HomeMy WebLinkAbout07-5768MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Chase Home Finance LLC, successor by merger
to Chase Manhattan Mortgage Corporation
10790 Rancho Bernardo Road
San Diego, CA 92127
V.
Samuella H. Woodrow
637 Hopkins Mill Road
Quarrysville, PA 17566
and
Kimberly M. Dewitt a/k/a Kimberly M. Woodrow
Dewitt a/k/a Kimberly M. Woodrow n/k/a Dewitt
10 Austel Drive
Marysville, PA 17053
and
Craig Dewitt
3 Pfautz Road, Apt. E
Duncannon, PA 17020
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number D 7- 57(0$ O Iv i( Term
CIVIL ACTION/MORTGAGE FORECLOSURE
NOTICE AVISO
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.
Le han demandado a usted en la corte. Si usted
quiere defenderse de estas demandas ex-puestas en
las paginas siguientes, usted tiene veinte (20)
dias de plazo al partir de la fecha de la demanda y
la notificacion. Hace falta asentar una
comparencia escrita o en persona o con un abogado y
entregar a la corte en forma escrita sus defensas o
sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se defiende,
la corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o
notification. Ademas, la corte puede decidir a
favor del demandante y requiere que usted cumpla
con todas las provisions de esta demanda. Usted
puede perder dinero o sus propiedades u otros
derechos importantes para usted.
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 Bar Association
2 Liberty Avenue
Carlisle, PA, 17013
800-990-9108
USTED LE DEBE TOMAR ESTE PAPEL A SU
ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE A UN ABOGADO, VA A O TELEFONEA LA
OFICINA EXPUSO ABAJO. ESTA OFICINA LO
PUEDE PROPORCIONAR CON INFORMATION
ACERCA DE EMPLEAR A UN ABOGADO.
SI USTED NO PUEDE PROPORCIONAR PARA
EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE
SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS
QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN I.N
HONORARIO REDUCIDO NI NINGUN
HONORARIO.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA, 17013
800-990-9108
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Chase Home Finance LLC, successor by merger
to Chase Manhattan Mortgage Corporation
10790 Rancho Bernardo Road
San Diego, CA 92127
V.
Samuella H. Woodrow
637 Hopkins Mill Road
Quarrysville, PA 17566
and
Kimberly M. Dewitt a/k/a Kimberly M. Woodrow
Dewitt a/k/a Kimberly M. Woodrow n/k/a Dewitt
10 Austel Drive
Marysville, PA 17053
and
Craig Dewitt
3 Pfautz Road, Apt. E
Duncannon, PA 17020
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number
CIVIL ACTION/MORTGAGE FORECLOSURE
1. Plaintiff is Chase Home Finance LLC, successor by merger to Chase Manhattan Mortgage
Corporation, a corporation duly organized and doing business at the above captioned address.
2. The Defendant is Samuella H. Woodrow, who is one of the mortgagors and real owners of
the mortgaged property hereinafter described, and her last-known address is 637 Hopkins Mill Road,
Quarrysville, PA 17566.
3. The Defendant is Kimberly M. Dewitt a/k/a Kimberly M. Woodrow Dewitt a/k/a Kimberly
M. Woodrow n/k/a Dewitt, who is one of the mortgagors and real owners of the mortgaged property
hereinafter described, and her last-known address is 10 Austel Drive, Marysville, PA 17053.
4. The Defendant is Craig Dewitt, who is one of the mortgagors of the mortgaged
property herinafter described, and his last-known address is 3 Kautz Road, Apt. E, Duncannon, PA
17020.
5. On 12/26/1995, mortgagors made, executed and delivered a mortgage upon the premises
hereinafter described to Colonial National Bank USA which mortgage is recorded in the Office of the
Recorder of Cumberland County in Mortgage Book 1298, Page 430.
6. On 2/25/2003, the aforesaid mortgage was thereafter assigned by Colonial National Bank
USA to Chase Home Finance LLC, successor by merger to Chase Manhattan Mortgage Corporation,
Plaintiff herein, by Assignment of Mortgage recorded in the Office of the Recorder of Cumberland County
in Assignment of Mortgage Book 694, page 3760.
7. The premises subject to said mortgage is described in the legal description attached as
Exhibit "A" and is known 98 Queen Avenue, Enola, PA 17025.
8. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 04/05/2007 and each month thereafter are due and unpaid, and by the terms of said mortgage,
,upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
9. The following amounts are due on the mortgage:
Principal Balance $ 15,458.01
Interest through 07/24/2007 $ 552.09
(Plus $ 3.97 per diem thereafter)
Attorney's Fee $ 1,500.00
Late Charges $ 144.12
Corporate Advances $ 85.00
Escrow Advances $ 60.55
Title Search $ 200.00
GRAND TOTAL $ 17,999.77
10. The attorney's fees set forth above are in conformity with the mortgage documents and
Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs Sale. If the
mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually
performed.
11. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice
required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail
with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $17,999.77,
together with interest at the rate of $3.97 per diem and other costs and charges collectible under the mortgage
and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG AND CONWAY, P.C.
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the
within action, and that he/she is authorized to make this verification and that the foregoing facts
based on the information from the Plaintiff, who is not available to sign this, are true and correct to
the best of his/her knowledge, information and belief and further states that false statements herein
are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE, WEISBERG AND CONWAY, P.C.
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro,
County of Cumberland and Commonwealth of Pennsylvania., more particularly bounded and
described as follows, to wit:
BEGINNING at a point on the Southern side of Queen Avenue (50 feet wide) at the Northern
corner of Lot No. 1 on the hereinafter mentioned Plan of Lots; thence by Queen Avenue, North
68 degrees 30 minutes East, a distance of twenty (20.00) feet to a point at Lot No. 3 on said
Plan; thence by Lot No. 3 South 21 degrees 30 minutes East, a distance of one hundred fifty
(150.00) feet to a point on a fifteen (15) feet wide alley; thence by said fifteen (15) foot alley,
South 68 degrees 30 minutes West, thence by said fifteen (15) foot alley, South 68 degrees 30
minutes West, a distance of twenty (20.00) feet to a distance of one hundred fifty (150.00) feet
to a point, the place of beginning.
BEING Lot No. 2 on a Final Subdivision Plan for Albert D. and Donna R. Leirenring made by
D.P. Raffensperger Associates, Camp Hill, Pennsylvania and recorded in Cumberland County
Plan Book 34 page 77.
HAVING thereon erected a townhouse and numbered 98 Queen Avenue.
Map #09-13-1002-160A
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
OCCUPANT
was served upon
the
DEFENDANT , at 1655:00 HOURS, on the 26th day of October , 2007
at 98 QUEEN AVENUE
ENOLA, PA 17025
JASON MCCLINTOCK
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.0 0
So Answers:
R. Thomas Kline
11/07/2007
MCCABE WEISBERG CONWAY
Sworn and Subscibed to By
Al t
before me this day Deputy Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
OCCUPANT the
DEFENDANT , at 1655:00 HOURS, on the 26th day of October , 2007
at 98 QUEEN AVENUE
ENOLA, PA 17025
REBECCA STERLING
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
111bq/b7 .00
16.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
11/07/2007
MCCABE WEISBERG CONWAY
By:
Deputy Sheri f
of A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-05768 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
WOODROW SAMUELLA H but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
NOT FOUND , as to
the within named DEFENDANT , WOODROW SAMUELLA H
98 QUEEN AVENUE
ENOLA, PA 17025
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs:
Docketing 18.00
Service 14.40
Affidavit 5.00
Surcharge 10.00
00
11 b4ol 47.40
So answer
R. Thomas Kline
Sheriff of Cumberland County
MCCABE WEISBERG CONWAY
11/07/2007
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-05768 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
DEWITT KIMBERLY M AKA KIMBERLY M WOODROW DEWITT AKA KIMBERLY but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT FOUND , as to
the within named DEFENDANT
M WOODROW DEWITT AKA KIMBERLY ,
DEWITT KIMBERLY M AKA KIMBERLY
98 QUEEN AVENUE
ENOLA, PA 17025
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs: So answers:
Docketing 6.00 s
Service .00 Not Found 5.00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
11,09/ 6 ? ? 21.00 MCCABE WEISBERG CONWAY
11/07/2007
Sworn and Subscribed to before
me this day of ,
A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-05768 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
DEWITT CRAIG
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
the within named DEFENDANT , DEWITT CRAIG
NOT FOUND , as to
98 QUEEN AVENUE
ENOLA, PA 17025
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
1I?C,gi ?
So answers,-
6.00 - -?
.00
5.00 R. Thomas Kline
10.00 Sheriff of Cumberland County
.00
21.00 MCCABE WEISBERG CONWAY
11/07/2007
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
WOODROW SAMUELLA H
but was unable to locate Her
deputized the sheriff of PERRY
in his bailiwick. He therefore
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs: So answers-
Docketing 6.00 '
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep Perry County 117.05 Sheriff of Cumberland County
Postage 2.23
144.28 / jrloolo1
11/07/2007
MCCABE WESIBERG CONWAY
Sworn and subscribe to before me
this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
to wit:
DEWITT KIMBERLY M AKA KIMBERLY M WOODROW DEWITT AKA KIMBERLY
but was unable to locate Her
deputized the sheriff of PERRY
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs: So answers:
Docketing 6.00
Out of County .00
Surcharge 10.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
16.00 ? ii/dy?o7
11/07/2007
MCCABE WEISBERG CONWAY
Sworn and subscribe to before me
this day of
in his bailiwick. He therefore
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DEWITT CRAIG
but was unable to locate Him
deputized the sheriff of PERRY
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Sheriff or Deputy Sheriff who being
in his bailiwick. He therefore
So answers-
6.00 .00
10.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
16.00
11/07/2007
MCCABE WWEISBERG CONWAY
Sworn and subscribe to before me
this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
WOODROW SAMUELLA H
but was unable to locate Her in his bailiwick. He therefore
deputized the sheriff of LANCASTER
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from LANCASTER
Sheriff's Costs: So answers : ,?----_-
Docketing 6.00
Out of County 9.00 j
Surcharge 10.00 R. Thomas Kline
Dep Lancaster Co 51.05 Sheriff of Cumberland County
.00
76.05
11/07/2007
MCCABE WEISBERG CONWAY
Sworn and subscribe to before me
this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
to wit:
DEWITT KIMBERLY M AKA KIMBERLY M WOODROW DEWITT AKA KIMBERLY
but was unable to locate Her
deputized the sheriff of PERRY
in his bailiwick. He therefore
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs: So answer
Docketing 6.00
Out of County .00 Surcharge 10.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
16.00
11/07/2007
MCCABE WEISBERG CONWAY
Sworn and subscribe to before me
this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2007-05768 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
WOODROW SAMUELLA H ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
DEWITT CRAIG
but was unable to locate Him
deputized the sheriff of PERRY
serve the within COMPLAINT - MORT FORE
County, Pennsylvania, to
On November 7th , 2007 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs: So answers:
Docketing 6.00
Out of County .00
Surcharge 10.00 Thomas Kline
.00 Sheriff of Cumberland County
.00
16.00
11/07/2007
MCCABE WEISBERG CONWAY
Sworn and subscribe to before me
this day of
in his bailiwick. He therefore
A. D.
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Horne Finance LLC
VS.
Samuella H. Woodrow et al
SERVE: Samuella H. Woodrow No. 07-5768 civil
Now, October 4, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Perry County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this day of , 20
copy of the original
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
20 , at o'clock M. served the
County, PA
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41St Judicial District
of Pennsylvania-
Perry County Branch
ZW7
No. IM-5768 Cumberland County
Chase Home Finance LLC
VS
Samuella H. Woodrow
10 Austel Drive OR 3-E Pfautz Rd.
Marysville, PA 17053 Duncannon, PA 17020
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit Samuella H.
Woodrow, but was unable to locate him/her in his bailiwick. He therefore returns the
within Complaint in Mortgge Foreclosure for the above named Defendant(s)
Samuella H. Woodrow, at 10 Austel Drive Marysville, PA 17062 OR 3-E Pfautz
Rd. Duncannon, PA 17020, NOT FOUND. AS PER DEFENDANTS DAUGHTER
AT 10 AUSTEL DR.MARYSVILLE,PA 17053, DEFENDANT LIVES AT 637
HOPKINS MILL RD. QUARRYVILLE, PA.(LANCASTER COUNTY).
Sincerely,
Sworn and subscribed to b ore me
this / F?hday of QC40007.
Carl E. Nace
Sheriff of Perry County
NOTARIAL SEAL
MARGARET F. FLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COUNTY
W rnMMISSION EXPIRES FEB. 16. 2008
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Hang Finance LLC
VS.
Samuella H. Woodrow et al
SERVE: Kimberly M. Dewitt @ Marysville address No.
Now, October 4, 2007
hereby deputize the Sheriff of
County to execute this Writ, this
Perry
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
Now, October 18, , 20 07 , at 8: 50 o'clock A M. served the
within Complaint in Mortgage Foreclosure
upon Kimberly M. Dewitt
at 10 Austel Dr. Marysville ( Rye Twp) Pa. 17053
by handing to Kimberly M. Dewitt, Defendant
Complaint in
a True & Attested copy of the original Mortgage Foreclosure
and made known to Her the contents thereof.
Sworn and subscribed befo e
me this LV day of de , 200,7
NOTARIAL SEAL
MARGARET F. FLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COUNTY
MY COMMISSION EXPIRES FEB. 16, 2008
I, SHERIFF OF CUMBERLAND COUNTY, PA, do
So answers,
Derek Bates
Deputy Sheriff of Perry County, PA
COSTS
SERVICE
MILEAGE _
AFFIDAVIT
07-5768 civil
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Hone Finance LLC
vs.
Samuella H. Woodrow et al
SERVE: Craig Dewitt @ Marysville address No. 07-5768 civil
Now, October 4, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Perry County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
Now, , 20 , at o'clock M. served the
within
upon All, o
at
by handing to J
a copy of the original
and made known to
Sworn and subscribed before
me this day of , 20
the contents thereof.
So answers,
Sheriff of
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
County, PA
SHERIFF'S OFFICE
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 • (717) 299-8200
SHERIFF SERVICE PLEASE TYPE OR PRINT LEGIBLY. 0
O
PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. d
1 PLAINTIFF/S/ 2 COURT NUMBER 9d
Chase Home Finance LLC
07-5768 civil
3
H
ro
0
Z
3 DEFENDANT/S/ 4 TYPE OF WRIT OR COMPLAINT
Samuella H. Woodrow et al Notice & C laint
SERVE 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC.. TO BE SERVED 3F3 I!?E£Q??iOx E16ors
Samuella H. Woodrow
6 ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP Code)
AT 637 Hopkins Mill Road Quarrysville, PA 17566
7. INDICATE UNUSUAL SERVICE: DEPUTIZE ? OTHER
Now, October 4 20 07 1, SHERIFF OF 00400~ COUNTY, PA., do here utize the S
Lancaster County to execute this Writ a Hof
to law. This deputation being made at the request and risk of the plaintiff.
SHERIFF Oil COUNT
INSTRUCTIONS OR
Cumberland
Please mail return of service to Cumberland County Sheriff. Thank you.
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under
within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on
the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof.
9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11 DATE
mG!AD A NIOL .T Moo n nu >~ en _ 215-790-1010 10/2/07
11SEND NOTICE OF SERVICE COPY TO MAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed)
MCCABE, WEISBERG, AND CONWAY, O.C.
123 SOUTH BROAD ST., SUITE 2080
PHILADELPHIA, PA. 19109
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
111 acknowledge receipt of the writ t NAME of Authorized LCSO Deputy or Clerk 14. Date Received 15 Expiration/Hearing date
or complaint as indicated above. ( JACKIE MICCICHE 717-390-2309 10/9/07 11/1/07
16. 1 hereby CERTIFY and RETURN that I ?flave personally served, ? have legal evidence of service as shown in "Remarks", ? have executed as shown in
"Remarks", the writ or complaint desc b don the individual, company, corporation, etc., at the address shown above or on the individual, company, cor-
poration, etc.. at the address inserted below by handing a TRUE and ATTESTED COPY thereof.
IT ? 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below)
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 19. ? No Service
See Remarks Below (No. 30)
20. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No . City, Boro. Twp 21 Date of Service 22 Time
State and Zip Code)
/
/6
1 )/O
EDST
1
10
11
23. ATTEMPTS D to Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int.
1o 11
24. Advance Costs 25. Service Costs 26. Notary Cert. 27 Mileage/Postage/N.F. 28 Total osts 29. co T D E R REFUND
150.00 3, -?
R
30. REMAR S:
S.T.A.
31. AFFIRMED and subscribed to before me this
3A lay of
20
ry
OF
36 D777)
35
`loth" 2. _Atletsrslt, 3. CANARY -Sheriff's Office 4. BLUE - Sheriffs Office
'1d3Q S.:4JI83HS
00 ; I I Wig 6 - i:30 tool
"1A1._
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Hang Finance LLC
VS.
Samuella H. Woodrow et al
SERVE: Kimberly Dewitt @ Duncannon address
No. 07-5768 civil
Now, October 4, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Perry County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
Now, , 20 , at o'clock M. served the
within
upon
at
by handing to
a copy of the original
and made known to the contents thereof.
Sworn and subscribed before
me this day of .320
So answers r "4y Derek ? S
Sheriff of County, PA
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
4
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Home Finance LLC
vs.
Samuella H. Woodrow et al
SERVE: Craig Dewitt @ Duncannon address
Perry
Now, October 4, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of
No. 07-5768 civil
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Please mail return of service to Cumberland County Sheriff. Thank you.
Affidavit of Service
Now, October 15,
20 97, at 8:00 o'clock P M. served the
within Complaint in Mortgage Foreclosure
upon Craig Dewitt
at 3-E Pfautz Rd Duncannon, ( Penn Twp) Pa 17020
by handing to Julie Brown, Defendants Girlfriend-PIC
True & Attested Complaint in
a copy of the original Mortgage For 1 oG ,re
and made known to Her the contents thereof.
So answers,
Aaron D. Richafds
Deputy Sheriff of Perry County, PA
Sworn and subscribed before
me this/ W day of , 20_2
NOTARIAL SEAL
MARGARET F. FLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COIJIM
MY COMMISSION EXPIRES FEB. 16,203
COSTS
SERVICE $
MILEAGE
AFFIDAVIT