. Keclder, South 21 degrees 30 minutes East 330.00 feet to a poinl; thence along same, South 72 degrees 00 minutes West 46.20 fi:et lo an iro~., pin se~, thence along land now or formerly of Valley Quarries, Inc., lqorth 21 degrees 30 minutes West 330.00 fe~t to a point in the center line of Hill St~t; tl~ence along the center line ofF/ill Street, North 72 degrees 00 minutes East 46.20 f~et to a point, tim Place o£Beginn!ng. BE1N~} improved with a two story fremc dwelling house known as 105 Hill Street, Mount Holly Springs, Pennsylvania. BEING the same premises which Riohard B. Weary and Barbara J. Wcasy, by deed datod February 24, 1995 and recorded in Cumberland County Deed Book '~tolume 119, Pago 128 granted and conveyed unto JulJe A Winner, Grantee herein. PREI, iISES EEI~IgG : ].05 H3~LL STREET VERIFICATION FRA. NCIS S. HALLINAN. ESQUERE hereby states that he is anomey for Plaintiff in this matter, tho Plaintiff is outside :he jurisdiction o f,.'he cou~ an&'or the veri?<affon could not be obtained within :he time allowed for the filing of :he pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. I02-t ( c ). and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by' Plaintiff and are true and correct to the best of its knowledge. information and belief. Furthermore. it is counsel's intention to substitute a ~eriJcation from Plaintiff as soon as it is received by counsel. The undersigned understands that this statemen~ is made subject ro the penalties of I~ Pa. C. S. Sec. 4904. relating to u.nswom £alsiflcation to au~ofides. DATE: Fifty'is S. Hallinan. Esquire Aaomey tbr Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-03216 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CLrMBERLAND CHASE MANHATTAN MORT CORP VS GRAY JENNIFER L BRIAN BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE GRAY JENNIFER L DEFENDANT , at 2058:00 HOURS, at 105 HILL STREET MT HOLLY SPRINGS, PA 17065 MANCIL GRAY, FATHER IN LAW a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 28th day of July the together with by handing to 2003 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this 6 ~ day of  ~ A.D. "~rothonotary So Answers: R. Thomas Kline~ -' ~ 07/29/2003 ~ FEDERMANBy: &~ ~l Deputy Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215] 563~7000 CHASE MANHATTAN MORTGAGE CORPORATION 345 VISION DRIVE COLUMBUS, OH 43219 Plaintiff, JENNIFER L. GRAY Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3216 CML TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THEPROTHONOTARY: Kindly emer an in rem judgrnent in favor of the Plaimiff and against JENNIFER L. GRAY and , Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 7/7/03 to 9/5/03 TOTAL $87,903.51 $634.40 $88,537.91 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~-~ PRO PROTHY FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 56~-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. JENNIFER GRAY Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-3216 CIVIL TERM TO: JENNIFER GRAY 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: AUGUST 19, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days fi:om the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other nnPortant 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 fred out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK F~ ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-03216 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERL~2qD CHASE MANHATTAN MORT CORP VS GRAY JENNIFER L REGULAR BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GRAY JENNIFER L DEFENDANT , at 2058:00 HOURS, at 105 HILL STREET MT HOLLY SPRINGS, PA 17065 MuA_NCIL GHAY, FATHER IN LAW a on the 28th day of July by handing to true and attested copy of COMPLAINT - MORT FORE the · 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this day of A.D. So Answers: R. Thomas Kline ..... 07/29/2003 ~ FEDERMANBy: &~ ~l Deputy Sheriff Prothonotary FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 {215} 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 345 VISION DRIVE Plaintiff, JENNIFER L. GRAY Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3216 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JENNIFER L. GRAY is over 18 years of age and resides at, 105 HILL STREET, MOUNT HOLLY SPRINGS, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHASE MANHATTAN MORTGAGE CORPORATION 345 VISION DRIVE Plaintiff, JENNIFER L. GRAY Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DIVISION NO. 03-3216 CIVIL TERM Notice is given that a Judgment in the above-captioned matter has been entered against you on 200 . 1~: D~EPUtU~T~ If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103 - 1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PlffRPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JENNIFER L. GRAY Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3216 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, Vo JENNIFER L. GRAY Defendant(s). No. 03-3216 CML TERM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/5/03 to DECEMBER 10, 2003 (per diem -$14.55) TOTAL $88,537.91 $1,396.80 and Costs $89,934.71 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Note: Please attach description of property.No. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land wilh improv~cmm~s tic. con crcctcd, situate iu t¢ Borough o[ tvlount Holly Springs, Curnberiaud ~llt, Pennsylvania, bounded aud described according to a Survey by Robcr~ L Fredrick, ir., P.L.S,, dated July 19, i991, (cOpy aU. ached her~o) as follows, lo wit: BEGINNING at a poit~t in th~ ccm,'r l~ of lti[[ ~t~'~l ~ ~e No~w~n ~m~ of ~ no~' or fox, fly of R~ C. K~er; ~e~c along said la~ of ~y C. K~kl~, S~th 21 de~e~ 30 minu~ East 330.~ feet to a ~i~; ~ flo~ ~e, Sau~ 72 de~ ~ m~ W~ 46.20 ~ to an iron pia set; ~e~ alo~ ~ now or ~rty of Vall~ ~a~i~, ~., N~th 21 ~s 30 ~au~ W~ 330,~ [~t m a ~im in t~ ~ l~ of Hill S~; ~ flnag ~a cente~ i~ of Hill Steer, North 72 deg~ ~ ~u~a ~ 46.~ feel m a poim, ~e pla~ of ~, TITLE TO SAID PREMISHS IS 'vESTED I]-4 lermirer L. Gray by Deed from Julie A. Witmer, dal~l 4i19/1099 and recorded 4/20/1999 in Deed Itook 197, Page 911. Tax Parcel g23-32-2336-348 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N003-3216 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From JENNIFER L GRAY 105 HILL STREET MOUNT HOLLY SPR/NGS PA 17065 (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 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are cY~rected to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Dues 88,537.91 L.L.$ 0.50 Interest FROM 9/5/03 TO DECEMBER 10, 2003 (PER DIEM-S14.55) $1,396.80 Atty's Corem % Due Prothy $1.00 Atty Paid $114.14 Other Costs Plaintiff Paid Date: SEPTEMBER10, 2003 (Seal) CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name FRANK FEDERMAN ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F KENNEDY BOULEVARD SUITE1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, JENNIFER L. GRAY Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 03-3216 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,105 HILL STREET, MOUNT HOLLY SPRINGS, PA 17065. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please intricate) JENNIFER L. GRAY 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Narne Last Known Address (if address cannot be reasonably ascertained, please indicate) CHASE MANHATTAN BANK AS INDENTURE TRUSTEE, C/O RESIDENTIAL FUNDING CORP. 1301 OFFICE CENTER DRIVE, #200 FORT WASHINGTON, PA 19034 5. Name and address of every other person who has any record lien on the property: NalTle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: NalTle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. September 5, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CHASE MANHATTAN MORTGAGE : CORPORATION : Plaintiff, : JENNIFER L. GRAY : Defendant(s). : TO: JENNIFER L. GRAY 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND COUNTY No. 03-3216 CIVIL TERM September 5, 2003 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 105 HILL STREET, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on DECEMBER 10, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $88,537.91 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P, Rule 3129.3. 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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: {215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may ftnd out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erecR~d, sitnate in the Bolough of Mount Holly Spring~, Cumberland C~ounly, pennsylvania, hounded and d~cribed according to a Survey b2,' Robert 1, l:redrick. Jr., P.L.S., datec~ July 19, i991. (cOpy attached he~o) as follows, to wit: BEGINNING at a point in the center tine of tlill Street at the Northwestern corner of [and now ar formerly of Rodney C. Keekler; thence along said lalM of R,~dncy C. If cider, South 2I degre¢~ 30 mian~es East 330.00 feet to a point; thc:nee along .%amc, South 72 clcgrees 00 minutes We~t 46.20 feet ro an iron piti set; thence alollg la{KC now or formert)~ of Valley ~arrie$, [,-lc., North 21 degrees 30 minutes West 330,00 feet to a point in the c.~-te~ ~ of Hill Street; thaace along the cemer line of Hill Street, North 72 degrees 00 minu~s East 46.20 t'eet to a point~ the place of begirming. TITLE TO SAID PREMISES IS VESTED I1'4 Jennifer L. Gray by De~d from Julle A. WJtmer, dav~ 4/19/1999 amJ recorded a/20/1999 in Deed Book: 197, Page 911. Tax Parcel #23-32-2336-348 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE iDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY ATTORNEY FOR PLAiNTIFF COURT OF COMMON PLEAS CIVIL DWISION CUMBERL~uND COUNTY No.: 03-3216 CiVIL TERM MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiffhas made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the result there from is attached hereto as Exhibit "B." WHEREFORE, Plaintiffrespectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAiNTIFF FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE DENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 03-3216 CIVIL TERM MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriffs return of"Not Found" or the fact that a Defendant has moved without leaving a new fonvarding address is insufficient evidence of concealment. Gonzales vs. Polls, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by :Ihe attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION DEFENDANT(S) JENNIFER L. GRAY SERVE JENNIFER L. GRAY AT 105 H ll ,L STREET MOUNT HOLLY SPRINGS, PA 17065 SERVED CUMBERLAND COUNTY No. 03-3216 CIVIL TERM ACCT. #1507809737 ~ Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 10, 2003 Served and made known to at , o'clock __.m., at of Pennsylvania, in the manner described below: Defendant, on the day of ,200~ Commonwealth __ Defendant personally served. __ Adult family member with whom Defendant(s) reside(s). Relationship is __ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. Other: an officer of said Defendant(s)'s company. Description: Age_ Height Weight Race __ Sex --. Other I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of ,200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. Onthe J7q'~ Moved ,attempt. 3rd Attempt:. NOT SERVED day of ~f~t~'~ [9~ r , 200~, at _~".'~-~'clock ~,m., Defendant NOT FOUND because: Unknown __ No Answer ~ Vacant / / Time: : 2"a Attempt: / / Time: : / / Time: : Sworn to and subscrib.,ed before me this ~day Nota~: ~.4 ~[-h y: At tornev foff-Plaintiff ~ Frank Federman, Esquire - I.D. No. 12248 ~ SKN Data Research Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 3-7361PA Attorney Firm: Federman & Phelan Subject: Jennifer Gray Current Address: 105 Hill St. Mount Holly Springs, PA 17065 Property Address: 105 Hill St. Mount Holly Springs, PA 17065 Mailing Address: 105 Hill St. Mount Holly Springs, PA 17065 I Scott Nulty, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Jennifer Gray - 196-64-7911 B. EMPLOYMENT SEARCH Jennifer Gray - A review of the credit reporting agencies provided no employment information. C. iNQUIRY OF CREDITORS On 7-7-03 our inquiry of creditors indicated that Jennifer Gray reside(s) at:105 Hill St. Mount Holly Springs, PA 17065 II. INQUIRy OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH On 7-7-03 our office contacted directory assistance which indicated that Jennifer Gray reside(s) at: 105 Hill St. Mount Holly Springs, PA 17065. Our office made a telephone call to the mortgagors phone number and received the following information: 717-486-7767 spoke to Jennifer. III. INQUIRy OF NEIGHBORS N/A 1V. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE On 7-7-03 we reviewed the National Address database and found the following information, Jennifer Gray - 105 Hill St. Mount Holly Springs, PA 17065 B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry with creditors, the following is a possihle mailing address: no addresses on f'fle V. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE Per the PA Department of Motor Vehicles, we were unable to obtain address information on Jennifer Gray. VI. OTHER INQUIRIES A. DEATH RECORDS As of 7-7-03 Vital Records and all public internet databases have no death record on f'de for Jennifer Gray. B. COUNTY VOTER REGISTRATION The Cumberland County Voter registration has a registration for Jennifer Gray residing at: last registered address. C. PUBLIC LICENCES ( PILOT, REAL ESTATE, ETC.) Our office conducted a search for public licenses and found the following: no records on ~e VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Jennifer Gray -YOB 1972 B. A.K.A. *All accessible public databases have been checked aud cross -referenced for the above named individual(s). *Please be advised all database information indicates the subject resides at the current address. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authoril:ies. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. AFFIANT Sc~. Nulty SKN Data Research Inc. President Sworn to and subscribed before me this 7~ day of ~ 2003 NO-TAR~,,~PUB Li~ - _ / Notarial Sea I Margaret E Nulty, Notary Public East Goshen Twp., Chester County My Commission Expires Dec. 19, 2005 Member, Pennsylvani; Association Of Notanes The above information is obtained from available public records and we are only liable for the cost of the affidavit VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE ATTORNEy FOR PLAINTIFF FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY ATTOR/xYEY FOR PLAiNTIFF COURT OF COMMON PLEAS CIVIL DIWISION CUMBERLAND COUNTY No.: 03-3216 CIVIL TERM CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on September 30, 2003. JENNIFER L. GRAY 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 Date: September 30, 2003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHiLADELPHIA, PA 19103 ~215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATe[ON VS. JENNIFER L. GRAy ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERL/~D COUNTY No.: 03-3216 CIVIL TERM ORDER ANDNOW, this ~]~_~ day of tOt"~ '2003, upon consideration ofPlaintiffs Motion and the Affidavit of Good Faith Investiga}ion attached fftereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), JENNIFER L. GRAY, by m~iling a true and correct copy of the. Notice of.Sale by certified mail and regular mail to Defendants last known address. Or~J Service of the aforementioned mailings is effective upon the date of mailing and is to be ' done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. VliXlV/\-I,,LSNN~d ALNqO'~ AFFIDAVIT OF SERVICE PLAINTIFF DEFENDANT (S) SERVE AT CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY No. GD 03-3216 CML TERM JENNIFER L. GRAY Type of Action - Notice of Sheriff's Sale 105 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 Sale Date: DECEMBER 10,i 2003 **Please post the PrOperty with the Notice of Sale BY NOVEMBER 10, 2003** SERVED of&~Jo~r ,200~.~atg,t]~-,o'clock~.m.,at lo,fi`/ /~// %/ Commonwealth of Permsylvaina, in the manner described below: day __Defendant personally served. Adult family ~nember with who,m Defendant(s) reside(s). Relationship is __ Adult in charge of Defendant(s) s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). __ Agent or pets )n in charge of Defendant(s)'s office or usual place of business. . · _ anofficer of said Defandant(s)'~ company. __ C_Other: C,o ¢. Description: Age __ Height Weight__ Race __ Sex Other I, C_~-~,,e,~t~ L, ( ~._~ ~'~,, a competent adult, being duly swam according to law, depose and state that I personally tosted a tree and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in 1 he captioned case on the date and at the address indicated above. Sworn to and subscefib{ d [" NOTARIAL SE~ before me tins ay ] M._a0 TSS0N, No : By: NO EkVED " i ***ATTEMPT SERVICE NLT THREE (3) TIMES*** On the day of ,200__, at __ o'clock __.m., Defendant NOT FOUND because: __ Moved __ Unknown__ No Answer Vacant 1 st attempt Date & Time Swam to and subscribe~ before me this d~y of ,200 __. Notary: Attorney for Plaintiff Frank Federman, Esq~ One Penn Center at SI Philadelphia, PA 1910. (215) 563-7000 ,2nd attempt Date & Time By: tire - I.D. No. 12248 burban Station- Suite 1400 ,3rd attempt Date & Time 2003 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER !PLAZA, SUITE 1400 PHILADELPHIA, PA19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL D1VISION CUMBERLANI) COUNTY No.: 03-3216 CIVIL TERM ORDER AND NOW, thi ~9'44q day of (~(L~C' ,2003, upon consideration of Plaintiffs Motion and the Affidax it of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtaifl service of the Notice of Sale on the above captioned Defendant(s), JENNIFER L. GRAY,IbY mailing a tree and correct copy of the Notice of Sale by certified mail and regular mail to De~ndant's last knownaddres§. 0.~C~ ~O-~3~l~q~ %~ Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorhey, who will file with the Prothonotary's Office an Affidavit of service. 7160 3901 9844 4121 2042 TO: JENNIFER L. GRAY 105 HILL STR£ET MOUNT HOLLY SPRINGS, PA 17065 SENDER: TEAM 2 JRL REFERENCE: PS Form 3800~ June go00 RETURN Postage RECEIPT Certified Fee SERVICE Return Recei~3t Fee ~7~'~Fe~sRestricted Delivery US Postal Service ~7 2.30 0.00 0.00 Receipt for Certified Mail NO Insurance Coverage Provided 2,67 POSTMARK OR DATE FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 - ONE PENN CENTER pHILADELPHIA, PA ~9103 215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY CUMBERLAND COUNTY COLrRT OF COMMON PLEAS CIVIL DiVISION NO, 03-3216 CiVIL TERM I hereby certify that matter was sent by re person(s) JENNIFER I SPRINGS, PA 17065, The undersigned tm s4904 relating to unsw, :lerstands that this statement is made subject to the penalties of 18 PA. C.S. ~m falsificaton to authorities. F1La~NK FEDEral, ES ATTORNEY FOR PLAINTIFF VERIFICATION a true and correct copy of the Notice of Sheriffs Sale in the above captioned gnlar mail and certified mail, return receipt requested, to the following .. GRAY on OCTOI~F,R 9~ 2003 at 105 .HILL STREET, MOUNT HOLLY n accordance with the Order of Court dated, OC_TI~,ILf,2Q~. DATE: October 28, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION VS. JENNIFER L. GRAY CiVIL ACTION i) CIVIL DIVISION NO. 03-3216 CIVIL TERM AFI~IDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CHASE MANHATTAN MORTGAGE CORPORATION hereby verify that on September 11~ 2003 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Novembe~ 4, 2003 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff I Z 01.500 COMMONWEALTH OF PENNSYLVANIA -~ COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Chase Manhattan Mtg Corn is the grantee the same having been sold to said grantee on the 10th day of Dee A.D., 2003, under and by virtue of a writ Execution issued on the 10th day of Sept, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 3216, at the suit of Chase Manhattan Mtg Corp against Jennifer L Gray is duly recorded in Sheriff's Deed Book No. 261, Page 1572. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this c~~- day of  , A'D200~j~F_~ ~ ~e ~~Recorder ofDeeds Chase Manhattan Mortgage Corporation VS Jennifer L. Gray In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3216 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2003 at 3:11 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jennifer L. Gray, by making known unto Jennifer Gray, personally, at 1462 Newville Rd., Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 9:39 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jennifer L. Gray located at 105 Hill Street, Mt. Holly Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Jennifer L. Gray, by regular mail to her last known address of 1462 Newville Road, Carlisle, PA 17013. These letters were mailed under the date of October 8, 2003 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Chase Manhattan Mortgage Corp. It being the highest bid and best price received for the same, Chase Manhattan Mortgage Corp. of 3415 Vision Drive, Columbus, OH 43219, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $639.49, it being costs. Sheriff's Costs: Docketing $30,00 Poundage 12.54 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.28 Levy 15.00 Surcharge 20.00 Law Journal 209.60 Patriot News 179.17 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $ 639,49 Sworn and subscribed to before me This 2 $,~day 2004, A.D. ~othonotary , So Answers: R. Thomas Kline, St~eriff Real Estate i)eputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to 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. PUBLICATIONs ALE #47 ';;;;'A.D. City Of Harrisburg, Dauphin County ?'~"~ My Commission Expires June 6, 2006 NOTARY PUBLIC Member, PennsytvanieASSCC~atJonOfNolal~es My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 179.17 c Receipt for Advertising Cost )ublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general of the aforesaid notice and publication costs and certifies that the same have 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. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is author/zed 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 tree. ESTATE SALE NO. 47 Writ No. 2003-3216 Civil Chase Manhatataxl Mortgage Corporation VS, denmfer L. Gray Atty.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in the Borough of Mount Holly Springs. Cumberland County, Pennsylvania, bounded and de scribed according to a Survey by Robert I. Fredrick. dr.. P.L.S,, dated duly 19. 1991, (copy attached here- to} as follows, to wit: BEGINNING at a point in the cen- ter line of Hill Street at the North- western corner of land flow or for- merly of Rodney C. Keekler: thence along said land of Rodney C. Kecklen South 21 degrees 30 minutes East 330.00 feet to a point: thence along sa_me, South 72 degrees 00 rmnutes ~sa~~,a MarieCoyne, Edlor ('~x~'~''~ SWORN TO AND SUBSCRIBiED before me this 31 day of OCTOBER, 2003 LOIS E. SNYDER, Not~/pub~ C,~,~e 6o;o, Cumbedand County Holly Springs. Cumberland County, Pennsylvania, bounded and de- scribed accorcllng to a Survey by Robert I. Fredrick, Jr.. P,L.S.. dated July 19, 1991, {copy attached here- to) as follows, to wit: BEGINNING at a point in the cen- ter line of Hgl Street at the North western corner of land now or for- merly of Rodney C. Keckler; thence along said land of Rodney C. Keel-der, South 21 degrees 30 minutes East 330.00 feet to a point; thence along sanle. South 72 degrees 00 minutes West 46.20 feet to an iron pin set: thence along land now or formerly of Valley Quarries. Inc., North 21 degrees 30 minutes West 330.00 feet to a point in the center line ol' Hill Street; thence along the center line of Hill Street, North 72 degrees 00 minutes East 46.20 feet to a point, the place of beginning, TITLE TO SAID PREMISES IS VESTED IN Jennifer L. Gray by Deed from Jttlte A. Witmer. dated 4/19/1999 and recorded 4/20/ 1999 in Deed Book 197, Page 911. Tax Parcel #23-32-2336-348. NJtarv NO?ARIAL SEAL LOIS E. SNYDER, Not~/public r.,~e Bom, cumt~d~md My ~ E~ims