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Home My WebLink About03-2873FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS 811 BRIAN DRIVE ENOLA, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERId CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the 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 Loan lD: 1179020265 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TV~ENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFYER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Lo~ID: 1179020265 Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS 811 BRIAN DRIVE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 03/15/2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1680, Page 614. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. Loan ID: 1179020265 The following amounts are due on the mortgage: Principal Balance Interest 02/01/2003 through 06/16/2003 (Per Diem $10.09) Attorney's Fees Cumulative Late Charges 03/15/2001 to 06/16/2003 Cost of Suit and Title Search Subtotal $53,579.74 1,372.24 1,250.00 54.36 $ 550.00 $ 56,806.34 Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $ 56,806.34 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sherift~s Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 56,806.34, together with interest from 06/16/2003 at the rote of $10.09 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDE AND PHE ' By: /s/Francis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIKE FRANCIS S. HALLINAN, ESQUIRE Attomeys for Plaintiff Lo~ID: 1179020265 A~L TP3~T CERTAIN u~i~ in the property known, named and i~entt~e~ in =he Declaration Plan, r~ferred to below as Wes=wood Village C¢,ndominium located in East Pe~s~ro To,ship, ~erl~ CO~=Y, Co~o~weal~h of Pe~sylv~ia, w~ ~s heretofore been ~C~ed Uo the pr~sions o~ =he ~c AcC oZ p~yl~la, Ac~ of July ~, 1963, ~. L. 196, ~ nne ~cor~d on J~ ~9, 197~, in ~sc. ~ 213, Page a~3, ~ Esc~lishing Westwc~ village ............ ,~ ~ a WesCwood ¥illage Cond~ium ~a~ed ~ly 21, 19=6, and recorded on July 26, 1.976, in Misc. Book 22~, Page ~4], ~ a ce~ain ~rd ~nb Co Declara=i~ ~aming ~d Es=~lishin~ Westwoo~ Village Con~o~i~ daced J~e 9, 19?8, ~ reco~e~ on ~e 19TB, ~ ~]isc. ~ok 236, Pa~e 225, ~d a certain Fou~h ~nC =o DeclaraCi~ ~eacing ~ EsC~lishing WesUwood Vtll~e Co~n~%~ ~ed J~e 13, 1978, in Misc. Book 236, Page 250, and a Coda o~ R~lacions o~ Wes=woo~ Villag~ Con~o~4n$~ J~ua~ 29, 19TS..~d r~c~r~ad o~ J~ i ~ ~n~= =o Code 19=6, ~ recorded on ~e 22, 1~76. in Mist. Book 222, pa~e 737, ~ Decl~:a=ioa PI~ o~ wesuwood Village Condo~ni~ J~ua~ ~9. 19~S, and record~ In J~ua~ 2~, 1~75, Pi~ Book ~a~e lS, ~ ~ed by a cer=a~ F~rs= ~zi¢~ to Pi~ o~ W~s~wood Village Cond~ium ~=ed ~uly 21, 1~76, ~ recor~ ¢,n ~ly 26, 1~6, in Pi~ Book 28, Pa~ 72, ~d ~ ~ a certain Se¢o~ ~n~= =o Decl~a=ion PI~ o~ Wes=w~ Village C¢~i~ ~t~ ~e 16. 1978, ~ recorded ~ J~e 23, 1~78. ~n ~1~ Bo~ 33, Page ~8. be~ aesi~a=ea oa Decl~a=i¢n PI~ of Wes~wo~ Village Con~i~ ~s ~i= No. -Suite 303, LS.~ in **~1o~ 92, Buil~n~ 91, ~o~ as ~11 Drive, Suite 302, B~ola, C~erl~_ County, PA, .as more fully described in such Declaration Plan ~_~ Declarau~on Creating and Establishi~g Wescwood Village Condominium, as ~he name a~ears of record as set forth above, including any amendments t~ereto, TO~XrdER wich a proportionate ~ndivided interest in ~he Elements as defined in such Declare=ions of One and Fifty-Four Thousandths Percent (1. 054%) , URDBR AND SUBJECT =o restrictions of record. THE GRAxr~B, by accsp=ance o~ t~s deed, for ~ on behalf of the Grantee and ~ran=ees' ~eirs, Person~l Hepresen=a=ives, Successors and Assig~s, cavenants ~ a~rees =o any ~ ~es ~or =he ~in~en~ce of, repairs =o, repla¢e~n= of ~d ~ense~ in co~c=ion wl~ ~i~ ~o ~ ~ =he C~cil in acco~ce with ~e ~i~ ~roper~y ~= of P~nsyI~a, U~U conveyed b7 U~s Deed shall be a~cs so assessed ~d =ha=, except insof~ as Sec=ions 705 a~ 706 of sai~ ~i= ~r~er~y Acu ~y relieve a ~se~= Unit 0~er o~ li~ili=y for prior ~ with and bi~ the l~d or Unit berry convey~ ~d all owners ~hereof. B~IN~ THE SANE PRaCtISES which Stephen F. Wa~er, single ~a~, by Deed daCed July 29, 19~9 a~ recorded Au~st 4, 1999 in =he O~ice of =he Hecorder of Deeds in and for Cumberland Counuy, Pennsylvania, in Dee~ Book 20S, Pa~e 252, ~r~nted and conveyed unEo Vanessa R. Eisnig, single woman. BEING KNOWNAS: 8~! BRIAN DRIVE. VERIFICATION Carol Berry hereby states that he/she is Assistant Vice-President of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Carol Berry Assistant Vice-President o :)= ..~ o:: ,~i SHERIFF'S RETURN OF SERVICE CUMBERLAND COUNTY Plaintiff(s) CHASE MANHATTAN MORTGAGE CORPORATION NLrMBER 03-2873 C.T, SHERIFF'S NUMBER Defendant(s) DENISE MELACHRINOS COST DISTRICT MILEAGE Serve At 2708 WARREN WAY MECHANICSBURG, PA 17050 Special Instructions _ Summons ~ Complaint __ Other TYPE OF ACTION Mortgage Foreclosure TO BE COMPLETED BY SHERIFF Served and made known to · Defendant, on the __ day of ,20_._, at o'clock, _.m., at , County of , Commonwealth of Pennsylvania, in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is Adult in charge of Defendant'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 office or usual place ofbnsiness. and officer of said Defendant company. Other: On the SHERIFF By: , Deputy Sheriff day of ,20__, at_ o'clock, _.m., Defendant not found because: _ Moved _ Unknown _ No Answer _Vacant Other SHERIFF By: , Deputy Sheriff DEPUTIZED SERVICE Now, this day of ,20 __, I, Sheriff of__ County, Pennsylvania do hereby deputize the Sheriff of County to serve this Complaint and nmke return thereof and according to law. SHERIFF By: , Deputy Sheriff. ATTORNEY FOR PLAINTIFF: Name Frank Federman, Esqtdre Id. No. 12248 Address One Penn Center Plaza Philadelphia, PA 19103 Suite 1400 TO BE COMPLETED BY PROTHONOTARY ATTEST Pro Prothy Date FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. i[2248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. DENISE MELACHRINOS Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No. 03-2873 C.T, PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: July 9, 2003 FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff /jrh, Svc Dept. SHERIFFIS RETURN CASE NO: 2003-02873 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS MELACHRINOS DENISE AKA DENISE - REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MELACHRINOS DENISE AKA DENISE ODETTE MELACHRINOS DEFENDANT , at 1955:00 at 811 BRIAN DRIVE ENOLA, PA 17025 DENISE MELACHRINOS a true and attested copy of HOURS, on the 29th day of July #302 COMPLAINT - the 2003 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 20 Affidavit Surcharge 10 48 00 70 00 00 00 70 Sworn and Subscribed to before me this ~ day of honotar~ ' So Answers: R. Thomas Kline 09/24/2003 {~.(..Deputy Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 ¢215} 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaint'iff, DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 3-2873 CML TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS, 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 Compl~fmt Interest from 6/17/03 to 10/8/03 TOTAL $56,806.34 $1,150.26 $57,956.60 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ IF51 ,,~E..~ {t~,~.t..t,.~_a "~ PRO PROTHY TEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL1NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?I'~) 56%7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. DENISE MELACHRINOS A/Y-dA DENISE ODETTE MELACHRINOS Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-2873 CML TERM TO: DENISE MELACI-IR/NOS A/K/A DEN/SE ODE'I'I'E MELACHRINOS 2708 WARREN WAY : MECHANICSBURG, PA 17050 DATE OF NOTICE: SEPTEMRER 2~;. 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?15) q63-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. DENISE MELACHRrNOS A/K/A DENISE ODETTE MELACHRiNOS Defendants : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-2873 CIVIL TERM TO: DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINO~ ~ 811 BRIAN DRIVE ENOLA, PA 17025 DATE OF NOTICE: SEPTEMBER 2~. 21103 THIS FIRM IS A DEBT COLLECTOR AI-fI~MPTrNG TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.I~ YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - REGULAR C~SE NO: 2003-02873 P COMMONWEALTH OF PENNSYLVAiWIA: COUNTY OF CUMBERLAND CHASE MAN-HATTAiq MORTGAGE CORP VS MELACHRINOS DENISE AKA DENISE CPL. MICHAEL BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon MELACHRINOS DENISE AKA DENISE ODETTE MELACHRINOS Sheriff or Deputy Sheriff of who being duly sworn according to law, on the 29th day of July #302 by handing to DEFEN-D~%NT , at 1955:00 HOURS, at 811 BRIAN DRIVE ENOLA, PA 17025 DENISE MELACHRINOS a true and attested copy of COMPLAINT - the , 2003 MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 20.70 Affidavit .00 Surcharge 10.00 .00 48.70 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 09/24/2003 /~ IDeputy Sheriff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215} 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE Plaintiff, DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 3-2873 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS is over 18 years of age and resides at, 2708 WARREN WAY, MECHANICSBURG, PA 17050. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center OCT-08-2003 07:33:40 Military. Status Report Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Infon'nation provided, as to all branches of the Military. Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington. VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility [br military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to sscra.helpdesk(~osd.pentagon, mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owa/sscra.prc_Select 10/8/2003 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, DENISE MELACHRINOS A/ICJA DENISE ODETTE MELACHRINOS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 3-2873 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS Defendant(s). No. 3-2873 CIVIL TERM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 10/8/03 to MARCH 3, 2004 (per diem -$9.53) TOTAL $57,956.60 $1,400.91 and Costs $59,357.51 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 ~ 1814 Attorney for Plaintiff Note: Please attach description of property.No. O0 ALL THAT CERTAIN .nit in the property known, named and identified in u'me Declaration P-lan, ~ In below as 'Westwo~ Village Condominium located in East Peonsboro Towushlp, Combefland Cou~y. Commonwca]lh of Pennsylvania, wht¢~ bas heretofixe bee~t s~ to rite provi~lor~ of:be Unit Property Act of PcnasyE, anla, Art of July 3, 19~3, P,L. I96, by thc recording in thc Office of the Recorder o f Deeds of Cumberla~ld County. Peuusylva~tla, of a Declaration C~eating aud F~ablish[ng West~,ood Village Condominium, dated January 29, 1975, ami tecouted on o'rauna~, 29, 1975, ia Miscellaneous Book 2,13, Page 283,, and auaended by c~i'l:ain First Ametulencnt to Declatatiou Cr~.-'ating aaa Establishing Westwood Villag~ Cou~mioium dau:d May 28, 1976, and ~e~'o~ed on Ju. ae 22, 1976, in lviiscellaneona Book 223, Page 729, and n oet~ain Se~oud Ame~lu~eum to Dee{aralion Creating and E,s~ablishiag Wes:wood Village Coadomlniu{a dated July 21, 1976, -and re~m:dad ne July Miscellaneous ~ook 29.3, Page 343, and a ctr~ain ThLrd Ar~elxlmetlt to Dec. latafion 'EanablishinE Westwood Viilase Condomiuimu dated June Mtscellaneous Book 216~ Page 225, and a certain I~uui-th 3dneucimeut :o Oeclaratio~ Creating 'and F..mlabli~ltLng W~wood Village Coudominium dated luue 13. 1978, ia Misc~llaneou,~ Book 236. Page 2.50, and a Code of Regulations u[ Wu~twood Viilnge Condomiaium dated .1anuary 29, 190'5, and l~corded on llanuary 29, 1975. in Miscellaneous Book 213, Pa&e 328, and anleaded by a certain First Amendment [o Code of Regulalious or' Weatwond Vii}age Coadomiaium da~cl May 28 1976, and ~cord-~'d June 22, 1976, Lu MiiceHa~l¢ous Book ~, Page 737, and Declaration Plan of W~lwood Village Cor, domi.inm dated January 29. 19?~. md reoolded ia .1~laUary 29. 1975. Plan Book 26, Page 15. and amended by a certain First Ameudmeut lo Declaratiou Plan of Westwood Vilia~ Coodominiam dated July 21 1976, a taco:dad on July 26, 1976, in Pla Book 28, Page 72, ad amended by a ceriaiu Second .aauendmr..nt In Declaration Plan of Westwood Village Condomiuium dated June 16, 1978, and rccord~l ntt June 23, 1978, itl Pla~ Book 33, Page 28, ~ing cle~{~mated on said Declara~iol~ Plan of Wcstwood VLllage Condominium as U~it No. $l 1, Suite :}02, L.5.GA in **Block #2, Building #1, known ~ 811 Btinn Drive, Suite 302, Enola, Cumberland County, PA, as more fuliy cksarilc~d ia such Declaration Plau an~ Declaration Creating and Establishing Westwood Village Coudorai_nlom, as ~he name appears of ~cord aa s~t forih above, i~ctnding any amuod.,neu~s tiWrrto. TOGETHER wi~ a proponiunate u~ivid~l tuterest in the Comanori £1erneuts as deftnecl in such Declarauons of One and g~tty Four Thousandths Perc~m TITLE TO ;SY,-1D P~EMISES IS VESTED 1N Denise Odette Melacbriaos, mar~,ea woman by Deed ~ Vanessa R. Stiason, forn'l~rly {mO,va as Valmessa R. 1~iitsig, ulso knows as Valle. ssa R. Eis~g, married woman da~,~ 3/1f/2001 amd recorded on 3/1912001 in D~ed Book 240, Page 1132. Tax Parcel WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-2873 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From DENISE MELACHRINOS MI{dA DENISE ODETTE MELACHRINOS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also cVtrected to attach the property of the de fendant(s) not levied upun in the possessiun of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an a~tachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possessiun of anyone other than a named garrfishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $57,956.60 L.L. $.50 Interest FROM 10/8/03 TO 3/3/04 (PER DIEM - $9.53) - $1,400.91 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $130.70 Other Costs Plaintiff Paid Date: OCTOBER 10, 2003 (Seal) CURTIS R. LONG Prothuno~t~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, DENISE MELACHRINOS A/I(JA DENISE ODETTE MELACHRINOS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DMSION NO. 3-2873 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,811 BRIAN DRIVE, ENOLA, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DENISE MELACHRINOS A/K/A DENISE 2708 WARREN WAY ODETTE MELACHRINOS MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgmeut is a record lien on the real property to be sold: Name EAST PENNSBORO TOWNSHIP Last Known Address (if address cannot be reasonably ascertained, please indicate) 98 S. ENOLA DRIVE ENOLA, PA 17025 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 811 BRIAN DRIVE ENOLA, PA 17025 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. October 9, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, DENISE MELACHRINOS A/K/A DENISE ODETTE MELACHRINOS Defendant(s). CUMBERLAND COUNTY No. 3-2873 CIVIL TERM October 9, 2003 TO: DENISE MELACHRINOS A/IqA DENISE ODETTE MELACHRINOS 2708 WARREN WAY MECHANICSBURG, PA 17050 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 811 BRIAN DRIVE, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on MARCH 3, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $57,956.60 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL TH^T CER'fA~N ~tnh in ~e property knowa, Ixan~cl a~td k:lel~iil~ecl in the l:)eclara~on P'l~n, referred to below as W~g~v oed Village Comiom!nh]m located in ~ ~ro To~h~. Cum~ C~n~, Commonw~ of Penn.Ivan., which ~ ~re b~ ~tt~ to ~ 'UnR Pro~ Act of ~y~ia, A~ o~ J~ly 3, 1~3, P,L. I9~, ~ the ~o~ ~ ~e O~ of W~ V~I~ Co~mt~i~, ~ J~ ~, 1975, ~ r~o~ ~ ~a~ M~iI~ ~ 213, P~e 283, a~ ~nd~ by c~ F~t A~dm~t to ~a~n ~ E~bl~i~ W~stwood V~e Co~m~m d~ May 28, t~6, ~ ~ ~ J~ ~, t976, in Mi~ellan~s ~k 223, P~e ~9, ~ n ~a~ S~o~ A~enl to ~c~on Cr~ ~bUshi~ Wes~o~ Vill~e ~um ~ I~y 21, 1~6, a~ r~ on M~II~ ~k ~, ~ge 343, ~ a ~a ~ Am~mem to ~a~on ~abli~ We~w~ V~age C~ ~ June 9, ~978 ~ r~ on Mgc~lan~ ~k 236, P~e 225, a~ a ~in ~ ~em to ~lar~gon ~abiis~g W~tw~ Village Co~om~ ~d Ju~ 13, 1~8, in Misc~llane~s ~k 236. Page ~, ~ a ~ of ~gu~ati~ of W~tw~ Vil~ge C~domini~ d~ Ja~ 29, ~ ~ ]~ 29, 1975, m Mh~ous ~ok 213, P~e 328, ~ ~ by A~m m ~e of ~l~m of We~wo~ Vtl~e Condomlni~ da~ ~y 28 1976, ~o~ Jn~ 22, 1976, ~ Mi~ella~ ~o~ ~2, Page ~7, ~d ~cl~a~ion ~m of Vill~ Co--injure ~ted Jan~ 29, 1~, ~ ~ed ~ J~ 29, 1975. ~ 15, ~ ~ by a ~Rain F~ ~ent ~ ~lam~n PI~ of Westwo~ V~ Co~ ~ July 21 1976, ~ ~ ~ July 26, 1~6, in PI~ ~ 28, P~e 72, ~d ~ by a e~a~ ~o~ ~m~ m D~l~n Plan ot Weglw~ Vi~ge Con~i~ ~ Jun~ 16, 1~8, ~ ~r~ on Ju~ 2'3, 1~8, in ~an B~k ~3, Pgge 28, ~ d~i~ on ~aid Hun of W~tw~ Villa~ Cond~inium as U~it No. 81 l, Suite ~02, ~.GA ~ **BIo~ ~, Boild~ng ~1, k~ ~ 811 Bti~ ~ive, Suite 302, Eno~, ~r~ ~, PA, m mo~ ~1y ~i~ m ~he ~e ~ars of~ as gt four T~ ~ a p~g u~ivi~ ~t in ~e C~ EIemeng as de~ ~ ~ch irlLE TO SA.ID PREMISF.3 15 VEST~ IN Denise Odet~ Melachri~.os, married wcnnan by Deed trorn Vanessa R. S~:inson, formerly known as Vanesm R. Einsig, also known a~ Van~r,e,a R. Etsnig, married ~v-on~a dated 3115/2001 and t~orded on 3/19/2001 in l~ed Book 240, Page 1132. Tax Par~e] ~9-12-2992-001A AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY No. GD 3-2873 CIVIL TERM DEFENDANT (S) DENISE MELACHRINOS, A/K/A DENISE ODETTE MACHRINOS Type of Action - Notice of Sheriff's Sale SERVE AT 811 BRIAN DRIVE APT. 302 ENOLA, PA 17025 Sale Date: MARCH 3, 2004 SERVED Served and made known to ~'~,ot.<¢~, [I~IO.F &t"ttoo.~I , Defendant, on the 07 tWC- day of 067' ,200_~,at ~ ;1o ,o'clock~.m.,at ~11 I~f'16_,,~ ~)f'l flf'"f'~.,?tT~'21e, t~°lG-! p~ 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 Defendant(s)'s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age ~ Height.~q' Weighto~'O Race O~ Sex f~ Other I, f']'l fl~} ,'~ ~"f~' '7'7'a c, , a competent adult, being duly sworn according to law, depose and state that I personally posted a hue and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this o~ r~ day of o'&. J5 ,200_J NOT SERVED JO~ELYN ,qUFFO Notar~ Public St~t~e of New Jersey remission Expires Mar 21,2007 ***ATTEMPT SERVICE NLT THREE (3) TIMES*** On the day of ,200__, at FOUND because: o'clock __.m., Defendant NOT Moved Unknown No Answer Vacant Other: 1st attempt ,2nd attempt ,3rd attempt Date & Time Date & Time Date & Time Sworn to and subscribed before me this day of ,200 _. Notary: By: Loan # 1179020265 Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station- Suite 1400 Philadelphia, PA 19103 (215) 563-7000 IN TIlE cOURT OF cOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE MANHATTAN MORTGAGE CORPORATION VS. DENISE MELACHR1NOS, A/K/A DENISE ODETTE MACHRINOS ) CIVIL ACTION ) ) CIVIL DIVISION ) NO. 3-2873 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CHASE MANHATTAN. MORTGAGE CORPORATION hereby verify that on October 10t 2003 tree and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE:~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Chase Manhattan Mortgage Corporation VS Denise Melachrinos aJk/a Denise Odette Melactuinos In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-2873 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Poundage 21.38 Advertising 15.00 Posting Handbills l 5.00 Levy 15.00 Sm'charge 20.00 Service 20.70 Law Journal 497.90 Patriot News 424.81 Law Library .50 Prothonotary 1.00 Share of Bills 29.32 $1090.61 paid by attorney 03/01/04 Sworn and subscribed to before me This .j,~' day of "7]4r. zcz./,~ 2004, ^.D. Prothonotary So Answers: .ft. Thomas Kline, Sheriff Real Estfi~ Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Coun~ous Book "M", Volume 14, Page 317. PUBLICATION COPY Sworn to and'subscribed b~for~'~his 23r~'"'d ',~of'~F'"'~ 2004 A.D. City Of Hardsburg, Dauphin ' ~. My Commission Expires June 6'C~/2006~' T- ~ '~TA'R~Y ~UBLIC Member, Pennsy'r,,ania~OfNo~w~es My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 424.81 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. ~, ted a~A~ ?3?. M~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L1784 STATE OF PENNSYLVANIA : _. COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE aALE NO. I0 Writ No. 2003-2873 Civil Chase Manhattan Mortgage Corporation VS. Denise Melachrlnos, a/k/a Denise Odette Melachrinos Atty,: Frank Federman ALL THAT CERTAIN unit in the property, known, named and iden tiffed in the Declaration Plan. re ferred to below as Westwood Vil- lage Condolrdnlum located in East Pennsboro Township. Cumberland County. Commonwealth of Pennsyl- vania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania. Act of July 3. 1963. P.L. 196. by the recording in the Office of the Recorder of Deeds of Cumberland County. Pennsylvania, of a Decla ration Creating and Establishing Westwood Village Condominium. dated January 29. 1975. and re- corded on January 29. 1975. in Miscellaneous Book 213. Page 283. and amended by certain First Amend- ment to Declaration Creating and Es- tablishing Westwo~d Village Condo- minium dated May 28, 1976. and recorded on June 22, 1976. in Mis- cellaxleous Book 223, Page 729. and a certain Second Amendment to DecLaration Creating and Establish lng Westwood Village Condominium dated July 21. 1976. and recorded on July 26. 1976 in Miscellaneous Book 223. Page 343. and a certain Third Amendment to Declaration Creating and Establishing Westwood Village Condomix~/um dated June 9. 1978 and recorded on June 23. 1978. in Miscellaneous Book 236, Page 225. and a certain Fourth Amendment to Declaration Creating ~and ~Esta?i~hing ,W~s ,t~o?d Vll _l~_e ~S~ ~afie~Coyne,~ditor SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004 LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland Cou~ My Commission Expires March 5, 2005 Act of Jniy 3, 1963, P.L. 196. by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Decla- ration Creating and Establishing Westwood Village Condominium. dated January 29, 1975. and re corded on January 29. 1975, in Miscellaneous Book 213, Page 283, and amended by cer(ain First Amend- ment to Declaration Creating and Es- tablishing Westwood Village Condo- minium dated May 28. 1976. and recorded on June 22. 1976. in Mis- cellaneous Book 223. Page 729, and a certain Second Amendment to Declaration Creating and Establish lng Westwood Village Condomlnitm~ dated July 21. 1976. auld recorded on July 26. 1976 in Miscellaneous Book 223. Pnge 343. and a certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9. 1978 and recorded on June 23. 1978. in Miscellaneous Book 236, Page 225. and a certain Fourth Amendment lo Declaraiion Creating and Establishing Westwood Village Condominium dated June 13. 1978. in Miscellaneous Book 236. Page 250. and a Code of Regula- tions of Westwoed Village Condo- minium dated January 29. 1975, and recorded on January 29, 1975, in Miscellaneous Book 213. Page 328. and alUended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28. 1976, and recorded June 22, 1976, in Miscellaneous Book 222. Page 737, and Declara- tion Plan of Westwood Village Con- domlnium dated January 29, 1975, and recorded in January 29, 1975. Plan Book 26, Page 15, and amend- ed by a certain First/Mnendment to Declaration Plan of Westwood Vil- lage Condoininiurn dated July 21, 1976, and recorded on July 26, 1976, in Plan Book 28, Page 72. and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16. 1978. and recorded on June 2.3, 1978, in Plan Book 33, Page 28, being designated on said Declaration Plan of Westwood Vil- lage Condominium as Unit No. 811, Suite 302, L5.GA in **Block #2. Building #1, known as Sll Brian Drive, Suite 302. Eno]a, Cumberland County. PA, as inore fully described in such Declaration Plan and Dec- laration Creating and Establishing Westwood Village Condominium, as the name appears of record as set forth above, including any amend- ments thereto. TOGETHER with a proportion- ate undivided interest in the Com- mon Elements as defined in such Declarations of One and Fifty Four Thousandths Percent [I.054%]. TITLE TO SAID PRBMISES IS VESTED IN Denise Odette Melachrl nos, married won~an by Deed from Vanessa R. Stinson, formerly known as Vanessa R. Einsig. also known as Vanessa R. Eisnig, married woman dated 3/15/2001 auld recorded on 3/19/2001 in Deed Book 240, Page 1132. Tax Parcel #09-12-2992-001A. I My Commission ExpiresMarch 5, 2~5 ~