HomeMy WebLinkAbout08-2108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
Vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
TO DEFENDANT
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
X_ 61?
ATTO----R PLAINTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANT IS:
401 Kunkle Lane
Mechanicsburg, PA 17050
k-
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
401 Kunkle Lane. Hampden Township
(CITY, BORO, TOWNSHIP,WARD)
ATTO NEY FOR PLAINTIFF "IJ
CIVIL DIVISION
NO.: 08 - a(o8
TYPE OF PLEADING
Civtt Tim
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
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,
Plaintiff,
vs.
NO.:
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
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 CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.:
Plaintiff,
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
CIVIL 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, Linardi Gouw and Francisca Hermawan, a/k/a Francisca
Hermanwan, are individuals whose last known address is 401 Kunkle Lane, Mechanicsburg,
Pennsylvania 17050.
3. On or about August 28, 2006, Defendants executed a Note in favor of JP Morgan Chase
Bank, N.A. in the original principal amount of $133,929.00. A true and correct copy of said Note is
marked Exhibit "A", attached hereto and made a part hereof.
4. On or about August 28, 2006, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to JP Morgan Chase Bank, N.A. a Mortgage in the
original principal amount of $133,929.00 on the premises hereinafter described, said Mortgage
being recorded in the Office of the Recorder of Deeds of Cumberland County on August 31,
2006 in Mortgage Book Volume 1964 Page 1681. 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. JP Morgan Chase Bank, N.A. assigned the aforesaid Mortgage and Note to
Plaintiff pursuant to the terms of a certain Assignment of Mortgage.
6. Defendants are the record and real owners of the aforesaid mortgaged premises.
7. 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 October 1, 2007 payment.
8. 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).
9. 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.
10. The amount due and owing Plaintiff by Defendants is as follows:
Principal $132,632.66
Interest to 3/14/08 $ 5,162.64
Late Charges to 3/14/08 $ 224.65
Escrow Deficiency to 3/14/08 $ 132.90
Corporate Advances $ 60.00
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2.500.00
TOTAL $142,012.85
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $142,012.85 with interest thereon at the rate of $26.27 per diem from March 14, 2008, 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:
Kris ne M. An hou, quire
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
True & ceMied COPY
NOTE FHA Case No.
Multistate .7848144.703
August 28, 2006
[Date]
401 Kunkle Ln
Mechanicsburg, PA 17050
[Property Address]
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
JPMorgan Chase Bank, N.A.
a bank which is organized and existing under the laws of the United States of America
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INWREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
One hundred thirty-three thousand nine hundred twenty-nine
Dollars (U.S. S 133,929.00 ), 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 Seven & 25/100
percent ( 7.250 %) 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
October, 1st , 2006 . Any principal and interest remaining on the first day of September
2036 , will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at JPMorgan Chase Bank, N.A., c/o Chase Home Finance, LLC
3415 Vision Drive, Columbus, OH 43219 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. S 913.64 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)
OGraduated Payment Allonge OGrowing Equity Allonge OOther (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.
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6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph
4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount
of Four percent ( 4.000 96} 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.
8. 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 TfUS 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
(Seal) .
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
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-Borrower
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covenants contained in this Note.
r'
(Seal)
Li I Gotiw _Borrower
1 ; c (, (Seal)
Franci sca HerMnw Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
EXHIBIT "B"
"BERT p, IlEvALER
RFCCRCE'R OF
F 18ER. OFEl)S
?,,rtD C0tl,rrf_Al
1006 RUG 31 flj7 10 SS
Prepared By:
Return To:
JPMorgan Chase Custody Services
P.O. Box 8000
Monroe, LA 71211
Parcel Number: Premises:
10220527133 401 Kunkle Ln
Mechanicsbur, PA 17050
[Space Above Ibis tine For Recording- Data]
FHA Case No.
Commonwealth of Pennsylvania MORTGAGE 441-7848144-703
THIS MORTGAGE ("Security Instrument") is given on August 28, 2006
The Mortgagor is
Linardi Gouw and
Francisca He r-
1-?e.rr?a,aar?
("Borrower"). This Security Instrument is given to
JPMorgan Chase Bank, N.A., a national banking association
which is organized and existing under the laws of the United States of America , and
whose address is l 1 [ 1 Polaris Parkway, Columbus, OH 43240
("Lender"). Borrower owes Lender the principal sum of
One hundred thirty-three thousand nine hundred twenty-nine and 00/100
Dollars (U.S. $ 133,929.00
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
September [, 2036 . 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
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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 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 401 Kunkle Ln [sweet)
Mechanicsburg
("Property Address"); [City), Pennsylvania 17050 [zip Codel
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances and fixtures now or hereafter a part 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) Ieasehold
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 eith : (i) sum for the
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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
Part 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.
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 1 and 2 shall be applied by Lender as
follows:
First, 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;
Second, 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;
Fourth, to amortization of the principal of the Note; and
Fifth, to late charges due under the Note.
4. Fire, 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 outstandin indebtedness
under the Note and this Security Instrument shall be paid to the entity legally entitled th to!
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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.
5. 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
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 th n; o (c) secures
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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 Gam-St. Germain Depository Institutions Act of 1982, 12 U.S.C.
1701 j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all
sums secured by this Security Instrument if.,
(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 termer 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 remain
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 commence ent of foreclosure
proceedings within two years immediately preceding the commencement of a nt foreclosure
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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.
11. 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-Signets. 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.
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 olvents, materials
containing asbestos or formaldehyde, and radioactive materials. As used in par; graph 16,
174245166$
-4R(PA) (owz) "ir.f,:
Ct
Paps 6 of 9
9KI964PG1686
"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.
18. 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 nonjudicial
power of sale provided in the Single Family Mortgage Foreclosure Act of '1994 ("Act") (12 U.S.C.
3751 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.
2 1. hour prior to thee commencement of bidding lm at a a to reinstate sheriff's sale provided
other sac pursuantt?to his 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 After 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 payabl from time to time
under the Note.
1742451668
40-01(PA) 105021 fritial "
® Peps 7 of 8
6K 1964PG 1687
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)].
? Condominium Rider ? Growing Equity Rider ? Other [specify]
Planned Unit Development Rider ? Graduated Payment Rider
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security
Instrument a 0 in any rider(s) executed by Borrower and recordqd-,with it.
as --kz L.C?'
1742451668
- (Seal)
-borrower
(Seal)
-Borrower
_ (Seal)
-Borrower
CVRtPA) rosozi page a of s
r
(Seal)
-Borrower
(Seal)
-Borrower
_ (Seal)
-Borrower
8KI964PGI688
C011MONWEcA^?L?T'I OF PENNSYLVANIA, CUMBERLAND County ss:
persoOn t tappeared - day of ?a?U , before me, the undersigned officer,
Linardi Gouw T,
Francisca Herma#Wan
known to me (or satisfactorily proven) to be the
person(s) whose name is/ subscribed to the within instrument and acknowledged that he/she/they
executed the same for the purposes herein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official s
My Commission Expires: 6S/tot 13CX:>-7
Commonwealth Of Penns ania
Notadal Seal
Mode Chlzmar, Notary Public Tide of Officer
Hampden Twp., Ctanborland Courtly
My COmn1b6im EVIres May 19.2W
Member, Ptu+nsyMmle ANocW0n Ot No*ln
Certifieake of Residence I. IV 1 CA(Q l.??V`'Lc.iC._
the within-narn
Lender is
,kd Witness my hand this c n d- day of
1742451668
ek-4RIPAI 105021
, do hereby certify that the correct address of
LA "7 tats
Agent of Lender
Paps 9 of 9
inlGlb: ?//
SKI964PG1689
• •
ALL THAT CERTAIN tract or land situated in Hampden Township, Cumberland County, Pennsylvania, more
particularly bounded and described as follows, to wit:
BEGINNING at a point at the Eastern side of a proposed fifty (50) foot right-of-way and corner of land now or
Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his
wife, North 76 degrees East eighty (80) feet to lands now or formerly of John C. Kunkel; thence South 23 degrees
East one hundred eighty-one and five tenths (181.5) feet to a point at corner of land now or Frank Brice, Sr. and
Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife, South 76
degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence along said
Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five tenths (181.5) feet to a
point, the Place of BEGINNING.
I Ccrti fv V- I
In Cur-,h _? ,
OKI964PGi690
VERIFICATION
, 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.
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
Cindy X. cknithr, Assistant Secretary
00
U,
a
o -?
co
C
% SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02108 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI 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
GOUW LINARDI but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
the within named DEFENDANT
401 KUNKLE LANE
GOUW LINARDI
NOT FOUND , as to
MECHANICSBURG, PA 17050
401 KUNKLE LANE IS VACANT. FORWARDING ON FILE AT
POST OFFICE IS PO BOX 696 NEW CUMBERLAND, PA 17070
Sheriff's Costs:
Docketing 18.00
Service 10.00
Not Found 5.00
Surcharge 10.00
Postage 58
41.1 SJ09 q-58
So answers:
R. TFiomas Kline
Sheriff of Cumberland County
GRENEN & BIRSIC
04/17/2008
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02108 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI 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
HERMAWAN FRANCISCA AKA FRANCISCA HERMANWAN but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT
FRANCISCA HERMANWAN
401 KUNKLE LANE
, NOT FOUND , as to
HERMAWAN FRANCISCA AKA
MECHANICSBURG, PA 17050
401 KUNKLE LANE IS VACANT. FORWARDING ON FILE AT
POST OFFICE IS PO BOX 696 NEW CUMBERLAND, PA 17070.
Sheriff's Costs:
Docketing 6.00
Service .00
Not Found 5.00
Surcharge 10.00
.00
y/? 8?oe 21.00
So answer
R. Thomas kl-irie
Sheriff of Cumberland County
GRENEN & BIRSIC
04/17/2008
Sworn and Subscribed to before
me this day of ,
A. D.
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.: 08-2108
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE
PURSUANT TO SPECIAL ORDER OF COURT
AND NOW, comes the Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan
Mortgage Corporation, by and through its attorneys, GRENEN & BIRSIC, P.C., and files the
within Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of
Court under Pennsylvania Rule of Civil Procedure 430 as follows:
1. On or about April 2, 2008, Plaintiff filed a Complaint in Mortgage Foreclosure
against the Defendants, Linardi Gouw and Francisca Hermawan, a/k/a Francisca Hermanwan, at
the above-captioned number and term.
2. On or about April 2, 2008, Plaintiff delivered to the Sheriff of Cumberland
County a copy of the Civil Action - Complaint in Mortgage Foreclosure filed by Plaintiff at the
above-captioned number and term along with direction cards requesting that each Defendant be
served a copy of the Complaint at their last known addresses being 401 Kunkle Lane,
Mechanicsburg, Pennsylvania 17050.
3. On or about May 1, 2008, Plaintiff received Notices from the Cumberland County
Sheriffs Office indicating that attempts were made to serve the Defendants, Linardi Gouw and Francisca
Hermawan, a/k/a Francisca Hermanwan with a copy of the Complaint at their last known address being
401 Kunkle Lane, Mechanicsburg, Pennsylvania 17050 but the house is vacant and mail is being
forwarded to P.O. Box 696, New Cumberland, PA 17070. A true and correct copy of the Sheriffs Return
is marked Exhibit "A", attached hereto and made a part hereof.
4. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has
been made to determine the whereabouts of Defendants, Linardi Gouw and Francisca Hermawan, a/k/a
Francisca Hermanwan, and the reasons why service of the Complaint in Mortgage Foreclosure cannot be
made, is marked Exhibit "B", attached hereto and made a part hereof.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Sheriff
of Cumberland County to serve Defendants, Linardi Gouw and Francisca Hermawan, aWa
Francisca Hermanwan with the Complaint in Mortgage Foreclosure by posting a copy of the
Complaint on the property at 401 Kunkle Lane, Mechanicsburg, Pennsylvania 17050 and permit
the Plaintiff to serve the Defendant by mailing a true and correct copy of the Complaint in
Mortgage Foreclosure by certified mail, return receipt requested and by First Class U.S. Mail,
postage pre-paid to 401 Kunkle Lane, Mechanicsburg, Pennsylvania 17050. Service of the
Complaint shall be deemed complete and valid upon posting by the Sheriff and mailing by the
Plaintiff.
GRENEN & BIRSIC, P.C.
BY:
Brian M. Kile, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
EXHIBIT "A"
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-0210
'COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI 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
GOUW LINARDI
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT FOUND , as to
the within named DEFENDANT
401 KUNKLE LANE
MECHANICSBURG, PA 17050
GOUW LINARDI
401 KUNKLE LANE IS VACANT. FORWARDING ON FILE AT
POST OFFICE IS PO BOX 696 NEW CUMBERLAND, PA 17070
Sheriff's Costs:
Docketing 18.00
Service 10.00
Not Found 5.00
Surcharge 10.00
Postage .58
43.58
So answe s:
R. T omas Kline
Sheriff of Cumberland County
GRENEN & BIRSIC
04/17/2008
Sworn and Subscribed to before
me this day of RECEIVED MAY 011008
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE N0: 2008-02100
`COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI 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
HERMAWAN FRANCISCA AKA
FRANCISCA HERMANWAN
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
the within named DEFENDANT
FRANCISCA HERMANWAN
401 KUNKLE LANE
NOT FOUND , as to
, HERMAWAN FRANCISCA AKA
MECHANICSBURG, PA 17050
401 KUNKLE LANE IS VACANT. FORWARDING ON FILE AT
POST OFFICE IS PO BOX 696 NEW CUMBERLAND, PA 17070.
Sheriff's Costs: So answer ??--
Docketing 6.00 r
Service .00
Not Found 5.00 R. Thomas ne
Surcharge 10.00 Sheriff of Cumberland County
.00
21.00 GRENEN & BIRSIC
04/17/2008
Sworn and Subscribed to before
me this day of \v?OMp`l
A.D. R?C?
FROM .:
FAX NO. :
erlaod Co. Sheriff
Cum'1
l?v 4 :
15 2008 03:29PM P1
k 266] K 1
RUNNY K ANDERSON
Smrtlf i ChW Deputy
EDWARO 6. SCHORPP JODY S. SMITH
Wettor R
Av,.14. 2008 4:09PM
R THOMAS KLImp-
OFFICE OF THE SHERIFF
One Courthouse Square
Carlisle, Pennsytvanla 17013
j i
i ,
i
To: -r sumstc Ageracy Conyrol o. b +?( ?
Date: l u
Address llnforooatlon Requ at
Plesse ftanish #64 a cwy with the mew address, if avwIable, for the following in&vkW or vaify whether
the address given bilow is one et wb6ch mafl for No iadivlduel in cxraently,heing delivered. If the
fonowing aad ess i : n poet office box, Please ffitaish die stredt address as irdoorded ou the box holder'R
application foma. '
Nanae;.li/r?t?d/i ?aaw , ?r?.,e?3r4 HG/.y+rav,?
L,aee IqehOWA Address: "CA 17r1e
7 certify the addrms'information for this in&vAnl is required for the perfoame of this ageiney'R official
duties.
(Signavrre of Ageaey Of fipisl)
For Post Oglce Use Only
() MO is delivered to eddVea gh?en.
i
() Not Known at Address Given
() Moved, Last No ifflwsrdmg Address
() 140 Such Address;
() Other (Specify) i
Agency Retnan A
Nara Address
Sox holders' Street Address
Pastmark/Date Stars
Plaaae h= retuitst toy the CumbtrIand Cangty SheriWs Qiltlte. Number (717) 240-6397
Address luformatidn Request (Required format)
Exhibit 352.44b
or r
Ph
(10'7 co
EXHIBIT "B"
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.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NO.: 08-2108
AFFIDAVIT PURSUANT TO PA. R.C.P. 430
COUNTY OF ALLEGHENY )
)SS
COMMONWEALTH OF PENNSYLVANIA )
Before me, a notary public, in and for the foregoing county and commonwealth, personally
appeared Brian M. Kile, Esquire, of GRENEN & BIRSIC, P.C. attorneys for Plaintiff and deposes and
says that the following accurately reflects efforts made to ascertain the exact whereabouts of the
Defendants, Linardi Gouw and Francisca Hermawan, a/k/a Francisca Hermanwan, named in the above-
captioned matter:
(a) On May 9, 2008, Plaintiff mailed to the United States Postmaster at New
Cumberland, PA 17070 requests to be furnished with a Physical Address for the
P.O. Box 696 listed for Defendants, Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan.
(b) On May 15, 2008, Plaintiff received responses from the United States Postmaster
indicating that the Defendants reside at 401 Kunkle Lane, Mechanicsburg, PA
17050. True and correct copies of those responses are marked as Attachment
"A", attached hereto and made a part hereof.
(c) Examinations were made of the Mechanicsburg Area Telephone
Directory; said examination failed to yield any useful information
regarding the whereabouts of Defendants.
(d) Examinations were made of the Cumberland County Tax Assessor
Records; said examination indicates that Defendants reside at 401 Kunkle
Lane, Mechanicsburg, PA 17050. A true and correct copy of that response
is marked as Attachment "B", attached hereto and made a part hereof.
(e) A computer records search of a nationwide database indicates that the
Defendants reside at 401 Kunkle Lane, Mechanicsburg, PA 17050.
Finally, affiant deposes and says that after the foregoing investigation, the Plaintiff
believes and avers that the Defendants, Linardi Gouw and Francisca Hermawan, a/k/a Francisca
Hermanwan resides at
GRENEN & BIRSIC, P.C.
BY:
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Sworn to an subscribed before me
this a? day of p" , 2008.
Cam,
Y otary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiarw, Notary PubNc
City Of Pbbjo, ANe"V County
My Comrrri m Ermines Jan. 6, 2D12
Member, Pennsylvania Association of Notaries
ATTACHMENT "A"
Date May 9, 2008
Postmaster
New Cumberland, PA 17070
City, State, ZIP Code
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or the name and street address (if a box holder) for the following:
Name: Francisca Hermawan a/k/a Francisca Hermanwan
Address: P.O. Box 696---------- + ^novor "t1",W AM`> "
NOTE: The name and last known address are required for change of address information. The name, if known, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR
265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation acting pro se must cite
statute):
3. The names of all known parties to the litigation: Chase v. Gouw/Hermawan
4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County
5. The docket or other identifying number if one has been issued: 108-21081
6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS
INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF
LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN
CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID
PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS,
OR BOTH (TITLE 18 U.S.C SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in cc ection with actual or prospective litigation.
A
Sit6ature
Elizabeth M. Paiano, Paralegal
Printed Name
Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650
FOR POST OFFICE USE ONLY
X 6tea A-*- TW, .5 A?De.?SS
No change of address order on file.
_ Not known at address given.
_ Moved, left no forwarding address
_ No such address.
POSTMARK
NEW ADDRESS OR BOXHOLDER'S
NAME and STREET ADDRESS
ge-
v
NBC
!1 ?. ? r?
a w?
a., yea Qom,
RECEIVED MAY 1.5 2008
0 Date May 9, 2008 •
Postmaster
New Cumberland, PA 17070
City, State, ZIP Code
Request for Change of Address or Boxholder
Information Needed for Service of Legal Process
Please furnish the new address or the name and street address (if a box holder) for the following:
Name: Linardi Gouw
Address: P.O. Box 696-----------PLEASE PROVIDE PHYSICAL ADDRESS
NOTE: The name and last known address are required for change of address information. The name, if known, and
post office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR
265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation acting pro se must cite
statute):
3. The names of all known parties to the litigation: Chase v. Gouw/Hermawan
4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County
5. The docket or other identifying number if one has been issued: 108-21081
6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS
INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF
LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN
CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID
PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS,
OR BOTH (TITLE 18 U.S.C SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for
pe ice of legal p, Ncess i c r? eotion with actual or prospective litigation.
Signature
Elizabeth . Paiano, Paralegal
Printed Name
Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650
FOR POST OFFICE USE ONLY
_ No change of address order on file. POSTMARK
Not known at address given. NEW ADDRESS OR BOXHOLDER'S
NAME and STREET ADDRESS
Moved, left no forwarding address hLe' I
_ No such address. ?'1 ?`-Grtitv? -5 r3.±j44 . I ? D -1b
RECEIVED MAY 1S lobt
ATTACHMENT "B"
Page 1
Assessment Record For CUMBERLAND County
owner Information
Name: GOUW, LINARDI & FRANCISCA HERMAWAN (Owner Occupied)
Address: 401 KUNKLE LN
MECHANICSBURG, PA 17050-3602
CUMBERLAND COUNTY
Property Information
Property Address: 401 KUNKLE IN
MECHANICSBURG, PA 17050-3602
CUMBERLAND COUNTY
Land Use: SINGLE FAMILY RESIDENTIAL
Legal Information
Assessor's Parcel Number: 10-22-0527-133
Book/Page: 276/2107
Assessment Information
Assessment Year: 2007
Assessed Land Value: $25,000
Assessed Improvement Value: $80,830
Total Assessed Value: $105,830
Tax Information
Tax Rate Code: CUMBERLAND VY SD
Property Characteristics
Year Built: 1948
Important: The Public Records and commercially available data sources used on reports have errors. Data is
sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be
relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently
verified. For Secretary of State documents, the following data is for information purposes only and is not an
official record. Certified copies may be obtained from that individual state's Department of State.
Copyright® 2008 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion for
Service of the Complaint in Mortgage Foreclosure Pursuant to Special Order of Court and Order
of Court was mailed to the following on this 9014\ day of 2008,
by first-class, U.S. Mail, postage pre-paid:
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
GRENEN & BIRSIC, P.C.
BY: ... u ?.. ?,?
Brian M. Kile, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
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CHASE HOME FINANCE LLC,
s/b/m/t CHASE MANHATTAN
MORTGAGE CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ORDER OF COURT
AND NOW, this 9th day of June, 2008, upon consideration of the within
LINARDI GOUW AND
FRANCISCA HERMAWAN,
a/k/a FRANCISCA HERMANWAN,
DEFENDANTS NO. 08-2108 CIVIL
Motion for Service of the Complaint in Mortgage Foreclosure Pursuant to Special
Order of Court,
IT IS HEREBY ORDERED AND DIRECTED that the Sheriff of
Cumberland County is hereby directed to serve Defendants, Linardi Gouw and
Francisca Hermawan, a/k/a Francisca Hermanwan with a true and correct copy
of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at
401 Kunkle Lane, Mechanicsburg, PA 17050 and Plaintiff is permitted to serve
Defendants by certified mail, return receipt requested and by First-Class U.S.
Mail, postage pre-paid at both 401 Kunkle Lane, Mechanicsburg, PA 17050, and
P. O. Box 696, New Cumberland, PA 17070. Service upon the Defendants shall
be deemed complete and valid upon posting by the Sheriff and mailing by the
Plaintiff.
By the Court,
M. L. Ebert, Jr., J.
VINVAIASNI
ono``)
ES :Z Wd 6- NIA' UZ
MVIONvkU06d 3Hl d0
Brian M. Kile, Esquire
Attorney for Plaintiff
inardi Gouw
Francisca Hermawan,
a/k/a Francisca Hermanwan
401 Kunkle Lane,
Mechanicsburg, PA 17050
P. O. Box 696
New Cumberland, PA 17070
Cumberland County Sheriff
bas
t 1-9-CL
` L!4/o8
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.: 08-2108-CIVIL
Plaintiff,
vs.
TYPE OF PLEADING
LINARDI GOUW and Praecipe to Reinstate Civil Action -
FRANCISCA HERMAWAN, a/k/a Complaint in Mortgage Foreclosure
FRANCISCA HERMANWAN,
Defendants.
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
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,
Plaintiff,
vs.
LWARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
NO.: 08-2108-CIVIL
PRAECIPE TO REINSTATE CIVIL ACTION -
COMPLAINT IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY
SIR:
Defendants.
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.
/ -
r L-1
BY: i Brian M. Kile, Esquire
Attorneys for Plaintiff
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?+. SH8RIFF'S RETURN - REGULAR
CASE NO: 2008-02108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND j
CHASE HOME FINANCE LLC
VS
GOUW LINARDI ET AL
DENNIS FRY Sheriff or Deputy Sheriff of
i
Cumberland County,Pennsy vania, who being duly sworn according to law,
says, the within COMPLAI T - MORT FORE was served upon
GOUW LINARDI the
DEFENDANT at 14 00 HOURS, on the 25th day of June 2008
at 401 KUNKLE LANE
MECHANICSBURG, PA 17050 by handing to
POSTED PROPERTY AT 401 I,?UNKLE LAND MECHANICSBURG
a true and attested copy of COMPLAINT - MORT FORE together with
i
i
and at the same time diijecting His attention to the contents thereof.
I
i
Sheriff's Costs: So Answers:
Docketing 1;8.00
Service 1;2.00
Posting i 6 . 0 0
Surcharge 0.00 R. Thomas Kline
Postage .59
17/02/0p C?. 6.59 06/26/2008
GRENEN & BIRSIC
Sworn and Subscibed to By:
before me this 4ay Deput Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
i
VS
GOUW LINARDI ET AL
DENNIS FRY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsy vania, who being duly sworn according to law,
i
says, the within COMPLAINT - MORT FORE was served upon
TTT' AfiTT.TATT LIDATTtlTC("A nun RAATrTgrA NPPMANWAN the
i
DEFENDANT at 141111:00 HOURS, on the 25th day of June
at 401 KUNKLE LANE
i
MECHANICSBURG, PA 17050 by handing to
POSTED PROPERTY AT 401 E
a true and attested
LANE MECHANICSBURG
i
of COMPLAINT - MORT FORE together with
and at the same time di?ecting Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Posting
Surcharge
7/01/0-f 1-;?
Sworn and Subscibed to
before me this
of
So Answers:
6.00
. 00 _
16.00
10.00 R. Thomas Kline a
00
2.00 06/26/2008
GRENEN & BIRSIC
By:
;Z2?
y Deputy h riff
A. D.
. 2008
A '.
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.: 08-2108
TYPE OF PLEADING
LINARDI GOUW and Proof of Service
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
FILED ON BEHALF OF PLAINTIFF:
Defendants.
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
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,
Plaintiff,
VS.
LINARDI GOUW and
NO.: 08-2108
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
PROOF OF SERVICE
Brian M. Kile, Esquire, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation being duly sworn according to law deposes and makes the
following Affidavit regarding service of Plaintiffs Complaint in this matter on Defendants,
Linardi Gouw and Francisca Hermanwan, a/k/a Francisca Hermanwan:
1. Pursuant to Order of Court dated June 9, 2008, service of the Complaint in
Mortgage Foreclosure upon Defendants, Linardi Gouw and Francisca Hermanwan, a/k/a
Francisca Hermanwan, was deemed complete and valid upon mailing by the Plaintiff by certified
mail, return receipt requested, and by first class mail, postage prepaid, addressed to 401 Kunkle
Lane, Mechanicsburg, PA 17050 and P.O. Box 696, New Cumberland, PA 17070, and by
posting of a copy of the Complaint, by the Sheriff of Cumberland County, at the property located
at 401 Kunkle Lane, Mechanicsburg, PA 17050. A true and correct copy of said Order of Court
is marked Exhibit "A", attached hereto and made a part hereof.
2. On June 30, 2008, Plaintiff mailed the Complaint in Mortgage Foreclosure to
Defendants, Linardi Gouw and Francisca Hermanwan, a/k/a Francisca Hermanwan at 401
Kunkle Lane, Mechanicsburg, PA 17050 and P.O. Box 696, New Cumberland, PA 17070, by
certified mail, return receipt requested and by first class mail, postage prepaid. True and correct
copies of the U.S. Postal Service form 3800, Article Numbers 7006-2760-0004-7013-2005;
7006-2760-0004-7013-1985; 7006-2760-0004-7013-1978; 7006-2760-0004-7013-1992, and the
Certificate of Mailing, evidencing service by certified mail and first class mail on the identified
Defendant, are marked Exhibit "B", attached hereto and made a part hereof.
3. On or about June 25, 2008, the Sheriff of Cumberland County posted the
Complaint on the property located at 401 Kunkle Lane, Mechanicsburg, PA 17050. A true and
correct copy of the Sheriff s Return is marked Exhibit "C", attached hereto and made a part
hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
BY: w
Brian M. Kile, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS DAY OF 1,40/0V , 2008•
.% a . A A I /A
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiano, Notary PuM
City Of Pfto arch, AAegtony County
My CornrnLe* , Expires Jan. 6, 2012
Member, Pennsylvania Association of Notaries
EXHIBIT "A"
1
7 a
CHASE HOME FINANCE LLC, IN THE COURT OF COMMON PLEAS OF
s/b/m/t CHASE MANHATTAN CUMBERLAND COUNTY, PENNSYLVANIA
MORTGAGE CORPORATION,
PLAINTIFF
V.
LINARDI GOUW AND
FRANCISCA HERMAWAN,
a/k/a FRANCISCA HERMANWAN,
DEFENDANTS NO. 08-2108 CIVIL
ORDER OF COURT
AND NOW, this 9th day of June, 2008, upon consideration of the within
Motion for Service of the Complaint in Mortgage Foreclosure Pursuant to Special
Order of Court,
IT IS HEREBY ORDERED AND DIRECTED that the Sheriff of
Cumberland County is hereby directed to serve Defendants, Linardi Gouw and
Francisca Hermawan, a/k/a Francisca Hermanwan with a true and correct copy
of Plaintiff's Complaint in Mortgage Foreclosure by posting the property at
401 Kunkle Lane, Mechanicsburg, PA 17050 and Plaintiff is permitted to serve
Defendants by certified mail, return receipt requested and by First-Class U.S.
Mail, postage pre-paid at both 401 Kunkle Lane, Mechanicsburg, PA 17050, and
P. O. Box 696, New Cumberland, PA 17070. Service upon the Defendants shall
be deemed complete and valid upon posting by the Sheriff and mailing by the
Plaintiff.
By the Court,
ra
N
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- 1%A I&
M. L. Ebert, Jr., J.
RECEIVED JUN 17 2009
EXHIBIT "B"
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?..ormU. S_ POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Yl R
Received From:
Grenen & Birsic, P.C..
One Gateway Center, 9th Floor, Pittsburgh, PA 15222
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One piece of ordinary mail addressed to: #'
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic, P.C.
One Gateway Center, 9"' Floor, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
b, yictA_?
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PS Form 3817, January 2001
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U.S. POSTAL SERVICE CERTIFICATE OF MAILINU -
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MAY BE USEC FOR DOWSTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOF INSURANCE-703rMASTER
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One G,Ite M' Center,0 Floor, Pittsburgh, PA 15222 1Ct?` a `
1) 7 mo.)
One pied: 3f ordinary mail iWessed flo:
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P,S Form 3817, January 2(N)1
U.S. POSTAL SERVICE CERTIFICATE OF MAILING or I'n' Al-W onst W- w- and
MAY BE USECI FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT ,+.
PRCYIDE I:OR INSURANCE-POSTMASTER
Received From: =
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One: Gateway Center 9?' Floor PittstwmnnPA 1
One piece of ordinary mail addressed to:
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PS Form 3817, January2001
EXHIBIT "C"
SHERIFF'S RETURN - REGULAR,
CASE NO: 2008-021
COMMONWEALTH OF PE SYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI ET AL
DENNIS FRY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
GOUW LINARDI the
DEFENDANT , at 1411:00 HOURS, on the 25th day of June 2008
at 401 KUNKLE LANE
MECHANICSBURG, PA 17050 by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 12.00
Posting 6.00
Surcharge 10.00
Postage .59
46.59
So Answers:
R. Thomas Kline
06/26/2008
GRENEN & BIRSIC
BY ,'__. 7
Deput. Sheriff
Sworn and Subscibed to
before me this day
of
A. D.
RECEIV ED JUt 10 1008
5HERi,4'Y' S HE'-"J-RN - REGULAR,
CASE NO: 2008-021h
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
GOUW LINARDI ET AL
DENNIS FRY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
HERMAWAN FRANCISCA AKA FRANCISCA HERMANWAN the
DEFENDANT
at 1411:00 HOURS, on the 25th day of June , 2008
at 401 KUNKLE LANE
MECHANICSBURG, PA 17050 by handing to
POSTED PROPERTY AT 401 KUNKLE LANE MECHANICSBURG
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
Service
Posting
Surcharge
Sworn and Subscibed to
before me this-
of
So Answers:
6.00
.00 6.00
10.00 R. Thomas Kline
.00
22.00 06/26/2008
GRENEN & BIRSIC
By:
day Deputy/Sh riff
A. D.
RECEIVED JUL 10 1008
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Proof of Service was
mailed by U.S. First-Class Mail, postage pre-paid, on the 12 Day of AUGUST, 2008, to the following:
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan
P.O. Box 696
New Cumberland, PA 17070
GRENEN & BIRSIC, P.C.
BY: L_ __' J?_?
Brian_-. Kile, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
1
6
? 'fit
V
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
Plaintiff,
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
I hereby certify that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
the last known address of
Defendants is:
401 Kunkle Lane
Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
G ENEN &BIR?SIC, P.C.
Attorneys for Plaintiff
NO.: 08-2108
TYPE OF PLEADING
PRAECIPE FOR DEFAULT JUDGMENT
(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:
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
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NO.: 08-2108
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Linardi Gouw and Francisca Hermawan, a/k/a Francisca Hermanwan, in the
amount of $146,648.28, which is itemized as follows:
Principal $132,632.66
Interest to 08/08/08 $ 8,959.12
Late Charges to 08/08/08 $ 404.13
Escrow Deficiency to 08/08/08 $ 678.18
Corporate Advances $ 174.19
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $1 46,648.28
with interest on the principal sum at the rate of $26.27 per diem (as may change from time to
time in accordance with the terms of the Note) from August 8, 2008, 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:
Brian M. Kile, 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 Brian M. Kile, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants were not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copies.
Sworn to and subscribed before me
this day of ? Ww ? 2008.
n
SYLVANIA
COMMONWEALTHPENN
Nom SeO
Elizabeth M. Paiarla, WXryoubllc
(?jY?E X12
Member. Pennsylvania Assodation of Notaries
P
E7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CHASE
MANHATTAN MORTGAGE CORPORATION,
CIVIL DIVISION
Plaintiff,
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
TO: Linardi Gouw
401 Kunkle Lane
Mechanicsburg, PA 17050
DATE OF NOTICE: July 21, 2008
NO.: 08-2108
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 or Toll Free (800) 990-9108
GRENEN & BIRSIC, P.C.
By:
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
FIRST CLASS MAIL, POSTAGE PREPAID (412) 281-7650
E
0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CHASE
MANHATTAN MORTGAGE CORPORATION,
CIVIL DIVISION
Plaintiff,
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
TO: Linardi Gouw
P.O. Box 696
New Cumberland, PA 17070
DATE OF NOTICE: July 21, 2008
NO.: 08-2108
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 or Toll Free (800) 990-9108
GRENEN & BIRSIC, P.C.
B r?
Y:
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
FIRST CLASS MAIL, POSTAGE PREPAID (412) 281-7650
E
Ell
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LI.C, s/b/m/t CHASE CIVIL DIVISION
MANHATTAN MORTGAGE CORPORATION,
Plaintiff,
NO.: 08-2108
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
TO: Francisca Hetmawan, a/k/a Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
DATE OF NOTICE: July 21, 2008
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 or Toll Free (800) 990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
GRENEN & BIRSIC, P.C.
By:
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
?r s
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.: 08-2108
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
TO: Francisca Hermawan, a/k/a Francisca Hermanwan
P.O. Box 696
New Cumberland, PA 17070
DATE OF NOTICE: July 21, 2008
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 or Toll Free (800) 990-9108
GRENEN & BIRSIC, P.C.
By:
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
FIRST CLASS MAIL, POSTAGE PREPAID (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,
NO.: 08-2108
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Linardi Gouw
401 Kunkle Lane
Mechanicsburg, PA 17050
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on e
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $146,648.28
with interest on the principal sum at the rate of $26.27 per diem (as may change from time to
time in accordance with the terms of the Note) from August 8, 2008, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
vs.
NO.: 08-2108
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF ORDEAL, DECREE OR JUDGMENT
TO: Linardi Gouw
P.O. Box 696
New Cumberland, PA 17070
( ) 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: $146,648.28
with interest on the principal sum at the rate of $26.27 per diem (as may change from time to
time in accordance with the terms of the Note) from August 8, 2008, 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.
ok-t? J
Deputy
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,
NO.: 08-2108
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, aWa
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Francisca Hermawan, a/k/a Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on $-lq- Q?r
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $146,648.28
with interest on the principal sum at the rate of $26.27 per diem (as may change from time to
time in accordance with the terms of the Note) from August 8, 2008, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
NO.: 08-2108
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF ORDER., DECREE OR JUDGMENT
TO: Francisca Hermawan, a/k/a Francisca Hermanwan
P.O. Box 696
New Cumberland, PA 17070
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on 9'-1q-0e-
) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $146,648.28
with interest on the principal sum at the rate of $26.27 per diem (as may change from time to
time in accordance with the terms of the Note) from August 8, 2008, 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.
I 6?9?
Deputy
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Caption:
PRAECIPE FOR WRIT OF EXECUTION
( ) Confessed Judgment
Chase Home Finance LLC, s/b/m/t (XX ) Other
Chase Manhattan Mortgage Corporation
VS.
Amount Due $146,648.28
Linardi Gouw and Francisca
Hermawan, a/k/a Francisca
Hermanwan
Interest $ 3,508.10 (from 8/9/08 to Sale)
: 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)
County,
401 Runkle Lane, Mechanicsburg, PA 17050
(see attached description)
PRAECIPE .FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the 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).
71 (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 Z/f ZO?
File No. 08-2108 Civil
Signature:
Print Name:
Address:
Attorney for:
Telephone:
Supreme Court ID No
Kristine M. Anthou
GRENEN B BMW
PITTSBUROK PA 15222
Plaintiff
(412) 281-7650
77991
(over)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
LINARDI GOUW and
NO.: 08-2108 Civil
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
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 Linardi Gouw and Francisca Hermawan located at 401
Kunkle Lane, Mechanicsburg, PA 17050 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
1. The name and address of the owners or reputed owners:
Linardi Gouw 401 Kunkle Lane
Francisca Hermawan Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
I
i
2. The name and address of the defendants in the judgment:
Linardi Gouw
Francisca Hermawan, a/k/a
Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
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 [PLAINTIFF]
Manhattan Mortgage Corporation
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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
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:
Tenant(s)
401 Kunkle Lane
Mechanicsburg, PA 17050
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 unworn falsification to authorities.
Kristin . Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS < < ' DAY OF OV 2008.
No 6y Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
Vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
CIVIL DIVISION
NO.: 08-2108 Civil
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974,41 P.S.101, ET. SEQ.
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, 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.
§ 1680.401 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
Defendants are not "residential mortgage debtors" as defined in 41 P. S. §101.
SWORN TO AND SUBSCRIBED BEFORE
ME HIS / qA DAY OF 9R q U-1 j 2008.
/ / i?W
Notary Pu is
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
LINARDI GOUW and
NO.: 08-2108 Civil
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
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, Attorney for the Plaintiff, who being duly
sworn according to law deposes and says that the owners of the property located at 401 Kunkle Lane,
Mechanicsburg, Pennsylvania 17050 are Defendants, Linardi Gouw and Francisca Hermawan, who
reside at 401 Kunkle Lane, Mechanicsburg, Pennsylvania 17050, to the best of her information,
knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF (Notary ublic
COMMONVI T PENVS1rLVAt?IIA
Notarial sew
RobW= Q Koe"Y' Notary PLd*
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
NO.: 08-2108 Civil
Plaintiff,
vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Linardi Gouw
401 Kunkle Lane
Mechanicsburg, PA 17050
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 December 10, 2008, at 10:00 A.M., the following described real estate, of which Linardi Gouw
and Francisca Hermawan are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
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.
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan,
Defendants,
at Execution Number 08-2108 in the amount of $150,156.38.
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.
By:
Kristin . 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,
NO.: 08-2108 Civil
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
LONG FORM DESCRIPTION
ALL that certain lot or tract of land situated in Hampden Township, Cumberland County, Pennsylvania, more
particularly bounded and described as follows, to wit:
BEGINNING at a point at the eastern side of a proposed fifty (50) foot right-of-way and corner of land now of
Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his
wife, North 76 degrees East eighty (80) feet to 1 ands now or formerly of John C. Kunkel; thence South 23
degrees East one hundred eighty-one and five-tenths (181.5) feet to a point at comer of land now of Frank
Brice, Sr. and Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife,
South 76 degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence
along said Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five-tenths
(181.5) feet to a point, the place of beginning.
KNOWN and numbered as 401 Kinkle Lane, Mechanicsburg, PA 17050.
PARCEL No. 10-22-0527-133
BEING the same premises which Jeanne E. Marshall, by deed dated August 15, 2006 and recorded in the
Office of the Recorder of Deeds of Cumberland County on August 31, 2006, at Deed Book Volume 276, Page
2107, granted and conveyed unto Linardi Gouw and Francisca Hermawan.
GRENEN & BIRSIC, P.C.
iLL c t?_
By:
Kristilne M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
NO.: 08-2108 Civil
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Francisca Hermawan
401 Kunkle Lane
Mechanicsburg, PA 17050
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 December 10, 2008, at 10:00 A.M., the following described real estate, of which Linardi Gouw
and Francisca Hermawan are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
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.
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan,
Defendants,
at Execution Number 08-2108 in the amount of $150,156.38.
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.
C
By
Krist . 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.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NO.: 08-2108 Civil
LONG FORM DESCRIPTION
ALL that certain lot or tract of land situated in Hampden Township, Cumberland County, Pennsylvania, more
particularly bounded and described as follows, to wit:
BEGINNING at a point at the eastern side of a proposed fifty (50) foot right-of-way and corner of land now of
Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his
wife, North 76 degrees East eighty (80) feet to 1 ands now or formerly of John C. Kunkel; thence South 23
degrees East one hundred eighty-one and five-tenths (181.5) feet to a point at corner of land now of Frank
Brice, Sr. and Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife,
South 76 degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence
along said Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five-tenths
(181.5) feet to a point, the place of beginning.
KNOWN and numbered as 401 Kinkle Lane, Mechanicsburg, PA 17050.
PARCEL No. 10-22-0527-133
BEING the same premises which Jeanne E. Marshall, by deed dated August 15, 2006 and recorded in the
Office of the Recorder of Deeds of Cumberland County on August 31, 2006, at Deed Book Volume 276, Page
2107, granted and conveyed unto Linardi Gouw and Francisca Hermawan.
GRENEN & BIRSIC, P.C.
By: 1L ?1-C c
Kristine 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 08-2108 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 LINARDI GOUW and FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN
(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 $146,648.28 L.L.$ 0.50
Interest from 8/09/08 to Sale - $3,508.10
Atty's Comm % Due Prothy $2.00
Atty Paid $262.17 Other Costs
Plaintiff Paid
Date: 8/22/08 O
Prothon
(Seal) By:
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC
ONE GATEWAY CENTER, NINE WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone : 412-281-7650
Deputy
Supreme Court ID No. 77991
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NO.: 08-2108
TYPE OF PLEADING
Pa. R.C.P. RULE 3129.2(c)(2)
PURSUANT TO RULE 3129.1
LIENHOLDER AFFIDAVIT OF
SERVICE
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
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,
Plaintiff,
NO.: 08-2108
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the
following Affidavit regarding service of the notice of the sale of real property on all persons
named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows
1. By letters dated August 27, 2008, undersigned counsel served all persons (other
than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule
3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set
forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit
Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are
marked Exhibit "A", attached hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
Kris ' M. Anthou, Es 'ire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS ?A DAY OF AllyX 1 , 2008.
(511'2AW? A--tlr"
otary Pu tic
COMMONWEALTH OF PENNSYLVANIA
NotmW Seal
Eitabetl? M. Palaw. Notary PubNc
C1y Of Pftburgh, Ale"V County
My Corer bWm Eames Jan. 6,2D12
Member. Penneylvenle AeeoolWan of No wins
EXHIBIT "A"
I ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
NO.: 08-2108 Civil
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
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 Linardi Gouw and Francisca Hermawan located at 401
Kunkle Lane, Mechanicsburg, PA 17050 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
1. The name and address of the owners or reputed owners:
Linardi Gouw 401 Kunkle Lane
Francisca Hermawan Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
f
(I
2. The name and address of the defendants in the judgment:
Linardi Gouw
Francisca Hermawan, a/k/a
Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
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 [PLAINTIFF]
Manhattan Mortgage Corporation
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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
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:
Tenant(s) 401 Kunkle Lane
Mechanicsburg, PA 17050
Ilk
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 unworn falsification to authorities.
t.?(,C $Jl_ ( rt r P
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF Cat CI 1? 2008.
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
Vs.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NO.: 08-2108
TYPE OF PLEADING
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
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
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,
Plaintiff,
NO.: 08-2108
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes the following
Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on December 10,
2008 as follows:
1. Linardi Gouw and Francisca Hermawan, a/k/a Francisca Hermanwan are the owners of
the real property and have not entered an appearance of record.
2. On June 9, 2008, this Court entered an Order authorizing Plaintiff to serve Defendants,
by posting the property and serving the Defendants by certified mail return receipt requested and first
class mail to addresses set forth in the Order, with service to be valid upon posting and mailing. A true
and correct copy of the Order is marked as Exhibit "A" attached hereto and made a part hereof.
3. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on August 27, 2008, the undersigned
counsel served Defendant, Linardi Gouw, with a true and correct copy of Plaintiffs notice of the sale of
real property by certified mail, return receipt requested, and regular U.S. mail postage prepaid, addressed
to P.O. Box 696, New Cumberland, PA 17070 and 401 Kunkle Lane, Mechanicsburg, PA 17050. True
and correct copies of the U.S. Postal Service form 3800, Article Number 7007 3020 0001 8989 1168 and
7007 3020 0001 8989 1175, and the Certificate of Mailing, evidencing service by certified mail and first
class mail on the Defendant, are marked Exhibit "B", attached hereto and made a part hereof.
4. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on August 27, 2008, the undersigned
counsel served Defendant, Francisca Hermawan, a/k/a Francisca Hermanwan, with a true and correct
copy of Plaintiffs notice of the sale of real property by certified mail, return receipt requested, and regular
U.S. mail postage prepaid, addressed to P.O. Box 696, New Cumberland, PA 17070 and 401 Kunkle
Lane, Mechanicsburg, PA 17050. True and correct copies of the U.S. Postal Service form 3800, Article
Number 7007 3020 0001 8989 1144 and 7007 3020 0001 8989 1151, and the Certificate of Mailing,
evidencing service by certified mail and first class mail on the Defendant, are marked Exhibit "C",
attached hereto and made a part hereof.
5. On September 20, 2008, Sheriff's Office of Cumberland County posted the property
located at 401 Kunkle Lane, Mechanicsburg, PA 17050. A true and correct copy of Sheriff's return of
Service is marked Exhibit "D", attached hereto and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my personal
knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
:... tzt (. L? L
BY:
Kri tine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS " DAY OF " xALA) , 2008.
LJ??
`
"?&tA )I
Notary Public'
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Pai" Notary PW*
CIV Of PNbbugh, A680" COU*
* Cliff" bn Ekes Jan. 6, 2012_
Mombsr, PennsylveNs As odation of NOWW
EXHIBIT "A"
E?
CHASE HOME FINANCE LLC, IN THE COURT OF COMMON PLEAS OF
s/b/m/t CHASE MANHATTAN CUMBERLAND COUNTY, PENNSYLVANIA
MORTGAGE CORPORATION,
PLAINTIFF
V.
LINARDI GOUW AND
FRANCISCA HERMAWAN,
a/k/a FRANCISCA HERMANWAN,
DEFENDANTS NO. 08-2108 CIVIL
ORDER OF COURT
AND NOW, this 9m day of June, 2008, upon consideration of the within
Motion for Service of the Complaint in Mortgage Foreclosure Pursuant to Special
Order of Court,
IT IS HEREBY ORDERED AND DIRECTED that the Sheriff of
Cumberland County is hereby directed to serve Defendants, Linardi Gouw and
Francisca Hermawan, a/k/a Francisca Hermanwan with a true and correct copy
of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at
401 Kunkle Lane, Mechanicsburg, PA 17050 and Plaintiff is permitted to serve
Defendants by certified mail, return receipt requested and by First-Class U.S.
Mail, postage pre-paid at both 401 Kunkle Lane, Mechanicsburg, PA 17050, and
P. O. Box 696, New Cumberland, PA 17070. Service upon the Defendants shall
be deemed complete and valid upon posting by the Sheriff and mailing by the
Plaintiff.
By the Court,
M. L. Ebert, Jr., J.
F RECEIVED JUN t 7 2008
EXHIBIT "B"
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EXHIBIT "D"
Chase Home Finance LLC, W m/t Chase
Manhattan Mortgage Corporation
VS
Linardi Gouw and Francisca Hermawan a/k/a
Francisca Hermanwan
In the Court of Anon Pleas of
Cumberland County, Pennsylvania RECEIVED NO V - 3 20
Writ No. 2008-2108 Civil Term
Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on
September 20, 2008 at 1130 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: Linardi Gouw
and Francisca Hermawan a/k/a Francisca Hermanwan by posting the premises located at 401
Kunkle Lance, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with
the said true and correct copy of the same.
Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
October 09, 2008 at 1227 hours, she posted a true copy of the within Real Estate Writ, Notice,
Poster and Description, in the above entitled action, upon the property of Linardi Gouw and
Francisca Hermawan a/k/a Francisca Hermanwan located at 401 Kunkle Lane, Mechanicsburg,
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 defendants, to wit: Linardi Gouw
and Francisca Hermawan a/k/a Francisca Hermanwan by regular mail to their last known address of
401 Kunkle Lane, Mechanicsburg, PA 17050. These letters were mailed under the date of October
7, 2008 and returned to the Sheriffs Office on October 9, 2008 marked unclaimed.
So Ai}s r • - .?
R. Thomas Kline, Sheriff
BY C'
Real Estate S rgeant
r°'
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Chase Home Finance LLC is the grantee the same having been sold to said
grantee on the 10th day of December A.D., 362008, under and by virtue of a writ Execution issued on
the 22nd day of Ate, A.D., 202008, out of the Court of Common Pleas of said County as of Civil
47
Term, civil Number 2108, at the suit of Chase Home Finance LLC against Linardi Gouw and Francisca
Hermawan aka Francisca Hermanwan is duly recorded as Instrument Number 200901281.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and teal of said office this /&/ day of
A.D.
N
of Deeds
ft=dif 01 D; Z'U, Cwmbarland County. CadL*, PA
My Con-R.' "Expo®s the First Monday of Jan. 2010
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. 2008-2108 Civil Term
Linardi Gouw and Francisca Hermawan a/k/a
Francisca Hermanwan
Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on
September 20, 2008 at 1130 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: Linardi Gouw
and Francisca Hermawan a/k/a Francisca Hermanwan by posting the premises located at 401
Kunkle Lance, Mechanicsburg, Cumberland County, Pennsylvania pursuant to order of court with
the said true and correct copy of the same.
Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
October 09, 2008 at 1227 hours, she posted a true copy of the within Real Estate Writ, Notice,
Poster and Description, in the above entitled action, upon the property of Linardi Gouw and
Francisca Hermawan a/k/a Francisca Hermanwan located at 401 Kunkle Lane, Mechanicsburg,
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 defendants, to wit: Linardi Gouw
and Francisca Hermawan a/k/a Francisca Hermanwan by regular mail to their last known address of
401 Kunkle Lane, Mechanicsburg, PA 17050. These letters were mailed under the date of October
7, 2008 and returned to the Sheriffs Office on October 9, 2008 marked unclaimed.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and
legal notice had been given according to law, he exposed the within described premises at public
venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10,
2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Kristine Anthou on
behalf of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation. It being the
highest bid and best price received for the same, Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation of 3415 Vision Drive, Columbus, OH 43219, being the buyer in
this execution, paid to Sheriff R. Thomas Kline the sum of $1,012.14.
Sheriffs Costs:
Docketing $30.00
Poundage 19.85
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Mileage 24.00
Levy 15.00
Surcharge 30.00
Posting 12.00
Law Journal 355.00
Patriot News 346.37
Share of Bills 14.92
Distribution of Proceeds 25.00
Sheriff s Deed 49.50 a /V 9
? ??
$1,012.14
So Answers:
R. Thomas Kline, Sheriff
t
BY \.1 b VV1.?
Real Estate Slergeant
ps -cb
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
NO.: 08-2108 Civil
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
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 Linardi Gouw and Francisca Hermawan located at 401
Kunkle Lane, Mechanicsburg, PA 17050 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
1. The name and address of the owners or reputed owners:
Linardi Gouw 401 Kunkle Lane
Francisca Hermawan Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
i 11.1 .
2. The name and address of the defendants in the judgment:
Linardi Gouw
Francisca Hermawan, a/k/a
Francisca Hermanwan
401 Kunkle Lane
Mechanicsburg, PA 17050
P.O. Box 696
New Cumberland, PA 17070
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 [PLAINTIFF]
Manhattan Mortgage Corporation
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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
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:
Tenant(s)
401 Kunkle Lane
Mechanicsburg, PA 17050
Ll
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 unworn falsification to authorities.
Kristin M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF CUI 2008.
N6 6y Public
COMMONWEALTH OF PENNSYLVANIA
Not" Seal
Rebewe G. Koodw, Notery Ptd*
CKy OFPfNahogN ANep"Courti
My Comrn"M N*M Jum 2, 9011
Metmber. P"A*VJv&A1* AlwwdeA M ""voc,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
NO.: 08-2108 Civil
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Linardi Gouw
401 Kunkle Lane
Mechanicsburg, PA 17050
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 December 10, 2008, at 10:00 A.M., the following described real estate, of which Linardi Gouw
and Francisca Hermawan are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
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.
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan,
Defendants,
at Execution Number 08-2108 in the amount of $150,156.38.
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.
By:
Kristin. 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,
NO.: 08-2108 Civil
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FR.ANCISCA HERMANWAN,
Defendants.
LONG FORM DESCRIPTION
ALL that certain lot or tract of land situated in Hampden Township, Cumberland County, Pennsylvania, more
particularly bounded and described as follows, to wit:
BEGINNING at a point at the eastern side of a proposed fifty (50) foot right-of-way and corner of land now of
Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his
wife, North 76 degrees East eighty (80) feet to 1 ands now or formerly of John C. Kunkel; thence South 23
degrees East one hundred eighty-one and five-tenths (181.5) feet to a point at corner of land now of Frank
Brice, Sr. and Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife,
South 76 degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence
along said Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five-tenths
(181.5) feet to a point, the place of beginning.
KNOWN and numbered as 401 Kinkle Lane, Mechanicsburg, PA 17050.
PARCEL No. 10-22-0527-133
BEING the same premises which Jeanne E. Marshall, by deed dated August 15, 2006 and recorded in the
Office of the Recorder of Deeds of Cumberland County on August 31, 2006, at Deed Book Volume 276, Page
2107, granted and conveyed unto Linardi Gouw and Francisca Hermawan.
GRENEN & BIRSIC, P.C.
Kristine 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
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
NO.: 08-2108 Civil
Plaintiff,
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Francisca Hermawan
401 Kunkle Lane
Mechanicsburg, PA 17050
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, 2ed Floor
1 Courthouse Square
Carlisle, PA 17013
on December 10, 2008, at 10:00 A.M., the following described real estate, of which Linardi Gouw
and Francisca Hermawan are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF LINARDI GOUW AND FRANCISCA
HERMAWAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN HAMPDEN TWP.,
CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING
KNOWN AND NUMBERED AS 401 KUNKLE LANE, MECHANICSBURG, PA 17050. DBV 276, PAGE
2107, AND PARCEL #10-22-0527-133.
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.
Linardi Gouw and Francisca Hermawan,
a/k/a Francisca Hermanwan,
Defendants,
at Execution Number 08-2108 in the amount of $150,156.38.
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.
?'k
By:.? L. /--t
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,
NO.: 08-2108 Civil
VS.
LINARDI GOUW and
FRANCISCA HERMAWAN, a/k/a
FRANCISCA HERMANWAN,
Defendants.
LONG FORM DESCRIPTION
ALL that certain lot or tract of land situated in Hampden Township, Cumberland County, Pennsylvania, more
particularly bounded and described as follows, to wit:
BEGINNING at a point at the eastern side of a proposed fifty (50) foot right-of-way and corner of land now of
Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his
wife, North 76 degrees East eighty (80) feet to 1 ands now or formerly of John C. Kunkel; thence South 23
degrees East one hundred eighty-one and five-tenths (181.5) feet to a point at corner of land now of Frank
Brice, Sr. and Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife,
South 76 degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence
along said Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five-tenths
(181.5) feet to a point, the place of beginning.
KNOWN and numbered as 401 Kinkle Lane, Mechanicsburg, PA 17050.
PARCEL No. 10-22-0527-133
BEING the same premises which Jeanne E. Marshall, by deed dated August 15, 2006 and recorded in the
Office of the Recorder of Deeds of Cumberland County on August 31, 2006, at Deed Book Volume 276, Page
2107, granted and conveyed unto Linardi Gouw and Francisca Hermawan.
GRENEN & BIRSIC, P.C.
By: ; L-"/
Kristine 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 08-2108 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 LINARDI GOUW and FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN
(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 $146,648.28
L.L.$ 0.50
Interest from 8/09/08 to Sale -- $3,508.10
Atty's Comm %
Atty Paid $262.17
Plaintiff Paid
Date: 8/22/08
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs
Prothonot
&Ae
By:
Deputy
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC
ONE GATEWAY CENTER, NINE WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
Real Estate Sale #42
On August 27, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA
Known and numbered as 401 Kunkle Lane, Mechanicsburg
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: August 27, 2008 By: a r ,
Real E to Sergeant
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 31, November 7 and November 14, 2008
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
LisaMarie Coyne,
SWORN-M AND SUBSCRIBED before me this
14 day of November, 2200
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO. CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
Rte, MWATZ BALE NO. 42
Writ No. 2008-2108 Civil
Chase Home Finance LLC
s/b/m/t Chase Manhattan
Mortgage Corporation
VS.
Linardi Gouw and
Francisca Hermawan a/k/a
Francisca Hermanwan
Atty.: Kristine M. Anthou
LONG FORM DESCRIPTION
ALL that certain lot or tract of
land situated in Hampden Township,
Cumberland County, Pennsylvania,
more particularly bounded and de-
scribed as follows, to wit:
BEGINNING at a point at the
eastern side of a proposed fifty (50)
foot right-of-way and corner of land
now of Elmer A. Brice and Janet A.
Brice, his wife; thence along said
land of Elmer A. Brice and Janet
A. Brice, his wife, North 76 degrees
East eighty (80) feet to lands now or
formerly of John C. Kunkel; thence
South 23 degrees East one hundred
eighty-one and five-tenths (181.5)
feet to a point at corner of land now of
Frank Brice, Sr, and Verna B. Brice,
his Ale; thence along said land of
wit Brice, Sr. and. Verna B. Brice,
his wife, South 76 degrees West
e*W (80) feet to the Eastern side
of a proposed fifty (50) foot right-of-
way; thence along said Eastern side
of said right-of-way North 23 degrees
West one hundred eighty-one and
five-tenths (181.5) feet to a point, the
place of beginning.
KNOWN and numbered as 401
Kinkle Lane, Mechanicsburg, PA
17050.
PARCEL No. 10-22-0527-133.
BEING the same premises which
Jeanne E. Marshall, by deed dated
August 15, 2006 and recorded in
the Office of the Recorder of Deeds
of Cumberland County on August
31, 2006, at Deed Book Volume 276,
Page 2107, granted and conveyed
unto Linardi Gouw and Francisca
Hermawan.
he Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
PAAAA iot•News
Now 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 end/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:
10/29/08
11/05/08
11/12/08
Sworn to an4ubscribed beforg me tip-25 day of November. 2008 A.D.
Notary Public
%0MM0NwEALT,i 03 - DENNS
- -• L? ?F`NIF
iVotalal Sea'
Sherrrie L. Kisner, !,4ct°try Pui?lic
(AY Of Hemi bufq DaUPhin county
co?nrnk-'sion fr*, I Nov iyB. 20 i .
- ?__
l ember. Da,n9vlbsrraAs?ctrs?ti n thf N
ntarip
Heal instate gale No. 42
Writ No. 2008-2108 Civil Term
Chase Home Finance LLC, sibs
Snit Chase Manhattan Mortgage
Corporation
VS
Linardi Gouw and
Francisca Hermawan aikia
Francisca Hermanwan
Attorney Kristine Anthou
LEGAL DESCRIPTION
ALL that certain lot or tract of land situated ir:
Hampden Township, Cumberland County.
Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a point at the eastern side of s
proposed fifty (50) foot right-of-way and comer
of land now of Elmer A. Brice and Janet A.
Brice, his wife; thence along said land of Elmer
A. Brice and Janet A. Brice. his wife. North 76
degrees East eighty (80) feet to lands now or
"Omterly of John C, Kunkel; thence South 23
degrees East one hundred eighty-one and fne-
tenths (181.5) feet to a point at corner of land
now of Frvik Brice, Sr. and Verna B. Brice, his
wife; thence along said land of Frank Brice, Sr.
and Verna B. Brice, his wife, South 76 degrees
Yiesi eighty (8u) leer to the Eastern side of
proposed fifty (50) foot right-of-way; thence
along said Eastern side of said right-of-wa
North 23 degrees West one hundred eighty-one
and five-tenths (181.5) feet to a point, the place
of beginning.
KNOWN and numbered as 401 Kunkle Lanc_
Mechanicsburg, PA 17050. PARCEL No. 10-22
0527-133
BEING the same premises which Jeanne V
Marshall, by deed dated August 15, 2006 and
recorded in the Office of the Recorder of Deeds
of Cumberland County on August 31, 2006, at
Deed Book Volume 276, Page 2107, granted and
conveyed unto Linardi Gouw and Francisca
tt FlTi18 W?i l1.