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HomeMy WebLinkAbout99-06189 }t l ?"'1 r . wr tk- / ?e44 ? Mt .,f A h r {y l Y t ? 4 ? 5 1 ? atyR k ?5 rte,,, +. . 5 41 , J , Ay ty?tY _ i1F` i k yri (J c 7rya } 1 CIO 1?C 't 4' 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 Plaintiff V. TERM NO. f? 4 /00? RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 Defendant(s) CUMBERLAND COUNTY CIVIL. ACTION - LAW MORTGAGE FORECLOSURE ON TICS PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COI.LEer A DEBT. ANY INFORMATION RECEIVED RILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT DE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCE-MENT 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 arc 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 wamcd 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 Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219-6009 2. The name(s) and lost known address (cs) of the Defendant(s) arc: RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/5/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to HART MORTGAGE CORP, which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1280, Page 954. By Assignment of Mortgage recorded 9/7/95 the mortgage was assigned to MELLON BANK, N.A. which Assibmmcnt is recorded in Assignment of Mortgage Book No. 503, Page 675. By Assignment of Mortgage recorded 9/9/96 the mortgage was assigned to MELLON MORTGAGE COMPANY which Assignment is recorded in Assignment of Mortgage Book No. 529, Page 666. By Assignment of Mortgage recorded 12/16/97 the mortgage was assigned to CHASE MANHATTAN BANK which Assignment is recorded in Assignment of Mortgage Book No. 564, Page 422. By Assignment of Mortgage recorded 5/18198 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No.576, Page 875. 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 5/1/99 and each month thereafter arc due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $63,133.49 Interest 2,413.77 4/1/99 through 10/1/99 (Per Diem $13.19) Attorney's Fees 3,156.00 Cumulative Late Charges 111.12 9/5/95 to 10/1199 Cost of Suit and Title Search 750.00 Subtotal 69,564.38 Escrow Credit 0.00 Deficit 238.02 Subtotal 8 02 TOTAL $ 69,802.40 7. The attorney's fees set forth above arc 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. The Temporary Stay as provided by the homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Ifousing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 ct 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 eL.lll Judgment against the Defendant(s) in the sum of $69,802.40, together with interest from 10/1/99 at the rate of $13.19 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. nnk Pedcrrnan ?SF FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff OCHASE 4. C Ike Manhattan Mortgage Corporation 3415 Vlelort Drive Columbus, OH 43219.6009 1.800848-9380 Collections 1.800582-M2 TDD/Text Telephone RICHARD A. WOOD 416 WATER S N NEW CUMBERLi, PA 17070-1951 RE: Loan 01904081353 Loan 111904081353 CERTIFICATE OF MAILING 07/05/1999 NOT2CE:OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by AFFILIATE OWNED (hereinafter we, us, or ours) on your property located at 416 WATER STS NEW CUMBERLAND, PA 17070-0000 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $534.36 for the months of HAY, JUNE, JULY. Late and other charge!s'to"date equal $1,173.06. The total amount now required to cure this default, or in other words, get caught up on your payments, as of the date of this letter is $2,776.14. You may cure this default within 30 DAYS of the date of this letter, by paying to us $2,776.14, plus any additional monthly payments and late charges which may fall due during this period. Payment must be made either by cashier's check, certified check, or money order, and sent to PO Box 349006, Columbus, OH 43234-9006. t If you do not cure the default-,within 30 DAYS, we intend to exercise our right to accelerate the mortgage balancd' This means that the outstanding balance, including but not limited to principal, interest, and all other outstanding charges and costs will be considered due immediately, and you may lose the chance to pay off the original mortgage in moi?thly installments. If full payment of the amount of the default is not made within'30 s,-Ka also intend to instruct our attorneys .101 - to start a lawsuit to foreclose your a ed property. If the mortgage is foreclosed, your mortgaged property bold by the Sheriff to pay off the mortgage debt. If we refer your case ,attorneys, but you cure the default before they begin legal proceedings ag ns -.you, you will still have to pay the reasonable attorney's fees actually i rr Q up to $50.00. Any attorney's fees will be added to whatever you owe us, is ay also include our reasonable costs. If you cure the default within the thi period, you will not be required to pay attorney's fees. We may also sue you personally for the unpai due under the mortgage. If you have not cur and foreclosure proceedings begin, you still prevent the sale at any time up to one hour' You may do so by paying the total amount of late or other charges then due, as well as t connected with the foreclosure sale (and per mortgage). balance and all other sums 1_'11'?-al fault within the 30 day period right to cure the default and e Sheriff's foreclosure sale. unpaid monthly payments plus any easonable attorney's fees and costs iany other requirements under the HIBIT A EX A RICHARD A. SHERWOOD 07/05/1999 PAOA 9 CERTIFICATE OF MAILING It is estimated that the earliest date that a Sheriff's sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's sale.will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. . .. You can find,`out what the required payment will be by calling us Monday through Friday at 1-800-848-9380 between BAM and 5PM, Eastern Time. This payment must be by cashier's check, certified check, or money order, and made payable to Chase Manhattan Mortgage Corporation, Regular Mails PO Box 9001068, Louisville, KY 40290-1068 o Overnight: 6716 Grade Lane, Building 9, Louisville, KY 40213-1401. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. You Have the Right to Sell the;P,roperty to Obtain Money to Pay Off the Mortgage Debt, or to Borrow Money from Another Lending Institution to Pay Off This Debt. You May Have the Right to Sell or Transfer the Property Subject to the Mortgage to a Buyer or Transferee Who Will Assume the Mortgage Debt, Provided That All the Outstanding Payments, Charges, and Attorney's Fees and Costs Are Paid Prior to or at the Sale and That the Other Requirements Under the Mortgage Are Satisfied. Contact Us to Determine Under What Circumstances This Right Might Exist. You Have the Right to Have This Default Cured by Any,Third Party Acting on Your Behalf. You Have the Right to Reinstate After Acceleration and the Right to Assert in the Foreclosure Proceeding the Non-Existence of a Default or Any Other Defense You May Have to Acceleration and Foreclosure. If you cure the default, the m moitgage will be restored to the same position as if no default had occurred. However,-,you are not entitled to this right to cure your default more than three times In any qljq?dar year. Chase Manhattan Mortgage Corporation information obtained will be used for Sincerely, AFFILIATE OWNED by CHASE MANHATTAN MORTGAGE CORPORATION, AGENT Cam Scott Casteel Loan Counselor Default Loan Servicing Department 173A( 173)/605 to collect a debt and any Is EXHIBIT A ?4 OCHASE Cie Mantf?ittan Mortgage Corporation 3415 Visio:ibflve Columbus,,Qh 432198009 1-800.84& Collections 1.800.582 TDDlrext Telephone 91 N Imant: Please read (Esta RICHARD A. SHERWOOD 416 WATER ST NEW CUMBERLAND, PA Loan #1904081353• CERTIFICATE OF !AILING 07/05/1999 Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 itice. You may be eligible for financial toward your mortgage payments don puede ser obtenida en Espanol) 17070-1951 RE: Loan 01904081353 Property: 416 WATER ST NEW CUMBERLAND,?!PA 17070-0000 Your Mortgage is in serious d6fiult because you have failed to pay installments of principal and interest pro4kly, as required, for a period of at least 60 days. The total amount of-3he;delinquency is $2,776.14. Slsi?l?d?3 That sum includes the followings Total of monthly payments from MAY 1999 to 8/1999 $ 1,603.08 Late and Other charges accrued, if an, 1,173.06 SUB-TOTAL $ 2,776.14 TOTAL AMOUNT OF DELINQUENCY $ 2,776.14 ?T RICHARD: 11. 07/05/1999 Page 2 temporary your contr determined Notice. I SHERWOOD CERTIFICATE OF MAILING Aible for financial assistance that will prevent foreclosure on if you comply with the provisions of the Homeowners' Emergency tance Act of 1983 (the "Act"). You may be eligible for emergency otance if your default has been caused by circumstances beyond bnd if you meet the eligibility requirements of the Act as the Pennsylvania Housing Finance Agency. Please read all of this Under the Act. aw are entitled to a temporary stay of foreclosure on your mortgage fo? 9 ,die s_From.the date of this Notice. During that time, you have the right to arrange.n•,"face-to-face" meeting with a representative of this lender, or with a des grated consumer credit counseling agency. The purpose of that meeting is to attea:pt to work out a repayment plan, or to otherwise settle your delinquency. TNit.'meetina must occur in the next 30 days. SEE ATTACHED LIST OF AGENCIES.; If you attend a face-t6=face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for 30 days after the date of that meeting. The name, address and telephone number of our representative is: Scott:Casteel Default Loan Servicing Chase:Manhattan Mortgage Corporation 3415 Vision Drive Columbus, OH 43219-6009 1-800-848-9380 It is only necessary to schedule one ff?face meeting. You should advise this lender immediately of your inten If you have tried and are unable to rfimlv ?'fhis problem at or after your face-to-face meeting, you have the rig t ..'Apply for financial assistance from the Homeowners' Emergency Mortgage As3ik Fund. In order to do this, you may fill out, sign, and file a compleCB :p owners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling,V,i.r application. It must be You must either mail your application to the`RIM%lbania Housing Finance Agency, or you must file it at the office of? of the designated consumer credit counseling agencies on the attached 1 y-. The Pennsylvania Housing Finance Agency is located a 2101?North Front Street, 2 PO Box 8029, Harrisburg, PA 17105. Telephone No.: 7 0-3800 or 1-800-342-2397 (toll-free number). EXHIBIT B .wqAS '7f RICHARD:% 07/05/1999 Page 3s? Available be disbur Act. SHERWOOD Lj ci-iasE CERTIFICATE OF NAILING for emergency mortgage assistance are very limited. They will the Agency under the eligibility criteria established by the every resnect:""'The counseling agency will help you The Pennsylvania Housing Finance Agency has 60 days receives your application. During that additional proceedings will be i# "d against you if you have set forth above. You All be notified directly by your application. to fill out the application. to make a decision after it time, no foreclosure met the time requirements the Agency of its decision on In addition you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose." You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upoi$Nhile you are receiving that assistance. Sincerely, / Scott Casteel Loan Counselor n q?rrg Default Loan Servicing Department Y Chase Manhattan Mortgage Corporation Telephone: 1-800-848-9380 v Enclosure 1738( 173)/605 ' •. r rYV EXHIBIT B ..w,r,-,1..... b. L.%"&.* DuD.p.wd d.. dd. HUD Am &d X...d 4..v6.r.: *ALLENTOWN NEIGHBORHOOD HOUSING SERVICES,: C. (NRC) 335 North'b h Street ALLENTO4 18102 Phona: 6 p37-4571 Fax: 61 37F9958 NORTHERN TIER 4NNITY ACTION CORPORATION t?FF`y" 135 West 4th S, at EMPORIUM. PA ,I1.' 3qE;; Phone: 814-4862 81" ;. ., BAYFRONT NATO, INC. `•• 312 Chestnut Street ERIE, PA 16507 Phonac 814-459-2761 k.s BOOKER T. WASHINGTON CENTER 1720 Holland Street ERIE, PA 16503 Phone: 814-453-5744 .Pii . COMMUNITY RESOURCES FOR INDEP. C 9222 Filmore Avenue ?•F ERIE, PA 16506 Phona: 814-838-7222 GREATER ERIE COMMUNITY ACTION AGENCY 18 West 9th Street ERIE, PA 16501 Phona: 814-459-4581 SHENANGO VALLEY URBAN LEAGUE 601 Indiana Avenue FARRELL, PA 16121 Phone: 412-981-5310 HARRISBURG FAIR HOUSING COUNCIL 2100 North 60 Street HARRISBURG, PA 17110 Phone: 717-238-9540 URBAN LEAGUE OF METRO 2107 North 6th Street HARRISBURG, PA 17110 Phone: 717-234-3253 INDIANA COUNTY COMMUNITY INC. 827 Water Street P.O. Box 187 INDIANA, PA 15701 Phone: 412-465-2657 ACTION PROGRAM, ELK COUNTY HOUSING AUTHORITY 424 Water Street Ext. P.O. Box 100 JOHNSONBURGH, PA 15845 Phone: 814-965-2532 ARMSTRONG COUNTY COMMUNITY ACTION AGENCY Armsdale Administration Bldg. R.D. 8 P.O. Box 28 KITTANNING, PA 16201 Phone: 412-548-3405 TABOR COMMUNITY SERVICES 439 East King Street LANCASTER, PA 17602 Phone: 717-397-5182 S COUNTY HOUSING GROUP East Richardson Avenue HORNE, PA 19047 e: 215-750-4310 215-750-4318 H PPORTUNITIES, INC. 1 th Avenue M T, PA 15132 PP?P04 9 P2-664- 1590 K,Pj R, IN EXHIBIT B r.y.. i?1?lYl IIUDAyp..N:taAm IfAlak?VAM C.r.iy Ardor wlO. r.i: I b.., a b.bd.i6.V7 HUD.M..q bdm. d e. HUD WW N,b..::m.e.&n .) it 11 A.IWULNEW FAMILY SERVICES 213 Centein'fitreet MEADVILLE AFA 16335 Phone: 814 37-8457 TREHAD CE1?(ER OF,NORTHEAST PENNSYLVANIA 7 Lake Avenue **1 MONTROSE, PA jVB801 Phone: 717-278?,'V38 LAWRENCE COUNTr,SOCIAL SERVICES, INC. 33-39 South JeffBeson Street.., NEW CASTLE, PA 16103 Phone: 412-658-7258 Nle'::. : •CCCS OF DELAWARE VALLBY;j(NFCC) 1211 Chestnut Street, Su_it& 400 PHILADELPHIA, PA 19307' "'` Phone: 215-563-5665 *PHILADELPHIA NEIGHBORHOOD HOUSING SERVICES. INC. (NRC) 511 North Broad Street 4th. flo'd PHILADELPHIA, PA 19123-323 0 Phone: 215-829-9899 Fax: 215-829-9039 %57 ACORN HOUSING CORPORATION 846 North Broad Street PHILADELPHIA, PA 19130 Phone: 215-765-0048 Fax: 215-765-0045 COMO PEDRO CLAVER, INC. 3565 North 7th Street PHILADELPHIA, PA 19140 Phone: 215-227-7111 Fax: 215-227-7105 HOUSING ASSOCIATION INFORMATION PROGRAM 1314 Chestnut St., Suite 900 PHILADELPHIA, PA 19107 Phone: 215-545-6010 INDIVIDUALS 4040 Market Street - 3rd Floor PHILADELPHIA, PA 19104 Phone: 215-895-5609 NEW KENSINGTON C.D.C. 2513-15 Frankford Avenue PHILADELPHIA. PA 19125 Phone: 215-427-0350 NORTHWEST COUNSELING SERVICE 5001 North Broad Street PHILADELPHIA, PA 19141 Phone: 215-324-7500 PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 North 17th Street Suite 600 PHILADELPHIA, PA 19103 Phone: 215-567-7803 PHILADELPHIA DEVELOPMENT PARTNERSHIP 1334 Walnut Street - 3rd Floor PHILADELPHIA, PA 19107 Phone: 215-545-3100 Fax: 215-546-8055 HOUSING DEVELOPMENT Market Street Floor DELPHIA, PA 19107 : 215-448-3137 OHIA REHABILITATION PLAN [t? 17th Street, 11th Floor LPHIA, PA 19103 215-561-1173 215-561-4871 EXHIBIT B ++tt r HUD AMM-4 H--Aft a?w;a:•:t.....bmUA ".UYHUOSra•4 y (m .Ift HUDRl AWNM.WW.-". ) V41 r,. p'" W4 RESOURCES FOR HUNAN DEVELOPMENT 3721 Midvale Avenue GARFIELD JUBILEE ASSOCIATION, INC. PHILADELPHIA, PA 19129 5138 Penn Avenue Phone: 215-051-0300 PITTSBURGH, PA 15224 Faxt 215P,951-0313 Phone: 412-665-5200 S' ACTIOROUP OF PHILADELPHIA 21 South 12th AtF'eet 12th Floor 1*11A PHILADELPHIA, Pk 19107 Phone: 215-575±0700 UNEMPLOYMENT INFORMATI6N CENTER 116 South 7th St. - Suite ¢10 PHILADELPHIA, PA 191061 x+. Phone: 215-592-0935 tc Faxt 215-592-7537 URBAN LEAGUE OF PHILADELPHIA 251-53 South 24th Street PHILADELPHIA, PA 19103 Phones 215-731-4100 *NEIGHBORHOOD HOUSING (NRC) 1415 Boyle Street PITTSBURGH, PA 15212 Phone: 412-321-0121 Faxs 412-321-6411 iikl SERVICES, TNC. CENTER FOR INDEPENDENT LIVING SW PA 7110 Penn Avenue PITTSBURGH, PA 15208 Phone: 412-371-7700 CONSUMER. CREDIT COUNSELING OF WESTERN PENNSYLVANIA 309 Smithfield Street suits 2000 PITTSBURGH, PA 15222 Phone: 412-471-7584 ELDER-ADO, INC. 320 Brownsville Road PITTSBURGH, PA 15210 Phone: 412-381-6900 HILL COMMUNITY DEVELOPMENT CORPORATION 2015-2017 Centre Avenue PITTSBURGH, PA 15219 Phone: 412-765-1320 URBAN LEAGUE OF PITTSBURGH one Smithfield Street PITTSBURGH, PA 15222 Phone: 412-261-1130 ECONOMIC OPPORTUNITY CABINET OF SCHUYRILL COUNTY, INC. 225 North Centre Street POTTSVILLE, PA 17901 Phone: 717-622-1995 Fax: 717-622-0459 *NEIGHBORHOOD HOUSING SERVICES OF READING, INC. (NRC) 383 Schuykill Avenue READING, PA 19601 Phone: 610-372-8433 FAX: 610-374-2866 w RRS COMMUNITY ACTION UNSELING CENTER AGENCY BUDGET ;.47 North Fifth Street READING, PA 19601 Phone: 610-375-7866 r r ,y{ A EXHIBIT B c, euDAmmdtin I w W b. bAwYly HUD *p..4 AWNradI.r .) -au. &us aaaunounnuvu HuuSING SERVICES, INC. (NRCj;_ 401 West 41rket Street SCRANTON,j1 18508 Phones 7 %k 48-6717 Faxs 71 1948-4798 Cn`'-CUMER CREDIT COUNSELING SERVICES 541 Wyoming Avenue SCRANTON, PA :8;501 iil;a.w? i:yAe. MERCER COUNTY CONMUNITy_/lCtiTf?N AGENCY 309 Ohio Street SHARON, Ph PA 16146 412 "C oney -342-6222 Faxt 412-342-6301 TABLELAND SERVICES, INC. 131 North Center Avenue P.O. Box 756 SOMERSET, PA 15501 Phone: 814-445-9628 FAYETTE COUNTY COMMUNITY 137 North Beeson Avenue UNIONTOWN. PA 15401 Phone: 412-437-6050 WARREN FOREST COUNTY E.O.C. 1209 Pennsylvania Avenue W. P.O. Box 547 WARREN, PA 16365 Phonet 814-726-2400 COMMUNITY ACTION SOUTHWEST 315 East Hallam Avenue WASHINGTON, PA 15301 Phone: 412-225-9550 TRI-COUNTY PARTNERSHIP FOR LIVING 69 East Beau Street WASHINGTON, PA 15301 Phone: 412-223-5115 the 1,f 4 WASHINGTON-GREENE COMMUNITY CORPORATION 22 West High Street WAYNESBURG, PA 15370 Phone: 412-852-2893 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 3671 Crescent Court East WHITEHALL, PA 18052 Phonet 610-821-4011 COMMISSION OF ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211-213 South Main Street WILKES-BARRE, PA 18701 Phonet 717-826-0510 HOUSING COUNCIL OF YORK 116 North George Street YORK, PA 17401 Phone: 717-854-1541 EXHIBIT B ALL THAT CcRTATN lot or pieca o! land situate in the Borough of. New Cumberland, County of Cumberland and State of Pennsylvania, bounded and deaeribed as follows, to wits BEGINNING at a poinc on the southerly line of Water Street at the center of -the canter wall betw"n houses Nos. 414 and 416 Water Street,; New Cumberland, Pennsylvania; thence in a westerly diraecion•along:the aouthesiy,line of Water Street, thirty seven and one-half (37}) feet, more or less; ze' Lot No: 37 on the General Plan of Now Cumberland: thence in a southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Allay; thence in an easterly dir- action along the line of Walnut Allay, thirty-seven and one-half (37}) fact, more or less, to a point: thence on a line pnrellal to the divtding.linc between Lot Nos. 36 and 37 on said Plan and through the center of the center wall.between houses Nna, 414 and 416 Water Street, one hundred fifty (150) teat to'che mouth- erly line of Water Street, the Place of BEGINNING. HAVING THEREON ERECTED one-half of a double frame dwelling house known as No. 416 Water Street, Now Cumberland, Pennsylvania 17070, UNDER AND SUBJECT to all applicable restrictions. raservations, easementa and rights of way of record. BEING THE SAME PREMISES which Konrad S. Winger and Terri Lynn Winger, husbund and wife, by their Dead dared June 11, 1994 and recorded June 17, 1994 in the Office of the Recorder of Deeda in and for Cumberland County in Dead Book 107, page 42, granted and conveyed unto Sherri L. Smith, married woman. Grantor herein. CHRISTOPHER STUMP hereby states that he is ASSISTANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure arc true and correct to the best of his 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 unswom falsification to authorities. DATE: 1 6' 54-qq m v ? , J tV J 11 ??? SHERIFF'S RETURN - REGULAR CASE NO: 1999-06189 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS. SHERWOOD RICHARD A RICHARD SMITH Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT IN MORTGAGE/FORE was served upon SHERWOOD RICHARD A the defendant, at 19:14 HOURS, on the 1st day of November 1999 at 416 WATER ST NEW CUMBERLAND PA 17070 CUMBERLAND County, Pennsylvania, by handing to KEN JOHNSON (ROOMMATE) a true and attested copy of the COMPLAINT IN MORTGAGE/FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 '? 4 2 Service 11.16 Affidavit .00 Surcharge 8.00 K."inomas R'1'TRe, X11/03 1999 PHELAN Sworn and subscrib d to before me this ? day of? C.c?'++?? by Cy"SREPTf[ 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 VS. Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 99-6189-CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Richard A. Sherwood, 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 $699802.40 Interest 10/1/99 to 12/6/99 8$ 83.73 TOTAL $70,686.13 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. FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: / PRO PROT "THIS FIRM IS A DEBT COLI.ECrOR ATTEMPTING TO COLLECT A DEBT AND ANY INFOMsIATION OBTAINED WILL DE USED FOR THAT PURPOSE.. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRAtED. TII IS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY. " ., ? ? ?„c? :: S? o ?lt- ;' ,?? a ?!.? r`: w u rn m s FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. RICHARD A. SHERWOOD Defendant(s) TOt RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 DATE OF NOTICE: NOVEMBER 23, 1999 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS . CIVIL DIVISION CUMBERLAND COUNTY NO. 99-6189-CIVIL 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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 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, Esquire Attorney for Plaintiff c u G. t q/ 41, U 1 ( 13 <,?: cri 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 Vs. : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION Richard A. Sherwood : NO. 99-6189-CIVIL Defendant(s) 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 Richard A. Sherwood is over 18 years of age and resides at 416 Water Street, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff " t S - ) v w 3y x? L (Rule of Civil Procedure No. 236 - Revised) Chase Manhattan Mortgage Corporation Plaintiff VS. Richard A. Shenvood : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION : NO. 99-6189-CIVIL Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on December 7 .1999. --B ? n.u DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215)563-7000 "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. •• of ?4. ' C7 m m M V 0 ?? ?InC 1o- ...... ... ......?.. <.«I _. 4 l 4 YY(et, Dt'f9 f^} ?4 1 PRAECIIiE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Va. RICHARD A. SHERWOOD i COURT OF COMMON PLEAS i CUMBERLAND COUNTY, PA i i NO. 99-6189 CIVIL i s PRAF.CIPE FOR WRIT OF EXECVnON I (MORTGAGE FORECLOSURE) i i Defendant(s) TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $70.686.13 Interest from 12/6/99 TO S 987.70 and Coats 3/1/00 (PER DIEM - $11.62) $71.673.83 Total E F K FEDERN} ESQUIRE T O PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. ? y Q w d '> co °; Wa oz ? a F O ..7 U 00 O 10 U a% w z° U a a m ?0 r7 O? W r 4) w? W v W w 0 0 P ri a • b d m A ? H ? H W a ? y H d a 3 d b a m N H ro ro a A DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel N 25.24-0813.052 TITLE TO SAID PREMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. 4 CHASE MANHATTAN MORTGAGE CORPORATION Vs. RICHARD A. SHERWOOD s CUMBERLAND COUNTY s COURT OF COMMON PLEAS s CIVIL DIVISION I NO. 99-6189 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 416 WATER STREET. NEW CUMBERLAND, PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): AM LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND. PA 17070 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 NONE 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) 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) PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET FINANCE AGENCY P.O. BOX 15530 HARRISBURG. PA 17105 S. 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 416 WATER STREET NEW CUMBERLAND. PA 17070 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. December 9, 1999 DATE F K FEDER N, ESQUIRE Attorney f Plaintiff i Ii f J-. N F ci ryr?? 4U . cl FEDERMAN and PHELAN Byt FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION vs. RICHARD A. SHERWOOD ATTORNEY FOR PLAINTIFF t CUMBERLAND COUNTY t COURT OF COMMON PLEAS t CIVIL DIVISION s : NO. 99-6189 CIVIL 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: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (XX) 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. F K FEDE N, ESQUIRE Attorney for Plaintiff Atl , ? ter' p7? i ?: cwa Jai CHASE MANHATTAN MORTGAGE CORPORATION s CUMBERLAND COUNTY s COURT OF COMMON PLEAS Va. s CIVIL DIVISION RICHARD A. SHERWOOD s NO. 99-6189 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY December 9, 1999 TO: RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 **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, 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 416 WATER STREET, NEW CUMBERLAND, PA 17070, is scheduled to be sold at the Sheriff's Sale on MARCH 1. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $70,686.13 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actions 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. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the Sheriff and will be made available for inspection in his office. The 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 filing of the proposed schedule. 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 1 DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel a 25-24-0813-052 TITLE TO SAID PREMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. f? N G. kz? rn 7 It I , f 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. RICHARD A. SHERWOOD Defendants CIVIL DIVISION No. 99-6189 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CHASE MANHATTAN MORTGAGE CORPROATION, hereby verify that on DECEMBER 10. 1999, 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 DECEMBER 10. 1999 and JANUARY 31. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. RANK FEDE MAN, ESQUIRE Attorney for A aintiff Date: February 2. 2000 9 Y. h N !C n. a Y Ua $aoa W p? o O e :? ?Fa 6 ? • ? 9 Yp y4 ^ 9 Y ?. Q O / li. J1) ?V I ? I L Dpi 6 e G } (? U `o W z p S a CG d ? ? O C C O 5 Q? z? a ?C? u ? ?w w c ? ai O U ca G O z y ? I^ ? C? y o z m z 3 3 .. o ? an i'.S.' {? F W vZ o G z .M.U Ly 4, z . . oy ` " ? N N1 ' 7 h ?O 1? 00 a O N M 4 Vl n F? r?.?--- ---------- ---Yr' -rim T? - R i T MiWA , rosrrePoC otr « W E N RECEIPT w[srwr.YDrftArw, . -4%/ '? yr & r A SERVICE r[wn(prt[•w[rVn. wrr[rt i r ? ross rosuc[ua r[[a ? s • ?C' m SENT TO' rwv ew[nowu y ! . •,. 3g CL PS FORM 3800 US Postal Service Receipt for Certified Mail RETURN ?? R ro3TMAAK OA OATS ? ? RECEIPT tarwCr[D D[V•Swr S . C7 SERVICE [[wir[p rR r¢ruw wec[rr ru rou[rosr+o[un r[ta ENT TO: ratrt w? rur?ru[ Ir + ?•.: ••t..r a PS FOR13800 US POStal Service Receipt for Certified Mail i" i ,? ?: ? ? ???: C c!: S ^ Cw: i.J .. n _ :=?. ? t- -?I! ? ? ?'= t : ?„? ? e 1, 1° .. ( ? n U ? ? i J .l PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Chase Manhattan Mortgage Corporation Cumberland County Plaintiff, V. No. 99.6189 Civil Richard A. Sherwood Derendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $70,686,13 Interest from 12/6/99 - 9/6/00 $3,195.50 and Costs (per diem - $11.62) $73,881.63 TOTAL FRA K FEDE MA , ESQUIRE -? TWO PENN CENTAR PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. N w 0 0 A Ow a u a ? m a e o v oo. F 0 A a U i° i5 5 u u 0 .a a pe a z 0 W? W w O a w a U h 0 0 ru w °o y ?y ad a u ?o a:; Phi a a v e V z DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel H 25-24-0813.052 TITLE TO SAID PREMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. uJ( G7 ,7 y ti? (1? ? tJ ? ri FEDERMAN and PHELAN Dy: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Chase Manhattan Mortgage Corporation CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION Richard A. Sherwood Defendant(s). NO. 99-6189 Civil 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: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. VF NK FE E AN, ESQUIRE ttorney for Plai tiff _ w r. / 71 p `' . 7(L } . CD i (Z2 U ?i Chase Manhattan Mortgage Corporation Plaintiff, V. Richard A. Sherwood Derendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6189 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Chase Manhattan Morteaee Cornoration, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Pmecipe for the Writ of Execution was filed the following information concerning the real property located at 416 Water Street, New Cumberland, PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Some 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 A 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.) Pennsylvania Housing 2101 North Front Street Finance Agency P.O. Box 15530 Harrisburg, PA 17105 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 416 Water Street New Cumberland, PA 17070 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 1 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. June 13. 2000 CQ? DATE I'RA K FEDE AD , ESQUIRE Att mcy for Plaintiff u ! ? 7 "i C p Chase Manhattan Mortgage Corporation CUMBERLAND COUNTY Plaintiff, V. No. 99-6189 Civil Richard A. Sherwood Defendant(s). June 13, 2000 TO: Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 ''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 416 Water Street, New Cumberland. PA 17070, is scheduled to be sold at the Sheriffs Sale on Sentember 6.2000 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 Sheriffs sale is postponed, the propertywill be relisted for the December 6, 2000 Sheriffs Sale. NOTICE. OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAL 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 Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE. ABLE. TO SAVE. YOUR PROPERTY AND YOU HAVE. OTHER RIGHTS EVEN IF THE SHERIFF'S SALE. DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may 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 decd 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 lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Ailey, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel b 25-24-0813-052 TITLE TO SAID PREMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. fr r. it, to U AFFIDAVIT OF SERVICE. PLAINTIFF Chose Manhattan Mortgage Corporation Cumberland County No.99.6189 Civil DEFENDANT(S) Richard A. Sherwood Type of Action SERVE AT 416 Water Street - Notice of Sherlff s Sale New Cumberland, PA 17070 Sale Date: September 6, 2000 SERVED Served and made known to O hA/tip AV AI AA)b , Defendant, on the day of 200,0 at f vJ, o'clock _em., at Vero W AeA ShPee s? / y?tw At , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult In charge of Dcfendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person In charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age S? Height 'fit) Weighty" Race W Sex /ti Other 9La48OOV 1, PK_h41zP , a competent adult, being duly sworn according to law, depose and state that 1 personally handed a e and correct copy of the to the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. .t? Sworn to and subscribed "^r?"n? before me this 21 day ROBERTA E. BIESEt aE: , fkttary Public amh land County of k uf, 200a Camp HiO, CuPa0r-. Jury 23,2001 IA7 Cc• mi >JS lt? r-fi,416_r? -j54 Notary: ?, -- NOTSERVED On the day of , 200_, at o'clock _.m., Defendant NOT FOUND because: _ Moved _ Unknown _ No Answer Vacant Other: Sworn to and subscribed before me this _ day of ,200 Notary: By: Attorney for Plaintlff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 I?c C*l fi.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff CIVIL DIVISION VS. RICHARD A. SHERWOOD Defendants No. 99-6189 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CHASE MANHATTAN MORTGAGE CORPORATION, hereby verify that on JUNE 15, 2000 AND AUGUST 23. 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 JUNE 15. 2000 by first class mall and certified mail return receipt requested, see Exhibit "B" attache / hereto. aa??? FRANK FE ERMAN, ESQUIRE Attorney f r Plaintiff Date: August 28, 2000 P(4-k Chase Manhattan Mortgage Corporation Plaintiff, V. Richard A. Sherwood Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6189 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Chase Manhattan Morteaae 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 416 Water Street. New Cumberland, PA 17070. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 2. 3 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 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.) Cumberland County 1 Courthouse Square Adult Probation Carlisle, PA 17013 4. 5. 6. 7. 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.) Pennsylvania Housing 2101 North Front Street Finance Agency P.O, pox 15530 Harrisburg, PA 17105 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 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 416 Water Street New Cumberland, PA 17070 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 arc made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. August 28, 2000 DATE f ANK FL )ER AN, ESQUIRE Attorney for Plai tiff z v', C 6 wd? O 09 ?FG I O Y A ? 'O Y ?. Z' t o e ? ? ( ? ; i . 4 - 1 cc•s S Irv _? nom. , : w O °u i x t w ? w z o t ? w = o w s Z ? b c c V ? = ` C x 4 C V ? zz C* z 33 F zM h zE z wo 0.ev ci 0.S w F'• Dw aZ $ ,,V a b? 9 z 111 "Op .- N M Q v? ?p r• 00 O• O rl r? -t V1 Y POSTAL SERVICE CERTIFICA I U.9 TE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCF-POSTMASTER Rapaivaa from; FFt1FRMAN AM TINFLAN 9t11q -'i? .TWO?PENN .p{CENTER ? PLAZA, SUI PtiLtMELPHIA, PA a OM puce at olamary mail aaorUlao to.. CUMBERLAND COUNTY ADULT PROBA hON-"; 1 COURTHOUSE SQUARE CARWSIX PA 17013 , DMK RE:SHERWOOD PS Form 3817. Mar, 1989 v ? ?o 7 V ^ t I N .l?IIII / P , LLLL? 17r ? 4¦11 m ca Ln .0 u- C Cr S M1 C' CL ag•.:[ PCToz Kffnict[c nt Mn. 9ECEV1 9C[MCE C[Pf1[p If[•n[P:IMl?di lPt tpiµ P.rit,Yl un.,(T SENT 0'. MOT. ayu? 616 VAT..R SiVkZET Xd1! CQt.Bcbl.AND, PA 17070 DAr? 3 FORM 3800 US Postal Service a LLW ypOy! F: t, ?i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff CIVIL DIVISION VS. "MAN CIVIL HELAN RICHARD A. SHERWOOD ATTORNEY FILE COPY Defendants PLFABE RETURN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA F RNEY FILE COPY H SS: CUMBERLAND COUNTY PUM RM11 % I, FRANK FEDERMAN, ESQ., attorney for CHASE MANHATTAN MORTGAGE CORPORATION, hereby verify that on JUNE 15, 2000 AND AUGUST 23. 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 JUNE 15, 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FWEFI;wAR ANQ 01L, J*K p,'f MR101Y FR ( Cf-)M FI Ri< A n? FRANK 4FEEARMAN2?, ESQUIRE Attorney f r Plaintiff Date: August 28. 2000 Chase Manhattan Mortgage Corporation Pinintirr, v. Richard A. Sherwood Derendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6189 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Chase Manhattan Mortenae Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praccipe for the Writ of Execution was filed the following information concerning the real property located at 416 Water Street. New Cumberland, PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) Some 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.) Cumberland County 1 Courthouse Square Adult Probation Carlisle, PA 17013 4. 5. 6. 7. 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.) Pennsylvania housing 2101 North Front Street Finance Agency P.O. Box 15530 Harrisburg, PA 17105 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 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 416 Water Street New Cumberland, PA 17070 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 unswom falsification to authorities. Aueust 38.2000 DATE F NK FE ERh AN, ESQUIRE Attorney for Plan tiff STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND Robert P Ziegler I?-----------------------------• I SS. ________ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which --------- Secretary of Veterans Affairs ______ is the grantee ------- - ------•------------------------------------------------ 4th the same having been sold to said grantee on the _______________________________________________ day of ---- October -------------------------- A. D, .g2000--_, under and by virtue of a writ______________ ----- Execution - -----------------------------issued on the _-14th ------------------------------ - day of June------------------- -- A D j,?c00 out of the Court of Comman Pleas of said County as of ------Civil- -- ---- ------- ---- --°- ---- - - --------- --- ------------ -- ---Tenn, 1999 Numberk!8!--_-_-----atthesuitof__ Chase-Manhat-tan- Mtg_Corp_______________________________ --------- --- ----------------------------------- against------ Richa------°rd-Sh----e------rwood --------------------------- is --- duly recorded in Sheriff's Deed Book No. _____ 231-Page -----i lt? IN TFSTMIONY WHEREOF, I have hereunto set my hand and seal of said office this day of ---' J /-/-------- -- A. D, 491 _w _ _`_ Recorder of Deeds Recorder of Derds, ambedand Camp, rAftle. PA My Commission Expires the first Monday of Aa 1002 Chase Manhattan Mortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Richard Sherwood No. 1999-6189 Civil Richard E. Smith Deputy Shcirff, who being duly sworn according to law, says on July 13, 2000 at 7:10 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and description in the above entitled action upon the within named defendant to wit: Richard Sherwood, by making known unto Richard Sherwood at 416 Water Street, New Cumberland County, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on July 13, 2000 at 7:10 o'clock P.M. EDST he posted a copy of real Estate Writ Notice Poster and Description on the property of Richard Sherwood located at 416 Water Street, New Cumberland, 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 the within named defendant to wit: Richard Sherwood by regular mail to 416 Water Street, New Cumberland, Pennsylvania. This letter was mailed under the date of July 14, 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 above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on October 4, 2000 and sold the same for the sum of $ 1.00 to Attorney Dale Shughart for Secretary of Veterans Affairs, An Office Of The United States OF America. It being the highest bid and best price received for the same Secretary of Veterans Affairs, Of P.O. Box 99640 Cleveland OH being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 768.03 it being costs. Sheriffs Costs Docketing 30.00 Poundage 12.15 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 County 1.00 Mileage 10.54 Certified Mail .78 Levy 15.00 Surcharge 20.00 Postpone sale 20.00 Law Journal 242.15 Patriot News 270.38 Share of Bills 23.53 Distribution of Proceeds 25.00 Sheriffs Deed ZQ $ 768.03 Pd By Atty 10/17/00 Sworn and Subscribed To Before Me This. G 4-'Day Of Oel.-L, Soanswe=?? 2000, A.D. Proth n tary R. Thomas Kline, Sheriff By & i Real Estate Deputy Ok 1• Ce. 3017 X-j ?.,• /0 30 7`f PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 28, AUGUST 4, 11, 2000 Afffanl 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. 51 Writ No. 1999.6189 Civil Chase Manhattan /(?Jf Mortgage Corporation vs. Roger M. Morgenthal, Editor Richard A. Sherwood Atty.: Funk Federman DESCRY ZION ALLTHAT CERTAIN lot or piece of land situate in the Borough of New Cumberland. County of Cumberland and State of Pennsylvania, hounded and described as follows, to wit: BEGINNING at a point on (lie Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 4161Vater Street. New Cumberland. Pennsylvania: thence to a Westerly direction nlong the southerly line of Water Street, thirty seven and one-half (37.1/2) feel, more or less, to Lot No. 37 on the Central Plan of New Cumberland: thence hill Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley: thence ill an Easterly direction along the line of Walnut Alley, thirty-seven arA one- half (37.1/2) feel, more or less, to a point: thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the cen- ter of the center wall helween houses Nos. 414 and 416 Witter Street, one hundred fifty (150) feel to the South- erly line of Water Street, the place of beginning. IIAVING thereon erected one-half of it double fume dwelling house known as No. 416 Water Street, New Cumberland, I'cnnsylvutla 17070. Tax parcel 025.24.0813.052 TITLE. TO SAID PREMISES IS VESTED IN Mchanl A. Sherwood. Singleman by Deed front Sherri L. 81111th, Man1e1I wollaal datMi 9/n/95. Irt'on ed ill 7/05. it, Urr,l limk 127, SWORN TO AND SUBSCRIBED before me this __ILday of AUGUST. 2000 NOTAIi t IOIS E. SNYDER. Notary Public Corlirle Bar*, Cumborlond County, M My Commiwon Expir" 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 : 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, JULY 26, AUGUST 4, 11, 2000 statements as to time, place and character of publication are true. 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 REAL ESTATE BALE NO. 51 Writ No. 1999-6189 Civil Chase Manhattan Mortgage Corporation - VS. Roger M. Morgenthal, Editor Richard A. Sherwood Ably.: Flank Federman SWORN TO AND SUBSCRIBED before me this DESCRIPTION _U-day of AUGUST. 2000 ALL711AT CERTAIN lot or piece of land situate to the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the NOTARI l ]h i Southerly line of Water Street at the toll E. SNYDER, Notary Pubk F S center of the center wall between t{,Is bra, Cumberland Courtly /A } houses Nos. 414 and 410NhterSlreel, New Cumberland, Pennsylvania: , COfflrnitsion Eapim March 5, 2001 thence in a Westerly direction along the Southerly line of Water Street. thirty seven and one-half (37.1/2) feet. more or less, to Lot No. 37 on the General Plan of New Cumberland: thence In a Southerly direction along said Lot No. 37, one hundred filly i (150) feet to Walnut Alley: thence in ... ... an Easterly direction along the line of Walnut Alley, thirty-seven and one- h half (37.1/2) feel, more or less, to a , point: thence ona line parallel to the j-, dividing line between Lot Nos. 36 and 37 on said plan and through the cen• } terof the center wall between houses ? -, Nos. 414 and 416 Water Street, one -, .1 hundred fifty (150) feel to the South- - erly line of Water Street, the place of beginning. LAVING thereon erected one-half ! j of a double frame dwelling house known as No, 416 Water Street. New Cumberland, Pennsylvania 17070. Tax Parcel x2524.0813.052 _r...-.f•-? TITLE TO SAID PREMISES IS L VESTED IN Richard A. Sherwood, -? Singleman by Deed from Sherri L. - , - /' Smith, ManledWomandated0/5/05, I recorded 0/7/05, In Deed Book 127, Page 1027. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Commonwealth of Pennsylvania, County of Dauphin) as James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT- NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, In the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published over 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 aditionsAssues which appeared on the 1st, 8th and 15th day(s) of August 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 behnlf 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 Iry? 17Ilaneous Book "M", Volume 14, Page 317. ?? / PUBLICATION COPY SALE 051 REAL !lTARdAkg"$l` writ ft IM4106 ; r `CMliwgt , " . C2liKuwiiffw';' , t f40rl?eyll?fp,J.v Rkhmf A. SMnesod i A 01IiCPoPTION ALL THAT CERTAIN M or pkte„of StreN;,tidrtyantn And one-rwr ur au het, more or kur, to tot No. 0 an the l:erwrA ILn of Sew Cumberland: (hence in a Souther) direction atnng said loot No. 37, one hunred fifty 11501 reel to Walnut AlkUnthence In in Ea4trly direction ilong the a of Walnut Alley, thinyeeten and oM.hall 157 1121 feet, more or test, to a point thence on a One parallel to the dhiding line between tot Nos. 36 and 37 on mid plan and through the center of the center will between hou%es Nos. 414 and 416 Water StrgK one hundred fifty (150) W to the Southerly line of Water Street HAVING thn erected owhall of a double frame dw Ilinghousekoownas No. 416 liValef Street, New Cumberland, 11ewMylvanu 17M Tot Nicol M14-0111145L TITLE TO SAID MtEMISES Is voted In Richard A. Sherwood. aingk man. by Deed from Sherri L Smith. muried.arooun,' diled 9151A recorded 917195, In Deed gook, 127, Pitt IIR7. 30th daV ofAuaifW2000 A.D. Tony L. Notarial Seel ARY PUBLIC expires Juno 6, 2002 Memhui, Venntylvanla A660aalbn CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement o} Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached j hereto on the above stated dates $ 268.88 Probating same Notary Foo(s) $ 1.50 Total $ 270.38 isherIs Receipt for Advertising cost that of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have THE PATRIOT-NEWS CO. By .................................................................... V 4141 Chase Manhattan Mortgage Corporation Plaintiff, V. Richard A. Sherwood Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6189 Civil 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 filed the following information concerning the real property located at 416 Water Street, New Cumberland. PA 17070. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 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 Ok 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.) Pennsylvania Housing 2101 North Front Street Finance Agency P.O. Box 15530 Harrisburg, PA 17105 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 416 Water Street New Cumberland, PA 17070 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 unworn falsification to authorities. June 13. 2000 DATE FR,, OK FEDE A$ , ESQUIRE Att mey for Plaintiff )Y ?' ?( :.?F v y ,,,, ? ? . J ?? 3 Jti„ I , ?' v Chase Manhattan Mortgage Corporation CUMBERLAND COUNTY Plaintiff, V. No. 99-6189 Civil Richard A. Sherwood Defendant(s). June 13, 2000 TO: Richard A. Sherwood 416 Water Street New Cumberland, PA 17070 "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 416 Water Street. New Cumberland. PA 17070, is scheduled to be sold at the Sheriffs Sale on September 6. 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 Morteaee Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 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. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may 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 ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel # 25-24-0813-052 TITLE TO SAID PRENMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-6189 CIVIL 19 _ CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, Interest and costs due Chase Manhattan Mortgage Corporation from Richard A. Sherwood PLAINTIFF(S) 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 properly 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 gamishee(s) is/are enjoined from paying arty debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If propettyof the defendant(s) notlevieduponan subject to attachment Isfound In the possession of anyone other than a named gamishee, you are directed to notify hinvherthat he/she has been added as agarnishee and Is enjoined as above stated. Amount Due $70.686.13 Interest Ism ?01.12d9Co03 Ally's Comr per diem - $11. ?? ) Ally Paid $829.78 Plaintiff Paid L.L. Due Prothy $1.00 Other Costs Date: June 14, 2000 REQUESTING PARTY: Name Frank Federman Esq Address: Twy Penn Center Plaza, Suite 00 Attorney for: Plaintiff Telephone: (219L g63-7000 Supreme Court ID No. 12248 Curtis R. Long Prothonotary, Civil Division by: JrbZ f U Deputy un qe-- ? /s: a-^'" the sheriff levied upon the defendams Interest in the real property situated In d--"' '-A Cumberland County, Pa., known and numbered MAW "&A4004 /44) and more full,, ;t:scribed on Exhibit "A" filed with this writ and by this reference incorporated herein. late: r BY' f? P.-M. V S i? Chase Manhattan Mortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Richard A.Sherwood No. 1999-6189 Civil R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing 30.00 Poundage 13.49 Advertising 15.00 Posting Bills 15.00 Law Library .50 County 1.00 Mileage 21.08 Certified Mail 1.42 Levy 15.00 Postpone Sale 40.00 Surcharge 16.00 Law Journal 297.95 Patriot News 216.60 Share of Bills 5.08 $708.12 pd by Atty 6/8//00 So answers: Sworn and subscribed to before me This I Z64 day of 2000,A.D. 61 ?k -/ ' P o onotary R. Thomas Kline, Sheriff II Real Estate Deputy '1.50 Clz.7dWt. •I CHASE MANHATTAN MORTGAGE CORPORATION V8. RICHARD A. SHERWOOD : CUMBERLAND COUNTY t COURT OF COMMON PLEAS : CIVIL DIVISION s NO. 99-6189 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 416 WATER STREET, NEW CUMBERLAND, PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 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) PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET FINANCE AGENCY P.O. BOX 15530 HARRISBURG, PA 17105 S. 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 DOMESTIC RELATIONS OF CUMBERLAND COUNTY 416 WATER STREET NEW CUMBERLAND. PA 17070 13 NORTH HANOVER STREET 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. December 9, 1999 - DATE F K FEDER , ESQUIRE Attorney folr Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION s CUMBERLAND COUNTY t COURT OF COMMON PLEAS vs. s CIVIL DIVISION RICHARD A. SHERWOOD NO. 99-6189 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY December 9, 1999 TO: RICHARD A. SHERWOOD 416 WATER STREET NEW CUMBERLAND, PA 17070 "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, 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 416 WATER STREET, NEW CUMBERLAND, PA 17070, is scheduled to be sold at the Sheriff's Sale on MARCH 1. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $70,686.13 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actions 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. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The 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 filing of the proposed schedule. 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Water Street at the center of the center wall between houses Nos. 414 and 416 Water Street, New Cumberland, Pennsylvania; thence in a Westerly direction along the Southerly line of Water Street, thirty seven and one-half (37-1/2) feet, more or less, to Lot No. 37 on the General Plan of New Cumberland; thence in a Southerly direction along said Lot No. 37, one hundred fifty (150) feet to Walnut Alley; thence in an Easterly direction along the line of Walnut Alley, thirty-seven and one-half (37-1/2) feet, more or less, to a point; thence on a line parallel to the dividing line between Lot Nos. 36 and 37 on said plan and through the center of the center wall between houses Nos. 414 and 416 Water Street, one hundred fifty (150) feet to the Southerly line of Water Street, the place of beginning. HAVING thereon erected one-half of a double frame dwelling house known as No. 416 Water Street, New Cumberland, Pennsylvania 17070. Tax Parcel!! 25-24-0813.052 TITLE TO SAID PREMISES IS VESTED IN Richard A. Sherwood, Singleman by Deed from Sherri L. Smith, Married Woman dated 9/5/95, recorded 9/7/95, in Deed Book 127, Page 1027. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO.99-6189 CIVIL W,-Tm COUNTY OF CUMBERLAND) CIVIL ACTION • LAW TO THE SHERIFF Of'C mberland COUNTY: To satisfy the debt, Interest and costs due Chase Manhattan Mortgage Corporation PLAINTIFF(S) from Richard A Sherwood 416 Wafer Strppt New nrnhprlnn1 Pa 1707n DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See attached description of property (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 defendant(s) or otherwise disposing thereof; (3) 11propertyof thedefendant(s) not levieduponan subjectlo attachment Is found in the possession of anyone other than a named garnishee, you are directed to notify hinvho r that he/she has been added as a garnishee and is enjoined as above stated. Amount Duel L.L. $0.50 from 12/6/99 to /O6 Per Diem - $T Interest $987 70 Due Prothy $1.00 Atty's Comm % _ Other Costs Any Paid 5109.16 Plaintiff Paid Date: December 13. 1999 REQUESTING PARTY: Name Frank Federman. EsQ. Address: Two Penn Center Plaze -Suite 900 Attorney for: Plnintiff Telephone: (2151 563-7000 Curtis R. Long Prothonotary, Civil Division by: ?z 6 !{1c CP. Deputy Supreme Court ID No. REAL ESTATE "Al un,c.".r,? 1r, 1191 the sheriff levied upon the defendants Interest in the real property situated Cumberland County, Pa., known and numbered as:VX Vi2L 'n&2 nnKand more 'ul; acscrib„d on Exhibit "A„ flied wit') this ?,vrit and by reference incorporated herein. Date: ?G? / /9ss BY, 142 m r V Y CR Un 0 VIVO Uva 0 O ? .li ? "1