HomeMy WebLinkAbout03-41801N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CWIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
TO DEFENDANT
You are hereby notified to plead
to the ENCLOSED COMPLAINT WITHIN
TWENTY (20) DAYS FROM SERVICE HEREOF
AT~RNEY FOR PlaINTIFF
1 HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANTS IS:
12335 South 44t" Court
Alsip, IL 60803
ATTORNEY FOR PI~AINTIFF
NO.:
TYPE OF PLEADING:
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF THE
REAL ESTATE AFFECTED BY THIS LIEN IS
111 E. Columbia Road
East Pcnnsboro, PA
(CITY, [~ORO,~ (WAP,~)
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.:
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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. [F YOU SHOULD NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files
this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Manhattan Mortgage Corporation, which has its principal
place of business at 3415 Vision Drive, Columbus, Ohio 43219.
2. The Defendants, Jennifer L. Drabek and Timothy D. Drabek, are individuals
whose last known address is 12335 South 44th Court, Alsip, Illinois 60803.
3. On or about November 21, 2001, Defendants executed a Note in favor of Plaintiff
in the original principal amount of $73,915.00. A true and correct copy of said Note is marked
Exhibit "A", attached hereto and made a part hereof.
4. On or about November 21, 2001, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $73,915.00 on the premises hereinafter described, said Mortgage being recorded in the Office of
the Recorder of Deeds of Cumberland County on November 26, 2001 in Mortgage Book Volume
1739, Page 4807. A true and correct copy of said Mortgage containing a description of the premises
subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof.
5. Defendants are the record and real owners of the aforesaid mortgaged premises.
6. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are
due for the April 1, 2003 payment.
7. Plaintiff was not required to send Defendants written notice pursuant to 35 P.S.
§ 1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior
to the commencement of this action for the reason that the aforesaid Mortgage is insured by the
Federal Housing Administration under Title II of the National Housing Act (12U.S.C.
§§1707-1715z-18) [35 P.S. §1680.401C(a) (3)].
8. Plaintiff was not required to send Defendants written notice of Plaintiffs intention
to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of
this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S.
§101 and Defendants are not "residential mortgage debtors" as defined in 41 P.S. §101.
9. The amount due and owing Plaintiff by Defendants is as follows:
Principal
Interest to 8/8/03
Late Charges to 8/8/03
Corporate Advances
Attorney's fees
Title Search, Foreclosure and
Execution Costs
$72,921.89
$ 2,145.33
$ 98.96
$ 86.72
$ 1,250.00
$ 2,500.00
TOTAL $79,002.90
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the mount due
of $79,002.90 with interest thereon at the rate of $13.49 per diem fi.om August 8, 2003, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises.
BY:
GRENEN & BIRSIC, P.C.
Kris(in~M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WiLL
BE USED FOR THATPURPOSE.
Exhibit "A"
19902815
1179028154
NOTE
111 H COLUMBIA ED, ENOI~A, PA 17025
November 21 , 2001
CHASE MANHATTAN MORTGAGE CORPORATION
Seventy-Three Thousand, Nine Hundred Fifteen and 00/100
Dollars (U.S. $ 7 3,915.0 0 ), plus interest, to thc order of Le~der. l~ter~st will ~e cha~ged on
4. ~A~R OF PA~N~
(A)
(C) A~un(
T~[f~O~D~
Exhibit "B"
Record a.d Retur~ to: ORIGINAL
CN3%SE MANHATTAN MORTGAGE CORPORATION
1500 N 19TH STREET
ATTENTION: FINAL CERTIFICATIONS
State or Pmnsylvanin MORTGAGE ~J f~
Seventy-Three Thousand, Nine Hundred Fifteen and 00/100
CUMBERLAND Count, Pennsylvania:
See Attached Legal Description
BI(I 739PGq807
UNIFORM COVENANTS:
~,~ ~,~,~,~ ~,,~: o~ ~1( I 7 3 9 Pr; L~ 8 0 8
........ ., 739P(~809
COMMONWEALTH OF PENNSYL,VANIA
COUNTY OF CUMBERLAND
On t~ 2~ 4a¥ of November, 2001
Exhibit A
ALL that certain tract or parcel of land and premises, situate, lying and being in the
Township of East Pennsboro in the County of Cumberland and Commonwealth of
Pennsylvania, bounded and described In accoednnce with a survey and plan thereof
made by John Bruce Shand, Professional Engineer, dated September 19, 1968, ns
follows:
BEGINNING at a point on the Northern line of Columbia Road opposite the center
of the partition wall separating house Nos. 109 and 111 Columbia Road; said point
being 18 feet North of a point on -+he curb line of Columbia Road, which last
mentioned point is 112.25 feet West of the Western end of a 10 fe~t radius curve
which connects the North curb line of Columbia Road and the West curb line of
Beaver Avenue; thence in a Northerly direction, through the center of the above
mentioned partition wall, a distance of 154.3 feet to a point in line of land now or
late of the Enala Realty Company; thence along said land in a Westerly direction a
distance of 24.8 feet to a point at a corner of premises known as No. 113 Columbia
Road; thence in a Southerly direction along said premises a distance of 150.5 feet to
a point on the Northern Hue of Columbia Road; thence in an Easterly direction
along the Northern line of Columbia Road a distance of 25.4 feet m the point and
Place of BEGINNING.
HAVING THEREON ERECTED a two and one half story semi-detached frame
dwelling house, known and numbered as 111 Columbia Road, Enala, Fennsylvania.
bc recorded
County PA
mecoroer of'Deeds
B~I739PG~812
Verification
I-i~TM~ I. ~ , Assistant Secretary, and duly authorized representative of?laintiff,
deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom
falsification to author/ties that the facts set forth in the foregoing Complaint are tree and correct
to his information and belief.
Assistant Secretary
IN THE COURT OF COMMON PLEAS OF CUMBERLA)ff) COUNTY, PENNSYLVANIA
CIViL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
NO.: 03-4180
TYPE OF PLEADING:
Proof of Service
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
FiLED ON BEHALF OF PLAINTIFF:
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
NO.: 03-4180
Defendants.
PROOF OF SERVICE
Kristine M. Anthou, Attorney for Plaintiff, Chase M,~mhattan Mortgage Corporation,
being duly sworn according to law deposes and makes the following Affidavit regarding service
of Plaintiffs Complaint in this matter on Defendants, Jennifer L. Drabek and Timothy D. Drabek:
1. On August 27, 2003, Plaintiff mailed a copy of the Complaint in Mortgage
Foreclosure to Defendants, Jennifer L. Drabek and Timothy D. Drabek, at 12335 South 44~
Court, Alsip, IL 60803, by certified mail, return receipt requested.
2. On or about August 30, 2003, the signed certified mail receipts were returned
to Plaintiff, indicating that Defendants, Jennifer L. Drabek and Timothy D. Drabek were served
with the Complaint in Mortgage Foreclosure. True and correct copies of the signed receipts are
marked Exhibit "A", attached hereto and made a part hereof.
I verify that the facts contained in this Affidavit are tree and correct based upon my
personal knowledge, information, and belief.
BY:
GRENEN & BIRSIC, P.C.
Krist~Sh~M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS IJ~c DAY OF 0 ~/"3~/( ,2003.
Notary Public / ~1
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Rebecca G. B~azlna, Nota~ Public
City Of Pittsburgh, Allegheny County
My Commission Expires June 2, 2(107
Exhibit "A"
2,30
I.'75
3, 50
E
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
NO,: 03-4180
ISSUE NUMBER:
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
I hereby certify that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
the last known address of
Defendants is:
12335 South 44th Court
Alsip, IL 60803
FILED ON BEHALF OF PLAINTIFF:
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D.#77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
GRENEN & BIRSIC, P.C.
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DMSION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 03-4180
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
TO: PROTHONOTARY
SIR:
PRAECIPE FOR DEFAULT JUDGMENT
against Defendants, Jennifer L. Drabek and Timothy D. Drabek, in the amount of $80,503.07, which
is itemized as follows:
Principal
Interest to 9/8/03
Late Charges to 9/8/03
Escrow Deficiency to 9/8/03
Corporate Advances
Attorneys' fees
Title Search, Foreclosure and
Execution Costs
$72,921.89
$ 3,033.13
$ 148.44
$ 589.89
$ 59.72
$ 1250.00
$ 2.500.00
TOTAL $80,503.07
with interest on the principal sum at the rate of $13.49 and additional late charges, additional
reasonable and actuaily incurred attorneys' fees, plus costs (including increases in escrow deficiency)
and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
BY: d~ 6~( ~ ci,6 cSZ~
Kristlne M. Anthou, Esqmre
Attorneys for Plaintiff
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Al .r .FGHENY
)
) SS:
)
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kfistine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants are not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment
was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
Sworn to and subscribed before me
this [~4~..dayof 0~0[~t~A-
Notary Public c c,
,2003.
COMMONWEALTH Of PENNSYLVANIA
I Notarial Seal
RebeCCa G. Blazina, Nolaly public
City Of pittsburgh, AllegheOy
L MyC~nmi~onExpiresJune2 007
IN THE COURT OF CO~vION PLEAS OF CUMBERLAND
PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE )
CORPORATION, )
)
)
Plaintiff, )
)
)
JENNIFER L. DRABEK and )
TIMOTHY D. DRABEK, )
)
)
Defendants. )
NO.: 034180
TO: Jennifer L. Drabek
12335 South 44~ Court
Alsip, IL 60803
DATE OF NOTICE: September 30, 2003
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 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
By:
GRENEN & BIRSIC, P.C.
Attome~yk for Pla~intiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF C~[~MON PLEAS OF CUMBERLAND
PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE )
CORPORATION, ) NO.: 03-4180
)
)
Plaintiff, )
)
)
JENNIFER L. DRABEK and )
TIMOTHY D. DRABEK, )
)
)
Defendants. )
TO:
Timothy D. Drabek
12335 South 44t~ Court
Alsip, IL 60803
DATE OF NOTICE: September 30, 2003
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 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
By:
GRENEN & BIRSIC, P.C.
At/oYneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff, NO.: 03-4180
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
TO:
NOTICE OF ORDER, DECREE OR JUDGMENT
Jennifer L. Drabek
12335 South 44t~ Court
Alsip, IL 60803
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $80,503.07
with interest on the principal sum at the rate of $13.49 per diem and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
EN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CWIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff, NO.: 03-4180
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
TO:
NOTICE OF ORDER. DECREE OR JUDGMENT
Timothy d. Drabek
12335 South 44~' Court
Alsip, IL 60803
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $80,503.07
with interest on the principal sum at the rate of $13.49 per diem and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAEClPE FOR WRIT OF EXECUTION
Caption: :
Chase Manhattan Mortgage :
Corporation
VS.
Jennifer L. Drabek and
Timothy D. Drabek
TO THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
(xx) Other
File No. 03-4180
Amount Due $80,503.07
Interest $ 2,424.03
Atty's Comm
Costs
(from 9/8/03 to sale)
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
issue writ of execution in the above matter to the Sheriff of CUMBERLAND
for debt, interest and costs, upo~ the foil,owing descril~ed proper~¥ of the defendant(s)
County
111E. Columbia Road, Enola, PA 17025
(see attached legal description)
PR~ClPE FOR ATTACHMENT ExEcuTION
Issue writ of attachment tO the Sheriff of County, for debt, interest and
costs, as above, directing attachment'against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the descrilMion; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
Date
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
/.A// /~lA.5 Signature:
Print Name:
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
Kris~ne M. Anthou
1 Gateway Center, 9 West
Pittsburgh, PA 15222
Plaintiff
(412) 281-7650
77991
(over)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 03-4180
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
LONG FORM DESCRIPTION
ALL that certain tract or parcel of land and premises, situate, lying and being in the Township o fEast
Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, bounded and described in
accordance with a survey and plan thereof made by John Bruce Shand, Professional Engineer, dated
September 19, 1968, as follows:
BEGINNING at a point on the Northern line of Columbia Road opposite the center of the partition
wall separating houses No. 109 and 111 Columbia Road; said point being 18 feet North ora point on the curb
line of Columbia Road, which last mentioned point is 112.25 feet West of the Western end ora 10 feet radius
curve which connects the North curb line of Columbia Road and the West curb line of Beaver Avenue;
thence in a Northerly direction, through the center of the above mentioned partition wall, a distance of 154.3
feet to a point in line of land now or late of the Enola Realty Company; thence along said land in a Westerly
direction a distance of 24.8 feet to a point at a comer of premises known as No. 113 Columbia Road; thence
in a Southerly direction along said premises a distance of 150.5 feet to a point on the Northern line of
Columbia Road; thence in an Easterly direction along the Northern line of Columbia Road a distance of 25.4
feet to the point and place of beginning.
HAVING thereon erected a two and one~half story semi-detached frame dwelling house, known and
numbered as 111 Columbia Road, Enola, Pennsylvania.
BEING the same premises which Rodney W. Hollabaugh, by Deed dated November 21,2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on November 26, 2001, at Deed
Book Volume 249, Page 1628, granted and conveyed unto Jennifer L. Drabek and Timothy D. Drabek.
By:
GRENEN & BIRSIC, P.C.
Kx( is~,M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Tax Map 09-13-1002 / Parcel 273
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 03-4180 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE
CORPORATION, Plaintiff(s)
From JENNIFER L. DRABEK AND TIMOTHY D. DRABEK
(I) You are directed to levy upon the property of the defendant (s)and to selI SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify lfirn/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $80,503.07 L.L. $.50
Interest $2,424.03 (FROM 9/8/03 TO SALE)
Atty's Comm % Due Prothy $1.00
Atty Paid $82.00 Other Costs
Plaintiff Paid
Date: DECEMBER 3, 2003
(Seal)
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: 1 GATEWAY CENTER, 9 WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
CURTIS R. LONG
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 03-4180
vs.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101, ET. SEO.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned author/W, a Notary Public in and for the said County and
Commonwealth, personally appeared Kr/stine M. Anthou, attorney for the Plaintiff, who being duly sworn
according to law deposes and says that Plaintiff was not required to send Defendants written notice pursuant
to 35 P.S. §1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 ~ Act 91 of 1983) prior
to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal
Housing Administration under Title II of the National Housing Act (12 U.S.C. §§ 1701-1715z-18) [35 P.S.
§ 1680.401C(a)(3)]. Additionally, Plaintiffwas not required to send Defendant written notice of Plaintiffs
intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement
of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101
and Defendants are not "residential mortgage debtors" as defined in 41 P,S. §101.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS/54- DAY OF ~)~ C ~t'}}~.~6 ( , 2003.
Notary Public
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DWISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 03-4180
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
AFFIDAVIT OF LAST KNOWN ADDRESS
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that the owners of the property located at 111 East
Columbia Road, Enola, Pennsylvania 17025 are Defendants, Jennifer L. Drabek and Timothy D.
Drabek, th
who reside at 12335 South 44 Court, Alsip, Illinois 60803, to the best of her information,
knowledge and belief.
SWORN TO AND SUBSCR/BED BEFORE
ME THIS j5¢ DAY OF ~[~['ii)J~ {
Notary Public
,2003.
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DW1SION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 03-4180
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Manhattan Mortgage Corporation, Plaintiffin the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information was of record concerning
the real property of Jennifer L. Drabek and Timothy D. Drabek located at 111 E. Columbia Road,
Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED ILEAL ESTATE SITUATED IN E. PENNSBORO TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREONA DWELLING BEING
KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA 17025. DBV 249, PAGE 1628,
AND TAX MAP 09-13-1002 / PARCEL 273.
1. The name and address of the owners or reputed owners:
Jennifer L. Drabek
Timothy D. Drabek
12335 South 44th Court
Alsip, 1L 60803
2. The name and address of the defendants in the judgment:
Jennifer L. Drabek 12335 South 44th Court
Timothy D. Drabek Alsip, IL 60803
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Manhattan Mortgage Corporation [PLAINTIFF]
4. The name and address of the last record holder of every mortgage of record:
Chase Manhattan Mortgage Corporation [PLAINTIFF]
5. The name and address of every other person who has any record lien on the property:
Cumberland County Domestic Relations
PA Dept. Of Revenue
Bureau of Individual Taxes
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 320
Carlisle, PA 17013
Inheritance Tax Division
Dept. 280601
Harrisburg, PA 17128-0601
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale: NONE
7. The name and address of every other person whom the plaintiffhas knowledge who has any
interest in the property which may be affected by the sale: NONE
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C,S.A. §4904 relating to unsworn falsification to authorities.
GRENEN & BIRSIC, P.C.
Attorney for Plaintiff
SWORN to and subscribed before
me this ]gP dayof 3[(~F}')/~ (
Notary Public ;?
,2003.
IN THE COURT OF GOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIl. DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
TO:
NO.: 03-4180
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
Jennifer L. Drabek
12335 South 442 Court
Alsip, IL 60803
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale at the
Curnberland County Courthouse
Commissioners Hearing Room, 2"~1 Floor
1 Courthouse Square
Carlisle, PA 17013
on Wednesday, March 3, 2004 at 10:00 A.M., the following described real estate, of which Jennifer
L. Drabek and Timothy D. Drabek are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN E. PENNSBORO
TWP., CLrMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA
17025. DBV 249, PAGE 1628, AND TAX MAP 09-13-1002 / PARCEL 273.
The said Writ of Execution has been issued on ajudgment in the mortgage foreclosure action of
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
Jennifer L. Drabek and Timothy D. Drabek,
Defendants,
at Execution Number 03-4180 in the amount of $82,927.10.
Claims against the property must be filed with the Sheriffbefore the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution,
Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriffno later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
This paper is a notice of the date and time of the sale of your property. It has been issued
because there is a judgment against you. It may cause your property to be held or taken to pay the
judgment. You may have legal rights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Court Administrator
4~ Floor, Cumberland County Courthouse
Carlisle, PA 17013
TELEPHONE: (717) 240-6200
You mayhave legal rights to prevent the Sheriffs Sale and the loss of your property, In order
to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or ob./ection,
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other
legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
Kris 't~ne M. Arftthou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 03-4180
V$,
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
LONG FORIVI DESCRIPTION
ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of East
Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, bounded and described in
accordance with a survey and plan thereof made by John Bruce Shand, Professional Engineer, dated
September 19, 1968, as follows:
BEGINNING at a point on the Northern line of Columbia Road opposite the center of the partition
wall separating houses No. 109 and 111 Columbia Road; said point being 18 feet North ora point on the curb
line of Columbia Road, which last mentioned point is 112.25 feet West of the Western end ofa 10 feet radius
curve which connects the North curb line of Columbia Road and the West curb line of Beaver Avenue;
thence in a Northerly direction, through the center of the above mentioned partition wall, a distance of 154.3
feet to a point in line of land now or late of the Enola Realty Company; thence along said land in a Westerly
direction a distance of 24.8 feet to a point at a corner of premises known as No. 113 Columbia Road; thence
in a Southerly direction along said premises a distance of 150.5 feet to a point on the Northern line of
Columbia Road; thence in an Easterly direction along the Northern line of Columbia Road a distance of 25.4
feet to the point and place of beginning.
HAVING thereon erected a two and one-half story semi-detached frame dwelling house, known and
numbered as 111 Columbia Road, Enola, Pennsylvania.
BEING the same premises which Rodney W. Hollabaugh, by Deed dated November 21,2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on November 26, 2001, at Deed
Book Volume 249, Page 1628, granted and conveyed unto Jennifer L. Drabek and Timothy D. Drabek,
By:
GRENEN & BIRSIC, P.C.
M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Tax Map 09o13-1002 / Parcel 273
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
CIVIL DIVISION
ISSUE NUMBER:
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
NO.: 03-4180
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(¢)(2)
PURSUANT' TO RULE 3129.1
LIENHOLDER AFFIDAVIT OF
SERVICE
CODE-
FILED ON BEHALF OF PLAINTIFF:
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
IQ'istine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
9 West
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: 6/9/04
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE CWIL DIVISION
CORPORATION,
Plaintiff, NO.: 03-4180
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Chase Manhattan Mortgage Corporation,
being duly sworn according to law, deposes and makes the following Affidavit regarding service
of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of
Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows:
1. By letters dated January 14, 2004, undersigned counsel served all persons (other
than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule
3129.1 with a notice of the sale of real property by ordinary mail[ at the respective addresses set
forth in the Affidavit Pursuant to Rule 3129.1. Tree and correct copies of said Affidavit Pursuant
to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked
Exhibit "A", attached hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are tree mad correct based upon my
personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
BY:
Kfistine M. Anjou, Esquire
Attomeys for Plaintiff
One Gateway Centex, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Sworn to and subscribed before
me this l~)~ktay of ~ , 20_.Q04.
No~)ry Public
COMMONWEALTH OF PENNSYLVANIA
Notadal Seal
Elizabeth M, pff~ano, N~ary Public
City Of Pittsburgt~, ,,Megheny County
My Commission Expires Jan, 6, 2008
Member, Pennsylvania Association Of Notaries
Exhibit "A"
· 1N TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 03-4180
VS.
JENN~ER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
AFFIDAVIT pURSUANT TO RULE 3],29.1
COMMONWEALTH OF pENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Manhattan Mortgage Corporation, Plaintiffin the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following infonmation was of record concerning
the real property of Jennifer L. Drabek and Timothy D. Drabek located at 111 E. Columbia Road,
Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN E. PENNSBORO TWP.,
cUMBERLAND cOUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA 17025. DBV 249, PAGE 1628,
AND TAX MAP 09-13o1002 / PARCEL 273.
1. The name and address of the owners or reputed owners:
Jennifer L. Drabek 12335 South 44th Col.u't
Timothy D. Drabek Alsip, IL 60803
2. The name and address of the defendants in the judgment:
Jennifer L. Drabek 12335 South 44th Court
Timothy D. Drabek Alsip, IL 60803
3. The name and last known address of every judgment creditor whose judgment is a record lien
~)n the leal property to be sold:
Chase Manhattan Mortgage Corporation [PLMNTITF]
4. The name and address of the last record holder of every mortgage of record: Chase Manhattan Mortgage Corporation [PLAINTIFF]
5. The name and address of every other person who has any record lien on the property:
Cumberland County Domestic Relations P.O. Box 320
Carlisle, PA 17013
PA Dept. Of Revenue
Bureau of Individual Taxes
Inheritance Tax Division
Dept. 2.80601
Harrisburg, PA 17128-0601
· P.O. Box 2675
Commonwealth of Pennsylvania Harrisburg, PA 17105
Department of Welfare
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale: NONE
7. The 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: NONE
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that fialse statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
GRENEN & BIRSIC, P.C.
SWORN to and subscribed before
methis JfP .dayof ~)~ (!(
Not~ Public t c~
_,2003.
Krigtir~M. Anthou, Esqmre
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA -~
COUNTY OF CUMBERLAND .~ SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Housing & Urban Develop, Sec is the grantee the same having been sold to
said grantee on the 9th day of Jnne A.D., 2004, under and by virtue of a writ Execution issued on the 3rd
day of December, A.D., 200_~3, out of the Court of Common Pleas of said County as of Civil Term, 2003
Number 4180, at the suit of Chase Man Mtg Corp against Jennifer L Drabek & Timothy D is duly
recorded in Sheriff's Deed Book No. 263, Page 3706
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this~D day o , A.D. 20~_~.
C~Recorder of Deeds
My ,e~dss~ F. xF~e~ d~e F~r~ ivlorx~ of Jnr~. 2~
AMENDED RETURN
Chase Manhattan Mortgage Corporation
VS
Jennifer L. Drabek and Timothy
D. Drabek
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003~4180 Civil Term
Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that
on January 13, 2004 at 9:18 o'clock A.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Jennifer L. Drabek and Timothy D. Drabek located at 111 E. Columbia Road, Enola,
Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriffmailed a notice of the pendency of the action to the within named
defendant, to wit: Jennifer L. Drabek, by regular mail to her last known address of 12335
South 44th Court, Alsip, IL 60803. This letter was mailed under the date of January 12,
2004 and was returned to the Sheriffs Office on January 26, 2004 as "Attempted, Not
Known."
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Timothy D. Drabek, by regular mail to his last known address of
12335 South 44th Court, Alsip, IL 60803. This letter was mailed under the date of
January 12, 2004 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry for the within named defendants, to wit: Jennifer L.
Drabek and Timothy D. Drabek, but was unable to locate them in his bailiwick. He
therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real
Estate Writ, Notice of Sheriffs Sale and Description according to law.
Dauphin County Return: And Now, May 5, 2004 at 3:34 PM served the within
Real Estate Writ, Notice of Sale upon Jennifer Drabek by personally hmading to
defendant one true attested copy of the original Real Estate Writ, Notice of Sale and
making known to her the contents thereof at Dauphin County Sheriffs Office, Front &
Market Sts., Harrisburg, PA 17108. So answers: J.R. Lotwick, SheriffofDauphin
County, PA.
Dauphin County Return: And now, May 5, 2004 at 3:34 PM served the within Real
Estate Writ, Notice of Sale upon Timothy Drabek by personally handing to defendant one
true attested copy of the original Real Estate Writ, Notice of Sale and making known to
him the contents thereof at Dauphin County Sheriffs Office, Front & Market Streets,
Harrisburg, PA 17108. So answers: J.R. Lotwick, Sheriff of Dauphin County, PA.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendants, to wit: Jennifer L. Drabek and Timothy D. Drabek, by regular mail to their
last known address of 820 Cardinal Drive, Harrisburg, PA 17111. These letters were
mailed under the date of May 13, 2004 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on June 9, 2004 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Kristine Anthou for Secretary of Housing and Urban
Development. It being the highest bid and best price received for the same, Secretary of
Housing and Urban Development of Wanamaker Building, 100 Penn Square East,
Philadelphia, PA 19107, being the buyers in this execution, paid to SheriffR. Thomas
Kline the sum of $914.92.
Sheriffs Costs:
Docketing $30.00
Poundage 17.07
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1,00
Mileage 11.04
Levy 15.00
Surcharge 30.00
Out of County 9.00
Dauphin County 35.25
Postpone Sale 20.00
Law Journal 330.50
Patriot News 251.74
Share of Bills 29.32
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
$ 914.92
Sworn and subscribed to before me
This 3~0- day of
2004, A.D. ~,~f~, ~. ~,~-"
So Answer~:
R. Thomas Kline, Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 03~4180
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Chase Manhattan Mortgage Corporation, Plaintiffin the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information was of record concerning
the real property of Jennifer L. Drabek and Timothy D. Drabek located at 111 E. Columbia Road,
Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN E. PENNSBORO TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA 17025. DBV 249, PAGE 1628,
AND TAX MAP 09-13-1002 / PARCEL 273.
1. The name and address of the owners or reputed owners:
Jennifer L. Drabek
Timothy D. Drabek
12335 South 44~ Court
Alsip, IL 60803
2. The name and address of the defendants in the judgment:
Jennifer L. Drabek 12335 South 44t~ Court
Timothy D. Drabek Alsip, IL 60803
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Manhattan Mortgage Corporation [PLAINTIFF]
4. The name and address of the last record holder of every mortgage of record:
Chase Manhattan Mortgage Corporation [PLAINTII~F]
5. The name and address of every other person who has any record lien on the property:
Cumberland County Domestic Relations
PA Dept. Of Revenue
Bureau of Individual Taxes
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 320
Carlisle, PA 17013
Inheritance Tax Division
Dept. 280601
Harrisburg, PA 17128-0601
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale: NONE
7. The name and address of every other person whom the plaintiffhas knowledge who has any
interest in the property which may be affected by the sale: NONE
I verify that the statements made in the Affidavit are tree and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
GRENEN & B[RSIC, P.C.
Kristir~oM. Anth~u, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
methis ]S'P dayof
Notary Public
,2003.
IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
TO:
NO.: 03-4180
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
Timothy D. Drabek
12335 South 44~ Court
Alsip, IL 60803
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale at the
Cumberland County Courthouse
Commissioners Hearing Room, 2"a Floor
1 Courthouse Square
Carlisle, PA 17013
on Wednesday, March 3, 2004 at 10:00 A.M., the following described real estate, of which Jennifer
L. Drabek and Timothy D. Drabek are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN E. PENNSBORO
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA
17025. DBV 249, PAGE 1628, AND TAX MAP 09-13-1002 / PARCEL 273.
The said Writ of Execution has been issued On a judgment in the mortgage foreclosure action of
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
Jennifer L. Drabek and Timothy D. Drabek,
Defendants,
at Execution Number 03-4180 in the amount of $82,927.10.
Claims against the property must be filed with the Sheriff before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
This paper is a notice of the date and time of the sale of your property. It has been issued
because there is a judgment against you. It may cause your property to be held or taken to pay the
judgment. You may have legal rights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
TELEPHONE: (717) 240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection,
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiffhas a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriffhas not made a valid
tatum of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other
legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
KristifleM. Anthou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DMSION
CHASE MANHATTAN MORTGAGE
CORPORATION,
maintiff,
NO.: 03-4180
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
LONG FORM DESCRIPTION
ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of East
Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, bounded and described in
accordance with a survey and plan thereof made by John Bruce Shand, Professional Engineer, dated
September 19, 1968, as follows:
BEGINNING at a point on the Northern line of Columbia Road opposite the center of the partition
wall separating houses No. 109 and 111 Columbia Road; said point being 18 feet North ora point on the curb
line of Columbia Road, which last mentioned point is 112.25 feet West of the Western end of a 10 feet radius
curve which connects the North curb line of Columbia Road and the West curb line of Beaver Avenue;
thence in a Northerly direction, through the center of the above mentioned partition wall, a distance of 154:3
feet to a point in line of land now or late of the Enola Realty Company; thence along said land in a Westerly
direction a distance of 24.8 feet to a point at a comer of premises known as No. 113 Columbia Road; thence
in a Southerly direction along said premises a distance of 150.5 feet to a point on the Northern line of
Columbia Road; thence in an Easterly direction along the Northern line of Columbia Road a distance of 25.4
feet to the point and place of beginning.
HAVING thereon erected a two and one-half story semi-detached flame dwelling house, known and
numbered as 111 Columbia Road, Enola, Pennsylvania.
BEING the same premises which Rodney W. Hollabaugh, by Deed dated November 21, 2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on November 26, 2001, at Deed
Book Volume 249, Page 1628, granted and conveyed unto Jennifer L. Drabek and Timothy D. Drabek.
GRENEN & BIRSIC, P.C.
Krf~e,M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Tax Map 09-13-1002 / Parcel 273
IN THE COURT OF GOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
TO:
NO.: 03-4180
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
Jennifer L. Dmbek
12335 South 44t~ Court
Alsip, IL 60803
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale at the
Cumberland County Courthouse
Commissioners Hearing Room, 2"d Floor
1 Courthouse Square
Carlisle, PA 17013
on Wednesday, March 3, 2004 at 10:00 A.M., the following described real estate, of which Jennifer
L. Drabek and Timothy D. Drabek are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JENNIFER L. DRABEK AND
TIMOTHY D. DRABEK OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN E. PENNSBORO
TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A
DWELLING BEING KNOWN AND NUMBERED AS 111 E. COLUMBIA ROAD, ENOLA, PA
17025. DBV 249, PAGE 1628, AND TAX MAP 09-13-1002 / PARCEL 273.
The said Writ of Execution has been issued bna judgment in the mortgage foreclosure action of
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
Jennifer L. Drabek and Timothy D. Drabek,
Defendants,
at Execution Number 03-4180 in the amount of $82,927.10.
Claims against the property must be filed with the Sheriffbefore the above sale date.
Claims to proceeds must be made with the Office of the Sheriffbefore distribution.
Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30)
days fi.om sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriffno later than ten (10) days fi.om the date when Schedule of Distribution is filed in the
Office of the Sheriff.
This paper is a notice of the date and time of the sale of your property. It has been issued
because there is a judgment against you. It may cause your property to be held or taken to pay the
judgment. You may have legal rights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
TELEPHONE: (717) 240-6200
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or d~lay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection,
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriffhas not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other
legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
By:~
Kris 't~e M. An{thou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 03-4180
VS.
JENNIFER L. DRABEK and
TIMOTHY D. DRABEK,
Defendants.
LONG FORM DESCRIPTION
ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of East
Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, bounded and described in
accordance with a survey and plan thereof made by John Bruce Shand, Professional Engineer, dated
September 19, 1968, as follows:
BEGINNING at a point on the Northern line of Columbia Road opposite the center of the partition
wall separating houses No. 109 and 111 Columbia Road; said point being 18 feet North of a point on the curb
line of Columbia Road, which last mentioned point is 112.25 feet West of the Western end ofa 10 feet radius
curve which connects the North curb line of Columbia Road and the West curb line of Beaver Avenue;
thence in a Northerly direction, through the center of the above mentioned partition wall, a distance of 154.3
feet to a point in line of land now or late of the Enola Realty Company; thence along said land in a Westerly
direction a distance of 24.8 feet to a point at a corner of premises known as No. 113 Columbia Road; thence
in a Southerly direction along said premises a distance of 150.5 feet to a point on the Northern line of
Columbia Road; thence in an Easterly direction along the Northern line of Columbia Road a distance of 25.4
feet to the point and place of beginning.
HAVING thereon erected a two and one-half story semi-detached frame dwelling house, known and
numbered as 111 Columbia Road, Enola, Pennsylvania.
BEING the same premises which Rodney W. Hollabaugh, by Deed dated November 21,2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on November 26, 2001, at Deed
Book Volume 249, Page 1628, granted and conveyed unto Jennifer L. Drabek and Timothy D. Drabek.
GRENEN & BIRSIC, P.C.
Kfl/i~.M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Tax Map 09-13-1002 / Parcel 273
· ' WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 03-4180 Civil
COUNTY OF CUMBERLAND) ~ CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE
CORPORATION, Plaintiff(s)
From JENNIFER L. DRABEK AND TIMOTHY D. DRABEK
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $80,503.07 L.L. $.50
Interest $2,424.03 (FROM 9/8/03 TO SALE)
Atty's Comm % Due Prothy $1.00
AttyPaid $82.00 Other Costs
Plaintiff Paid
Date: DECEMBER 3, 2003
(Seal)
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: 1 GATEWAY CENTER, 9 WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
CURTIS R. LONG
.97
Deputy
Real Estate Sale # 58
On December 05, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 111 E. Columbia Road,
Enola, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: December 05, 2003 By: c~l
Real Estat~ Deputy
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 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
Sundav 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 regurar 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
Volume 14, Page 317,
PUBLICATION
REAL ~ 8A'LE No.
Writ No, 200~4180
County of Dauph~in Miscellaneous Book "M",
A.D.
Teny L. Russell,~~N~a~y P~i~//~//~~/~ ~//~
~s~rg, Dau~n ~ /~
' ~N~ARY PUBLIC
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 er publication attached
hereto on the above stated dates
Total
$ 251.74
ofca~~a~,~of~,~ Publisher's Receipt for Advertising Cost
~ ~ ~ ~,a~o., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
~ ~a~ofl~ ....
~of~c~;~,dge recmpt of the aforesaid nohce and publication costs and codifies that the same have
H3~R~ha~y~
~ ~'~a~l~ ~ a ~y ....................................................................
"~ ~y ~ ~ ~ N~ ~ of
~L,~ ~yD, ~k,
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA.'
:
COUNTY OF CUMBERLAND :
SS.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JANUARY 16, 23, 30, 2004
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Joumal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are tree.
REAL ESTATE SALE NO. 58
Writ No. 2003 4180 Civil
Chase Mmatmttan
Mortgage Corporation
VS.
denmfer L. Drabek and
Timothy D. Drabek
Atty.: Kristine Anthou
LONG FORM DESCRII:rI'ION
ALL that certain tract or parcel
of land and pren~ises, situate, lying
and being in the Tounash~p of East
Pennsboro In the County of Cum-
berland and Commonwealth of
Pennsylvania, bounded and de-
scribed in accordance with a sur-
vey and plan thereof made by John
Bruce 8hand, Professional Engl
neer. dated September 19, 1968.
as follows:
BEGINNING at a point on the
Northern line of Columbia Road
opposite the center of the partition
wall separating houses No. 109 and
SWORN TO AND SUBSCRIBED before me this
30 day of JANUARY 2004
LOIS fi. SNYDER, Notary Public
carlisle Boro, Cumberland County
My Commission Expires March 5, 2005
ALL thai certain tract or parcel
of Land azld pren~ses, sltttate, lying
and belong in the Township of East
Pennsboro in the County of Cum-
berland and Commonwealth of
Pennsylvania, bounded and
scribed in accordance vzlth a sur
vey and plan thereof made by John
Bruce Shand, Professional Engi-
neer, dated September 19. 1968.
as follows:
BEGINNING at a point on the
Northern line of Columbia Road
opposite the center of the partition -
wml/separating houses No. 109 and
111 Columbia Road: smd point be
lng 18 feet North of a point on the
crwb line of Columbia Road, which
last mentioned point is 112.25 feet
West of the Western end of a 10
feet radius curve which connects
the North curb line of Columbia
Road and the West curb line of Bee
vet Avenue: thence in a Northerly
direction, through the center of the
above mentioned partition wall, a dis-
tance of 154.3 feet to a point in ilne
of lamd now or late of the Enola Re-
alty Company; thence along said
land in a Westerly direction a dis-
tance of 24.8 feet to a point at a
corner of premises known as No.
113 Columbia Road; thence in a
Southerly direction along said pre
mises a distance of 150.5 feet to a
point on the Northern line of
lumbla Road; thence in an Easterly
direction along the Northern line of
Columbia Road a dlaiance of 25.4
feet to the point and place of beg~n~
ning.
HAVING thereon erected a two
and one half story semi-detached
frame dwelling house, known and
numbered as 111 Columbia Road,
Enola, Pennsylvania.
BEING the same premises which
Rodney W. Hallabaugh, by Deed
dated November 21, 2001 and re-
corded in the Office of the Recorder
of Deeds of Cumberland County on
November 26. 2001, at Deed Book
Volume 249, Page 1628, granted
and conveyed unto Jennir~- '
Drabek o~'~ ~'
LOIS E. SNYDEfl, Notal
Carlisle Bom, Curnberlan
My Commission Expires Ma