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HomeMy WebLinkAbout07-6188a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, Vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. TO DEFENDANT CIVIL DIVISION NO.: Q17 - &( 88 TYPE OF PLEADING Civil erM CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF ATTO MYFOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANT IS: 32 Hope Terrace Carlisle, PA 1701 t, A EY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 32 Hope Terrace North Middleton Township Chase Home Finance LLC, s/b/m/t 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 Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 (CITY, BORO, TOWNSHIP,WARD) ATT EY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. NO.. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, 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. 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, CIVIL DIVISION NO.: O 7. G 1 U &, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. CIVEL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Thomas S. Pedersen and Donna K. Pedersen, are an individuals whose last known address is 32 Hope Terrace, Carlisle, Pennsylvania 17013. 3. On or about November 19, 2001, Defendants executed a Note in favor of Plaintiff in the original principal amount of $106,575.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about November 19, 2001, as security for payment of the aforesaid Note, Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount of $106,575.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on November 30, 2001 in Mortgage Book Volume 1740 Page 3189. 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 June 1, 2007 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 (12 U.S.C. "1707 1715z 18). 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 the Defendants are not a "residential mortgage debtor" as defined in 41 P. S. '101. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal $ 98,400.62 Interest to 9/29/07 $ 2,561.20 Late Charges to 9/29/07 $ 397.63 Escrow Deficiency to 9/29/07 $ 1,405.34 Corporate Advances $ 45.00 Unapplied funds ($ 380.78) Attorneys' Fees $ 1,300.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $106,229.01 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $106,229.01 with interest thereon at the rate of $16.85 per diem from September 29, 2007, 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. GRENEN & BIRSIC, P.C. BY: Kristi a M. thou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" 1590320317 NOTE FHA Case No. Multistate 441- 6756342 - 703 November 19, 2001 [Uatel 32 Hope Ter Carlisle, PA 17013 lftpeny Addressl 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means Chase Manhattan Mortgage Corporation 343 Thornall Street, Edison, NJ 08837 and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of One hundred six thousand five hundred seventy-five Dollars (U.S. $ 106, 575.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Six b 25/100 percent ( 6.250 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on January, 1St , 2002 . Any principal and interest remaining on the first day of December 2031 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at Chase Manhattan Mortgage Corporation, 343 Thornal l Street Edison, NJ 08837 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 656.21 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ?Graduated Payment Allonge ?Growing Equity Allonge ?Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. FHA MuttWate Fixed Rate Note -10/95 ®•11t t90o1?.O1 VMP MORTGAGE FORMS . 18001521-7291 Paps 1 of 2 1 WWI: ---JI = ' 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment 'requ red by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payntett is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. S. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) (Seal) -Borrower Thomas S. Pederson -Borrower (Seal) t (Seal) -Borrower Ale jpn .Borrower (Seal) 'MI pout C (Seal) - Pay to ft Order Borrower -Borrower ithaid Fle- =-- -an ?-4•d i (Seal () I A= apt "tease Manhattan Norge COM 01 -Borrower -?'?tta quo ®®-tR 19eoi?.oiav -,f-44 WILSO WASS? S-ECRETA .2of2 co 9e EXHIBIT "B" ,,.MAIL TO: Chase Manhattan Mortgage Corporation Final Documents 1500 N, 19th Street, 3rd Floor Monroe,_LA 71201 Loan Parcel {; ? ;, is •..•.., ., „ C ?? -?. X11 L?L..VLCf'?IECOc:D_i, OF DEEDS '?UMBERUND COUNTY-FA "01 NOU 30 RR 11 23 Space Above TMs Line For Recoraiing Data] FHA Can No. Commonwealth of Pennsylvania MORTGAGE 441.6756342-703 THIS MORTGAGE ("Security Instrument") is given on November 19, 2001 The Mortgagor is Thomas S. Pederson and Donna K. Pederson ("Borrower"). This Security Instrument is given to Chase Manhattan Mortgage Corporation which is organized and existing under the laws of The State of New Jersey and whose address is 343 Thornal l Street, Edi son, NJ 08837 ' One hundred six thousand five hundred seventy-five and 00/100 Lender the principal sum of Dollars (U.S. $ 106,575.00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on December 1, 2031 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance A PenMivaNa Mortgage - 4/96 ?4R(PA) FH tsso41.o1 VMP MORTGAGE FORMS - 18001521.7291 Papa 1 o18 initials: BK 17 4, 0 PG 31.8.9 ilet?,? J :. of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, -grant and convey to the Lender the following described property located in CUMBERLAND County, Pennsylvania: See attached Schedule A which has the address of 32 Hope Ter, Carlisle [Street, City], Pennsylvania 17013 [Zip code] ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a pan of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment' of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Pan 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. ®-4R(PA) iseoa).ol p.o. = of e Dtp sx 1 V. ?a 96' If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs I and 2 shall be applied by Lender as follows: Eim, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; ScMnd, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; EQUah, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4. Flre, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. S. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or -4R(PA) 49e04r.01 Psp.9 of e Initi.b: '001?'NO PG 31.91 G abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights In the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if: (M-4R(PA} leeoa).of Papa a of a INUabc /<-N ! f c << ,j?i?i P1%3 192 (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall retrain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. ll. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 40•4R(PA) mwlai Z Ppe s or e Du ? 7.4 O-PG 3 1. ? UP Ic 0.1 - to s ti 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. ?-4RWA1180o4F.o1 Pape 6 of 8 ?n?tiNe: btlp : 1:11 11C r, .; 1i MCI 740?93 4" IS. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided In this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nogjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 37SI et seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing In the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23. Interest Rate Ana Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time,under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)]. 0 Condominium Rider [] Growing Equity Rider 0 Other [specify] EJ Planned Unit Development Rider 0 Graduated Payment Rider (ft4RtPA) 1sso4).ol a? i A? ?v 1 o 'n P+p? 7..Of 8 gK{7 40PG3.'t-9.5 1nitlW? BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: (seal) Thomas S. Pederson -Borrower 7 h 01V\ (Seal) Donna K. Pederson -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower Certificate of Residence / l t'0 S ?. iK4- / 4,1` , do hereby certify that the correct address of the withi -named I;ender is 7 L 3 V3 _I , 0-e" o Witness my hand this day of Agent of Lender COMMONWEALTH OF PENNSYLVANIA, CUMBERLAND County ss: On this, 1'91 day of /(.Apv before me, the undersigned officer, personally appeared Thomas S. Pederson Donna K. Pederson known to me (or satisfactorily proven) to be person S' whose name S subscribed to the within instrument and acknowledged that executed the same for the purposes herein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. My Commission Expires: NOTARIAL SEAL ?- DOUGLAS C. Fx.' )^.' ;UT, Votary -011C Worf i.: i -nd Col V Jay 1 ZO 3 -4R(PA) teoo4l.ot 4. ot.a .y - A,,.90 4- u??c Title of Officer `'v ? C I X8 BK 1740PG3 196. V10 1. 0 Old Republic National Title Insurance Company Commitment Number: C200111009 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsyyvania, bounded and described as follows: BEING Lot No. 148 on Plan of Kingsbrook, Section "2", as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126; containing 110 feet along the South along Hope Terrace ; containing 171.79 feet along the West along Lot No. 147 on said Plan; containing 110.03 feet along the North along land now or formerly of Hooke, Lebo 8 Hooke, and containing 170 feet along the East along Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two storty brick dwelling known as 32 Hope Terrace, Carlisle, Pennsylvania. Parcel #29-14-0868-061 ALTA Commitment Schedule C I Certify this to be recorded In Cumberland County PA " R (C1?0111d&P1;D1C200 I?a1?109V75) BKJ740PG3197 VERIFICATION SUMMER 1PJJNLUAf4U"ER-PATEL . Assistant Secretary, and duly authorized representative of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation deposes and says, subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her knowledge, information and belief. OME FINANCE LLC, s/b/m/t ihattan Mortgage Corporation i SUMMER WINEGARDNER-PATEL ' ssistant Secretary Oo M .Q 00 00 a C7 ?? tV :> 1 C>J =a.7 CD C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. TYPE OF PLEADING Praecipe to Reinstate Civil Action - Complaint in Mortgage Foreclosure FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C.--= One Gateway Center Ninth Floor c Pittsburgh, PA 15222 (412) 281-7650 r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NO.: 07-6188 PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: Kristine . Anthou, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, CIVIL DIVISION NO.: 07-6188 VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 the last known address of Defendant, Donna K. Pedersen, only, is 9 Todd Road Carlisle, PA 17013 TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) AS TO DEFENDANT, DONNA K. PEDERSEN, ONLY FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. A eys for Plain ff GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. CIVIL DIVISION NO.: 07-6188 PRAECIPE FOR DEFAULT JUDGMENT AS TO DEFENDANT, DONNA K. PEDERSEN, ONLY TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Donna K. Pedersen, only, in the amount of $109,091.76, which is itemized as follows: Principal $ 98,400.62 Interest to 12/11/07 $ 3,746.18 Late Charges to 12/11/07 $ 454.84 Escrow Deficiency to 12/11/07 $ 2,955.38 Corporate Advances $ 115.52 Unapplied Funds ($ 380.78) Attorneys' Fees $ 1,300.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $109,091.76 with interest on the principal sum at the rate of $16.85 per diem from December 11, 2007, 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. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Attorney for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was 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 copy. Sworn to and subscribed before me this day of 6"Wyw?'j 2007. PA, LaMk otary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seel Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commisslon Expires Jan. 8, 2008 Member, Pennsylvania Association Of Notaries . IN THE COURT OF C ON PLEAS OF CUMBERLAND C*NTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. TO: Donna L. Pedersen 9 Todd Road Carlisle, PA 17013 DATE OF NOTICE: November 30, 2007 NO.: 07-6188 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, 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 32 S. Bedford Street Carlisle, PA 17013 ----- 249--3466- Toll Free (800) 990-9108 By: GRENEN & BIRSIC, P.C. OpEGateway Center, Ninth Floor Pittsburgh, PA 15222 FIRST CLASS MAIL, POSTAGE PREPAID (412) 281-7650 AA. +v a Q 1 .o 0 rte. r? l71]Jy? S 1J.1 J. 00 --GG c-n W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Donna K. Pedersen 9 Todd Road Carlisle, PA 17013 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $109,091.76, with interest on the principal sum at the rate of $16.85 per diem from December 11, 2007, 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. it. - 00 eputy ?'? SHERIFF'S RETURN - REGULAR CP..SE NO: 2007-06188 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS PEDERSON THOMAS S 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 "T T'%"n OnAT MnTT,TT V the DEFENDANT at 0910:00 HOURS, on the 9th day of November , 2007 at 9 TODD ROAD CARLISLE, PA 17013 by handing to DONNA PEDERSEN 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 4.80 Affidavit .00 Surcharge 10.00 / .00 2 0. 8 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 11/14/2007 GRENEN & BIRSIC B Deputy Sheriff of A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06188 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC Vs PEDERSON THOMAS S 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 PEDERSEN THOMAS S but was unable to locate Him in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the the within named DEFENDANT NOT FOUND , as to PEDERSEN THOMAS S 32 HOPE TERRACE CARLISLE, PA 17013 32 HOPE TERRACE IS VACANT. DEFENDANT LIVES AT 3109 N FRONT ST HARRISBURG Sheriff's Costs: Docketing Service Not Found Surcharge Postage 18.00 4.80 5.00 10.00 .58 38.38 So answ R. Thomas Kline Sheriff of Cumberland County GRENEN & BIRSIC 11/14/2007 Sworn and Subscribed to before me this day of , A.D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-06188 P .COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS PEDERSON THOMAS S 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: PEDERSEN THOMAS S but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On December 28th , 2007 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answez. Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas line Dep Dauphin County 35.25 Sheriff of Cumberland County Postage 2.23 74.48 ? /?a3l0P 12/28/2007 GRENEN & BIRSIC Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Chas Hone Finance. LLC VS. Thomas S. Pedersen No. 07-6188 civil Now, December 12, 2007 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA t Affidavit of Service Now, , 20 , at o'clock M. served the within upon at by handing to a and made known to copy of the original So answers, Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA the contents thereof. ( 00- it of the ?$4crjff Mary Jane Snyder R 1 Estate Depu ; William T. Tully t Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Commonwealth of Pennsylvania County of Dauphin Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy CHASE HOME FINANCE LLC VS THOMAS S PEDERSEN Sheriff s Return No. 2007-T-1740 OTHER COUNTY NO. 07-6188 And now: DECEMBER 18, 2007 at 1:36:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon THOMAS S PEDERSEN by personally handing to 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 3109 NORTH FRONT STREET HARRISBURG PA 17110 SERVED ERIC LEVENGOOD ADULT IN CHARGE Sworn and subscribed to So Answers, ((? before me this 20TH day of December, 2007 A7? NOTARIAL SEAL RY JANE SNYDER, Notary Publi Highspire, Dauphin County LM Commission Expires Sept 1 2010 Sheriff of Dauphin County, Pa. Y Deputy Sheriff Deputy: T STRUBHAR Sheriffs Costs: $35.25 12/14/2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 07-6188 Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 the last known address of Defendant, Thomas S. Pedersen, only, is: 3109 North Front Street Harrisburg, PA 17110 TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) AS TO DEFENDANT, THOMAS S. PEDERSEN, ONLY FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. Attorneys for Plaintiff GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. CIVIL DIVISION NO.: 07-6188 PRAECIPE FOR DEFAULT JUDGMENT AS TO DEFENDANT, THOMAS S. PEDERSEN, ONLY TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Thomas S. Pedersen, only, in the amount of $109,091.76, which is itemized as follows: Principal $ 98,400.62 Interest to 12/11/07 $ 3,746.18 Late Charges to 12/11/07 $ 454.84 Escrow Deficiency to 12/11/07 $ 2,955.38 Corporate Advances $ 115.52 Unapplied Funds ($ 380.78) Attorneys' Fees $ 1,300.00 Title Search, Foreclosure and Execution Costs $ 2.500.00 TOTAL $1 09,091.76 with interest on the principal sum at the rate of $16.85 per diem from December 11, 2007, 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. GRENEN & BIRSIC, P.C. BY: Kristine -M. Anthou, Esquire Attorney for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was 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 copy. /l L (2 Lr Sworn to and subscribed before me this a:?A day ofd 2008. IF N ary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seed B M. PaWw, Notary Pubk c4 Pftbw#" Moo" My O?aYrt"M E)gphu ism 82092 Member, pennsylvenla Assodatlon of Notarlaa IN THE COURT OF C(,..,MON PLEAS OF CUMBERLAND C -JNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, CIVIL DIVISION NO.: 07-6188 vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. TO: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 DATE OF NOTICE: January 8, 2007 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, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. ??Atto , s f or PlaintOne Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 .Wc ? D ? D r? e? r - _71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $109,091.76. with interest on the principal sum at the rate of $16.85 per diem from December 11, 2007, 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. 91? Y r" '? - t? "'i1 i i'7 ?3 ?D ?. . 4` __.> - j'; .d"' , i:7 -.. "":- T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment Chase Home Finance LLC, et al. (XX) Other File No. 07-6188 VS. Amount Due $109,091.76 Interest $ 3,332.85 Thomas S. Pedersen and Donna K. Pedersen : Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: 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, upon the following described property of the defendant(s) SEE ATTACHED DESCRIPTION PRAECIPE FOR ATTACHMENT EXECUTION County, 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 description; 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). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name: Kr? ,,fine M. Anthou Address: One Gateway Center, Ninth Floor Pittsburgh, PA 15222 Attorney for: Plaintiff Telephone: 412-281-7650 Supreme Court ID No.: 77991 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.R No. 3129). 70 L If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. ..o s; O O F D (o D j W {- 0 0 8 O O oo p? S UP D ._ rJ r_'3 C" i•D Ti -{ r_ ?.v 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. LONG FORM DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 148 on the Plan of Kingsbrook, Section "2," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126; containing 110 feet along the South along Hope Terrace; containing 171.79 feet along the West along Lot No. 147 on said Plan; containing 110.03 feet along the North along land now or formerly of Hooke, Lebo & Hooke, and containing 170 feet along the East along Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two-story dwelling known and numbered as 32 Hope Terrace, Carlisle, Pennsylvania. SUBJECT to a draining easement as shown on said Plan. BEING subject to the Building and Use Restrictions as recorded in the Office aforesaid in Miscellaneous Book No. 184 at Page 763. BEING THE SAME PREMISES which Thomas E. Wickard and wife, Doris Y. Wickard, and The Homestead Group, Inc., a PA Corporation, by Deed dated December 19, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 23, 1997 in Deed Book Volume 0- 156, Page 277, granted and conveyed unto Thomas S. Pedersen and Donna K. Pedersen, husband and wife. GRENEN & BIRSIC, P.C. By - c2 C Z Kristi e M. hou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. Pedersen and Donna K. Pedersen located at 32 Hope Terrace, Carlisle, Pennsylvania 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. PEDERSEN AND DONNA K. PEDERSEN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF NORTH MIDDLETON, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 32 HOPE TERRACE, CARLISLE, PENNSYLVANIA 17013. DEED BOOK VOLUME 156, PAGE 277 AND PARCEL 29-14- 0868-061. 1. The name and address of the owners or reputed owners: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 Donna K. Pedersen 9 Todd Road Carlisle, PA 17013 2. The name and address of the defendants in the judgment: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 Donna K. Pedersen 9 Todd Road Carlisle, PA 17013 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 Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation Citizens Bank of PA Citizens Bank of PA 525 William Penn Place Suite 2720 Pittsburgh, PA 15219 c/o Jack F. Ream, Esquire 119 East Market Street York, PA 17401 James J. Touloumes, Jr. James J. Touloumes, Jr. Old Republic National Title 1 West Pine Street Mt. Holly Springs, PA 17065 c/o Jacques H. Geisenberger, Jr., Esquire Wheatland Place 941 Wheatland Avenue, Suite 201 Lancaster, PA 17603 1265 Drummers Lane Suite 220 Wayne, PA 19087 Old Republic National Title PHH Mortgage Corporation PHH Mortgage Corporation Homefirst Lending LLC Homefirst Lending LLC c/o Robert C. Saidis, Esquire 26 West High Street Carlisle, PA 17013 3000 Leadenhall Road Mt. Laurel, NJ 08054 c/o Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 3000 Leadenhall Road Mt. Laurel, NJ 08054 c/o Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare 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 plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 32 Hope Terrace Carlisle, PA 17013 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. Q? Kris ' e M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY ()F? / ? OJJA 2008. i? X- Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Ef¢abeM M. PaiM, Notary Public City Of PRObtrgh. Allegheny County My Cannlasion Expires Jan. 6.2012 Member, Pennsylvania Asswation of Notaries ?:<a ° ?- -? 'r? i?J - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 32 Hope Terrace, Carlisle, Pennsylvania 17013 are Defendants, Thomas S. Pedersen and Donna K. Pedersen, who reside at 3109 North Front Street, Harrisburg, Pennsylvania 17110 and 9 Todd Road, Carlisle, Pennsylvania 17013, respectively, to the best of her information, knowledge and belief. ?? _ C?L C iC C GL ?C ?-?- SWORN TO AND SUBSCRIBED BEFORE ME THIS D Y OF 3??NAAA 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal EY¢abelh M. Palewfo, Notary Public City Of P41hrO, ANegherry Cou* W CWwrission E*kw Jan. 6, 2012 Member, Pennsylvania Association of Notaries C ? iJ U7 ,r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE CIVIL DIVISION MANHATTAN MORTGAGE CORPORATION, Plaintiff, NO.: 07-6188 vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, 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 authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, 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. §1680.40 1 C(a)(3)]. Additionally, 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 Defendant are not "residential mortgage debtors" as defined in 41 P.S. §101. SWORN TO AND SUBSCRIBED BEFORE ME THIS Y OF i 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal EkabaM M. PaWA Notary Public City OF Pb burgN Alsoany County W Wm "on Expires Jan. 6, 2012 Member, Pennsylvania AssodsWn of NoW@* ij ?w5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 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 in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 11, 2008 at 10:00 A.M., the following described real estate, of which Thomas S. Pedersen and Donna K. Pedersen are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. PEDERSEN AND DONNA K. PEDERSEN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF NORTH MIDDLETON, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 32 HOPE TERRACE, CARLISLE, PENNSYLVANIA 17013. DEED BOOK VOLUME 156, PAGE 277 AND PARCEL 29-14- 0868-061. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Thomas S. Pedersen and Donna K. Pedersen, Defendants, at Execution Number 07-6188 in the amount of $112,424.61. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. B V t? L C z k Kris ' e M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 _ .j - x ?_ ,. ? ? ? ___ ,6 _.. 1 ?? ?? I l.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NO.: 07-6188 LONG FORM DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 148 on the Plan of Kingsbrook, Section "2," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126; containing 110 feet along the South along Hope Terrace; containing 171.79 feet along the West along Lot No. 147 on said Plan; containing 110.03 feet along the North along land now or formerly of Hooke, Lebo & Hooke, and containing 170 feet along the East along Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two-story dwelling known and numbered as 32 Hope Terrace, Carlisle, Pennsylvania. SUBJECT to a draining easement as shown on said Plan. BEING subject to the Building and Use Restrictions as recorded in the Office aforesaid in Miscellaneous Book No. 184 at Page 763. BEING THE SAME PREMISES which Thomas E. Wickard and wife, Doris Y. Wickard, and The Homestead Group, Inc., a PA Corporation, by Deed dated December 19, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 23, 1997 in Deed Book Volume 156, Page 277, granted and conveyed unto Thomas S. Pedersen and Donna K. Pedersen, husband and wife. GRENEN & BIRSIC, P.C. By: !i ?1 C ,cG t? Kristi M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6188 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. PEDERSEN and DONNA K. PEDERSEN (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 $109,091.76 L.L. $.50 Interest -- $3,332.85 Atty's Comm % Due Prothy $2.00 Arty Paid $276.66 Other Costs Plaintiff Paid Date: 1/25/08 Prt honotary (Seal) By: REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. CIVIL DIVISION NO.: 07-6188 FILED ON BEHALF OF PLAINTIFF: TYPE OF PLEADING Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 -W I. Defendants. PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE TO: PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 vs. Plaintiff, THOMAS S. PEDERSEN and DONNA K. PEDERSEN, SIR: Kindly settle and discontinue without prejudice the above-captioned matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: Kristin . Anthou, Esq ire Attorney for Plaintiff Sworn to and subscribed before me this day of _Loll.,& _ 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA No W Seat EYzevelh M. Peian0. Nohary Ptf?lic Clq? Of PN?br?. A1eAhery Coutb My Mnnftim Expires Jan. 6, 2012 Member. Permm rM Assc datlon of Nloterles IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, CIVIL DIVISION NO.: 07-6188 TYPE OF PLEADING PRAECIPE TO SATISFY JUDGMENT Defendants. FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY SIR: Kindly satisfy the judgment at the above-captioned matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: C Kristine M. Anthou, Esquire Attorney for Plaintiff Sworn to and subscribed before me this day of 2008. ? ?_ ___? t?? &k ?N V A?? Notary Pu is COMMONWEALTH OF PENNSYLVANIA Nobw Seal W Of PRIbLY9% AkghwW 0=* EVkNJ8 Mwmw, P9nfw ?+ A6*ARw_ of NoWW c4 Chase Home Finance LLC, s/b/m/t Chase In the Court of Common Pleas of Manhattan Mortgage Corporation Cumberland County, Pennsylvania Vs Writ No. 2007-6188 Civil Term Thomas S. Pedersen and Donna K. Pedersen Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 17, 2008 at 2035 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Thomas S. Pedersen and Donna K. Pedersen by making known unto Donna K. Pedersen personally, at 9 Todd Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Thomas S. Pedersen was served via Dauphin County Sheriff's Office on 03-26-08 at 1050 hours. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 02, 2008 at 1110 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and description, in the above entitled action, upon the property of Thomas S. Pedersen and Donna K. Pedersen located at 32 Hope Terrace, Carlisle, Cumberland County, 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 Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Thomas S. Pedersen by regular mail to his last known address of 3109 North Front Street, Harrisburg, PA 17110. This letter was mailed under the date of April 1, 2008 and never returned to the Sheriffs Office. 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: Donna K. Pedersen by regular mail to her last known address of 9 Todd Road, Carlisle, PA 17013. This letter was mailed under the date of April 1, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Kristine Anthou. Sheriff's Costs: Docketing 30.00 Poundage 2,246.69 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 10.00 Levy 15.00 Surcharge 30.00 Out of County 9.00 Dauphin County 35.25 Patriot News 350.30 Share of bills 14.73 $2,773.47 t? A -0'e 1p, L j6ot ('y3ok t , sJ ?it?-/0D? So Answers: R. Thomas Kline, Sheriff i BY Real Estate ?geant r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 07-6188 Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. Pedersen and Donna K. Pedersen located at 32 Hope Terrace, Carlisle, Pennsylvania 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. PEDERSEN AND DONNA K. PEDERSEN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF NORTH MIDDLETON, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 32 HOPE TERRACE, CARLISLE, PENNSYLVANIA 17013. DEED BOOK VOLUME 156, PAGE 277 AND PARCEL 29-14- 0868-061. 1. The name and address of the owners or reputed owners: Thomas S. Pedersen Donna K. Pedersen 3109 North Front Street Harrisburg, PA 17110 9 Todd Road Carlisle, PA 17013 2. The name and address of the defendants in the judgment: Thomas S. Pedersen Donna K. Pedersen 3109 North Front Street Harrisburg, PA 17110 9 Todd Road Carlisle, PA 17013 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 Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation Citizens Bank of PA Citizens Bank of PA James J. Touloumes, Jr. James J. Touloumes, Jr. Old Republic National Title PLAINTIFF 525 William Penn Place Suite 2720 Pittsburgh, PA 15219 c/o Jack F. Ream, Esquire 119 East Market Street York, PA 17401 1 West Pine Street Mt. Holly Springs, PA 17065 c/o Jacques H. Geisenberger, Jr., Esquire Wheatland Place 941 Wheatland Avenue, Suite 201 Lancaster, PA 17603 1265 Drummers Lane Suite 220 Wayne, PA 19087 r. Old Republic National Title PHH Mortgage Corporation PHH Mortgage Corporation Homefirst Lending LLC Homefirst Lending LLC c/o Robert C. Saidis, Esquire 26 West High Street Carlisle, PA 17013 3000 Leadenhall Road Mt. Laurel, NJ 08054 c/o Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 3000 Leadenhall Road Mt. Laurel, NJ 08054 c/o Francis S. Hallinan, Esquire 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations PA Department of Revenue Department of Welfare P.O. Box 320 Carlisle, PA 17013 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare 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 Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS Q?, . A DAY 2008. -2A A AA W) , n? Notary Public COMMONWEALTH OF PENNSYLVANIA Notadat Seal Elizabeth M. P&WA Notary Public qty Of PMeburgh, Also eny County My CorrrrWon E*Ww Jan. 6, 2012 Member, Pennsylvenle Mwaetlon of Nota is 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: Tenants 32 Hope Terrace Carlisle, PA 17013 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. l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. Pedersen 3109 North Front Street Harrisburg, PA 17110 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 in the Cumberland County Courthouse Commissioners Hearing Room, 2"d Floor 1 Courthouse Square Carlisle, PA 17013 on June 11, 2008 at 10:00 A.M., the following described real estate, of which Thomas S. Pedersen and Donna K. Pedersen are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. PEDERSEN AND DONNA K. PEDERSEN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF NORTH MIDDLETON, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 32 HOPE TERRACE, CARLISLE, PENNSYLVANIA 17013. DEED BOOK VOLUME 156, PAGE 277 AND PARCEL 29-14- 0868-061. 1 { The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Thomas S. Pedersen and Donna K. Pedersen, Defendants, at Execution Number 07-6188 in the amount of $112,424.61. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. Kris ' e M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NO.: 07-6188 LONG FORM DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 148 on the Plan of Kingsbrook, Section "2," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126; containing 110 feet along the South along Hope Terrace; containing 171.79 feet along the West along Lot No. 147 on said Plan; containing 110.03 feet along the North along land now or formerly of Hooke, Lebo & Hooke, and containing 170 feet along the East along Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two-story dwelling known and numbered as 32 Hope Terrace, Carlisle, Pennsylvania. SUBJECT to a draining easement as shown on said Plan. BEING subject to the Building and Use Restrictions as recorded in the Office aforesaid in Miscellaneous Book No. 184 at Page 763. BEING THE SAME PREMISES which Thomas E. Wickard and wife, Doris Y. Wickard, and The Homestead Group, Inc., a PA Corporation, by Deed dated December 19, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 23, 1997 in Deed Book Volume 156, Page 277, granted and conveyed unto Thomas S. Pedersen and Donna K. Pedersen, husband and wife. GRENEN & BIRSIC, P.C. By: Q Kristih nthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, NO.: 07-6188 Plaintiff, vs. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Donna K. Pedersen 9 Todd Road Carlisle, PA 17013 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 in the Cumberland County Courthouse Commissioners Hearing Room, 2°d Floor 1 Courthouse Square Carlisle, PA 17013 on June 11, 2008 at 10:00 A.M., the following described real estate, of which Thomas S. Pedersen and Donna K. Pedersen are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. PEDERSEN AND DONNA K. PEDERSEN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF NORTH MIDDLETON, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 32 HOPE TERRACE, CARLISLE, PENNSYLVANIA 17013. DEED BOOK VOLUME 156, PAGE 277 AND PARCEL 29-14- 0868-061. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Thomas S. Pedersen and Donna K. Pedersen, Defendants, at Execution Number 07-6188 in the amount of $112,424.61. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. gy?? Kris ' M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. THOMAS S. PEDERSEN and DONNA K. PEDERSEN, NO.: 07-6188 Defendants. LONG FORM DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 148 on the Plan of Kingsbrook, Section "2," as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126; containing 110 feet along the South along Hope Terrace; containing 171.79 feet along the West along Lot No. 147 on said Plan; containing 110.03 feet along the North along land now or formerly of Hooke, Lebo & Hooke, and containing 170 feet along the East along Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two-story dwelling known and numbered as 32 Hope Terrace, Carlisle, Pennsylvania. SUBJECT to a draining easement as shown on said Plan. BEING subject to the Building and Use Restrictions as recorded in the Office aforesaid in Miscellaneous Book No. 184 at Page 763. BEING THE SAME PREMISES which Thomas E. Wickard and wife, Doris Y. Wickard, and The Homestead Group, Inc., a PA Corporation, by Deed dated December 19, 1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 23, 1997 in Deed Book Volume 156, Page 277, granted and conveyed unto Thomas S. Pedersen and Donna K. Pedersen, husband and wife. GRENEN & BIRSIC, P.C. By:( 1(c lip <? Kristi a A Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6188 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. PEDERSEN and DONNA K. PEDERSEN (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 $109,091.76 Interest -- $3,332.85 Atty's Comm % Atty Paid $276.66 Plaintiff Paid Date: 1/25/08 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $2.00 Other Costs 1-4 rothonotary By: _ Deputy Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 w -AJ i rvv Real Estate Sale # 52 On March 5, 2008 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 32 Hope Terrace, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 5, 2008 By: Real Estat Sergeant S Z -Z CJ 8Z NVf 0001 (?`F7 Gv'il bd 'XiNno:i u- 4, .4 ciri?l l AWNS 3H1 A 301JJ0 .The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the PNow you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/23/08 04/30/08 05/07/08 Sworn to of May, 2008 A. D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chyrie L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29, 2010 Member, Pennsylvania Association of Notaries Real Estate Sale #52 Writ No. 2007-6188 Civil Term Chase Home Finance LLC, s/b/ »/! Chase Manhattan Mortgage Corporation VS Thomas S. Pedersen and Donna K. Pedersen Attorney: Kristine Anthou DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County. Pennsylvania, bounded and described as follows: BEING Lot No. 148 on the Plan of Kingsbrook, Section '2" as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 24, Page 126: containing 110 feet along the South along Hope Terrace: containing 171.79 feet along the West along Lot No. 147 on said Plan: containing 110.03 feet along the North along land now or formerly of Hooke, Lebo & Hooke, and containing 170 feet along the East alone Lot No. 149 as shown on said Plan, and containing 18,798.45 square feet. BEING improved with a brick and aluminum two-story dwelling known and numbered as 32 Hope Terrace. Carlisle, Pennsylvania. SUBJECT to a draining easement as shown on said Plan. BEING subject to the Building and Use Restrictions as recorded in the Office aforesaid in Miscellaneous Book No. 184 at Page 763. BEING THE SAME PREMISES which Thomas E. Wickard and wife, Doris Y. Wickard, and The Homestead Group, Inc., a PA Corporation, by Deed dated December 19,1996 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 23, 1997 in Deed Book Volume 156. Page 277, granted and conveved unto Thomas S. Pedersen and Donna K. Pedersen, husband and wife.