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Home My WebLink About99-05252 V O i It b f U i v N ry ;iii SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline., Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT RANDY L but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania. to serve the within COMPLAINT - MORT FORE REINS On _September 30th 1999 , this office was in receipt of the attached return from LEBANON County, Pennsylvania. Sheriff's Costs: So answer Docketing 18.00 ? Out of County 9,00 Surcharge 8.00 o.as in eri Dep. Lebanon Co 41.22 $7572 FEDER & PHELAN 09/30 1999 Sworn and subscribed before me this 30 =x day of _ 1999 A.D. rro o n?i _"_yg SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT GERALDINE A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania. to serve the within COMPLAINT - MORT FORE REINS On September 30th, 1999 , this office was in receipt of the attached return from LEBANON County, Pennsylvania. Sheriff's Costs: So answerer i Docketing 6.00 Out of County .00 L Surcharge 8.00 R. I mas ine, 5 eri 4 FEDERKAN & PHELAN 09/30/1999 Sworn and subscribed o before me this 366- day of 19 q A.D. o n' 13! Tt ?;I i?:>i'?'^.'FT) i?OTTCF, ; MORTGAGE 1'OR7CLCSURE No. 1999-5252 CHASE MANHATTAN MORTGAGE CORP Vs. RANDY L. WILT and GERALDINE A. WILT Lebanon, PA, September 28, 1999 (RETURN TO CUMBERLAND CO. SHERIFF) FEDERMAN & PHELAN DOCKET PAGE 14267 STATE OF PENNSYLVANIA } COUNTY OF LEBANON ; SS: David A. Heath, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within REINSTATED NOTICE & MORTGAGE FORECLOSURE upon RANDY L. WILT, the within named DEFENDANT, by handing a true and attested copy thereof, to him, personally, on September 23, 1999, at 3:20 o'clock P.M., at 433 West Queen Street, #13, Annville (Borough), Lebanon County, Pennsylvania, and by making known to him the contents of the same. Michael J. DeLeo, Sheriff, being duly sworn according to law deposes and says that, after due and diligent search by him having been made in his bailiwick, and after having exhausted all known facets to locate defendant, as stipulated under Rule of Civil Procedure, Rule 430, "good faith effort," he was unable to find GERALDINE A. WILT, the within named DEFENDANT, and he therefore returns "NOT FOUND," as to the said GERALDINE A. WILT, the said within named Defendant. Information was given that GERALDINE A. WILT, within named DEFENDANT, lives on Kelso Street in Harrisburg. Sworn to and subscribed before me this 28th day of September, A.D., 1999 Notary Public NOTARIAL - q SE NANCY L. STARNER. N:ta?y Public .ebanen Lebanon County Pa. M. ;,a?nssun uprt es Au(ust 8 2002 SO ANSWERS, ? A DEPU a HE SHER F SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced costs paid on 09/22/99 Check No.047060 Amount 75.00 Costs incurred: Amount 41.22 Refund: Check No. Amount 33.78 All Sheriff's Costs shall. be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the cost's thereof, all unpaid sheriff's fees obligated by law to make return thereof. _Sec. ?., Act of June on the same before he shall be 20, 1911, P.L. 1072 In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mortgage Corporation VS. Randy Wilt, et. al. Serve: Randy L. Wilt No 99-5252 Civil Now, 9/21/99 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this deputation being made at the request and risk of the Plainti Sheriffof Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of , 19 19_, at o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA $ In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mortgage Corporation VS. Randy L. Wilt, et. al. Serve: Geraldine A. Wilt No. 99-5252 Civil Now, 9/21/99 19_,1, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, Sheriff of Sworn and subscribed before me this _ day of , 19 19_, at o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA 0 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (315) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS. OH 43219-6009 V. Plaintiff RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 Defendant(s) TERM NO. 99_S2S. C(vl ( !_" l CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE C ;Z THIS FIRM IS A'DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WEB OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIIfFDA DISCHARGE IN BANKRUPTCY. THIS CORRESPONDENCE SHOULD NOT BE CONSTRUEITTO 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 fpt(owie_g pages, you must take action within twenty (20) days after this Complaint and Notice are "servedr 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. We hereby certoy the Wfthir, to be a true snd correct copy of ifl1 Original fileC of record FEDERMAN AND PfJELAPJ CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE. PA 17013 717) 249-3166 TRUE FROM REOORD In Testimony wtweaf, I twre unto bet 'Y' hww T . Pa. INW I A c W C11 r115119 4 n n ?- T ANC PHELAN ATTORNEY FILE COPY PLEASE RETURN FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563.7000 COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219.6009 TERM Plaintiff V. RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 NO. CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS X DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE 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 roust 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 CUMBERLAND COUNTY BAR ASSOCIATION We hereby the .2 LIBERTY AVENUE cortpy PA within to be a true and CARLISLE, 17013 Correct copy of the (717) 49--3 3166 original filed of record FEDERMAN AND PHELAN 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 2. The name(s) and last known address(es) of the Defendant(s) are: RANDY L. WILT GERALDINEA. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/30/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1391, Page 632. By Assignment of Mortgage recorded 3127/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 231. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $91,627.20 Interest 3,265.02 3/1/99 through 8/1/99 (Per Diem $21.34) Attorney's Fees 4,000.00 Cumulative Late Charges 160.24 6/30/97 to 8/1/99 Cost of Suit and Title Search 550.00 Subtotal 99,602.46 Escrow Credit 359.08 Deficit 0.00 Subtotal 359.08 TOTAL $99,243.38 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $99,243.38, together with interest from 8/1/99 at the rate of $21.34 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. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff I LEGAL DESCRSPTSON ALL THAT CERTAIN lr:r r 1.:::1 •.irio.ot:• ir• L •,,, r dl l? L. r`uiuttc, n:-nn.;'Ic. nine l::inna: tl ..na r9n , r iF: rl in Crnnbr-1.1.,fill .?i•ru Cr.l.a n:`r• e.lth .?: vu't ,.•i :i:,a l•1 :,c tl'.:. ,•,:..-:f it:,:?., l:? Grt:: •?.t ... 1 fn:r, •.ni.ol f•trjin:-•i d-lt .•.1 r'I: .. 1070, :'•• ..? M.,r:h 3n, t97n, ..; 11::%,.: FE01 S'd10; it 0 F.: in: :-rl.ol h! ii. r: ?i: n, .. r. i ln.. <.i,n! In•...• t.itlo- r,F F'r:•1tr, P,,-,0, s.'4 irl Lit iint l:r•inj _ ...?.7 fn:orl•ho-,,i.A of th:- i,:t-•r., lo" h:- ....:,Ilu.• I •.i t.. !:r P..•il::? F'....td ..toil 11:-. mir1,hinAsL stile r:f "la r" - hoht?- r R:;.id ; 1.1:•(1.- natny .:l::n!I F.1t.:n Road North 48 deyrr,es IT:rst i' fest t'.?: i or Grit th,e herr•i.naftr-r m.=nti.nnod jdalt of th'-fic" al::ny ..,ill I::t South 42 da,jr.•es East. 109 Fyf.,t tr! 1,.,int in 04• .lin- of l.:,t -N:.. 23• rh.eore al<:ng L•,ts X,:.-- 23 .+n:l 22 S,iutlt 4^ IGr•?: '. r.' finet. to, a corner of 3Q now or fnr'merIy ref Thrnnas J. 0eru,tt, .1r. and Stella Ann DNrmott, We wife; thenr•re alony sAirl lama Along the litre Of a fence North 42 degrees West 412 feet to r•ornr.r; thence North 48 degrays East 1.4 feet., to a point on L'he dividing line between Lots Now. 16 and 17 on satd p:l.n of lots; th-noe along said dividing line North 42 degrees West 63.3 fret to th•- point and place of BEGINNING. BEING all of Lot No. 16 and a small part. of Lc,t No. 17, in Blrick "O", on A plan of lots of Highland Parl., showing BI^r.k5; "N", "N", °O •• °P", "R" "S", and "T" which said Platt is recorded in Plan Boole 4, Page 9', Cumb-_rlana Crunt?' F.ecarrls. HAVING thereon erected a on:e and on, half story brick frame dwelling known A,, No. 1249 Salton Rnad. BEING THE SAME PPFNTSF.S which John C. Thort,t4 and Judith F. Thomas, his wife, by OPPll dr,t& Jelly 6, 1971 and ra"inQ4 Arigu;t 10, 1971 in the Re::':at•dNr ::f needs nFfLup in :onrd Bic nwilierIAM County, Pennsylvania, in Deed Book 24-F, Page 617, granter` ?nd Cnnveye:l nntn gtanlry H. Far•Itl;vl.i .i..:'1 ?L: t'i:;n r•. RAY•h d-•1:?, }'... wife, grantor's hr-rein. PREMISES BEING: 1299 KELTON ROAD CAMP HILL, PA 17011 P% ". \r T•, r.•m. D„ii - Inn2 :'.:.i . 1 .`7 I" 11r:3. VERIFICATION CHRIS STUMP hereby states that he is ASSITANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of IS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: '6I.)4191 '?+• cy?•r s, zo 3 42 Ph1'5 k SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT RANDY L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND as to the within named defendant WILT RANDY L DEFTMOVED TO 433 WEST QUEEN ST., #13, ANNVILLE, PA 17003. s: Sheriff's Costs: So ans;ae Docketing 18.00 Service 9.30 Not found return 5.00 Surch arge 8.00 s i e i $4U-.SU FEDER AND PHELAN 09/10 1999 Sworn and subscribed o before me this 16 r-4? day of 19A.D. '? ro?no?no?tary?? SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT GERALDINE A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named defendant WILT GERALDINE A DEFT. MOVED TO 433 W. QUEEN ST., #13, ANNVILLE, PA. Sheriff's Costs: So answers: Docketing 6.00 y/?- ' Service .00 Not found return 5.00%%yc+? ' Surcharge 8.00I oma s Kline S eri $=-OU FEDERMAN AND PHELAN 09/10/1999 Sworn and subscribed ?o before me this /0C? day of 1991 A. D. ]"`Prr Y' ` FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219.6009 V. Plaintiff TERM RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 Defendant(s) NO. 99 -- sa.s ;Z_ ot-o d` q CUMBERLAND COUNTY CIVIL ACTION . LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 We hereby ma (717) 249-3166 within to be a TRUE COPY FROM RECORD correct copy trut ?d of the ",cony whereof, I here unto set my hand r original filed of record s:.al of said Cou at Carlisle, Pa. FDERMANAND PHE(.AIV L13 ? ay 19 P thonotary 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219.6009 2. The name(s) and last known address(es) of the Defendant(s) are: RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/30/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1391, Page 632. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 231. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $91,627.20 Interest 3.265.02 3/1/99 through 8/1/99 (Per Diem $21.34) Attorney's Fees 4,000.00 Cumulative Late Charges 160.24 6/30/97 to 8/1/99 Cost of Suit and Title Search 0 550.0 Subtotal 99,602.46 Escrow Credit 359.08 Deficit 0.00 Subtotal 53 9.0 TOTAL $99,241.38 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $99,243.38, together with interest from 8/1/99 at the rate of $21.34 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. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff LEGAL DESCR=PT20N ALL THAT CERTAIN 1rr ,:r 1::: l ?ir..:.lr• i. r'• L: ,', :•r I1 :: Crrr•lber'land r`onnt 1. ? 'f:a:nsl:i.L•, ?, f4'll l: •, 1l'A fl i.i, }irania.,:.l ., n:3 doy 'l rll:H:l lrl .ir•c't?r?h?n,:?:.• wirh ..: S:Irlr.•1 :.:,:1 L•1.-: r• r},,,L,,..,f ...,:. I•:.,II::.,I. Pr•r:fr•:-•,,.,. 1:, f:? Frn:.?r rl.ll fn•Jlu:.•i ;L11,-.1 r:'I: 1970, I':•,•:::•;l Mar':h ?n, E:EQi'GtI'C(; i. L.:.Ih: I:. rl•,,.•:1 !: L: In-• ii i?f•., sldry rlf 6r-•1 tr:n Rn.id; s,i ld I::iaY hr•11i ?7 r. lu- i. Ir.• ' r L J - ? • . fr•,=Y n:?rr}u-•n 1 r.,p•chi.l rn t.:: 1.:• ,. .u. lu•.:yl ti{:j..^I f n?•II::n R. L.I:1 .4 rnl 1It- s i.,I,, of 6uu I:^:,I:-r R:;.,a; Lh,-nrr• sh,•lullny .II::Ii(i I<-•11',,0 Rnad Nurr,h 4^ Llayrn•e: F.rSr ; f •r-r r., .; c::rn, r' :;f t.::r Vn. ! :. th". hr.r(•inaEt(-r rn•ntinn,•d 111.v1 :) E Ell's; Yh•nr il::rig a.iill lilt South 42 dr.•' rHe. F-) t: rh:. ,. C 1 i.n- r:f r.:,t 2 -„ thrvn"F• alrrlg ,otti \nti. 2? .lull ?? F:Jtlr 11 $2 d:'. JC'r1?-s fir•nl ,':(.? feet. r.ri .a c::lt'n,[r of It r iot rr f:,r-r'.rrIy of Thrnnas J. Decm:,rt, .;t, and Str-IIa Ann Dermntl', his w•ifr; thenrr along ,.lid land .il: rlg the- lirir of a Eerl,:e North 42 rlE,gc're5 W ,t 41.8 fret tr. .. thence No rt--h 48 ddi roes +:'rrl2 r; J Fast 1.4 fw_et to .i point on the :livid t. riJ Ilne hetw•een Lots N:>s. 16 and 17 on said plan of lots; th:en::•e alr:ng said divLding line NnrFh 42 degr•r:•es W,m!st 61.2 fret to r.h:- point, and plane nE BEGTNNING. BEING all of hot No. 16 and a sma11 part of rot No. 17, in Block on a plan of lots of Highland Pail, showing Blacks al,r N.: O": "P" "R", "S", and "T" whi.c•h plan is rerc?t•der.1 in Plan Book 4, Page 9P, Cumberlan:l Count}' R(i-C-.l•dt. HAVING thereon ere(>ted :t one and oni- h.;r1E stnr.v brick Carl frame dwelling known aa, No. 1299 GFalton BEING THE FAME PPP?1iFFS whic-1) C. Thnrto,s arl:'l Jrtrlith E. Thomas, his wife, by Di-rd Jt;ly 6, 1771 a nl "I:':; I-dli!ll ..\,•J LIRr 1.0, 1.971 iit th,` RN:r(7r1?-r nF n,:e:ls orELilk' 1I: :Ind f,lt i I1Pll:r•Yl.;r::'l ('minty, Pemnsylvini.•+, it, peed P(Irl: 24-F, Page 617, gr.intr-:? ,,trl run Cpyt? -J tint_n Sr.anlr>1' H. F..t:•lilr•:l.i Inrl til..ri:: ri L. $.q r•h l,:•.la, wife, grantors herein. PREMISES BEING: 1299 KELTON ROAD CAMP HILL, PA 17011 P1 \(T1 (.::a t: :1,1 i - I^9' ?.: I`I 17'19^-• VERIFICATION CHRIS STUMP hereby states that he is ASSITANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: '61-74111 W O rQ ?a A w m o3 OC(OL[2 BJB fN w p1?A2LL 0.B ?I mMlNwtul "Oil elele'Oi10 wfw0 Y pp ILO _ 1 31tl15 lltl 4 !? a, >. ? ?J. ? H 4 ? ?? ,. y '? o ' ? ?_R ? ?. 4? ? ~ _ ? ': ;n ? pv Q v- ?? Q FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 V. Plaintiff TERM RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 Defendant(s) NO. 49 -SaS-? 0" ? -r" CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 ASSOCIATION We hereby CQrtMy the CUMBERLAND ICOUNTY AAVENUE Within to be a true and CARLISLE, PA 17013 correct copy of the (717) 249-3166 original filed of record FEDERMAN AND PHELAN TRUE COPY FROM RECORD !r, Testimony whereof, I here ur-'!: -3a: my hand wad the seal of said Cou at Cat lisle. Pa. Thi day f 19 99 1 25 Monotary Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 2. The name(s) and last known address(es) of the Defendant(s) are: RANDY L. WILT GERALDINEA. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/30/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1391, Page 632. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 231. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $91,627.20 Interest 3,265.02 3/1/99 through 8/1/99 (Per Diem $21.34) Attorney's Fees 4,000.00 Cumulative Late Charges 160.24 6/30/97 to 8/1/99 Cost of Suit and Title Search 550.00 Subtotal 99,602.46 Escrow Credit 359.08 Deficit 0.00 Subtotal 359.08 TOTAL $99,243..38 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $99,243.38, together with interest from 8/1/99 at the rate of $21.34 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. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff LEG.ZIL DESCRS PTION ALL THAT CERTAIN I on r I ,,, 1 r,,., t • , in 1,; r \ I I .•:: Curtln-eland ronnt?, P-nn',1lcnnt•i, l::nu;•1.•rl . t .ri•:"ri r'd.?: n:':.. t.{I•h .: v:rt ,..l r, n;l 1.1 ;??. n:3 rletir r'ihr[, in t 1, . ,•,:...f ii.,a ?• h. Fr•r; •?..t 1':.. ib;:?.:', Pen f,•:-. •, •un.:l r•r,?J i::.? ?, ?.3.:1 .•.l '... ?'-L ". 1170, t•••.':. :•:1 ML,r.'h in, 1970, n? r,,i l side- of Fe•Ih':n Rr:,nl; s.,irl 1::?iar l:.•in _ .?? rr?•,-r the-• inr-•r:,?•cr i.:.:r: of I I.:• ,..u. I,:., ?til .i:L r,f n.•I I:,r. G•'.:..r;l ..n:i 1 h-. norl-AleAtit. sble of tLv:•1, •:,t •r R::,nl; Lh. nr ,. t,.n:liny ,:l::n_; n Road North 4P d.,y •:..e, f: r 7 fr:•:,t ' :rn„r t. h- herr,inaft,- r rwmtion:•:l Id Au of i:':I:,; th..•rice aIr1ny d l South 42 di---g eg b"t 105 Flot rn A 1,o i nI in 1- ho 1 in,- of t.:,r 2'; t henre along Loth kr:';• 2 And 22 South 42 ilr•lt•r;•a•, Utit ,';(.? feet to .a nomyr of In,t not; ur En rmerIy of Thranas a. r.)f n tt:, and Stellar Ann D.+rmoth, his wife; thenr•,-• ,,luny said land alontJJr. the line of a Eence North 42 degrees Went 4l.8 feet to a corner; thence North 48 deyrews East 1.4 feet to a point on the ili.vidi.ng line hetween Lots Soli. 16 and 17 on v.:,itl plan of lots; th;-nn along said divi.diny line North 42 degrees Wrest 61.2 foot to the- point and plane of BEGINNING. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "0", on a plan of lots of Highland Park, showing Blocks Dt .. "P" "S", and "T" tt•hith said plan is recorded in Plan Book 4, Page 9?, Cur.rbr-_rland Ccuntg Rr-nerds. HAVING thereon err-rte:1 A nn? and on,- h.;,lf story brink anal f.ratne dwelling known as No. 1299 UoIton Pn.i:l. BERG THE SAME PPFMTSF.S whinh Tnhn V. Thnmas anl .Turlith E Thomas, his wife, l'Dr•ed :1r,l,d J uly G, . 1971 and rmr::t•ded \::guar in, 071 in th,_ Re::•or•ds•r ::f needh nffi_, , i;: -00 for Clmiherkr•:rl County, Pennsylvania, in Deed %ok 24-F , Paye r,17, grantr-:i rrl conveyed unto StanDn R. B:t:•l:lr•:la awl Y Ari:;n L. Barlilp:1::, . wife, grantors he=rein. PREMISES BEING: 1299 KELTON ROAD CAMP HILL, PA 17011 P% 2tt im r.:"n n„I i - 1 9x12 r ,..?-,,; j`I 1, ' 11'1^ I VERIFICATION CHRIS STUMP hereby states that he is ASSITANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of IS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: '61 4H hi W Z w; r cry 4: N Ux Cl 4! Q a_ 1F w o dQ c ?a U ? Z . C 9 cr X6 W ?p H d l ln OOBOll2908 R1'<UI^QtttQB v? 11uL+1.uglu? nn.9y w 1V'Iw0 r ccuo 'iroannis nr FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. RANDY L. WILT GERALDINE A. WILT Defendants COURT OF COMMON PLEAS . CIVIL DIVISION Cumberland County . No. 99-5252 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: September 16. 1999 S v n LLl L N ?.S Tv l.) C ti L1 J ] ? O N CC1. N Sl d Lu N .? ` ti c w 0 N rJ) Z L 0- 4J ui O cr% U L { I FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE. IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 TERM Plaintiff NO. 99 - S?ZS CUMBERLAND COUNTY RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 2. The name(s) and last known address(es) of the Defendant(s) are: RANDY L. WILT GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/30/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1391, Page 632. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 231. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $91,627.20 Interest 3,265.02 3/1/99 through 8/1/99 (Per Diem $21.34) Attorney's Fees 4,000.00 Cumulative Late Charges 160.24 6/30/97 to 8/1/99 Cost of Suit and Title Search 550.00 Subtotal 99,602.46 Escrow Credit 359.08 Deficit 0,00 Subtotal 359.08 TOTAL $99,243.38 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $99,243.38, together with interest from 8/1/99 at the rate of $21.34 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. 1s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff LEGAL DESCR=PT=bN ALL THAT CERTAIN lilt rr I.-,,l ihn.ifr in L:1'n1=r \11:•n 'P;adn;hi.l•, CUI•tlit-cI.inrl (`onnlr'r-nnsylvani.i, I,rnuul,,,J end (Insr.r•il:rl:l in rCr:u el•in;`.• t. i hh .a u1:1 1.1 .;r hl:: I,..;r 11:1:1.:• 1,e P' v::•'-.f ... IC.111:,•Ir Pr-rlrr•, •,nn.11 I•I:)in:1 ILrt ,•.i 11 1970, r?•?'i:1 ?Lir!'h in, 1970, .ic f1:1 l::tr RFt?I,\iV ll'i(i .il .: 11:: 1?: ::11'Iti: •:1 f:? t:: ?1'::r }'.i n. al, illr• P.::It!Ilr.??,t side rrf Nr•ItC;n M,ocl; s:rlrl l:::i:tt hr`Im) :rn.',7 rr•,-•I' n::rlht-•,r.nt :1r 11ir' 111Yr•t':itaut 6frI 11r I h;• I:r•,-tii till • t ,r n:-i r:n R.r..1a .,rul I i• i,I rh.li e•ist. si.de• rrf +I.i nt - l:: ,-r 8::.1:1; 1 I1„n1 1•ct,•ndinl) :I I: rr1(; }.:.•I h:; ri Rc:1.9d Noct.h 48 t11=y rl-•r•?. First ]f7 f.r:.•1-•t 1'.i .i :a:t'nr•r' :ir LnY Ur:. I 1 :)n 1.111:' her( ''rnditc,r rwIf t1rlnr•d 111.911 ar 111it), tit !0 .1If:IIt) 8.1111 I:rt SOUth 42 dr-•.?C vdR C,.lht 105 rrr?h 1" it'l in tn.• .I l n:' I,C T.nh 21; 'thr-twe alt:ng L?Itn \r::,. 2' .+n11 ?? Sou.Ihlt 42, i]cr?Y.r:1>:, Wr•s; ',r,.4 feet, tr, .:t corner of It.it npti ,I' fr)r-rn,?rly of Thomas J. DHI'r:Itt, Tr. and Ste 11.-t Ann Der.mott, his wife; th(m(e along said land :thing thr, line of a CPnf.e vorl:l'1 •12 rL;•greea W1?sh 41.8 feet t.n ,9 C'PrIf 2r; thence North 48 degrees Fast 1.4 feet, to a point on the rli.vidi.ng line botwer-_•n Lots Nos. 1.5 and 17 on said f11:1n of lots; thence alr:ng said divi.d.i.ng line North 42 rlegr'ers W1:!st 63.2 fret to thr-• point. and plane nf. RFGTNNI\G. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "O", on a plan of lists of Highland Parlr, showing Blocks "M", "N", "O", "P" "Q)" "Rn "S" and "T"1 wh 6li sAld f:l all 1S recorded in Plan Book 4, Page 98, Cumherlan,l County Records. HAVING thereon arr•ctea a rrne$ and ont• half story brick and frame dwelling known as No. 1.299 Ur-It-on Rti.:stl. BF.INC THE SAME PRP?1TSFS which J:Ihn V. Thnm.is an:1 Judith F. Thomas, his wife, by Deed d;rl:r•;1 July f, 1971 and r•::•ratd:=.d \ngl.lst 1.0, 1.971 in the Rer.:lyde•r nr newly nrEilr i;1 :Inrl C:1r Cnr11',rrlarl:l County, Pcinnsylvani.,+, in Deed Rook 24-F, I'age 6;17, gr.tutt'e1l -,nd conveyed tinto Stamloy R. F•a'l lr•17.:1 9na +Liri::n L. Rarhl::•]:1, ''1=. wife, grantors herr-!in. PREMISES BEING: 1299 KELTON ROAD HILL, PA 17011 Iri r12 VERIFICATION CHRIS STUMP hereby states that he is ASSITANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: '61a4Im 1 ? r Z . O m - r) C ? v c IO <17 1\1) o` LLJ Q 4 f' ? O 9.-? Of ?. 5 0 U N a d , o z z ? a 4 v3 or m S v O=,,ft N a ii` aaxotlenna rrv ?? alsoeri an aui rui?.ww ?r iN W.wnw?tl pY1LO ? Y1Itl'J II 11tlI511p FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Chase Manhattan Mortgage Corporation , Plaintiff, , v. Randy L. Wilt Geraldine A. Wilt Defendant(s). , CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5252 Civil Term CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRA K FEDE AN ESQUIRE At rney for Plai iff CL- C Ill U L- Ia LL. o o v Chase Manhattan Mortgage Corporation Plaintiff, V. Randy L. Wilt Geraldine A. Wilt Defendant(s). TO: Randy L. Wilt Geraldine A. Wilt 433 West Queen Street, #13 Annville, PA 17003 CUMBERLAND COUNTY No. 99-5252 Civil Term March 1, 2000 1299 Kelton Road Camp Hill, PA 17011 Notice of Sheriffs Sale of Real Estate "*THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1299 Kelton Road, Camp Hill, PA 170111 is scheduled to be sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the coup judgment obtained by Chase Manhattan Mortme Corporation (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE. OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto postpone the sale for good cause. 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.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated March 24, 1970, revised March 30, 1970, as follows: BEGINNING at a point, marked by an iron pin, on the Southeast side of Kelton Road said point being 268.37 feet northeast of the intersection of the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a corner of Lot No. 15 on the hereinafter mentioned plan of lots; thence along said lot South 42 degrees East 105 feet to a point in the line of Lot No. 23; thence along Lots Nos. 23 and 22 South 48 degrees West 56.4 feet to a corner of lot now or formerly of Thomas J. Dermott, Jr. and Stella Ann Dermott, his wife; thence along said land along the line of a fence North 42 degrees West 41.8 feet to a corner; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. 16 and 17 on said plan of lots; thence along said dividing line North 42 degrees West 63.2 feet to the point and place of BEGINNING. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "0" on a plan of lots of Highland Park, showing Blocks "M", "N", "0", "P", "Q", "R", "S", and "T", which said plan is recorded in Plan Book 4, page 98, Cumberland County records. HAVING thereon erected a 1 112 story brick and frame dwelling known as No. 1299 Kelton Road TAX PARCEL k13-23-0545-196 TITLE TO SAID PREMISES IS VESTED IN Randy L. Wilt and Geraldine A. Wilt, husband and wife by Deed from Stanley H. Bachleda and Marion L. Bachleda, husband and wife dated 6/30/97, recorded 7/3/97, in Deed Book 160 page 551. ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated March 24, 1970, revised March 30, 1970, as follows: BEGINNING at a point, marked by an iron pin, on the Southeast side of Kelton Road said point being 268.37 feet northeast of the intersection of the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a corner of Lot No. 15 on the hereinafter mentioned plan of lots; thence along said lot South 42 degrees East 105 feet to a point in the line of Lot No. 23; thence along Lots Nos. 23 and 22 South 48 degrees West 56.4 feet to a comer of lot now or formerly of Thomas J. Dermott, Jr. and Stella Ann Dermott, his wife; thence along said land along the line of a fence North 42 degrees West 41.8 feet to a corner; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. 16 and 17 on said plan of lots; thence along said dividing line North 42 degrees West 63.2 feet to the point and place of BEGINNING. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "O" on a plan of lots of Highland Park, showing Blocks "M", "N", "0", "P" "Q" "R", "S", and "T", which said plan is recorded in Plan Book 4, page 98, Cumberland County records. HAVING thereon erected a 1 1/2 story brick and frame dwelling known as No. 1299 Kelton Road. TAX PARCEL #13-23-0545-196 TITLE TO SAID PREMISES IS VESTED IN Randy L. Wilt and Geraldine A. Wilt, husband and wife by Deed from Stanley H. Bachleda and Marion L. Bachleda, husband and wife dated 6/30/97, recorded 7/3/97, in Deed Book 160 page 551. F:. ? r_ 1 .._ _ , Ill'.: ti.l ('j ? i . 1. ?! ( I IL :t ` y It J fc! nz ?r;? F. ?,. ?; ,:Ili) ?! L d FEDERMAN AND PHELAN By: Frank Federman, Esquire Attorney I.D. No.: 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Chase Manhattan Mortgage Corporation Plaintiff, V. Randy L. Wilt ' Attorney for Plaintiff Cumberland COUNTY COURT OF COMMON PLEAS CIVIL, DIVISION Geraldine A. Wilt NO. 99-5252-CIVIL TERM Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)1403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriffs Sale was made by sending a true and correct copy by certified mail and regular mail to Defendants, Randy L. Wilt and Geraldine A. Wilt at 433 West Queen Street #13 Annville, Pa 17003, and 1299 Kelton Road Camp Hill, Pa. 17011 on March 2, 2000 in accordance with the Order dated December 16, 1999. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unswom falsification to authorities. / FRANK FEDE AN, ESQUIRE April 12, 2000 P 973;738 904.war. , Jt. `??7711'14iMn p f* ? .? K 3 Vic. ?.31 '" '? ? v # I ?'•? hI ' 'r RJ 4r? ak ff? A '.': . 43 i? f > guuz3j (n r* - "N gr It CL L06 9EL EL6 d IMPORTANTI PLACE STICKER AT TOP OF ENVELOPE TO -. 5S3tlOOtl NtlfLL3tl O .LHOI 3H1 RE TURN ennowc .5S3HCOtl Ng?MfU:io JMDltl 3H1 I` OL 3dOl3AN3 j0 dOl IV tl351OLLS 33"d LLNVIIlOdWI OL 3dO-I3AN3 AO dOl ltl tl3MJLLS 3Otlld ? LLNVLtlOdWI ? 42 V I V ` > 1 ? ! N I ? N . yyp F 8 d 8 O.. F? ¢ z w w Z f a ?+ Z .? N I d a a? N d 906 ML E? .BY:. Lisa D.;,Blanken_burg, Esq. ` y Att I D #78020 ?S!• yari'K a., ..w 'S+:iilrYt - .•:'.'`ir?xryMN?;i i. ^Ster 900/Two,Penn ? Center Plaza Philadelphia ;:'PA '19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 1 VS. RANDY L. WILT GERALDINE A. WILT ORDER AND NOW, this day of r u _?Y.f COURT OF COMMON PLEAS y` CIVIL DIVISION CUMBERLAND COUNTY No. 99-5252-CIVIL TERM , 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff . may obtain service of the Complaint on the above captioned Defendant(s), RANDY L. WILT AND GERALDINE A. WILT, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, 433 WEST QUEEN STREET #13, ANNVILLE, PA 17003 and to the mortgaged premises at 1299 KELTON ROAD, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will y; file with the Prothonotary's Office an Affidavit as to the mailing. "'11Tk` BY THE URT: J. ?_1 ( ?... 1 _ ?? , ? , . C ..I ?. f t ?• 6i I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff CIVIL DIVISION VS. RANDY L. WILT GERALDINE A. WILT Defendants No. 99-5252 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA CUMBERLAND COUNTY SS: I, FRANK FEDERMAN, ESQ., attorney for CHASE MANHATTAN MORTGAGE CORPORATION, hereby verify that on MARCH 2. 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on MARCH 2, 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ? n FRP K EDERMAN, ESQUIRE Attorne for Plaintiff Date: April 28, 2000 °a Z ? N j ? O x'a?; ?=a e eU= p o =° ?7 3 s is FD. I_I C N d E L L 9 h zao s I Z ? p `o z 0 a= mm ` y T ? n a 60.F uF U En E F F pw tzm O ?v O U •: C a m m E"> ZvFi ?j 9 F ? o F]F a p o .F]p o ?O _ o Zp o > ^ A z o _ 3Z o a O ? ? a 30 = um U? = aa y0 ? < < ; O ? ari a am a ?x z a <? z oa 'a ap a ux UZ a ?z Ca s y? vt y; ? 3 4 ?i zo a ?i 3° _ Zo e ?F ? ? p x x x x '? E < o y? p 3 -? > ?? a 3 > y4] p Y a W a Y a ^a c x ? a ? Z47 Y Z a E v'? ? ? tn 3 Z 3 A E ? z z z z za E za p _ a ZZ ?i a A z a? oze z a Ue Z a aH CL- a U ?N C a u oe Un a U er F- a U on p- a U S7'. =z` X E 0 z °e _ C u N N M ? h b 1? W U ? ? N M ? h Z, l --- ----------- 11 REtuRN RCCEIPi •+CStngEO CELIVCNY POSTMARK OR DATE S SERVICE IECM1FLD FEE• PE runN NE'Cll Er t01µ ^ StA E AND FEES Co A SENT TO: INOT FORINTERNA ON.L MAIL f m m b.i3 n.5: t tr; E; fTi; Ll', Ct? M1 9?;\V7:.i.7;, PA 17003 r a Dwt? I r - C3 a Co m r m r• c C_ PS FORM 3800 US Postal Service Receipt for Certified Mail POSTMARK OR DATE Povc,E L RETURN PF;;mrrcc CC,1E1 C C RECEIPT f.EPM1F E: •EE.PEryR, ^CCC'.R! k E SERVICE tOtlL iG4>uE >IA FEET ` SENT TO IN V AN V VI NTE NOC FOR II, INN. Oil MAIL L ( 1 t:Ai'.' F?1':., ?;. 17911 i I 00A K PS FORM 3800 US Postal Service nCCC(NIL w( Certified Mail I nerunn 1 S POSTMARK OR DATE } nFSiniC }fULE[`/Ln' nECE IPi ? 0 J SERVICE CF.Pris EOrlf nErunrygFDer rcrnl r,•,ui,urm rf ES SENT TO: mono"n lnr nnmonu MU[ - - ` E m r v-?PLO:XP. A. i•:Ii? m 433 WVST qU!-.EN S^R£ET Y13 r` • , dt;:vu!S:, 2.1 17003 e a (? IA /1 V PS FORM 3800 US Postal Service Receipt for Certified Mail C 0 0" CC) m r, m r- C" Q. PS FORM 3800 US Postal Service Receipt for Certified Mail c c u u u c e C r c u c E E L f' tom`: r J LL r .t STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND SS. Robert P Ziegler h ------------------°---------------------------------------°----------------- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ---------------- Chase Manhattan Mtg Corp ------------------------------------------------------------------------------------ is the grantee 7th the same having been sold to said grantee on the ----------------------------------------------- day of June ----------------------------- A. D., 14- 00----, under and by virtue of a writ-------------- execution 3rd --------------------------------issued on the ------------------------------------- day of --March ------------------ A D ff 00, out of the Court of Common Pleas of said County as of civil 99 --------------------------------------------------------------------------------- Tenn, 19 ------- 5252 Chase Manhattan Mtg Corp Number -------------- at the suit of --------------------------------------------------------------- Randy L Wilt & Geraldine A ---------------------------------- against--------------------------------------------------- is 224 412 duly recorded in Sheriffs Deed Book No. ------------, Page ------------- IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ---? --- day of --- --------------------- A. D., Recorder of Deeds Reendo, of Dekt. Offa r4k Cauny, ptNslR M My Ibow=Eap "IDSfiM:; M1r.a an Chase Manhattan Mortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Randy L. Wilt and Geraldine A. Wilt No. 99-5252 Civil Harold J. Weary Deputy Sheriff who being duly sworn according to law, says on March 29, 2000 at 5:11 o'clock P.M. EST, he posted a copy of real Estate Writ Notice Poster and Description on the property of Randy L. Wilt and Geraldine A. Wilt located at 1299 Kelton Road, Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Randy L. Wilt by First Class Mail to his last known address 1299 Kelton Road, Camp Hill, Pennsylvania. This letter was mailed under the date of March 30, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the wihtin named defendants to wit: Geraldine Wilt by First Class Mail to her last known address 1299 Kelton Road, Camp Hill, Pennsylvania. This letter was mailed under the date of March 30, 2000 and never returned to the Sheriff's 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 within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on June 7, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00 to Attorney Dale Shughart, JR. for Chase Manhattan Mortgage Corporation. It being the highest bid and best price quoted for the same Chase Manhattan Mortgage Corporation of 3415 Vision Drive, Columbus Ohio being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 931.87 it being costs. Sheriffs Costs Docketing 30.00 Poundage 18,27 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 9.92 Certified Mail 1.97 Levy 15.00 Surcharge 30.00 Law Journal 381.65 Patriot News 297.26 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriffs Deed 26.50 $ 931.87 Pd by Atty 6/22/00 Sworn and Subscribed To Before Me This 9/ of Day o 2000, A.D. ?l Zy. Pr h notary art5? .aerr k? y ,,;.c ?= So R. Thomas Kline, Sheriff By Real Estate Deputy uA 5 ?qDv I J" Chase Manhattan Mortgage Corporation CUMBERLAND COUNTY V. Plaintiff, COURT OF COMMON PLEAS . Randy L. Wilt CIVIL DIVISION Geraldine A. Wilt NO. 99-5252 Civil Term Defendant(s). , AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) Chase Manhattan Mortea a 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 1299 Kelton Road, Camp Hill PA 17011. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Randy L. Wilt 433 West Queen Street, #13 Annville, PA 17003 Geraldine A. Wilt 433 West Queen Street, #13 Annville, PA 17003 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Commercial Credit 3401 Hartzdale Drive Corporation Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1299 Kelton Road Camp Hill, PA 17011 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 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 tht xr' penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. f March 1, 2000 ? DATE FRA < FEDER AN, SAttot ey for Plaintiff J I Chase Manhattan Mortgage Corporation Plaintiff, v. Randy L. Wilt Geraldine A. Will Defendant(s). TO: Randy L. Wilt Geraldine A. Wilt 433 West Queen Street, #13 Annville, PA 17003 CUMBERLAND COUNTY No. 99-5252 Civil Term March 1, 2000 1299 Kelton Road Camp Hill, PA 17011 Notice of Sheriffs Sale of Real Estate "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1299 Kelton Road Camp Hill PA 17011, is scheduled to be sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Chase Manhattan Mortgage Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by tiling a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. I 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.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .1 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated March 24, 1970, revised March 30, 1970, as follows: BEGINNING at a point, marked by an iron pin, on the Southeast side of Kelton Road said point being 268.37 feet northeast of the intersection of the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a corner of Lot No. 15 on the hereinafter mentioned plan of lots; thence along said lot South 42 degrees East 105 feet to a point in the line of Lot No. 23; thence along Lots Nos. 23 and 22 South 48 degrees West 56.4 feet to a corner of lot now or formerly of Thomas J. Dermott, Jr. and Stella Ann Dermott, his wife; thence along said land along the line of a fence North 42 degrees West 41.8 feet to a corner; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. 16 and 17 on said plan of lots; thence along said dividing line North 42 degrees West 63.2 feet to the point and place of BEGINNING. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "0" on a plan of lots of Highland Park, showing Blocks "M", "N", "0", "P", "Q", "R", "S", and "T", which said plan is recorded in Plan Book 4, page 98, Cumberland County records. HAVING thereon erected a 1 1/2 story brick and frame dwelling known as No. 1299 Kelton Road. TAX PARCEL 1/13-23-0545-196 TITLE TO SAID PREMISES IS VESTED IN Randy L. Wilt and Geraldine A. Wilt, husband and wife by Deed from Stanley H. Bachleda and Marion L. Bachleda, husband and wife dated 6/30/97, recorded 7/3/97, in Deed Book 160 page 551. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-5252 CIVIL 119( Term COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF _ Cumberland COUNTY: To satisfy the debt, interest and costs due __Chase Manhattan Mortgage Corporation from Randy L. Wilt and Geraldine A. Wilt, 433 West Queen Street, #13, Annville, PA 17003 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 GARNISHEE(S) 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 defendagt(s)IQWtPWIse disposing thereof, (3) If property ofthelffl` flt13rtt(strro iedupon ansubject toatlachmentisfound inthepossess*pfanyone other than a named garnishee, you are directed to notify hinVher that he/she has been added as a gariiis`ha antlis Enjoined as above stated. Amount Due $103,532.72 L.L._ $.50 from 2711100 - 5123700 per _deU -_ Interest $17.09) - $1 ,650.94 and CnGtG Due Prothy $1.0 Ally's Comm Other Costs Atty Paid $221.52 Plaintiff Paid Date: March 3, 2000 Curtis R. REQUESTING PARTY: Name Frank Federman, Es Address: Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Prothonotary, Civil Division P Deputy Supreme Court ID No. I'd I ? un m, 4,&e /,y, 2.y-v t.-I- :,i,e iii iavied upon itie d64ondan,s Interest in the real property siaiated in -?" A&-n%, A em ? Cumberland County, Pa., know, and numbered as: /199 - and more fully described on Exhibit "A„ filed with this writ and by this reference incorporated herein. p1;'i a rE CQ (go UUW THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication .11111111E All No 587. BDSroued Mau 16, 1979 Commonwealth of Pennsylvania, County of Dauphin} as Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 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 editions/issues which appeared on the 2nd, 9th and 16th day(s) of May 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. ) I a1 r _ PUBLICATION COPY SALEk48 at Notanal5Cr1 his 2nd da f Ju 000 A.D. Terry L. Russell, Notary Public Harrisburg, Dauphin County My Gomm"sston Expires June 6, 200 Member, Pennsylvania AssociationolNolapes? OTARV PUBLIC N wIY commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 c"nlimai"" Statement of Advertisim- Costs RTAIN tract n paring of liluate, lying and being in To THE PATRIOT-NEWS CO., Dr. rerAlkninthecountpof For publishing the notice or publication attached I Commonwealth of particularly de<aib<d as hereto on the above stated dates $ 295.76 probating same Notary Fee(s) $ 1.50 with a sunray and plan iesll. Nalker,pmfessiowl Total $ 297.26 Larch 24, 1970, revised flows: 1 a point, marked by an Sher • s Receipt for Advertising cost [heat sidorhea 831 (eel northeast sl of the or of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general soulhebl side of Kelton iceipt of the t d a f M aforesaid notice and publication costs and certifies that the same have er an res o ,It dingg ?along Kelton Rand As1.55 feet to a comer of THE PATRIOT-NEWS CO. Iminafter mentioned plan said lot South 42 degrw. By .................................................................... in the line of Lm N,,. os. 23 and 22 South 4? to a corner of lot nor, s I. Donnell, Jr. and is *; thence Jkm§ iu act, fence North 4. t to a corner; thence 1.4 degrees 1.4 feel to a ine between lots Nos. a of lots; thence along It 42 dvgnos West 63.2 aceof 6EGINNING. Jo. 16 and a small part 'O"on arlan al tub ul gg BWks M ,"N ,00 N-, which said plan is 4, page 93, Cumberland envied a 1 112 stun ling known as No. 1: Road. 645.196. PH71SES IS VESTED od eraldine A. Will Dad from Stanley ti- n L Bachelda, husband 197, recorded 713197, in 51. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swam, 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: APRIL 28, MAY 5, 12, 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 SALE NO. 48 Writ CNo. hase Ma.nha2 Civil Chaase Maha ttan C/ Mortgage Corporation Rog r M. Morgenthal, Editor VS. Randy L. Wilt and Geraldine A. Wilt Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate. lying and being in the Township of Lower Allen in the County of Cumber- land and Commonwealth of Pennsyl- vanla, more particularly described as follows: In Accordance with a survey and plan thereof node by Ernest J. Walk- er, Professional Engineer. dated March 24, 1970, revised March 30, 1970. as follows: BEGINNING at a point, marked by an imn nin. on the Southeast side of SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 1015 E. SNVOER, Notary Publk CortiYe Roro, CumFarlund County, PA My Comm4ron Explnr March S, 2001 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates. Affbant 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. 48 Writ No. 99 Civil Chase Manha / ? Mortgage Corporation Rog r M. Morgenthal, Editor VS. Randy L. Wilt and Geraldine A. Wilt Ally.: Frank Fedennart DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Township of Lower Alien In the County of Cumber- land and Commonwealth of Pennsyl- vania. more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. walk- er. Professional Engineer, dated March 24. 1970, revised March 30. 1970, as follows: BEGINNING at a point, narked by an Iron pin. on the Southeast side of Kelton Road said point being 268.37 feet northeast of the Intersection of the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a comer of Lot No. 15 on the hereinafter mentioned plan of lots: thence along said lot South 42 de- grees East 105 feet to a point In the line of Lot No. 23; thence along Lots Nos. 23 and 22 South 48 degrees West 56.4 feel to a corner of lot now or formerly of Thomas J. Dermott,Jr. and Stella Ann DermolL his wife: thence along said land along the line of a fence North 42 degrees West 41.8 feet to a corner; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. Wand 17 on said plan of lots; thence along said dbvld- Ing line North 42 degrees West 63.2 feet to the point and place of BEGIN- NING. BEING all of Lot No. 16 and a small part of Lot No. 17. In Block "0" SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 LCNS E. SNICER, Notary Public Cor!Wo boro, Cumberland County, PA My Comm;won Expires March 5, 2001 l , 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 swom, 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. APRIL 28, MAY 5, 12, 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. 48 WC No. 99-5252 Civil Chase Manhattan Mortgage Corporation Rog h M. Morgenthal, Editor VS. Randy L. Wilt and Geraldine A. Wilt Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumber- land and Commonwealth of Pennsyl- vanla, more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. Walk- er, Professional Engineer, dated March 24, 1970, revised March 30, 1970, as follows: BEGINNING at a point. marked by an Iron pin, on the Southeast side of Kelton Road said point being 268.37 -1 feet northeast of the intersection of { the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a comer of Lot No. 15 on the hereinafter mentioned plan of lots: thence along said lot South 42 de- grees East 105 feel to a point in the line of Lot No. 23: thence along Lots j Nos. 23 and 22 South 48 degrees West 56.4 feet to a comer of lot now or formerly of Thomas J. Dermott, Jr. i and Stella Ann Dermott, his wife: j thence along said land along the line of a fence North 42 degrees West 41.8 feel to a comer; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. 16 and 17 on said plan of lots: thence along said dlvld- Ing line North 42 degrees West 63.2 feet to the point and place of BEGIN- NING. BEING all of Lot No. 16 and a small part of Lot No. 17, In Block "O" on a plan of lots of Highland Park. showing Blocks "M". "N". "O". "P". "Q". "R", "S", and *I-. which said plan Is recorded in Plan Book 4, page 98, Cumberland County records. HAVING thereon erected a 1 1/2 story brick and frame dwelling known as No. 1299 Kelton Road. TAX PARCEL # 13-23-0545-196. TITLE TO SAID PREMISES IS VESTED IN Randy L. Wilt and Ger- aldine A. WBL husband and wife by Deed from Stanley H. Bachleda and Marian L. Bachleda, husband and wife dated 6/30/97, recorded 7/3/97, in Deed Book 160 page 551. SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 tOiS E. SNYDER, Notary Publk Cartidu Soro, Cumberland County, PA My Commimon Expires March S, 2001 i.. t? Real Estate No 48 $1000.00 Advance Costs Paid 3/13/00 Atty Frank Federman Assessed Valuation $ 6,330 Writ No. 1999-5252 Civil Chase Manhattan Mortgage Corp. -vs- Randy L. Wilt and Geraldine Wilt 1299 Kelton Road Camp Hill, PA Real Debt $ 103,532.72 Interest 2/17/00-5/23/00 & 17.02 per diem 1,650.94 Atty's Fees Atty's Writ Costs 221.52 Escrow Late Charges Sheriff's Costs Docketing 30.00 Poundage 18.27 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 9.92 Certified Mail 1.97 Levy 15.00 Surcharge 30.00 Postpone Sale Out of County Legal Search Law Journal 381.65 Patriot News 297.26 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 TAXES Refuse 375.70 Chase Manhattan Mortgage Corporation Plaintiff, V. Randy L. Wilt Geraldine A. Wilt Defendant(s). .. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-5252 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Chase Manhattan Morteaee 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 tiled the following information concerning the real property located at 1299 Kelton Road, Camp Hill, PA 17011. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Randy L. Wilt 433 West Queen Street, #13 Annville, PA 17003 Geraldine A. Wilt 433 West Queen Street, #13 Annville, PA 17003 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Commercial Credit 3401 Hartzdale Drive Corporation Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1299 Kelton Road Camp Hill, PA 17011 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 1, 2000 DATE FRA C FEDER AN, SQUIRE )VI Attoptey for Plaintiff ° r i1 - Cl) <. Cl) ?r Ill i= 4 s y?ri 9 O - j C- ) U PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Chase Manhattan Mortgage Corporation Plaintiff, V. Cumberland County No. 99-5252 Civil Term Randy L. Wilt Geraldine A. Wilt Defendant(s), , TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY Issue writ of execution in the above matter: Amount Due Interest from 2/17/00 - 5/23/00 (per diem - $17.02) $103.532.72 $1,650.94 and Costs $105,183.66 TOTAL FRA KFED 2MAN ESQUIRE TW PENN CENT PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. CQ ON Q? F z o 0 0 O z a w -. C w U w? Y O ti z ? N ra d O ac ad or Dz = ? w o x; ? w iZi V V Or CL M .r Y d V O d -- ? O' a G y M ? ?aa M Y O C 3aa J C M C a?a v s a L s 3 r DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In Accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated March 24, 1970, revised March 30, 1970, as follows: BEGINNING at a point, marked by an iron pin, on the Southeast side of Kelton Road said point being 268.37 feet northeast of the intersection of the southeast side of Kelton Road and the northeast side of Manchester Road; thence extending along Kelton Road North 48 degrees East 55 feet to a corner of Lot No. 15 on the hereinafter mentioned plan of lots; thence along said lot South 42 degrees East 105 feet to a point in the line of Lot No. 23; thence along Lots Nos. 23 and 22 South 48 degrees West 56.4 feet to a comer of lot now or formerly of Thomas J. Dermott, Jr. and Stella Ann Dermott, his wife; thence along said land along the line of a fence North 42 degrees West 41,8 feet to a corner; thence North 48 degrees East 1.4 degrees East 1.4 feet to a point on the dividing line between Lots Nos. 16 and 17 on said plan of lots; thence along said dividing line North 42 degrees West 63.2 feet to the point and place of BEGINNING. BEING all of Lot No. 16 and a small part of Lot No. 17, in Block "0" on a plan of lots of Highland Park, showing Blocks "M", "N", "O", "P", "Q", "R", "S", and "T", which said plan is recorded in Plan Book 4, page 98, Cumberland County records. HAVING thereon erected a 1 1/2 story brick and frame dwelling known as No. 1299 Kelton Road. TAX PARCEL #13-23-0545-196 TITLE TO SAID PREMISES IS VESTED IN Randy L. Wilt and Geraldine A. Wilt, husband and wife by Deed from Stanley H. Bachleda and Marion L. Bachleda, husband and wife dated 6/30/97, recorded 7/3/97, in Deed Book 160 page 551. t C Cl•• G J Q- 4C) a sz! q, C) C?p C3 U FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION vs. RANDY L. WILT GERALDINE A. WILT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5252-CIVIL TERM ORDER AND NOW, this day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), RANDY L. WILT AND GERALDINE A. WILT, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, 433 WEST QUEEN STREET #13, ANNVILLE, PA 17003 and to the mortgaged premises at 1299 KELTON ROAD, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's office an Affidavit as to the mailing. BY THE URT: RKS FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Vs. RANDY L. WILT GERALDINE A. WILT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5252-CIVIL TERM MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the defendant's last known address, 433 WEST QUEEN STREET,#13, ANNVILLE, PA 17003, and to the mortgaged premises at 1299 KELTON ROAD, CAMP HILL, PA 17011 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as exhibit "B". WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Lisa D. B1 nkenburg, Esquire ATTORNEY FOR PLAINTIFF t FEDERMAN AND PHELAN ATTORNEY FOR PLAINTIFF BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. No. 99-5252-CIVIL TERM RANDY L. WILT GERALDINE A. WILT 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 (s) and the reasons why service cannot be made. Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 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 Sheriff's Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B" WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail to the defendant's last known address. ecCfullly submitted: Lisa D. la nburg, Esquire Attorney for Plaintiff CASE NJ: l ilb-U5252 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP vs. WILT RANDY L ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT GERALDINE A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named defendant WILT GERALDINE A DEFT. MOVED TO 433 W. QUEEN ST., #13, ANNVILLE, Sheriff's Costs: So answers: Docketing 6.00 Service .00/%y Not found return 5.00 Surcharge 8.00"I'Tis R i e, 5 i ST= FEDERMAN 1999. ND PHELAN Sworn and subscribed to before me this day of 19 A.D. ITA r no ary CA5E NO: 1999-0 3? r COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL ,, 41. R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT RANDY L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND as to the within named defendant WILT RANDY L DEFTMOVED TO 433 WEST QUEEN ST., 413, ANNVILLE, PA 17003. Sheriffs Costs: So answers: Docketing 18.00 Service 9.30 Not found return 5.00 ? Surcharge 8.00 ma in , $?Q FEDERM/A?N9A9ND PHELAN 01 Sworn and subscribed to before me this day of 19 A.D. n ry EXHISITA SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT RANDY L but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania. to serve the within COMPLAINT - MORT FORE REINS On September 30th, 1999 , this office was in receipt of the attached return from LEBANON County, Pennsylvania. Sheriff's Costs: So answe. Docketing 18.00 Out of County 9.00 Surcharge 8.00 1 g?- Dep. Lebanon Co 41.22 X22 09%30 1999 PHELAN Sworn and subscribed to before me this day of 19 A.D. ?H181Tq 0 ono ry SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-05252 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. WILT RANDY L ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WILT GERALDINE A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania. to serve the within COMPLAINT - MORT FORE REINS On _September 30th 1999 , this office was in receipt of the attached return from LEBANON County, Pennsylvania. Sheriffs Costs: So answer Docketing 6.00 Out of County 00 rf ?` Surcharge 8.00 A'. a Mir'Te,-5 4iT4UQ FEDERM1999 PHELAN Sworn and subscribed to before me Ct?-=t??d11 this day of 19 A. D. ono y AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Subject: Last Known Address: Current Address Mailing Address: Last Known Number: Federman & Phelan Randy L. Witt Geraldine A. Witt 1299 Kelton Road Camp Hill, PA 17011-6107 1299 Kelton Road Camp Hill, PA 17011-6107 1299 Kelton Road Camp Hill, PA 17011-6107 non-published t EXHIBIT p George H. Lewis, III, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of researcher for EKL DATA, INC. 2. On September 14, 1999, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: 1. Credit Information A. Social Security Number 1. Randy L. Witt: 194-44-6289 2. Geraldine A. Witt: 237-98-5249 B. Employment Search: Could not locate any employment for the above named subjects. C. Inquiry of Creditors: The creditors indicated that Randy L. Witt and Geraldine A. Witt both reside at 1299 Kelton Road, Camp Hill, PA 17011-6107. AFFIDAVIT OF GOOD FAITH INVESTIGATION II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has Randy L. and Geraldine L. Witt listed with an address of 1299 Kelton Road, Camp Hill, PA 17011-6107. The phone number is non-published. III. Inquiry of Neighbors Contacted Mrs. Drane of 1297 Kelton Road, Camp Hill, PA 17011-6107 and verified that Randy L. Witt and Geraldine A. Witt do indeed reside at 1299 Kelton Road. IV. Inquiry of Post Office A. National Address Update: As of September 14, 1999 the National Change of Address has Randy L. Witt and Geraldine A. Witt listed at 1299 Kelton Road, Camp Hill, PA 17011-6107. V. Inquiry of DMV rHIBR-8 The Pennsylvania Department of Motor Vehicles has Randy L. Witt and Geraldine A. Witt listed at 1299 Kelton Road, Camp Hill, PA 17011-6107. VI. Other Inquiries A. Death Records: As of September 14, 1999 the Social Security Death Index has no death record on file for Randy L. Witt under his social security number nor is there a record for Geraldine A. Witt under her social security number. B. Public Licenses None found C. County Voter Registration: The county does not have Randy L. Witt or Geraldine A. Witt listed as registered voters with an address of 1299 Kelton Road, Camp Hill, PA 17011-6107. D. A.K.A.: None AFFIDAVIT OF GOOD FAITH INVESTIGATION E. D.O.B.: Randy L. Witt: 1956 Geraldine A. Witt: 1954 F. Miscellaneous Information None EXHIBirs Notary Public Nolariol Seal Ellen K, Lewis, Notary Public Loner S:er.0 Idnn!comery CounPj E.epirec'Feb.24, 2003 Subscribed and swom before me. V E R I F I C A T I O N Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her 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. November 24, 1999 San Lisa D. Blankenburg, Esquire Attorney for Plaintiff ? If ` )FC 51..999 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County VS. No. 99-5252-CIVIL TERM RANDY L. WILT GERALDINE A. WILT CERTIFICATION I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy of the Motion for Alternate Service has been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. RANDY L. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 GERALDINE A. WILT 1299 KELTON ROAD CAMP HILL, PA 17011 433 WEST QUEEN STREET, #13 ANNVILLE,PA 17 003 433 WEST QUEEN STREET,#13 ANNVILLE, PA 17003 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. J? Lisa D. Blanlc? nburg, Esquire Federman and Phelan Date: November 24. 1999 in . V FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Attorney for Plaintiff COURT OF COMMON PLEAS . CIVIL DIVISION Vs. RANDY L. WILT Cumberland County GERALDINE A. WILT Defendants No. 99-5252-CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ?L? FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: January 4, 2000 r C) w9 M ?? U ??:, TC U7, L!'e 7 lilw U O o 7 U FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. RANDY L. WILT GERALDINE A. WILT Defendant(s) Attorney for Plaintiff . COURT OF COMMON PLEAS CIVIL DIVISION . CUMBERLAND COUNTY . NO. 99-5252-CIVIL TERM VERIFICATION I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to RANDY L. WILT and GERALDINE A. WILT at 1299 KELTON ROAD,CAMP HILL, PA 17011 and 433 WEST QUEEN STREET,#13, ANNVILLE, PA 17011 on January 13. 2000 , in accordance with the Order of Court dated DECEMBER 16, 1999. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN,ESQUIRE DATE: January 13. 2000 Attorney for Plaintiff t .n C?7 F= ? l 9 c"I py L U FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Chase Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219-6009 Plaintiff Attorney for Plaintiff : Cumberland COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION VS. Randy L. Wilt : NO. 99-5252 Civil Term Geraldine A. Wilt 433 West Queen Street #13 Annville, PA 17003 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Randy L. Wilt and Geraldine A. Wilt, 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 8/1/99 to 2/17/00 TOTAL $99,243.38 $4.289.34 $103,532.72 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237. 1, copy attached. i ? FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: . ,tea r PRO PR HY /,eZ "THIS FIRM IS A DEBT COLLECTOR ATrE%irrING TO COLI.E(T A DF.Br AND ANY INFORMATION OBTAINED WILL BE uSF.D FOR THAT PURPOSE. IF YOU HAVE. PREVIOUSLY RECEIVED A DISCHARGE IN RANKRCPT('Y AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT HE CONSTRUED TO BEAN ATTEMPT TO C01.I.F.(-r A DEBT. IIUT ONLY ENFOR('E.NIF.NT OF A I.IF.N AGAINST PROPF.R7'V. •• -. ;:? Vs. RANDY L. WILT GERALDINE A. WILT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-5252-CIVIL TERM ORDER AND NOW, this day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), RANDY L. WILT AND GERALDINE A. WILT, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, 433 WEST QUEEN STREET #13, ANNVILLE, PA 17003 and to the mortgaged premises at 1299 KELTON ROAD, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's office an Affidavit as to the mailing. BY THE URT: J. BY: Lisa D. BianKennurg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 _ CHASE MANHATTAN MORTGAGE CORPORATION FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza ATTORNEY FOR PLAINTIFF Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff RANDY L. WILT GERALDINE A. WILT Defendant TO: GERALDINE A. WILT 433 WEST QUEEN STREET, #13 ANNVILLE,PA 17003 DATE OF NOTICE: FEBRUARY 3. 2000 . CIVIL DIVISION CUMBERLAND COUNTY NO. 99-5252-CIVIL TERM 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 PROEPRTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esaaire Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza ATTORNEY FOR PLAINTIFF Suite 900 Philadelphia, PA 19102-1799 12151 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff Vs. RANDY L. WILT GERALDINE A. WILT FeLerldanL TO: RANDY L. WILT 433 WEST QUEEN STREET, #13 ANNVILLE,PA 17003 DATE OF NOTICE: FEBRUARY 3. 2000 CIVIL DIVISION CUMBERLAND COUNTY NO. 99-5252-CIVIL TERM 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 PROEPRTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION '- LIBERTY AVENUE CARLISLE, PA 17013 (717)''-49-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Chase Manhattan Mortgage Corporation Plaintiff VS. Randy L. Wilt Geraldine A. Wilt Defendant(s) Attorney for Plaintiff : Cumberland COUNTY : Court of Common Pleas CIVIL DIVISION :NO. 99-5252 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 Randy L. Wilt is over 18 years of age and resides at whereabouts unknown. (c) that defendant Geraldine A. Wilt is over 18 years of age, and resides at whereabouts unknown. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. 7 F NK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) Chase Manhattan Mortgage Corporation Plaintiff VS. Randy L. Wilt Geraldine A. Wilt Cumberland COUNTY Court of Common Pleas CIVIL DIVISION NO. 99-5252 Civil Term Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on February 2000. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDER-MAN, ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA PA 19102 (215)563-7000 **THIS FIRM IS A DEBT COLLECTOR A ITNIPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** R) ?? _ ` ? J YY ? ? ? <? 2 ? ??