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HomeMy WebLinkAbout08-3566IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, 3S.L16, nn- ,1 NO.: U 1. Plaintiff, vs. THOMAS S. WHITE, Defendant. TO DEFENDANT TYPE OF PLEADING CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FR SERVICE HEREOF ATTORNEY FOR PLAINTIFF 1 HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANT IS: 17 Creekside Drive E ola, PA 17025 ATT NEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 17 Creekside Drive. Borough of West Fairview (CI BORO, TOWNSHIP,WARD) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Daniel J. Birsic, Esquire Pa. I.D. #48450 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. THOMAS S. WHITE, Defendant. NO.. 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 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.: d$ - .3SLL a u?L Plaintiff, VS. THOMAS S. WHITE, Defendant. 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 Defendant, Thomas S. White, is an individual whose last known address is 17 Creekside Drive, Enola, Pennsylvania 17025. On or about January 3, 1992, Defendant executed a Note in favor of Sears Mortgage Corporation ("SMC") in the original principal amount of $56,700.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about January 3, 1992, as security for payment of the aforesaid Note, Defendant made, executed and delivered to SMC a Mortgage in the original principal amount of $56,700.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992 in Mortgage Book Volume 1041, Page 1110. 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. SMC assigned all of its right, title and interest in and to aforesaid Note and Mortgage to Metmore Financial, Inc. ("MFI") pursuant to a certain Assignment of Mortgage recorded in the Office of the Recorder of Deeds of Cumberland County on October 8, 1992 at Mortgage Book Volume 428, Page 646. 6. MFI assigned all of its right, title and interest in and to aforesaid Note and Mortgage to Plaintiff pursuant to a certain Assignment of Mortgage. 7. Defendant is the record and real owner of the aforesaid mortgaged premises. 8. Defendant is 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. Defendant is due for the December 1, 2007 payment. 9. On or about February 1, 2008, Defendant was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first-class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 101, et seq. 10. The amount due and owing Plaintiff by Defendant is as follows: Principal $39,147.38 Interest to 5/27/08 $ 1,793.22 Late Charges to 5/27/08 $ 185.42 Escrow Deficiency to 5/27/08 $ 1,317.41 Corporate Advances $ 70.00 Attorneys' Fees $ 850.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $45,863.43 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $45,863.43 with interest thereon at the rate of $8.56 per diem from May 27, 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: ,L,.e? Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT A LENDER* 07-37-52238 LOW :,Or, .?A at;: OT Y! q VA rrs 16- 433% abN PENNSYLVANIA pORppnM"l. Sstloe 1010, Title VA CASE t-CH"4'48951=-1L= ='= U.S.C. Aw"Wo to Federal MORTGAGE NOTE •?°'? -?*.7, ? r 1 Nr 0?. i991A?1oA?lba G: •?r'1 ?'.:: •?. ,;::era': ,. NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOU.TriT:HiE•ko APPROVAL OF THE DEPARTMENT OF VjETERA?NS9C.; AFFAIRS OR ITS AUTHORIZED AGENT. CAMP HILL, Pennsylvania. $56,700.00 JANUARY 3 , 1992 FOR VALUE RECEIVED, the undersigned, THOMAS S. WHITE. UNMARRIED MAN , hereinafter called the Maker, promises to pay to SEARS MDRIOAGE CORPORATION .,or order, a corporation organized and existing under the laws of the STATE OF OHIO hereinafter designated as the Payee, the principal sum of ---------------------------------------------------- FIFTY-SIX THOUSAND SEVEN HUNDRED AND 00/100----------------- =------------------------------------------- ----------------------------------------------------------------------- Dollars ($56.700.00-------------- ) with interest from date at the rate of EIGHT------------------------------------------------------- per centum (---------------- 9. o000 %) per annum on the unpaid balance until paid. The said principal and interest shell be payable at the office of SEARS NORTBAGE CORPORATION InRiVERWOODS. ILLINOIS 60015 4112500 LAKE COOK ROAD or shch plea as the holder may designate in writing in monthly installments of -------------------------------- FOUR HUNDRED SIXTEEN AND 04/100--------------------------------------------------------------------°= - -------------------------------------------------- Dollars($416.04---------------- ), comma i ng on the first day of MARCH ,19 92 , and on the first day of each month thereafter until the principal and Interest are fully paid, excerpt Out the final payment of the entire indebtedness evidenced hereby, If not sooner paid, shall be due and payable on the first day of. FEBRUARY, 2022 Privilege is reserved to prepay at any time, without premium or fee, the entire Indebtedness or any part IhL-.eof not less than the amount of one installment, or One Hundred Dollars ($100.00), whichever is less. ?err. •eyrr.-nt In full dull be credited on the date received. Partial prepayment, other than on an installment due .rate; nee:: not be credited. until the next following installment due date or thirty days after such prepayment,' wnichever Is earlier. Simultaneously with the execution of this Note the Maker has executed and delivered to the Payee a Mortgage sec--.d upan certain premises situated in the County of CUMBERLAND Commonwealth of Pennsylvania, more particularly described in the Mortgage. All of the terms, covenants, provisions, condition, stipulations and agreements contained in said Mortgage to be kept and performed by the Maker are hereby made a part of this Note to the same extent and with the same force and effect as if they were full ?..,u forth herein, and the Maker covenants and agrees to perform the some, or cause the some to be kept and aerforrned, strictly in accordance with the termsand provisions thereof. The whole of the principal sum or any part thereof, and of any other sums of money secured by the Mortgage given to secure this Note, shall, forthwith, at the option of the Payee or any subsequent holder thereof, become due and•poyable immedietely, without notice or demand, if default be made in any payment under this Note, and if the default is not made good prior to the due date or the next such installment; or upon the happening of any default wh'.:h, by the terms of the Mortgage given to secure this Note, shall entitle the Payee, or any subsequent holder hereof, to declare the same, or any part thereof, lobe due and payable. The Maker does hereby empower any attorney of any court of record within the United States or elsewhere to appear for Maker, with or without a declaration filed, and confess judgment or judgments against said Maker in favor of the Payee or any subsequent holder hereof, as of any term, for the entire unpaid principal of this Note, and all other sums paid by the holder hereof to or on behalf of the Maker pursuant to the terms of this Note or said Mortgage, and all arreoraga of interest thereon, together with costs of suit, attorney's commission of FIVE--------------------------------------------- (--5.DODD) % for collection. and a release of all errors, on which ®r- ment execution or executions may Issue forthwith. The Maker hereby waives the right of inquisition on all pprroolevied upon to collect the indebtedness evidenced hereby and does voluntarily condemn the same and authorizes tite Prothonotary to enter such condemnation, and waives and releases all laws, now in fora or hereafter enacted, relating to exemption, approlsement or stay of execution. The agreements herein contained dell bind, and the benefits and advantages shall inure to, the respective :.recess:... and assigns of the parties herelo. Wherever used, the singular number shall include the plural, the plural .he sin&ular, and the use of any gender shall be applicable to all genders. N WITNESS WHEREOF, the Maker has caused these presents to be executed un er sal the day and year :. above write . soled livered the Presenoe of: (Seal) T S S. WHITE (Sal) (Sat) (Sal) THIS IS TO CERTIFY that this is the Notedescribed in and secured by Mortgage of even date herewith secured , on ree l estate situated +.-6HMBEp County, mmon Ith of Pennsylvania. NOTA AL SEAL HMLY F. KELLER, rWrjy t+abra i = . linrr;dorn flrpl, Ctat>bf.: b - 400-21PAI tqIom L MY lsotfrlt ;.-1W Erwbw L*W 4 f E, tE?3 "yotar7 Poara "MP,Me)RiGraEi1e11Ma ?YTA 100 • (600)521-7201 •=XCNOSD (.C)• XC3405D - PAYTOTIMMMOP= INC. MErnpQR FINANCIAL, gTM aN MOB RY WITHOUT RECOURSE PAY TO THE ORDER OF MEETMOR FINANCIAL. INC. BY: Y?cO . ?e?. Mary L Gould Assistant Vice President EXHIBIT B 4 RECE'D FEB 1 0 1992 fj RECORD AND RETURN 10: ;tEi;ORCED-O-=ICE C7 ill- J?'1 SEARS AHILLS CORPORATION RECORD,,' DEEDS 2207 FOREST DRIVE - CU;.!RERLAQ COUNTY-PA. (J/' HARRISBURG, PA 17112 '92 JAN ? Pal 2 12 TA Form is-NIS ti Led i (Spece Aden This Line For Recor/in g Date) R..b.o Geo. 1975. L%* Optional. PENNSYLVANIA Soelim 1910. Title 30, PURCHASE MONEY VA CASE t: LH 448951 N'= %j ' lo Federal MORTGAGE LENDER'S t: 07-97-52238 (A. d w9. i9" NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. The attached RIDER is made a part of this instrument. THIS INDENTURE, made the 3RD year of our Lord one thousand nine hundred and NINETY TWO THOMAS S. WHITE, UNMARRIED RAN day OI JANUARY In the BETWEEN (hereln8}2erC1klied MOrtaagor)and SEARS MORTGAGE CORPORATION a corporation organized and existing under the laws Of THE STATE OF OHIO and havingltsprincipal officeandpost-olfheaddress In RIVERWOODS. ILLINOIS 60015 AT 2500 LAKE COO( ROAD , (herefnaftercalled Mortgagee): WITNESSETH: That the Mortgagor toserine the paymentof ------------------------------------------ FIFTY-SIX THOUSAND SEVEN HUNDRED AND 00/100------------------------------------------------------------ DOIIorS(556,700.00------------- ), With Interest from date, at the rate of EIGHT-------------------------------- -------------------------per centum(----------------- 8,000%) per annum On the unpaid balance until paid, as provided In a Note of even date herewith, from the Mortgagor to the Mortgagee, in monthly Installments of FOUR HUNDRED SIXTEEN AND 04/100-------------------------------------------------------------------------- --------------------------------------------------------------------------------------------------------- ------------------------------------------Doll= (S 416.04--------------- a, commencing on the Ilrst day of MARCH ,19 92 , and continuing thereafter on the list day of each month until such debt Is fully paid, except that, If not sooner paid, the final payment thereof shall be due and payable on the first day of FEBRUARY , 2022 , and also to secure the performance of all covenants, agreements and conditions herein contained, does by these presents grant, bargain, sell, assign, release, convey and confirm to the Mortgagee, ALL the lollowhngdescribed reel property situated in the BOROUGH of WEST FAIRVIEW , County of CUMBERLANC and Commonwealth of Pennsylvania, to wit: SEE ATTACHED COMMONLY KNOWN AS: 17 CREEKSIDE DRIVE. ENOLA. PENNSYLVANIA 17025-2916 TOGETHER with all and singular the buildings, improvemerts, and lixtures On said premises, as well as all additions Or improvements now or hereafter made to sold premises, streets, alleys, passages, ways, waters, water courses, rights, llbertks, privileges. heredliammts, and appurtenances whatsoever thereunto belongtng, or in any wise appettaining, and the level afons and remainders, rents, issue, and profits thereof, and in addition thereto the following described household appliances, which are, and shall be deemed to be, fixtures and a part of the rally, and are a portion of the security for the Indebtedness herein mentioned, namely, PMtol4 40trxpA) nwuo+ XCIIOSDAAA .10 vMO MORTGAGE FORMS • t2131292.9100 • t9001521-72111 C Inilinll?_ XC1405D eo(m 104 1 rw 1110 STGVE REFRIGERATOR ALL CEILING FANS WINDOW TREATMENTS BLINDS provided, however, that the Mortgagor shell be entitled to collect and retain the sold rents, issues, and profits until default hereunder: TO HAVE AND TO HOLD said property, hereby granted, with the appurtenances, unto sold Mortgagee to Its own use forever: This Indenture is made, however, subject to the following covenants, conditions, agreements and stipulations, and the Mortgagor covenants and agrees: 1. That the Mortgagor will promptly pay the principal of and interest on the indebtedness evidenced by the said Note, at the times and in the manner therein provided, with privilege reserved to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less then the amount of one installment, or one hundred dollars ($100.00), whichever is less. Prepayment In full shell be credited on the date received. Partial prepayment, other than on an Installment due date, need not be credited until the next following installment due dote or thirty days after such prepayment, whichever is earlier. 2. To more fully protect the security of this Mortgage, the Mortgagor shall pa to the Mortgagee as trustee Nrtder the lemur of this trust as hereinafter stated) In addition to and concurrently with, each monthly installment of pr:ncipei and Interest until said Note is fully paid, the following sums: (a) A sum equal to the ground rents, if any, next due, plus the premiums that will next become due and payable on policies of fire and other hazard insurance, plus taxes, assessments, and sewer and water rents, next due on the premises covered by this Mortgage (all as estimated by the Mortgagee, and of which the Mortgagor Is ratified) less all sums already paid therefor divided by the number of months lo elapse before one month prior to the date when such ground rents, premiums, taxes, assessments, and sewer and water rents, will become due, such sums to be held by Mortgagee in trust to pay said ground rents, premiums, taxes, assessments, and sewer and water rents. (b) The aggregate of the amounts payable pursuant to subparagraph (a) and those payable on this debt shall be paid in a single payment each month, to be applied to the following items in the order stated: (I) ground rents, taxes, assessments, sewer and water rents, tare and other hazard insurance premiums; (II) interest on this debt; and (III) amortization of the principal of this debt. Any deficiency In the amount of any such aggregate monthly payment shall constitute an event of default hereunder and under sold Note, unless made good by Mortgagor prior to the due date of the next such payment. At Mortgagee's option, Mortgagor will pay a 'late charge" not exceeding four per centum (4%) of any installment when paid more then fifteen (15) days after the due date thereof to cover the extra expense Involved in handling delinquent payments, but such 'late charge" shell not be payable out of the proceeds of any sale made to satisfy the hrdebtedness secured hereby, unless such proceeds of any sale mare to satisfy the Indebtedness secured hereby, unless such proceeds are sufficient to discharge the entire indebtedness and all proper costs and ezper>sa secured thereby. 3. If the total of the payments made by Mortgagor, under (a) of paragraph 2 preceding, shell exceed the er~ou +.of payments actually made by Mortgagee as trustee for ground rents, taxes, assessments, sewer or water iwas, u? innsurance premiums, as the case may be, such excess shall be credited on subsequent payments to be made by Mortgagor for such items or, at Mortgagee's option," trustee, dull be refunded to Mortgagor. If, however, such monthly payments shell not be sufficient to pay such Items when the same shell become due and pyabie, then Mortgagor stall pay to Mortgages as frusta any amount necxsssry to make up the deficien y within thirty (30) days after written notice from Mortpgee stating the amount of the defleiency, which notice may be given by mail. It at any time Mortgagor shell fader to Mortgaggeeee, fo accordance wlih the provisions hereof, the full payment of the entire bdebtehhesa represented hereby, IKortgeges, as trustee, stall !n computing the amount of such i»debtefrness, credit to the account o[ Mortgagor any credit balernce remheinin`` under the provisions of (a) of paragraph 2. If these shell be a debris under any of the provisions of the Note endthis Mortgage securing the same, which results M e public seek of the premiss covered thereby, or it title to the property Is otherwise eo?ired by the Mortgagee after the default, the Morlgesee, as trustee, dull apply, at the time of the ?t of such proocceeeeddIngs or et the time the properly is otherwise acquired by the Mortgagee, the balance then remaining to the it of Mortgagor wader (a) of paragraph 2, as a credit on the Interest accrued and unpaid, and the balance on the principal then remaining unpaid on the Note. 4. Mortgagor shall pay to Mortgagee all ground rents, taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied at any time by any lawful authority upon the premises covered by this Mortgage which, by any present or future law or laws, stall have priority in lion or payment to the debt represented by said Note and secured by this Mortgage, and provision for the payment of which is not otherwise made herein, such payment to be made by Mortgagor within thirty (30) days after demand by Mortgagee, stating the amount. 5. Tlar principal indebtedness hereby evidenced end secured represents money actually used for the acquisition of of for improvements to the premises secured by said Mortgage. 6. Mortgagor will continually maintain hazard insurance, of such type or types and amounts as the Mortgagee nuy from lime to time require, on the improvements now or hereafter on said premiss, and except when payment . all sc.L., premiums has theretofore been made under (a) of paragraph 2 hereof, will pay promptly when due any premium therefor. All insurance shell be carried In companies approved by Mortgagee and the policies and renewals thereof shell be held by Mortgagee and have bttached thereto dos payable clauses in favor of end in form exceptable to Mortpga. In event of foes, Mortgagor will give Immediate notice by mail to Mortgagee, and Mortgagee may make proof of loss if not made promptly by Mortgagor, Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Mortgagee instead of to Mortgagor and Mortgages jointly. The inarance proceeds, or any pert thereof, rimy be applied by Mortgagee at its option either to the reduction of the bdebtedrless or to the restoration or, repair of the property damaged. In the sole and absolute dlscretbn of Morttggage, in event of torecbsure of the Mortgage or trencfer of title to the mortgaged property in parttel or tote) exifinguishment of the Note thereby secured, ell right, title, and Interest of Mortgagor In and to an Insuranex pollelea lthen in forte stall peas to the purchaser or grentes Or sha11 be canceled and the ancelletio proceeds, cf any, retained by Mortgagee. Full power is hereby given lo Mortgagee to settle or compromise all clai,ns wrier shah policies end lo demand, receive end receipt for ell manrys becoming payable thereunder, at771PAIIs9 ,01 XCI-OSDAA13 .ID .p.2.r .InilielL j ?? RoK 1041 P E 1111 7. MOrigiagor shall not execute or file of record any Instrument Which Imposes a restriction upon the sale or occupancy of the property herein described on the basis of race, color or creed. 8. Mortgagor will not suffer any lien superior to the lien created by this Mortgage toattach to or to be enforced against the premises covered by this Mortgage. Mortgagor shall not commit or permit waste; and shall maintain the property In as good condition as at present, reasonable wear and tar excepted. Upon any failure so to maintain, Mortgagee, at its option, may cause reasonable maintenance work to be performed at the cost of Mortgagor. 9. Mortgagee shall hove the right to pay any ground rents, taxes, assessments, sewer and water rents, and all other charges and claims which Mortgagor has agreed to pay under the terms hereof, to advance and pay any runs of money that In its judgment may be necessary to perfect or preserve the title of the premises covered by this Mortgage,or for Insurance premiums or for any authorized maintenance work. Any amount or amounts so pall or advanced shall be aided to the principal debt, shall bar interest at the rate provided for in the principal indebtedness from the date of payment or advance, and shall be secured by this Mortgage ratably with sold principal debt and interest thereon. Mortgagee, at its option, also shall be entitled to be subrogated to any lien, claim, or demand paid by it, or discharged with money advanced by It and secured by this Mortgage. The payments and advances so made shell be payable In approximately equal monthly payments extending over such periods as y be cgree4 upon by the Mortgagor and Mortgagee, but not beyond the due date of the final instalhrnent of the principal debt. In event of failure to agree on date of maturity, the whole of the sum or sums so paid or advanced doll be due and payable thirty (30) days after demand by Mortgagee. 10. The lien of this Mortgagee shall remain in lull force and effect during postponement or extension of the time of payment of the indebtedness, or any put thereof, which it secures. 11. Upon the request of Mortgagee, Mortgagor shall execute and deliver a supplemental Note or Notes for the sum or sums advanced or paid by Mortgagee for the alteration, modernization or improvement of the mortgaged property made at Mortgagor's request; and for maintenance of saki property, or ground rents, taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied against saki property by any lawful authority, or for any other purpose elsewhere authorized hereunder. Sold Note or Notes shall be secured by this Mortgage on a parity with and as fully as if the amounts stated In such Note or Notes were part of that stated in the Note hereby secured. Said supplemental Note or Notes shall bear interest at the rate provided for In the principal Indebtednness and shall be payable in approximately equal monthly payments for such period as may be agreed upon by Mortgagor and Mortgagee. In event of failure to agree on date of maturity, the whole of the sum or sums so advanced or paid shall be due and payable thirty (30) days after demand by Mortgagee; but In no event shell any such maturity of due date extend beyond the due date of the final Installment of the principal debt. 12. If the indebtedness secured hereby be guaranteed or Insured under Title 30, United States Code, such Title and Regulations issued thereunder and in effect on the date hereof shall govern the rights, duties and liabilities of the parties hereto, and any provisions of this or other instruments executed In connection with said indebtedness which are inconsistent with said Title or Regulations are hereby amended to conform thereto. 13.:1, at any time, a Writ of Execution (Money Judgment) or other execution Is properly Issued upon a judgment obtained upon sold Note, or if an Action of Mortgage Foreclosure or any other appropriate action or Gxcxeding to foreclose a mortgage is instituted upon or under this Mortgage, an attorney's commission of FIVE------------------------------------------------ percentum(---------------- 5.0000`b) of said principal debt shall be payable, and recovered In addition to all principal and interest and all other recoverable sums then due, together with costs of suit. 14. If any deficiency In the amount of any aggregate monthly payment mentioned in (b) of paragraph 2 shall not be made good by Mortgagor prior to the due date of the nett such payment, or if default be made at any time In any of the covenants and agreements herein, or in the Notesecured, then and In every such case, the whale principal debt shall, at the option of Mortgagee, become due and payable immediately. Payment thereof and all Interest accrued thereon, with an attorney's commission as hereinbefore mentioned, may be enforced and recovered at once, an,,thbng herein contained to the contrary notwithstanding. in the event of any breach of any covenant, condition, or agreement of said Note, or of this Mortgage, it shall be towtul for Mortgagee to enter upon all and singular the land, buildings, and other rights, corporal and incorporeal, granted by this Mortgage, and to take possession of the same, and of the fixtures and equipment therein, and to have, hold, manage, lease to any person or persons, use and operate the some in such parcels and on such terms and for such periods of time as Mortgagee may deem proper in Its sob discretion. Mortgagor agreeing thst he shall and will, whenever requested by Mortgagee so to do, assign, transfer, and deliver unto Mortgagee any base or sublease; and to collect and receive all rents, issues, and profits of said mortgaged premiss and every put t!'deot, ;or all of which said Note shall be a sufficient warrant whether or not such lase or sublease has been assigned; and to make from time to time all reasonable alterations, renovations, repairs, and replacements thereto, After dacxthns the cost of such alterations, renovations, repairs, replacement$,am the experaea Incident to taking and retaining possession of the mortgaged properly, the management and operation thereof, and to keeping the pruixity insured, to apply any residue of such rents, Issues, and profits to the payment of (a) all ground rents, taxes, charges, claims, assessments, sewer and water rents, and any other liens that may be prior In lien or payment to the debt secured by this Mortgage, with Interest thereon, (b) premiums for said insurance, with interest thereon, (c) the Interest and principal due and secured by this Mortgage with all costs and attorney's fees; In such order or 3 Mortgagee may determine, any statute, low, custom, or use to the contrary notwithstanding. The taking of possession of the mortgaged premises by Mortgagee, as herein provided, shall not relieve any default by Mortgagor, or prevent theenforcement of any of the remedies provided by said Note or this Mortgage. The remedies provided by said Note and this Mortgage or any other Indebtedness therein provided or secured by this Mortgage, and for the performance of the covenants, conditions, and agreements of said Note or this Mortgage are cumulative and concurrent, and may be pursued singly, or successively, or together, at the sole discretba of Mortgagee, and may be exercised as oftenas occasion therefor shall occur. 4IMk-xIPAI iswo + XCI4050AAC .10 P eo KK 1041 PACE 1112 • PROVIDED, that In case default shall be made in the payment of any Installment of principal and interest, or any other payment hereinabove or In the conditions of said recited Note provided for, or in the keeping and performance by the Mortgagor of any covenant or agreement contained therein or in this Mortgage to be by said Mortgagor kept and performed, in the manner and at the time specif led for the perfornwm thereof, such default w:e entitle Mortgagee forthwith to bring and sue out an Action of Mortgage Foreclosure upon this Indenture of Mortgage, or to institute any other appropriate action or proceeding to foreclose a mortgage, and to proceed thereon to judgment and execution, for recovery of said principal debt or sums and all interest thereon and all other sums hereby secured, together with an attorney's commission for collation, as aforesaid, and costs and expenses of such proceeding, and to pursue any and all other appropriate legal or equitable remedies in such ass provided without further stay of execution or other process, any law, usage, or custom to the contrary notwithstanding. Mortgagor expressly waives and relblquishes all benefit that may accrue by virtue of any and every law made or to be made exempting the mortgaged premises or any other premises or property whatever, real or personal, from attachment, levy, or sale under execution, or any part of the proceeds arising from any sale thereof, and all benefit of any slsy of execution or other process. Mortgagor hereby waives and relinquishes unto and in favor of the Mortgagee, all benefit tender all laws now In effect or hereefter passed to relieve the Mortgagor In any manner from the obligations essumed In the Note for which this Indenture is security. -PUT PROVIDED ALWAYS, nevertheless, that if said Mortgagor shell pay or cause to be paid unto the said Mortgagee, the aforesaid debt secured by this Mortgage, when and in the manner hereinbelore mentioned and apiwlated for payment of the same, together with interest and aA other sums hereby secured, then and from thenceforth, this Indenture, and the estate hereby granted, as well as said recited Note, shall tease, determine, and become void, anyihing hereinbefore or In said Note contained to the contrary notwithstanding. It this Mortgage is executed by more than one person as Mortgagor, the liability of each shall be joint and several. i he covenants, conditions, and provisions contained in said Note, or in this Mortgage, shall bind, and the benefits and advantages thereof shall Inure to, the respective heirs, executors, administrators, successors, vendee, and assigns of the parties hereto or thereto; and whenever used in aid Note or in this Mortgage, the singular, number shall Include the plural, the plural the singular, the use of any gender shall be applicable to ell genders, and the term 'Mortgagee' shall include any payee of the indebtedness represented by said Note, or secured by this Mortgage, or any transferee thereof, whether by operation of law or otherwise. IN WITNESS WHEREOF, Mortgagor hereunto sets his hand and seal. Dated the day and year first hereinabove written. SIGNED, SEALED AND DELIVERED !N I -.E PRESENCE OF: a f •? W ?'1^?' (Sat) THOMAS S. WHITE Borroww (Sell) Bwroww (Seal) •Bwmww (Sal) •Borrmwr CERTIFICATE OF RESIDENCE I, the subscriber, Jeanne M. Pigdore , do hereby certify that the correct address of the within-named Mortgagee is 2500 Lake Cook Road, Riverwoods, Illinois 60015 Witness my land this 3rd day of January .19 92 ?.? A t of M COMMONWEALTH OF PENNSYLVANIA ` ){ ss COUNTY OF CUMBERLAND CA this 3rd day of January , A.D., 19 92 before me, came the above-named Thomas S. White ar)draahno.1ledged the within Indenture of Mortgage to be his act and deed, and ?:iesir saw to be recorded as such. ?,........ Y Grand andpal, the day and year aforesaid. D y'f ? My commission expiry '19 'i3 '•~? ^: 1tM of Offl r 71'r_+-?= •..,• .. . N01.?PAL': AL* t:OA?1 8Y FRLY F. !frill EFl R':!? . F*c ) FGDORE F?:rnT*,i..Cumbeolaw "y 1 HARRi11lll?Rfi, PA 17112 fAor?rl+^?kia?xyrvaAlareii Is. eras _t - IPAI ww"01 XCI405DAAD .I0 P.ps 4 of BOO 1041 PAccli 3 ALL THAT CERTAIN piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and describ as follows, to wits BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minute west fifty three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty eight (168) Peet, more or less, to a point; thence north sixty nine (69) degrees thirty (30) minutes east fifty three (53) Peet, more or less, to a stake, the place of BEGINNING. ALL THAT CERTAIN piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoguinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoguinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degrees east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of BEGINNING. State of Pennsylvania t SS t? County of Cumberland S Recorded in the office for the recording of Deeds eMind for uu berfand County, Pa irooVol. Page ' witness my hand an eai of oAice Carlisle, PAthi 'I C, e 1041 PACE 1114 Recorder .14, ell 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 N ? ? N rte` 3 M1 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-03566 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC ET AL VS WHITE THOMAS S 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 unable to locate Him in his bailiwick. ("r)MDT.A TTTT' _ MnT)rr LPr)DL2 but was He therefore returns the the within named DEFENDANT WHITE THOMAS S 17 CREEKSIDE DRIVE NOT FOUND , as to ENOLA. PA 17025 PER NEIGHBOR, HOUSE IS ABANDONED. PER POST OFFICE MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: Docketing Service Affidavit Surcharge Postage 0 0lo 7 4 ? So answers- 18.00 15.00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County GRENEN & BIRSIC 06/25/2008 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 CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. THOMAS S. WHITE, Defendant. TO DEFENDANT You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FR SERVICE HEREOF ATTORNEY FOR PLAINTIFF CIVIL DIVISION NO.. 69 _3-544- TYPE OF PLEADING C,. 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: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANT IS: 17 Creekside Drive ERola, PA 17025 ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION 1 HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 17 Creekside Drive Borough of West Fairview (CI7, BORO, TOWNSHIP, WARD) ATTORNEY FOR PLAINTIFF Daniel J. Birsic, Esquire Pa. I.D. #48450 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 in 1'ejgrt,r? g r i,1 here t. MY hind CO Pit TA i .:lad=t'?? how try 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.: THOMAS S. WHITE, Defendant. 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 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, Plaintiff, NO.. vs. THOMAS S. WHITE, Defendant. 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: 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 Defendant, Thomas S. White, is an individual whose last known address is 17 Creekside Drive, Enola, Pennsylvania 17025. 3. On or about January 3, 1992, Defendant executed a Note in favor of Sears Mortgage Corporation ("SMC") in the original principal amount of $56,700.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about January 3, 1992, as security for payment of the aforesaid Note, Defendant made, executed and delivered to SMC a Mortgage in the original principal amount of $56,700.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992 in Mortgage Book Volume 1041, Page 1110. 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. SMC assigned all of its right, title and interest in and to aforesaid Note and Mortgage to Metmore Financial, Inc. ("MFI") pursuant to a certain Assignment of Mortgage recorded in the Office of the Recorder of Deeds of Cumberland County on October 8, 1992 at Mortgage Book Volume 428, Page 646. 6. MFI assigned all of its right, title and interest in and to aforesaid Note and Mortgage to Plaintiff pursuant to a certain Assignment of Mortgage. 7. Defendant is the record and real owner of the aforesaid mortgaged premises. 8. Defendant is 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. Defendant is due for the December 1, 2007 payment. 9. On or about February 1, 2008, Defendant was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first-class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 101, et seq. 10. The amount due and owing Plaintiff by Defendant is as follows: Principal $39,147.38 Interest to 5/27/08 $ 1,793.22 Late Charges to 5/27/08 $ 185.42 Escrow Deficiency to 5/27/08 $ 1,317.41 Corporate Advances $ 70.00 Attorneys' Fees $ 850.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $45,863.43 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $45,863.43 with interest thereon at the rate of $8.56 per diem from May 27, 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: Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT A l • LENDER* 07-37=52238 .0r::.:0at OT 't1.9 the ?sl.a PENNSYLVANIA MnRehas Mw* ? 19 I919.. Uu I+W 'h"lH US?;w?.u'e oN MORTGAGE NOTE "A CASE (Afteddal Feb.. 1 "0 NOTICE: THIS LOAN IS NOT ASSUMABLE W.-ITHOU.T?THiE'? 1? APPROVAL OF THE DEPARTMENT OF VIETER_tVS AFFAIRS OR ITS AUTHORIZED AGENT. HILL, CAMP Pennsylvania. $56.700.00 JANUARY 3, 1992FOR VALUE RECEIVED, the undersigned, THOMAS S. WHITE. UNMARRIED MAN hereinafter called the Maker, promises to pay to SEARS MORTGAGE CORPORATION .;or order, a corporation organized and existing under the laws of the STATE OF OHIO hereinafter designated as the Payee, the principal sum of ---------------------------------------------------- FIFTY-SIX THOUSAND SEVEN HUNDRED AND 00/100------------------------------------------------------------- ----------------------------------------------------------------------- Dollars (956.700.00-------------- ) with Interest from date at the rate of EIGHT------------------------------------------------------- per centum (---------------- 8. DODO %) per amum on the unpaid balance until paid. The said principal and Interest shall be payable at the office of SEARS MORTGAGE CORPORATION IRRIVERWOOOS. ILLINOIS 60015 at 25011 LAKE COOK ROAD or Atch plece as the holder may designate in writing in monthly installments of FOUR HUNDRED SIXTEEN AND 04/100-----------------------------------------------------------------------=- -------------------------------------------------- Dollars(5416.04---------------- ), commencing on the first day of MARCH. 1992 , and on the first day of each month thereafter until the principal and Interest are fully paid, except that the final payment of the entire indebtedness evidenced hereby, if not sooner paid, shall be due and payable on the first day of. FEBRUARY, 2022 Privilege is reserved to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or One Hundred Dollars (SIOO.OD), whichever is less. ?rr, aymtnt in full stall be credited an the date received. Partial prepayment, other than on an installment due . ate; nee.: not be credited. until the next following installment due date or thirty days after such prepayment, whichever is earlier. Simultaneously with the execution of this Note the Maker has executed and delivered to the Payee a Mortgage sec-.-.d uFan certain premises situated in the County of CUM)ERLANO Commonwealth of Pennsylvania, more particularly described In the Mortgage. All of the tams, covenants, provisions, conditions, stipulations and agreements contained in said Mortgage to be kept and performed by the Maker are hereby made a part of this Note to the same extent and with the same force and effect as if they were full;/:-,.: forth herein, and the Maker covenants and agrees to perform the same, or cause the same to be kept and :*erfo: med, strictly in accordance with the termsand provisions thereof. The whole of the principal sum or any part thereof, and of any other sums of money secured by the Mortgage given to secure this Note, shalt, forthwith, at the option of the Payee or any subsequent holder thereof, become due and•poyable immediately, without notice or demand, It default be made in any payment under this Note, and if the default is not made good prior to the due date or the next such installment; or upon the happening of any default wh'.:h, by the tams of the Mortgage given to secure this Note, shall entitle the Payee, or any subsequent holder hereof, to declare the same, or any part thereof, to be due and payable. The Maker does hereby empower any attorney of any court of record within the United States or elsewhere to appear for Maker, with or without a declaration filed, and confess Judgment or judgments against said Maker in favor of the Payee or any subsequenl holder hereof, a of any term, for the entire unpaid principal of this Note, and all diner sums paid by the holder hereof to or on behalf of the Maker pursuant to the terns of this Note or said Mortgage, and all arrearages of interest thereon, together with costs of suit, attorney's commission of FIVE--------------------------------------------- 1--5.DOOD)`b for collection, and a release of all errors, on which judgment execution or executions may Issue forthwith. The Maker hereby waives the right of Inqulaitlon on all pprroperl.- levied upon to collect the indebtedness evidenced haft and does voluntarily condemn the same and luthu. im use Prothonotary to enter such condemnation, and waives and releases all laws, now in fora or hereafter enacted, relating to exemption, appraisexment or stay of execution. The agreements herein contained shall bind, and the benefits and advantages shall inure to, the respective `xcesica. and assigns of the parties hereto. Wherever used, the singular number shall include the plural, the plural :..e singular, and the use of any gender stall be applicable to all genders. N WITNESS WHEREOF, the Maker has caused these presents to be executed u a sal the day and year above write . iRs#d ivered the Presence of: (Sal) T S S. WHl TE (Seal) (Sal) (Seel) THIS IS TO CERTIFY that this Is the Note described in and secured by Mortgage of even date herewith secured on reel estate situated ..- .-6y118E County, --?^-`---?,T ? ?D hh a Pennsylvania. ,,. FUMY F. KELL M ftriv P"bro . '` L lfmrdanTir,7<, Csanbe?lnd f': ; .:ty ? t15;[?-21PA1 wwA My ?' Am Embus kbDUi 15.12Q j -?w.r7 Public 0-4 -MOswc•ss-ceaMa .errr NA coo . swov52 s-129 s -xcHOSO COO- XC34050 PAY To TO COM Orr MUM R ?NAN IA.INC. C" 'ARY HELM J.WYRA WITHOUT RECOURSE PAY TO THE ORDER OF METMOR FINANCIAL, INC. BY: MA?cl. . Mary L. Gould Asslstent Vice President EXHIBIT B 1 RECEAD FEB 1 0 1991 ?j RECORB AND RETURN TO: 5E-- ORCED-C-=ICE C- ills SEARS MORTGAGE CORPORATION - tE C O R D F ' . D _ E 0 S 2207 FOREST HILLS DRIVE CU?!RER! A!.; COUNTY-PA, HARRISBURG. PA 17112 10 9-2 A 7 PM 2 12 ,A r.rs 20-UN Gle" tNl ISp0eAbe" T k Line For AwwrNnsDotal PENNSYLVANIA Revived Jane 197S. the OpUmel. Sabo 1910, Till. >•, PURCHASE MONEY VA CASE 1: LH 448951 U.S.C. rili.IS1o?rrK: ibi.Fo0cMiai LENOER'S 1: 07-37-52238 <A?ae« s6,, 1,atN MORTGAGE NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. The attached RIDER is made a part of this instrument. THIS INDENTURE, made the 3RD year of our lard one thousand nine hundred and NINETY IWO THOMAS S. WHITE, UNMARRIED MAN day of JANUARY In the .BETWEEN (herelrnafSlrCalled MortgagM)Ind SEARS MORTGAGE CORPORATION a corporation organized and existing under the laws of THE STATE OF OHIO and havirS Its principal office and post-officeaddress In RIVERWOODS, ILLINOIS 60015 AT 2500 LAKE COOK ROAD , (hereh afatcalled Mortgagee), WITNESSETH: That the Mortgagor to secure the psymentof -------------------------------------------- FIFTY-SIX THOUSAND SEVEN HUNDRED AND 001100-------------------------------------------------------------- ---------------------------------------------------------------------------------------------- -------- Dollars ($56, 700, 00------------- % with interest from date, at the rate of EIGHT -------------------------------- ------------------------- percentum( ----------------- 8.000 b) per annum on the unpaid balance until paid, as provided In a Note of even date herewith, from the Mortgagor to the Mortgagee, in monthly Installments of FOUR HUNDRED SIXTEEN AND 04/100-------------------------------------------------------------------------- --------------------------------------------------------------------------------------------------------- ----------------------------Dollars (S 416.04---------------- , commericingon the first day of MARCH , 1992 , and continuing thereafter on the first day of each month until such debt Is fully paid, except that. If not sooner paid, the final payment thereof shall be due and payable on the fint day of FEBRUARY 2022 , and also to secure the performance of all covenants, agreements and conditions herein contained, does by these presents grant, bargain, sell, assign, release, convey and confirm to the Mortgagee, ALL the following described real property situated in the SMOUGH Of WEST FAIRVI EW ,County of CUMBERLANV and Commonwealth of Pennsylvania, to wit: SEE ATTACHED COMMONLY KNOWN AS: 17 CREEKSIOE DRIVE, ENOLA, PENNSYLVANIA 17025-2916 TOGETHER with all and singular the buildings, Improvements, and fixtures on sold premises, as well es all additions or improvements now or hereslter made to sold premises, streets, alleys, passages, ways, waters, water courses. rights, liberties, privileges, hacditsrrwnts. and appurtenances whitsoever themnlo belonging, or In any wise opp0tafning, and the. eye abns and remainders, rents, issues, and profits thereof, and in addition thereto the following described household appliances, which are, and shall be deemed to be, fixtures and a part of the rally, and are a portion of the security for the indebtedness herein mentioned, namely, P"*1*1a 4W71PAI91,0001 XC14050AAA .10 vAO AAOa TOAOE faRMa . fS170rq 9t,0. f,0016r 1.7291 C Initiall'j4V XC1405D anon 1.091 PAGC 2110 • • STOVE REFRIGERATOR ALL CEILING FANS WINDOW TREATMENTS BLINDS Provided, however, that the Mortgagor shall be entitled to collect and retain the sold rents, Issues, and profits until default hereunder: TO HAVE AND TO HOLD said property, hereby granted, with the appurtenances, unto saw Mortgagee to its own use forever: This Indenture is made, however, sub)ect to the lollowing covenants, conditions, agreements and stipulations, and the Mortgagor covenants and agrhxs: 1. That the Mortgagor will promptly pay the principal of and Interest on the indebtedness evidenced by the said Note, at the times and in the marcher thaxin provided, with privilege reserved to prepay at any time, without premium or fa, the entire Indebtedness or any part thereof not lea than the amount of one instaitment, or one hundred dollars ($100.00), whichever is it=. Prepayment in full shall be credited on the date received. Partial prepayment, other than on an Installment due date, need not be credited until the next following installment due date or thirty days after such prepayment, whichever is earlier. 2. To more fully protect the security of this Mortgage, the Mortgagor shell pa to the Mortgagee as trustee (vnder the terms of this trust as hereinafter staled) in addition to and concurrently with, each monthly Installment of prtrwipel end Interest until said Note is fully paid, the following sums: (a) A sum equal to the ground rents, if any, next due, plus the premiums that will next become due and payable on policies of (ire and other hazard insurance, pies texas, esaessments, and sewer and water rents, next due on the premises covered by this Mortgage (all a estimated by the Mortgagee, and of which the Mortgagor Is notified) less all sums already paid therefor divided by the number of months to elapse before one month prior to the date when such ground rents, premiums, tams, assessments, and sewer and water rents, will become due, such sums to be held by Mortgagee In trust to pay said ground rents, premiums, tams, assessments, and sewer and water rents. (b) Tne aggregate of the amounts payable pursuant to subparagraph (a) and those payable on this debt shall be paid in a single payment each month, to be applied to the following items in the order staled: (I) ground rents, Was, assessments, sewer and water rents, fire and other hazard insurance premiums; (II) Interest on this debt; and (III) amortizatIonof the principal of this debt. Any deficiency In the amount of any such aggregate monthly payment shall constitute an event of default hereunder and under said Note, unless made good by Mortgagor prior to the due date of the nest such payment. At Mortgagee's option, Mortgagor will pay a •kte charge' not exoeedIng four per centum (4111) of any installment when paid more than fHIM (15) days alter the due date thereof to cover the extra expense involved In handling delinquent payments, but such gate charge" shall not be payable out of the proceeds of any sale made to satisfy the Indebtedness secured hereby, unless such proceeds of any sale muse to satisfy the indebtedness secured hereby, unless nth proceeds are sufficient to discharge the entire indebtedness end all proper coats and expense secured thereby. 3. If the total of the payments made by Mortgagor, under (a) of paragraph 2 preceding, shall exceed the ar'•oma.af payments actually made by Mortgagee as trustee for ground rents, taxes, assessments, sewer or water : ants, w lahsurance premiums, as the can may be, such excess shall be credited on subsequent payments to be made by Mortgagor for such items or, at Mortgagee's option,as trustee, shall be refunded to Mortgagor. It, however, such monthly payments shall not be sufficient to pay such items when the same shall become due and payable, then Mortgagor shall pay to Mortppe as trustee any amount necessary to make up the deficiency within thirty (30) days alter written notice from Mortgagee stating the amount of the deficiency, which notice may be given by mail. If at any time Mortgagor shall tender to Mortgagee, in accordance with the provisions hereof, the full payment of the entire indebtedness rep am itel hereby, Mortgagee, as truitei, shall in computing the amount of such indebtedness, credit to the account of Mortgagor any credit balance remaining under the provisions of (a) of paragraph 2. If there shell be a default under any of the provisions of the Note and this Mortgage securing the same, which results n a ubHc sale of the premiss covered thereby, or if title to tha property la otherwise enxluired by the Martgaagga alter the default, the Mortgagee, a trustee, shall apply, at the time of the commencement of each proceedings or at the time the property is otherwise aaxpttred by the Mortgagee, the balance then remanng to the credit of Mortgagor under (a) of paragraph 2, u a credit on the interest accrued end unpaid, and the balance on the principal then rernatnng unpaid on the NNote. 4. Mortgagor shall pay to Mortgagee all ground rents, tams, assessments, sewer and water rents, and all other charges and claims assessed or levied at any time by any lawful authority upon the premiss covered by this Mortgage which, by any pnrsahl or future law or laws, shall have priority in lien or payment to the debt represented by said Note and secured by this Mortgage, and provision for the payment of which is not otherwise made herein, such payment to be made by Mortgagor within thirty (30) degas after demand by Mortgagee, stating the amount. S. Time principal indebtedness hereby evidenced and secured represents money actually used for the acquisition of err for improvements to the premises secured by said Mortgage. 6. Mortgagor will continually maintain hazard insurance, of such type or types and amounts as the Mortgagee nary from time to time require, on the improvements now or hereafter on said premiss, and except when payment or all sh.c., premiums has theretofore been made under (a) of paragraph 2 hereof, will pay promptly when due any premiums therefor. All Insurance shall be tarried In companies approved by Mortgagee and the policies and renewals thereof shall be held by Mortgagee and have iltached thereto loo payable clauses In favor of and In form acceptable to Mortpgee. In event of loo. Mortgagor will give Immediate notice by mail to Mortgagee, and Mortgaae,t may maakkee proof of bee if not made promptly by Mortgagor. Each insurance company concerned is hereby authorized and directed to make payment for such lace directly to Mortgagee instead of to Mortgagor and Mortgage jontly. The inhserance Proceeds or any pert thereof, rruy be applied by Mortgagee at its option either to the reduction of the indebtedness err to the restoration or, repair of the property damaged. In the sole and absolute discretion of Mortga ge, n event of forecioahue of the Mortgage or transfer of title to the mortgaged property in W I err foul extinguishment of the , anlerost of Mortgagor n and to aninsurance policis then n fll to haer grantee dull be canceled and the cancellation prds, it any, rosMor tNo.. 11 is thereby given lo Matpga to settle or compromise all lams under receive and receipt for all moneys becomng payable thereunder. 4Mt731vAt 16904A1 Itt140SnAA9 10 r,p T Inili0lht? ?y. linl)1(1041 PAIf 1111 T. Mortgagor shall not execute or file of record any Instrument which imposes a restriction upon the sale or occupancy of the property herein described on the basis of race, color or creed. 6. Mortgagor will not suffer any lien superior to the lien crated by this Mortgage to attach to or to be enforced against the premise covered by this Mortgage. Mortgagor shall not commit or permit waste; and shall maintain the property in as good Condition as at present, reasonable war and tar excepted. Upset any failure so to maintain, Mortgages, at its option, may cause reasonable maintenance work to be performed at the cost of Mortgagor. 9. Mortgagee shall have the right to pay any ground rents, taxes, assessments, sewer and water rents, and all other charges and claims which Mortgagor has agreed to pay under the terms fereol, to advance and pay any sum of money that In its judgment may be necessary to perfect or preserve the title of the premises covered by this Mortgage, or for insurance premiums or for any authorized maintenance work. Any amount or amounts so paid or advanced shall be added to the principal debt, shall bear interest at the rate provided for In the principal indebtedness from the date of payment or advance, and shall be secured by this Mortgage ratably with said principal debt and interest thereon. Mortgagee, at its option, also shall be entitled to be subrogated to any lien, claim, or demand paid by it, or discharged with money advanced by It and secured by this Mortgage. The payments and advances so made shall be payable in approximately equal monthly payments extending over such periods as racy be Need upon by the Mortgagor and Mortgagee, but not beyond the due date of the final installment of the principal debt. In event of failure to agree on date of maturity, the whole of the sum or sums so paid or advanced shall be due and payable thirty(30) days after demand by Mortgagee. 10. The lien of this Mortgagee shall remain in full fora and effect during postponement or extension of the time of payment of the indebtedness, or any put thereof, which it secures. 11. Upon the request of Mortgagee. Mortgagor shall execute and deliver a supplemental Note or Notes for the sum or urns advanced or paid by Mortgagee for the alteration, modernization or Improvement of the mortgaged property made at Mortgagor's request; and for maintenance of aid property, or ground rents, taxes, aweasnents, sewer and water rents, and all other charges and claims asoc aW or levied against said property by any lawful authority, or for any other purpose elsewhere authorized hereunder. Said Note or Notes shall be served by this Mortgage on • partly with and as fully as if the amounts stated In such Note or Notes were part of that stated In the Note hereby secured. Sid supplemental Note or Notes shall bar interest at the rate provided for In the principal i ndebt .-on; and shall be payable in approximately equal monthly payments for such period as may be agreed upon by Mortgagor and Mortgagee. In event of failure to agree on date of maturity, the whole of the sum or surm so advanced or paid shall be due and payable thirty (30) days titer demand by Mortgagee; but in no event shall any such maturity or due date extend beyond the duedate of the final Installment of the principal debt. 12. If the indebtedness secured hereby be guaranteed or Insured under Title 39, United States Code, such Title and Regulations issued thereunder and in effect on the date hereof shall govern the rights, duties and liabilities of the parties hereto, and any provisions of this or other instruments executed In connection with said indebtedness vrhich are inconsistent with said Title or Regulations are hereby anended to conform thereto. 13.:1, at any time, a Writ of Execution (Money Judgment) or other execution Is properly issued upon a judgment obtained upon said Note, or if an Action of Mortgage Foreclosure or any other appropriate action or pi%eeding to foreeloae a mortgage is Instituted upon or under this Mortgage, an attorney's commission of F IVE------------------------------------------------ per eentum( ---------------- 5.MW %) of said principal debt shall be payable, and recovered In addition to all principal and Interest and all other recoverable sums then due, together with costs of suit. 14. It any deficiency In the amount of any aggregate monthly payment mentioned In (b) of paragraph 2 shall not be made good by Mortgagor prior to the due dale of the next such payment, or if default be made at any time in any of the covenants and agreements herein, or in the Note secured, then and In every such case, the whole principal debt shall, at the option of Mortgagee, become due and payable immediately. Payment thereof and all interest accrued thereon, with an attorney's commission as hereinbefore mentioned, may be enforced and recovered at once, an; thing herein contained to the contrary notwithstanding. in the event of any breach of any covenant, condition, or agreement of said Note, or of this Mortgage, it shall be lawrul for Mortgagee to enter upon all and singular the land, buildings, and other rights, corporal and incorporeal, granted by this Mortgage, and to take possession of the same, and of the fixtures and equipment therein, and to have, hold, manage, lease to any person or persons, use and operate the same in such parcels and on such terms and for such periods of time as Mortgagee may deem proper in Its sole discretion, Mortgagor agreeing thst he shall and will, whenever requaled by Mortgagee so to do, assign, transfer, and deliver unto Mortgagee any lease or sublease; and to collect and receive all rents, issues, and profits of said mortgaged premiss and every part thai*l, .4 all of which said Note shall be a sufficient warrant whether or not such lase or sublease has been assigned; and to make from time to time all reasonable alterations, renovations, repairs, and replacements thereto. After dxrctin4 the cost of such alterations, renovations, repairs, replacements, and the expesaes incident to taking and retaining possession of the mortgaged properly, the management and operation thereof, and to keeping the !;;ir;2 pn,parxy insured, to apply any residue of such rents, Issues, and profits to the payment of (a) all ground rents, taxes, charges, claims, assessments, sewer and water rents, and any other liens that may be prior In lien or payment to the debt secured by this Mortgage, with interest thereon, (b) premiums for said insurance, with interest thereon, (c) the In terest and principal due and secured by this Mortgage with all costs and attorney's tees; In such order or q s Mortgagee may determine, any statute, taw, custom, or use to the contrary notwithstanding. The taking of powessIon of the mortgaged premises by Mortgagee, as herein provided, shall not relieve any default by Mortgagor, or prevent the enforcement of any of the remedies provided by said Note or this Mortgage. The remedies provided by sold Note and this Mortgage or any other indebtedness therein provided or secured by this Mortgage, and for the performance of the covenants, conditions, and agreements of sold Note or this Mortgage are cumulative and concurrent, and may be pursued singly, or sutuxasively, or together, at the sole discretion of Mortgagee, and may be exercised as often as occasion therefor shall occur. 42¢xPAt ipwa i xctwsoenc .to .... a ^ imr•ii I Id. Do KK 1041 PAGE 1112 PROVIDED, that In case default dull be made in the payment of any Installment of principal and Interest, or any other payment hereinabove or in the conditions of said recited Note provided for, or In the keeping and performance by the Mortgagor of any covenant or agreement contained therein or in this Mortpp to be by saki Mortgagor kept and performed, In the manna and at the time specified for the performance thereof, such default wail entitle Mortgagee forthwith to bring and sue out an Action of Mortgage Foreclosure upon this Indenture of Mortgage, or to institute any other appropriate action or proceeding to foreclose a mortgage, and to proceed thereon to judgment and execution, for recovery of said principal debt or sums and all interest thereon and all other sums hereby secured, together with an attorney's commission for collection, as aforesaid, and cats and expenses of such proceeding, and to pursue any and all other appropriate legal or equitable remedies in such cases provided without further stay of execution or other process, any law, usage, or custom to the contrary notwithstanding. Mortgagor expressly waives and relinquishes all benefit that may accrue by virtue of any and every law made or to be made exempting the mortgaged premises or any other prenbes or property whatever, real or personal, from stlactanent, levy, or sale under execution, or any part of the proceeds arising from any sale thereof, and all benefit of any ally of execution or other process. Mortgagor hereby waives and relinquishes unto and in favor of the Mortgagee, all benefit under all laws now In effect or hereafter passed to relieve the Mortgagor in any manner from the obligations assumed In the Note for which this hndenture Is security. ;UT PROVIDED ALWAYS, nevertheless, that if said Mortgagor shell pay or cause to be paid unto the said Mortgagee, the aforesaid debt secured by this Mortgage, when and in the manner hereinbefore mentioned and aplr sated for payment of the same, together with interest and all other sums hereby secured, then and from thenceforth, this bdelture, and the estate hereby granted, a well as said recited Note, shall cease, determine, and become void, anything hereinbefore or in said Note contained to the contrary notwithstanding. If this Mortgage is executed by more than one person as Mortgagor, the liability of each shell be 'pint and several. covenants, conditions, and provisions contained in said Note, or In this Mortgage, shall bind, and the benefits and advantages thereof shall Inure to, the respective heirs, executors, administrators, sw ssors, vendee, and assigns of the parties hereto or thereto; and whenever used in said Note or in this Mortgage, the singular, number shell include the plural. the plural the singular. the use of any gander shall be applicable to all genders, and the term 'Mortgagee' shell include any payee of the indebtedness repree-led by said Note, or secured by this Mortgtp, or any transferee thereof, whether by operation of law or otherwise. IN WITNESS WHEREOF, Mortgagor hereunto sets his hand and sal. Dated the day and year first hereinsbove written. SIGNED, SEALED AND DELIVERED EN '1ti:E PRESENCE OF: / Y/? ?(,(/jJ?ilf' (Sell) THOMAS S. WHITE Berrower _ (Sal) -Burrower (Sal) -Borrower (Sell) -Borrower CERTIFICATE OF RESIDENCE I, the subscriber, Jeanne M. Figdore do hereby certify that the correct address of the within-named Mortgagee is 2500 Lake Cook Road, Riverwoods, Illinois 60015 Witness my land this 3rd day of January < .19 92 A tofN COMMONWEALTH OF PENNSYLVANIA ss COUNTY vF CUMBERLAND Cn this 3rd day of January , A.D., 19 92 before me, acme the above-named Thomas S. White yayg:d?,n?ehnowledged the within Indenture of Mortgage to be his act and dad, and 0",... 4611 k e to be recorded as such. nd and,seal, the day and year efortxsid. to' My commission expires .19 rs p l1 Ali By , Hi LY F. 1 111ER k-, • P.tblic Fui00RE.?nTay.: CMG "' •HARNIAG. PA 17112 Cor_aN=?I?nF`hG ;85 -j '?aiVAIweoaor XC1405DAA0 .10 r.e. 4.r 4 5-0i 1041 PACE 1113 C 0 ALL THAT CERTAIN piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and descri as follows, to wits BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty eight (168). feet to a point at the Conodoquinet Creek; thence along said Conodoquinet creek south seventy-nine (79) degrees nine (9) minute west fifty three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty eight (168) feet, more or less, to a point; thence north sixty nine (69) degrees thirty (30) minutes east fifty three (53) feet, more or less, to a stake, the place of BEGINNING. ALL THAT CERTAIN piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wits BEGINNING at a point along the Conodoguinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoguinet creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degrees east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of BEGINNING. 1 ? • \p4t? " W of State of Pennsylvania SS County of Cumberland Recorded in the office for the recording of Deeds et . i nd forRu beriand County, Pa i 0OWUvol. Page witness my hand an eai of o?Ofl ce Carlisle, PA thi • 1 B 00K 1041 PncE #114 Recorder 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 unworn falsification to authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her knowledge, information and belief. Assistant Secretary Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation of 4~:l 1a Z fl .E d E i NoIr goal 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil TYPE OF PLEADING MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE PURSUANT TO SPECIAL ORDER OF COURT FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Daniel J. Birsic, Esquire Pa. I.D. #48450 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil 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 June 13, 2008, Plaintiff filed a Complaint in Mortgage Foreclosure against the Defendant, Thomas S. White, at the above-captioned number and term. 2. On or about June 13, 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 a direction card requesting that Defendant be served a copy of the Complaint at his last known addresses being 17 Creekside Drive, Enola, PA 17025. On or about July 10, 2008, Plaintiff received Notice from the Cumberland County Sheriffs Office indicating that an attempt was made to serve the Defendant, Thomas S. White with a copy of the Complaint at his last known address being 17 Creekside Drive, Enola, PA 17025 but no service was made. A true and correct copy of the Sheriffs Returns 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 Defendant, Thomas S. White, 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 Defendant, Thomas S. White with the Complaint in Mortgage Foreclosure by posting a copy of the Complaint on the property at 17 Creekside Drive, Enola, PA 17025 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 17 Creekside Drive, Enola, PA 17025. 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: N'_ "' Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 EXHIBIT "A" SHERIFF'S RETURN - NOT FO CASE NO: 2008-03566 COMMONTWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC ET AL VS WHITE THOMAS S 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 WHITE THOMAS S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , WHITE THOMAS S 17 CREEKSIDE DRIVE ENOLA, PA 17025 PER NEIGHBOR, HOUSE IS ABANDONED. PER POST OFFICE MAIL IS DELIVERED TO GIVEN ADDRESS. Sheriff's Costs: So answers: Docketing 18.00 Service 15.00 Affidavit 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Postage .59 48.59 GRENEN & BIRSIC 06/25/2008 Sworn and Subscribed to before me this day of , A. D. RECEIVED JUL 10 1008 EXHIBIT "B" 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil 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 Defendant, Thomas S. White, named in the above-captioned matter: (a) On July 7, 2008, Plaintiff mailed to the United States Postmaster at Enola, PA 17025 a request to be furnished with a forwarding address of Defendant, Thomas S. White. (b) On July 14, 2008, Plaintiff received response from the United States Postmaster indicating that the Defendant resides at 17 Creekside Drive, Enola, PA 17025. A true and correct copy of the response is marked as Exhibit "I", attached hereto and made a part hereof. (c) A search of a nationwide computer database found a current address of 17 Creekside Drive, Enola, PA 17025 for Defendant, Thomas S. White. A true and correct copy of the search is marked Exhibit "2", attached hereto and made a part hereof. (d) Examinations were made of the Pennsylvania Voter Registration Records; said examination failed to yield any useful information regarding the whereabouts of Defendant, Thomas S. White. (e) A search of Online Directory Assistance indicates that the Defendant resides at 17 Creekside Drive, Enola, PA 17025. A true and correct copy of said search is marked Exhibit "3", attached hereto and made a part hereof. (f) A search of the Cumberland County Tax Assessor records revealed that Defendant has a mailing address of 17 Creekside Drive, Enola, PA 17025. A true and correct copy of said search is marked Exhibit "4", attached hereto and made a part hereof. Finally, affiant deposes and says that the last known address of Defendant, Thomas S. White, is 17 Creekside Drive, Enola, PA 17025. GRENEN & BIRSIC, P.C. BY: ? "`- L, 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 -LLC?j*o day of - , 2008. C! N Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Public City Of Pittsburgh, Allegheny County My Commission E)ires June 2, 2011 Member, Pennsylvania Association of Notaries Exhibit 11 1" Date July 7, 2008 Postmaster Enola, PA 17025 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: Thomas S. White Address: 17 Creekside Drive, Enola, PA 17025 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 Home Finance LLC, et al. vs. White 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: 08-3566 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 connection with actual or prospective litigation. Signature Zili Dai Printed Name Grenen & Birsic, P.C., One Gateway Center, Ninth Floor, Pittsburgh, PA 15222 (412) 281-7650 , i 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 No such address X ?Oop RECEIVED JUL 142008 Exhibit "2" Lexis.com Public Records Page 1 of 1 View: Results List I Full 1 - 1 of 1 FOCUSTm Terms Go; Search: Public Records > Comprehensive Person Report Search s Terms: ssn(187 -44-8363) state(ALL) radius(30) ( Edit Search ) r Select for Delivery r No. Full Name Address Phone SSN View Report Click for Additional Searches Phone Search SSN Search (- 1. WHITE. 17 CREEKSIDE DR 7.17.732-1064 187-44-XXXX THOMAS _S 07 964 O ENOLA, P.A..17025-2916 i Phone may be disconnected (PA:1969- 1970) /1 (D B: ) (Age: 44) CUMBERLAND COUNTY (01/1992-Current) 16 CREEKSIDE DR 717-732-1064 ENOLA, PA 17025.-2915 1 Phone may be disconnected CUMBERLAND 000NTY- (O1/1992) 1129 S CHESTNUTS T ELIZABETHTOWN ...... P.. 170227 28 1 LANCASTER COUNTY- (10/1988) Key A High Risk Indicator. These symbols may prompt you to investigate further. i ?A...1 .. ?-.?.. A:..I. T.. .1:....?w- Tl....... ... .... 1....1.. ....... .. ..F .. F... :... ..F:.. .. F.. F....FL...- 1 https://r3.lexis.comllexisprmalResults.aspx?setId=cdO5O7f3-ad84-4207-b78f-5cd8e9OO9l64 7/10/2008 Exhibit "3" WhitePages.com - Online Directory Assistance Page 1 of 1 White Pages. coff" {,carch, find, onnect. 1 Result matching "Thomas White, Enola, PA, 17025" Thomas S White 17 Creekside Dr Age: 55-59 Enola, PA 17025-2916 (717) 732-1064 awOil Sti X10, S? Srat° St ?? 1944 1 Mitroioft' ? Virtual Earth' 0 N07 cwo ' 0 M7 " 0 ANtE Listing date Dec. 2007 Copyright CrD 1996-2008 WhitePages.co Privacy. Policy, Legal Notice and Terms under whi( Microsoft MapPoint Terms of Use an( http://www. whitepages. comisearchIFindPerson?extra_li sting=mixed&form_mode=opt_b&... 7/16/2008 Exhibit "4" Results Page 1 of I View: Results List I Full 1 of 22 -NEXT' '0 , Search: Real Property Search Terms: first-name(thomas) last-name(white) middle-name(s) street address(17 crddkside drive) state(PA) zip code(17025) ( Edit-Search ) Pers----- Locator r (N.ationwide) Owner Information Bankruptcies Name: WHITE, THOMAS S (Owner Occupied) Foreclosures $ Address: 17 CREEKSIDE DR ENOLA, PA 17025-2916 Judgments & Liens CUMBERLAND COUNTY Property Information Property 17 CREEKSIDE DR Address: ENOLA, PA 17025-2916 CUMBERLAND COUNTY Land Use: SINGLE FAMILY RESIDENTIAL Further Searches Assessment Record For CUMBERLAND County Person Legal Information Assessor's Parcel Number: 45-16-1050-099 Recording Date: 01/07/1992 Book/Page: 35L/1086 Brief Description: TR 2 RESIDENTIAL BUILDING .1 https://r3.lexis.com/lexisprma/SourceDocReportResults.aspx?docID=1 &nextReportDocID... 7/10/2008 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 10, day of T? 2008, by first-class, U.S. Mail, postage pre-paid: Thomas S. White 17 Creekside Drive Enola, PA 17025 GRENEN & BIRSIC, P.C. BY: Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 [? f^J r::: W `7 'T"t .,_ .'7 C."+ .:: ... _, ry _, &? ". ,t ??y A y v JUL 21 2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. THOMAS S. WHITE, Defendant. CIVIL DIVISION NO.: 2008-03566-Civil ORDER OF COURT AND NOW, to wit, this I- day of 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, ADJUDGED and DECREED that the Sheriff of Cumberland County is hereby directed to serve Defendant, Thomas S. White with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at 17 Creekside Drive, Enola, PA 17025 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First-Class U.S. Mail, postage pre-paid at 17 Creekside Drive, Enola, PA 17025. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. J. BY THE COURT: 'mil ? d - 13 Of ? -Clk vowi kit ?? l?1` Ji , 7:4I'.F/?` ly Aipp f 1 TIC BUZ r t?_ t 4nj ,4. 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil TYPE OF PLEADING Praecipe to Reinstate Civil Action - Complaint in Mortgage Foreclosure FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Daniel J. Birsic, Esquire Pa. I.D. #48450 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: w Brian M. Kile, Esquire Attorney for Plaintiff R? `^?` V Yi SHERIFF'S RETURN - REGULAR CASE NO: 2008-03566 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC ET AL VS WHITE THOMAS S MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WHITE THOMAS S the DEFENDANT , at 0016:20 HOURS, on the 13th day of August , 2008 at 17 CREEKSIDE DRIVE ENOLA, PA 17025 by handing to POSTED PER COURT ORDER @ 17 CREEKSIDE DR, ENOLA, PA 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 Service Affidavit Surcharge Posting Sworn and Subscibed to before me this of So Answers: 18.00 ? Olt op, 15.00 00 0 10.00 R. Thomas Kline 6.00 49.00 08/14/2008 GRENEN & BIRSIC By: day Dep ty Sheriff A. D. 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. THOMAS S. WHITE, Defendant. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 the last known address of Defendant is: 17 Creekside Drive Enola, PA 17025 GRENEN & BIRSIC, P.C. Atto s for Plaintiff NO.: 2008-3566-Civil 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: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. THOMAS S. WHITE, Defendant. TO: PROTHONOTARY NO.: 2008-3566-Civil PRAECIPE FOR DEFAULT JUDGMENT SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Thomas S. White, in the amount of $46,962.87, which is itemized as follows: Principal $39,147.38 Interest to 9/18/08 $ 2,769.06 Late Charges to 9/18/08 $ 309.02 Escrow Deficiency to 9/18/08 $ 1,317.41 Corporate Advances $ 70.00 Attorneys' Fees $ 850.00 Title Search, Foreclosure and Execution Costs 2,000.00 TOTAL $46,962.87 with interest on the principal sum at the rate of $8.56 per diem (as may change from time to time in accordance with the terms of the Note) from September 18, 2008, 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. Kris ' e M. An ou, Esquire Attorney for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. Sworn to and subscribed before me this 17*J4 day of ??t6&641 2008. 1.- Notary Public cooNwTH 14WayLyAmA NNWW 3oW Re boom a Ka ft. NoWy PuW city Mr OamnMNon 2 2017 Me dw, Pe ONO A6900tatlon of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. THOMAS S. WHITE, Defendant. TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 DATE OF NOTICE: September 3, 2008 CIVIL DIVISION NO.: 2008-03566-Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 TOLL FREE (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. By: Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 S N r.a ca cr> Fn g, c? 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.: 2008-3566-Civil THOMAS S. WHITE, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 ( ) 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: $46,962.87 with interest on the principal sum at the rate of $8.56 per diem (as may change from time to time in accordance with the terms of the Note) from September 18, 2008, 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. s K. D/ d.4? eputy 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.: 2008-3566-Civil TYPE OF PLEADING: THOMAS S. WHITE, Proof of Service Defendant. FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil PROOF OF SERVICE 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 Plaintiffs Complaint in this matter on Defendant, Thomas S. White: 1. Pursuant to Order of Court dated July 22, 2008, service of the Complaint in Mortgage Foreclosure upon said Defendant 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 17 Creekside Drive, Enola, Pennsylvania 17025, and by posting of a copy of the Complaint, by the Sheriff of Cumberland County, at the property located at 17 Creekside Drive, Enola, Pennsylvania 17025. A true and correct copy of said Order of Court is marked Exhibit "A," attached hereto and made a part hereof. 2. On August 7, 2008, Plaintiff mailed the Complaint in Mortgage Foreclosure to said Defendant at 17 Creekside Drive, Enola, Pennsylvania 17025, via certified mail, return receipt requested; and by first class mail, postage prepaid. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7007 3020 0001 8989 7238, and the Certificate of Mailing, evidencing service by certified mail and first class mail on said Defendant, are marked Exhibit "B," attached hereto and made a part hereof. 3. On or about August 13, 2008, the Sheriff of Cumberland County posted the Complaint on the property located at 17 Creekside Drive, Enola, Pennsylvania 17025. 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: ?t ?+?J Kristi a M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS P, DAY OF J e 7(0') ?6,C , 2008. Notary Public :;GiWMQNyy TH F P NBYLVANIA PAW= city Of PftburoK G` NOWY Pubic JW* 2.2011 Member, P""""Ma A18001ation of Notaries ..?: ?;:? ?. ?„ . ,. Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. THOMAS S. WHITE, Defendant. CIVIL DIVISION NO.: 2008-03566-Civil ORDER OF COURT AND NOW, to wit, this V,2&AJ- day of 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, ADJUDGED and DECREED that the Sheriff of Cumberland County is hereby directed to serve Defendant, Thomas S. White with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at 17 Creekside Drive, Enola, PA 17025 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First-Class U.S. Mail, postage pre-paid at 17 Creekside Drive, Enola, PA 17025. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: RECEIVED JUL 28 2008 Flu r' v (4 ti?f8 r ?/ S h3Y ? i '•,? ,t :.r a 1.31t?? ;-hi l Qk-C , w Exhibit "B" co m ti r` I cc Ir Poetape s co Certified Fee o Retum ReosyFoo t a o. y Z C3 ?I ru O Total Po"p & Few $ M ? n cn , nn`,.. 4 t 'K?) U.S. POSTAL SERVICE CE - MAY BE USED FOR DOMESTIC AND INTER PROVIDE FOR INSURANCE-POSTMASTER Received From: s Grenen & Birsic P.C. _Qne Gateway Center, 9th Floor, Pittsburgh, PA 15222 One piece of ordinary mail addressed to: Thomas S. White 17 Creekside Drive Enola, PA 17025 75-8429 ZD (SOC) ?k fin! ? ro ?^1 PS Form 3817, January 2001 Exhibit "C" SH?Klr'r'' S x?1UK:.v - xG?,uL,r-arc CASE NO: 2008-03566 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC ET AL VS WHITE THOMAS S MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE WHITE THOMAS S DEFENDANT the at 0016:20 HOURS, on the 13th day of August , 2008 at 17 CREEKSIDE DRIVE ENOLA, PA 17025 was served upon by handing to POSTED PER COURT ORDER Q 17 CREEKSIDE DR, ENOLA, PA 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 15.00 Affidavit .00 Surcharge 10.00 Posting 6.00 49.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 08/14/2008 GRENEN & BIRSIC By: Dep ty Sheriff A. D. RECEIVED AUG 20 2008 ?„ co r" -? rz`3 ?» s l CD t.?a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation ( ) Confessed Judgment ( ) Other File No. 2008-3566-Civil vs. Thomas S. White TO THE PROTHONOTARY OF THE SAID COURT: Amount Due $46,962.87 Interest $ 1,584.02 (from 9/19/08 to Sale) Atty's Comm Costs 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) 17 Creekside Drive, Enola, PA 17 County, (see attached legal 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). 171 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: clkk? Print Name: Kristine M. Anthou GREM a BIRSIC Address: PITTSBURGH. PA 15222 Attorney for: Plaintiff Telephone: (412) 281-7650 Supreme Court ID No.: 77991 (over) IE wa ut v 0,0 VI* 4 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By ( i-(I; J Krist a M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 ? c ? f ` ....y ca T _ ?? J'e't??S ?- ..j Y i ?'?'? _ ?+T'ry r`°? ?'? f i ( 4 ., ? ? ? ?? . ?? { " SJ d E 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 0 2. The name and address of the defendants in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 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, et al. Cumberland County Adult Probation [PLAINTIFF] Court of Common Pleas 9th Judicial District One Courthouse Square Carlisle, PA 17013 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, et al. [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Krine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 74'fk DAY OF SP ? -nL& Z 2008. Notary Public L'C-OW $_V? Z 2011 ? Wei JUft9M8* C? ? 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101, ET. SEO. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Attorney for the Plaintiff, who being duly sworn according to law deposes and says that on February 1, 2008, Defendant was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first-class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 101, et seq. SWORN TO AND SUBSCRIBED BEFORE MET 2q DAY OF J P'e? 2008. Notary Public CAMM TH OF P Ne;Y V NoWlal Seel Reba= Cs. KW* NoWy Pubk City Of PlMebWV% AM"h" C OU* * CarenNe m M vVu June Z, 2011 Moftw, Permylvvft ANW8 "of Nolenar - C? n '0 cr. ?' CO 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.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. 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 owner of the property located at 17 Creekside Drive, Enola, Pennsylvania 17025 is Defendant, who resides at 17 Creekside Drive, Enola, Pennsylvania 17025, to the best of her information, knowledge and belief. U?.c ?Icl SWORN TO AND SUBSCRIBED (BEFORE ME THIS 20' DAY OF 2008. Notaryublic COMMONw TN of PENNBnV~ A'4' Mel- WCOR? EW+oinsZ2MI mwft r, P*"Yl ?M. Mtoa.tlon of NotarNc r-J w- C, 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 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 March 4, 2009, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $46,962.87. 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. 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.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff, thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By.i?i >C. U< ?- 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 08-3566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE, LLC s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. WHITE (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 $46,962.87 L.L.$ 0.50 Interest from 9/19/08 to Sale - $1,584.02 Atty's Comm % Due Prothy $2.00 Atty Paid $226.59 Other Costs Plaintiff Paid Date: 9/26/08 L*ry4 Prothono (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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil 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 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil 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 well as all persons named in Plaintiff s Supplemental Affidavit pursuant to Rule 3129.1 as follows: By letters dated October 2, 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. 2. By letters dated November 6, 2008, undersigned counsel served the persons named in Plaintiffs Supplemental Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective address set forth in the Supplemental Affidavit Pursuant to Rule 3129. 1. A true and correct copy of said Supplemental Affidavit Pursuant to Rule 3129.1 and Certificate of Mailing are marked Exhibit "B", 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: `- <;?o C'?-- Kristine . 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 , 2009. tary Public COMMONWEALTH OF PENNSYLVANIA NotaM Seal Bzabelh M. Pa law Notary Ptd* Cry Of Pftbugh, A ftherry Carly My CorrnWM E*kw Jan. 8.20'12 h s EXHIBIT "A" 6 6 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.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 0 0 2. The name and address of the defendants in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, et al. Cumberland County Adult Probation [PLAINTIFF] Court of Common Pleas 9`h Judicial District One Courthouse Square Carlisle, PA 17013 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, et al. [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE 0 0 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. 71 Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ?QrJI ??l???i ME THIS DAY OF 2008. i Notary Public TM' v? so" 2011 nh. , `? ?? As June flob m$ o N U. N U. m m W o NU c ?t O o w c 0 E --, , a a E ¢=aao o & 04 04 C14 C14 A v L 0 a E c IO m n? U ?ELp b m as 13000 N N m U m e- c 0 :3 8 O U) a O ` ? c ? C7 O 4)0 M C m a N I` O `b o A m ? E H jr- n t- '" C EC7Q wa Q c? Ep o o (N Ord CO o^a to 0 r- a. a U?'u'S c o d N 0 N o 7 C d m N o V C E N ?i H -00000 » N 1E c z m E a E c 00 t U0)OU a0 ma i U CL o L _o o w Cc a? O a 's o) ; L L.: 04 L) d) c,4 ' o C Z 4 g a N -w C E C v V -9 U ° v N o m c d 3 a cm c v cc aci N rn [ . c O = ? m . z (D 0 m Q. E C L s e ° ¢ m g U) Ua U a o ZE a 0a o N M v c ri c d n eo a CL C O a c H a m m CL E 8 N O a? N m 2 d LL M °N N 0 LL Cl) a r- EXHIBIT "B" 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil SUPPLEMENTAL 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-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, PA 17025, and is more fully described as follows ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Stephan Stasko 3603 Waymouth Drive Mechanicsburg, PA 17050 Stephan Stasko 1429 Walnut Street, 16`h Floor c/o Paul Sadler, Esquire Philadelphia, PA 19102 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. BY: `?' ?C C NL C ?? SWORN TO AND SUBSCRIBED BEFORE ME THIS ?- DAY OF , 2009. a44Nota Public COMMONWEALTH OF PENNSYLVANIA Novdel Seal ftsbeM M. Pdano, Notary Putft CRY Of PNbbug. AkgtwW County My C mdaUon Eip M JWL 0, 9092 Member P%I-V w?nle Awooletlon of NoWfts Krist' M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 J.S. POSTAL S R ICE CERTIFICATE OF MAIL NAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N( 'ROVIDE FOR INSURANCE-POSTMASTER Received From: P ''TM .t F ?yK,1 t ' ".i F Y? J.S. POSTAL SERVICE CERTIFICATE OF MAILING FRAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT 2ROVIDE FOR INSURANCE-POSTMASTER Received From: Floor Pittsbur h PA 2 9 EMQ) One piece of ordinary mail addressed to: v be H' PS Form 3817, January 2001 n` 09f 41 One piece of ordinary mail addressed to: \_c?\ d , ' ?`4a z' j J 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil TYPE OF PLEADING SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC 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 J 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil SUPPLEMENTAL 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-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, PA 17025, and is more fully described as follows ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. f The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Stephan Stasko 3603 Waymouth Drive Mechanicsburg, PA 17050 Stephan Stasko 1429 Walnut Street, 16`h Floor c/o Paul Sadler, Esquire Philadelphia, PA 19102 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. BY: C- X , Kx C 2_ Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS e_ DAY OF , 2009. A4 A N"??Notary Public COMMONWEALTH OF PENNSYLVANIA NoWM Seal Ebobelh M. Palam K*wy Ptd* CRY Of PNbbsg, Ak"W C=* My Oom iselon E*ku Jan, 8, 2012 lkmi-r, P gylwnla Asudedon of Nofarla 1, 1 „ / r ' 3 _..5 » -. ) .. - { Jfii 33 < Chase Home Finance LLC, s/b/m/t In The Court of Common Pleas of Chase Manhattan Mortgage Corporation Cumberland County, Pennsylvania VS Writ No. 2008-3566 Civil Term Thomas S. White Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on December 30, 2008 at 2020 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Thomas S. White, pursuant to order of court by posting the premises locates at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania with its contents according to law. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2009 at 2048 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White located at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Thomas S. White, by regular mail to his last known address of 17 Creekside Drive, Enola, PA 17025. This letter was mailed under the date of January 9, 2009 and returned to the Sheriffs Office as UNABLE TO FORWARD on January 13, 2009. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sherif'f's Costs: Docketing 30.00 Poundage 21.00 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 27.00 Levy 15.00 Surcharge 20.00 Postpone sale 40.00 Law Journal 437.00 Patriot News 432.92 Share of bills 15.52 1,070.94 So Answe : M R. Th<as Kline, Sheriff BY Real , to Coordinator r .? r fv? ;fit (O) ??clG I 1J-7 ? ? 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Home Finance LLC, sib/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 2. The name and address of the defendants in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 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, et al. Cumberland County Adult Probation [PLAINTIFF] Court of Common Pleas 91h Judicial District One Courthouse Square Carlisle, PA 17013 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, et al. [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS { h DAY OF ?? 2008. f_ Notary Public COMMONyy TH OF SOW PE" YLVAM4 Nobft ROW? G. Courk.V CRY Of PKWWV? Aleghwr; Am Z 2011 M.n, ' p"MI Oll E YH'MM AIWIN"GA of N414,4, 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.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 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 March 4, 2009, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DBV L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $46,962.87. 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. 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 CHASM HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, NO.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County., Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 13 5 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By"-/ yr Uc 1?r;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 COQ NIONWEALTI FOF PENNSYLVANIA) NO 08-3566 Civil COUNTY OF CUMBERLAND) 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 'I'IIOMAS S. WHITE (1) 1'ou 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 GARNISiII--E(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying and debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otheneise 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 $46,962.87 L.L.$ 0.50 Interest from 9/19/08 to Sale - $1,584.02 Atry's Comm Due Prothy $2.00 Atty Paid 5226.59 Other Costs Plaintiff Paid Date: 9/26/08 Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: hRISTINE NI. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC ONE GATEWAY CENTER, NINE WEST PITTSBURGH, PA 15222 Attorney Ibr: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 Real Estate Sale #25 On November 6, 2008 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA. Known and numbered as 17 Creekside Drive, Enola more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 6, 2008 By: ,. vt: Real Estate Sergeant IN THE COURT OF COMMON PLEAS OF COLUMBIA COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary ? s00 back Cumber" SIR: Please issue a Writ of Execution, directed to the Sheriff ofC-&Iemb-ia County, against the Defendant, Thomas S. White, as follows: Amount Due $46,962.87 Interest from 9/18/08 $ 7,262.16 TOTAL $54,225.03 GRENEN & BIRSIC, P.C. By: clL?' is Attorneys for Plaintiff O lzot. *00, FILED-01 I. too "CE OF THE 2009 JUL - I Pli 1: 19 .$A4.oo PO AT" 48.59 CBF gq.oo ,• 0,10 a4 ?8.50 10.00 '• 14.00 A4.00 ?• I 1319. 03 - P6 Airy 4.2.00 L7ue (? o*007468 (A)r,+ of & %60ed 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.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 2. The name and address of the defendans in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PLAINTIFF Cumberland County Adult Probation Stephan Stasko Court of Common Pleas 9`h Judicial District One Courthouse Square Carlisle, PA 17013 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16`h Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS -n)3_ DAY OF -__.???? -) 2009. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Beal Patricia A. Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2011 1. -1 Member, Pennsylvania Association of Notaries ? ? f 4J OF THE LF, Y 2009 JUL - I P1i I * 19 -P4 CUB= r _ Y J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, CIVIL DIVISION NO.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. 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, Esquire, Attorney for the Plaintiff, who being duly sworn according to law deposes and says that on February 1, 2008, Defendant was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first-class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 101, et seq. SWORN TO AND SUBSCRIBED BEFORE ME THIS d L DAY OF 2009. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricla A. Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2011 Member, Pennsylvania Association of Notaries FIU ?': 'r F "C; TAP OF 'ME y 2OD9 JUL _ I P?O, I. 19 CUrp i ? ,d s . _ t ?tiC`t1?'r i pr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, vs. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 9, 2009, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $54,225.03. 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. Oc - By: 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 CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff, thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By; 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 08-3566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. WHITE (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 $46,962.87 L.L. Interest from 9/18/08 -- $7,262.16 Atty's Comm % Due Prothy $2.00 Atty Paid $1,319.03 Other Costs Plaintiff Paid Date: 7/01/09 Curtis R. Lo*rot y (Seal) By: Deputy REQUESTING PARTY: Name: KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, PC ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil 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 Sale Date: 12/9/09 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.: 2008-03566-Civil VS. THOMAS S. WHITE, Defendant. 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 March 4, 2009 as follows: Thomas S. White is the owner of the real property and has not entered an appearance of record. 2. On July 22, 2008, this Court entered an Order authorizing Plaintiff to serve Defendant, Thomas S. White, by posting the property and serving the Defendant 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. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on July 20, 2009, the undersigned counsel served Defendant, Thomas S. White, 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 17 Creekside Drive, Enola, Pennsylvania 17025. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7008 3230 0003 2807 8287, 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. On September 28, 2009, Sheriff's Office of Cumberland County posted a true and correct copy of Plaintiffs notice of the sale of real property on the property located at 17 Creekside Drive, Enola, Pennsylvania 17025. A true and correct copy of the Sheriff's return of Service 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:? J C C? e? C /? Kristine M. Anthou, Esq re Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2009. Notary Public COMMONWEALTH OF PENNSYLVANIA Noterial Seal Patricia A. Townsend, Notaty Public City of Pittsburgh, AlNgheny County My Commission Expires June 2, 20111 Member, Pennsylvania Association of Notaries EXHIBIT "A" JUL ? 1 X008 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil ORDER OF COURT AND NOW, to wit, this day of 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, ADJUDGED and DECREED that the Sheriff of Cumberland County is hereby directed to serve Defendant, Thomas S. White with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at 17 Creekside Drive, Enola, PA 17025 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First-Class U.S. Mail, postage pre-paid at 17 Creekside Drive, Enola, PA 17025. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: 01"' V4"$60 'lu I Nor9 uric set my Hatt RECEIVED JUL 2 8 2008, ;...,_, ?. rt , t ;; ; ?:313Y Pd EXHIBIT "B" r- m _ru ca m a O 0 O M ru m ca a 0 r- r- 1 %wr e O Co , a ti Corditd Fes Fes Return '00" (Endorsemerd Required) a ReeWcbd Dslvsry Fee (Endorsement RKIWred) _.._ _i Qv U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES FC±Sj PROVIDE FOR INSURANCE-POSTHASTE yyy+qy Received From: Grenen & Birsic P.C. On Gatewa Center, 91h Floor T One piece of ordinary mail addressed to: -?? nnos Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current -PITNEY SOWE8 001.150 r0 1911a I +r ,i PS Form 3817, January 2001 EXHIBIT "C" Shef s Office of Cumberland Court R Thomas Kline Sheriff ??ttp of i:iunbc??? Ronny R Anderson vQ ?b i? Chief Deputy Jody S Smith r Civil Process Sergeant OF ME OF Th4E SHERIFF Edward L Schorpp Solicitor Chase Home Finance LLC vs. Thomas S White SHERIFF'S RETURN OF SERVICE Case Number 2008-3566 09/28/2009 07:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1850 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. 09/28/2009 07:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1850 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law ('' ?{y?-?(??? 1,. ?,,??"iy"?! (`fit Rf7?1 Z?1(?9 ???? -4 Pi ? 2? SS f ? r`t?i??t? ?Li?? , 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. THOMAS S. WHITE, Defendant. Sale Date: 12/9/09 NO.: 2008-03566-Civil 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, VS. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, 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 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: By letters dated July 20, 2009, 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. A BY: a,(- Kristine M. Ant ou, quire Attorneys for Plaintiff r One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF Lb .m )e , 2009. Notary Pub Pubic COMMONWEALTH OF PENNSYLVANIA NoWal Seel Palle A. Townsend, Notary Public City of Pittsburgh, Allegheny County My Commission Expires June 2, 2011 Member, Pennsylvania Association of Notaries EXHIBIT "A" 0 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 E 2. The name and address of the defendans in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PLAINTIFF Cumberland County Adult Probation Stephan Stasko Court of Common Pleas 9`h Judicial District One Courthouse Square Carlisle, PA 17013 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 Ll 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE 1 verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. 0 Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF ??rQ 2009. Notary Public COMMONWE_ATN OF PENNSYLVANIA NoteMai 8eaf . Townsend, Notary Pubk Cttaburgh, ANagnany County une Z, 2011 PEr', My mipion Expires J Member. Pennsylvania Assodabon Of NOtarles r O3 Ng,, 7t W o co 0 J I 0 n K 3 Z ?y w tl? ? O ? fi N ma t ' . y. t ? A Q W yN? ••?' tD 1 o, N O? 'St 4 N `'N N o ? it O m ? 3 'CI ? N ro C"? c • O cl n 'a O Dad S ?? am a y?°9 & o a o? 5N=g a s, s i 3 b A3 3 co y c x? r? KR 0 ad ? )t o c?°. -aWv v° Q? tL?t NCi?0 C N?•.. (D .s tJ .,y "'f to ° ?, ct?+ °? N3 O tG - C S' ?' -?' O .. W W tt ? (PS lit L a xy Q1n p -o ? g .P N ?n )r . N m 3 ? A a n , '.7 ,.? -jQ i r +r. OF THr F f H!:10'Tk9Y 2009 NOV -4 P l Z: 55 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline FILED-OtTl, ? ? Sheriff Or- ? r c pn(1 . _,N Ronny R Anderson .. ? Chief Deputy 2009 DEC 10 A g; 1 Jody S Smith CUPf` `tl?( Civil Process Sergeant ?tc ,i E•Y .-," Edward L Schorpp Solicitor Chase Home Finance LLC I Case Number vs. I{ 2008-3566 Thomas S White SHERIFF'S RETURN OF SERVICE 09128/2009 07:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1850 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. 09/28/2009 07:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 09-28-09 at 1850 hours, he posted a true copy, pursuant to Court Order, of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law 12/09/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states the writ is returned STAYED, due to lack of representation by the Plaintiff or the Plaintiffs representative at the December 9, 2009 Real Estate Sale. SHERIFF COST: $844.15 ?? i 110167 SO ANSWERS, 1010 December 09, 2009 R THOMAS KLINE, SHERIFF (cj GountySuite Sherntf. Te!ecsoft. Inc. 3 y 63 ilk Z 3,f ?"r7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH.OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. WHITE (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 $46,962.87 L.L. Interest from 9/18/08 -- $7,262.16 Atty's Comm % Due Prothy $2.00 Atty Paid $1,319.03 Other Costs Plaintiff Paid Date: 7/01/09 ur is R. Lo & rothono ry (Seal) By: REQUESTING PARTY: Name: KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, PC ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Deputy Supreme Court ID No. Real Estate Sale# On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as, 17 Creekside Drive, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 a By: Re state aurdinator ZZ :ut Z -` i?''vc 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.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 2. The name and address of the defendans in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation Cumberland County Adult Probation Court of Common Pleas Stephan Stasko 9"' Judicial District One Courthouse Square Carlisle, PA 17013 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16`" Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. 0 Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2009. Al-1+? Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Publle City of Pittsburgh, Allegheny County My Commission Expires June 2, 2011 Member, Pennsylvania Assodabon of Notaries 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.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 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 9, 2009, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $54,225.03. 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: 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 CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By.'.? Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 08/04/2009 08:40 4122817657 GRENEN & BIRSIC, PC PAGE 02/03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2008-3566-Civi1 Plaintiff, vs. THOMAS S. VOTE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south, two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-threc (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 13 5 feet to a pipe; thence along land now or formerly of Mazy E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creeksi.de Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By. `'-? Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 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 23, October 30 and November 6, 2009 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 6 da of November. 2009 Ce??Ntary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 TM na. ONS640M CONS Chase Home Fri nance LLC, s/b/m/t Chase Manhattan Mortgage Corporation vs. Thomas S. White Atty: Kristine Anthou ALL that certain piece or parcel of land situate in the East Peinnsboro Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hun- dred sixty-eight (168) feet to a point at the Conodoquinet Creels; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a poW; ttieeace along land o(Jom*h H, and &wdm N. 9lretra ew north two (2) de;rccs West one hundred sixty-e*t (168) feet, more or less, to a point; therice north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the East Penns- boroTownship, Cumberland County, Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050- 099. BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumber- land County on January 7, 1992, at Deed Book Volume L-3S, Pale 1086, ranted wad convoyed unto TUeenas Wtiite. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE z4f PNow you know CARLISLE PA 17013 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 Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below That neither she 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 she 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: 10/23/09 10/30/09 11/06109 Sworn to and subscribed before me this 16 day fff November, 2009 A.D. , , ? /i r s', Notary Public 0O,- MMQNWE L1h uF PENNSYUVANIR. Notaral Sea! Shetrie I_ rife;, Notary Public City Of H3rlsb.'00. Dauphin County s M2I comrr:ra'.10" ?xpirwi Nov. 26,20-11 Member t ntSyvl sdni. .? s;04'13.lon of Notaries} Writ No. 2006-3566 Civ i C`iase Horne Finance LLC, sib/ mtt Chase Manhattan Mortgage Corporation Vs Thomas S. White Atty: Kristine Anthou ALL that certain piece or parcel of land situar in the East Pennsbore, Township, Cumberland County, Pennsylvania, bounded and described a, follows, to wit: BEGINNING at a stake at the western line ?., land of Edward Neff; thence along land cf Edward Neff south two (11 degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek: thence along said Conodoquinet Creek south seventy-nine (79 degrees nine (9) minutes west fifty-three (53, feet to a point; thence along land of Joseph li, and Sandra N. Strauser north two (2) degree, west one hundred sixty-eight (168) feet, more tar less, to a point; thence north sixty-nine WP degrees thirty (30) minutes east fifty-three t53` feet, more or less. to a stake, the place „- beginning. ALL that certain piece or parcel of land situate ;n the East PennsboroTownship, Cumberland County, Pennsylvania, bounded and described a• follows, to wit: BEGINNING at a point along the Conodoqumc: Creek at the western line of land now immerly of Dennis and Mary Ellen Ensmingcr thence along said Conodoquinet Creek south 74 degrees 9 minutes west 87.98 feet to a point thence along lan.d now or formerly of James D9 Riland, north I degree east, 135 feet to a pipe thence along land now or formerly of Mary I Pyne north 89 degrees 30 minutes east, 38 fee, to a stake; thence north 2 degrees 30 minute +est 25 feet to a stake; thence north 69 degree, 30 minutes east 44 feet to a point; thence alon,• land now or formerly of Dennis and Mary Eller Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Dm: Enola, PA 17025. TAX PARCEL No. 45-16-1050.099 BEING the same premises which Dennis t. Ensminger and Mary Ellen Ensminger, by deef dated January 3, 1992 and recorded in the Oftia 4 the Recorder of Deeds of Cumberland Count, on January 7, 1992, at Deed Book Volume L-'15 Page 1086, granted and conveyed unto Thom& White. IN THE COURT OF COMMON PLEAS OF COLUMBIA COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. THOMAS S. WHITE, Defendant. CIVIL DIVISION NO.: 2008-3566-Civil PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) ?a?t. vv 48.54 44 . o0 I,ow. q4 8gq.15 18.5 p 10.00 K. oo 014.00 odq, 00 ? a,187. is TO: Prothonotary SIR: Please issue a Writ of Execution, directed to the Sheriff of Columbia County, against the Defendant, Thomas S. White, as follows: Amount Due Interest from 9/18/08 TOTAL 0 ,BF 4 ?f u P 0 ATT -f $ a - 00 f-?Ue CIET1 /Z4101 P,:*- xeqeb Rezm--'Wf? $46,962.87 $27,158.05 $74,120.92 GRENEN & BIRSIC, P.C. ct, Att rneys for Plaintiff n N O Lr ? J Tll1-TF_ >C: !!? ?R C , CA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. 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, Esquire, Attorney for the Plaintiff, who being duly sworn according to law deposes and says that on February 1, 2008, Defendant was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first-class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. 101, et seq. SWORN TO AND SUBSCRIBED BEFORE ° ME THIS DAY OF f )2 PJO 2010 _ Q . -^ 1. G IL cn ca© " L / d } ] Qae', 2? _ s 7 Notary Public ; C:, %D 6rn cn ON CQF PENNSYL-TH T, wry Public City of MY Ex?? 2ZO?1 I Member. Pence Aaodetfon of Noted" IN THE COURT OF COMMON PLEAS OF COLUMBIA COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was not in the military service of the United States of America to the best of her knowledge, information and belief. Sworn to and subscribed before me this day of 1 (l 2010. Notary Public m{µ n _rn COMMONWEALTH OF PENNSMANIA < t C? 0 Notarial uw C Patricia A. Townsend, Notary Public City Of Pittaburgh, Allegheny County {, ? i My COmmleeion EXPIM June 2, 2011 p , m Member, FiWWWnla A$Wddon of Notarlea Cn t A 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: n a - White 17 Creekside Drive Thomas S `' . Enola, PA 17025 -• - cn 7 Cn 2. The name and address of the defendant in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PLAINTIFF Cumberland County Adult Probation Court of Common Pleas 9t' Judicial District One Courthouse Square Carlisle, PA 17013 Stephan Stasko 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16' Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 0- DAY OF 2010. Notary Public ---M TN OF PENN8riVgyIKA No Pufrlda A. Tll as ownswW, Nohry Pubdc MWY ConOf RhOUP0 wM wt n ' A?W»nY County JUM 22011 MernDsrI dy e 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. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, Attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 17 Creekside Drive, Enola, Pennsylvania 17025 is Defendant, who resides at 17 Creekside Drive, Enola, Pennsylvania 17025, to the best of her information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE C7 ° n' a ? 3 (mil cn c? ME THIS DAY OF rjt) 2010. ?I spa CD - L -' P n C LO Notary Public C4MMIO1?wyreAl,TH of PEN MU LM atricia A. Townsend, Notary Public CRY of Pilisburo . aw y County L P June 2, 2011 AAemEer, ennay ftla of -ft IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2008-3566-Civil Plaintiff, VS. THOMAS S. WHITE, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 2, 2010, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WESb FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING G _ ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 7 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE A$6, TA PARCEL #45-16-1050-099. , U cn Cif The said Writ of Execution has been issued on a judgment in the mortgae foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $74,120.92. 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 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 CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.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 08-3566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. WHITE (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 $46,962.87 Interest from 9/18/08 -- $27,158.05 Atty's Comm % Atty Paid $2,187.18 Plaintiff Paid Date: 3/5/10 L.L. Due Prothy $2.00 Other Costs L David D. Buell, Prothono (Seal) By: Deputy REQUESTING PARTY: Name: KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, PC I GATEWAY CENTER, 9TH FLR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. TI'M 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. THOMAS S. WHITE, Defendant. Sale Date: 6/2/10 NO.: 2008-03566-Civil 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, VS. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, 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 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 March 10, 2010, 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. BY: Kristine M. Anthou, quire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2010. C--?y \--?u -,1 0 -^ - fA Notary Public COMM NW ,., PENN Y VANiA NeMAM gal POW A. TOWAV O. NOWY Pubft Cigr EXHIBIT "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, NO.: 2008-3566-Civil vs. THOMAS S. WHITE, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 U 2. The name and address of the defendant in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PLAINTIFF Cumberland County Adult Probation Stephan Stasko Court of Common Pleas 9" Judicial District One Courthouse Square Carlisle, PA 17013 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16* Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF LLLPh--) 2010. Notary Public no comma"" a.. piowwsw C01 10 PftMVVK A P:_WaV r JW* ConNni wit r? N `?6 03 ?'•?' (p w X A ? Iwo A 0 v 0 C CD A ?+C N 3 A ".L W G)Z w ^' Q I A N (D 5 s+ 0 G) :3 3 > 90 t„n tDO a 3 °-? cg 0) CO "OC 7 a v O) D ?K N 0) 06 °' q n U) CD v 27 N Oti 7 O G 3 o .? N o C7 tD ? '' '11 (OD s; O o ? N _ -p CA ? -0 c -P DDDDD C O N Z ? oil Q1 ?L¢? N K cD ? Nom' ?'NqO 3 m c -p °i 0, ?>"a 0 0, 5.0 = W .0 T+ U ate, CD c CD N ?A su oa > tD y •D ?• C? y1 ? Oo t9 (p N ? Q('QD ? >c yA LIM (D 7 N N Rill N ?giD go ro ? ? A Yry "N y T 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. THOMAS S. WHITE, Defendant. Sale Date: 6/2/10 NO.: 2008-03566-Civil 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 _ C? 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.: 2008-03566-Civil vs. THOMAS S. WHITE, Defendant. 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 March 4, 2009 as follows: Thomas S. White is the owner of the real property and has not entered an appearance of record. 2. On July 22, 2008, this Court entered an Order authorizing Plaintiff to serve Defendant, Thomas S. White, by posting the property and serving the Defendant 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 March 10, 2010, the undersigned counsel served Defendant, Thomas S. White, 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 17 Creekside Drive, Enola, Pennsylvania 17025. A true and correct copy of the U.S. Postal Service form 3800, Article Number 7009 0080 0000 4244 2635 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. On April 14, 2010, Sheriff's Office of Cumberland County posted a true and correct copy of Plaintiffs notice of the sale of real property on the property located at 17 Creekside Drive, Enola, Pennsylvania 17025. A true and correct copy of the Sheriff's return of Service 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:y?cLC Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS..jt0-0 DAY OF [:b , 2010. Notary Public ppNNYLVA- A pabid@ A. Townwra, Netm?y public Lc a t?ar?n. ? r1 June nra?won EXHIBIT "A" JUL IOO 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. THOMAS S. WHITE, Defendant. NO.: 2008-03566-Civil ORDER OF COURT AND NOW, to wit, this 7,2&*J- day of 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, ADJUDGED and DECREED that the Sheriff of Cumberland County is hereby directed to serve Defendant, Thomas S. White with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at 17 Creekside Drive, Enola, PA 17025 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First-Class U.S. Mail, postage pre-paid at 17 Creekside Drive, Enola, PA 17025. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: /y zAAA44-A_.,1 & d"A') , OF U c:;'r t,( I here urto Sat my hens RECEIVED JUL 28 1008 u t; ,.:.... r::. rt .'t ;ilB, P.1 hid ??? .z y EXHIBIT "B" Ln M .A ti s ti 0 0 0 0 CO 0 0 6' 0 M N cE °MIN:1. STATES Certificate Of 1: Ps or This CeAibcata of I%Wg provides evidence that mail has been presented to USPS® for mailing. This form may be used for domestic and international mail. From: . `` Grenen irsic, F .U. One Gateway a rittsbulgh PA 15222 r . ? 'en ? ? q9c j To: zl ???°'LJ ? 2A9 ra PA i7no S' j PS Form 3817, April 2007 PSN 7530-02-000-9065 EXHIBIT "C" SHERIFF`FFICE OF CUMBERLANOUNTY Ronny R Anderson Sheriff u'?xr at ?,un8ry Jody S Smith yh? c a Chief Deputy Edward L Schorpp - -? Solicitor QFFtCF OF THE $ISERIFF Chase Home Finance LLC Case Number vs. Thomas S White 2008-3566 SHERIFF'S RETURN OF SERVICE 04/07/2010 02:57 PM - Michael Barrick, Deputy Sheriff, who being duty swom according to law, states that on 4/7110 at 1457 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at, 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. 04/14/2010 Michael Barrick, Deputy Sheriff, who being duly swom according to law, states that on 4/7/10 at 1457 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at, 17 Creekside Drive, Enola, Cumberland County, Pennsylvania by posting property pursuant to court order according to law. SHERIFF COST: $898.42 April 26, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shentt. Teleosoft. Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~,utr of 4~n+~brrf~~~ -;~ h {4~ ;; ;{a Chase Home Finance LLC vs. Thomas S White Case Number 2008-3566 SHERIFF'S RETURN OF SERVICE 04/07/2010 02:57 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on 4/7110 at 1457 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at, 17 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. 04/14/2010 Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 4/7/10 at 1457 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Thomas S. White, located at, 17 Creekside Drive, Enola, Cumberland County, Pennsylvania by posting property pursuant to court order according to law. 06/02/2010 Property sale postponed to 7/7/2010. 07/07/2010 Property sale postponed to 9/8/2010. 09/09/2010 Ronny R. Anderson, 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 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Kristine Anthou on behalf of Secretary of Veterans Affairs, his successors and assigns, of, 1240 East 9th Street, Cincinnati, Ohio 44199, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,028.33 SHERIFF COST: $1,028.33 October 21, 2010 ~f IL`E'D'T3FFIC~ OF THE PROTttONOTARY 20lO QCT 25 PM 12~ 03 CtlMBERtAND COUNTY PENN5YLYANIA SO ANSWERS, RON R ANDERSON, SHERIFF y~~•Da Pd . ~. ~.~ ~• ~. ~~ ~~i~ (cj CountySuito Sheriff. Teleosoft, hoc. ~! '~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b!m/t CNIL DNISION Chase Manhattan Mortgage Corporation, Plaintiff, vs. THOMAS S. WHITE, Defendant. NO.: 2008-3566-Civil 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, Plaintiffin the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Thomas S. White located at 17 Creekside Drive, Enola, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRNE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. 1. The name and address of the owner or reputed owner: Thomas S. White 17 Creekside Drive Enola, PA 17025 i~ 2. The name and address of the defendant in the judgment: Thomas S. White 17 Creekside Drive Enola, PA 17025 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation PLAINTIFF Cumberland County Adult Probation Stephan Stasko Court of Common Pleas 9`~ Judicial District One Courthouse Square Carlisle, PA 17013 3603 Waymouth Drive Mechanicsburg, PA 17050 And c/o Paul Sadler, Esquire 1429 Walnut Street, 16~' Floor Philadelphia, PA 19102 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t PLAINTIFF Chase Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Department of Welfare Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest maybe 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 maybe affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. ~~ Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ~ DAY OF ~ :z~`.1~ 2010. ~' ~l -, . ~ l Notary Public COMM NWEq ~ OF P Y V IA c°mnlwo^ ~ Z Z01 ~ r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Thomas S. White 17 Creekside Drive Enola, PA 17025 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2°d Floor 1 Courthouse Square Carlisle, PA 17013 on June 2, 2010, at 10:00 A.M., the following described real estate, of which Thomas S. White is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF THOMAS S. WHITE OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN WEST FAIRVIEW BOROUGH, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 17 CREEKSIDE DRIVE, ENOLA, PA 17025. DEED BOOK VOLUME L-35, PAGE 1086, TAX PARCEL #45-16-1050-099. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Thomas S. White, Defendant, at Execution Number 2008-3566-Civil in the amount of $74,120.92. 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. ~. /~' Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 J r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2008-3566-Civil Plaintiff, vs. THOMAS S. WHITE, Defendant. LONG FORM DESCRIPTION ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the East Penns Borough Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050-099 ~~ BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumberland County on January 7, 1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. White. GRENEN & BIRSIC, P.C. By:~l~1C-,fit- ~ .~-r;~"~~".c ~ /t- ~.- 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) NO 08-3566 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From THOMAS S. WHITE (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 $46,962.87 Interest from 9/18/08 -- $27,158.05 Atty's Comm Atty Paid $2,187.18 Plaintiff Paid Date: 3/5/10 L.L. Due Prothy $2.00 Other Costs avid D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, PC 1 GATEWAY CENTER, 9'~ FLR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. "J~qQ ., On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Tovcroship, Cumberland County, PA, Known and numbered as, 17 Creekside Drive, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 8 i o ~` Z I ~~~d OI~~ By: Real Estate Coordinator ,~. ~.:` 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, V12: April 16, Apri123, and Apri130, 2010 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. ~- i`~~ Li Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 30 day of April. 2010 Notary NOTARIAL S oEeoRaF+ a coLUNs NM~- Pubpc CARLN<LE SOROUBH. CtNYIOERLANO COUNTY ~- commbaan ~e• as 2e. 20» ~slt ]Ie. ~00~-3S66 Cldl Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation vs. Thomas S. White Atty: Kristine M. Anthou ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a stake at the western line of land of Edward Neff; thence along land of Edward Neff south two (2) degrees east one hun- dred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquinet Creek south seventy-nine (79) degrees nine (9) minutea west fifty-three (53) feet to a point; thence along land of Joseph H. and Sandra N. Strauser north two (2) degrees west one hundred sixty-eight (168) feet, more or less, to a point; thence north sixty-nine (69) degrees thirty (30) minutes east fifty-three (53) feet, more or less, to a stake, the place of beginning. ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees 9 minutes west 87.98 feet to a point; thence along land now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30 minutes east, 38 feet to a stake; thence north 2 degrees 30 minutea west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 fcet to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the place of beginning. KNOWN and numbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16-1050- 099. BEING the same premises which Dennis E. Ensminger and Mary Ellen Enaminger, by deed dated January 3, 1992 and recorded in the Office of the Recorder of Deeds of Cumber- land County on January 7, 1992, at Decd Book Volume L-35, Page 1086, grt;nted and conveyed unto Thomas S. White. 5 # ~,ltltd t ytr ,~~ The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he~latriot-Neu-s Now You know CARLISLE PA 17013 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she 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 she 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: 04116/10 ~, 04/23/10 ~ ~--~ 04/30/10 ;Sworn to an~ ubscribed before met s 18 cYa ,of_ May, 2010 A. D. ~~~, // Notary Public Jt 4~`~~'`- ~~"'IM(3r.,~,yEAL'II i r f>I_,!~iSYLVA~"VL4 Norartal ~~! t ~r~,r~. P>axta~'i .w i., f vuHc 3 d%~+uphln f.~unCy °ryr r <trrt;nls,lo_a Frcpfies tinv. ~6, 2013'. w ~„~ ".w i _ v1t~;i~ i ,; '~ +3ti~n <,r NOTa~iES Writ Mo. 2008-3566 Civll Term [khase Home Finance CLC sNb/mR Chase Manhattan Mortgage Corporation Vs. Thomas S White Atty: Krlstlne M Anthou ALL that certain piece of parcel of land situate in the Borough of West Fairview, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING eta stake at the western line of land ofFdwatdNeff; thence along land ofBdward Neff south two (2) degrees east one hundred sixty-eight (168) feet to a point at the Conodoquinet Creek; thence along said Conodoquipet Creek south seventy-nine (79) degrees nine (9) minutes west fifty-three (53) feet to a point; thence along land of Joseph I~. and Sandra N. Strauser north two (2) deg>•eac wed die htmtb+eA sixty-eight (168) feet, tnae ~ less, ur a point thence nottb siitty-nine (69) degrees dtiriy (30) minttus eax hfty-ifu~ee (i3) fief, ttiotete of leas, to a'stake, the place of ~' ~• ALL that certain piece or parcel of land situate in the Borough of West Fairview, Cumberland County, Pemsylvaaia, bounded and described as follows, to wit: BEGINNING at a point along the Conodoquinet Creek at the western line of land now or formerly of Dennis and Mary Ellen Ensminger; thence along said Conodoquinet Creek south 79 degrees ' 9 minutes west 87.98 feet to a point; thence along ]and now or formerly of James M. Riland, north 1 degree east, 135 feet to a pipe; thence along land now or formerly of Mary E. Pyne north 89 degrees 30minutes east, 38 feet to a stake; thence north 2 degrees 30 minutes west 25 feet to a stake; thence north 69 degrees 30 minutes east 44.5 feet " to a point; thence along land now or formerly of Dennis and Mary Ellen Ensminger, south 2 degrees east 168 feet, more or less, to a point, the " place of beginning. KNOWN and nurpbered as 17 Creekside Drive, Enola, PA 17025. TAX PARCEL No. 45-16.1050-099 BEING the same premises which Dennis E. Ensminger and Mary Ellen Ensminger, by deed " dated January 3,1942 and recorded in the Office of the; Recorder of Deeds of Cumberland County on January 7,1992, at Deed Book Volume L-35, Page 1086, granted and conveyed unto Thomas S. W; zy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Veterans Affairs Secretary is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 5th day of March, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 08 Number 3566, at the suit of Chaes Home Finance LLC sbmt Chase Manhattan Mtg,Corp against Thomas S White is duly recorded as Instrument Number 201030479. IN TESTIMONY WHEREOF, I have h~ of }e alto set my hand and seal of said office this c~ ~ ~" day of A.D. ~~ (~ I~orcler of Deeds O~i1~iA~a~MI,M w e~~e~r~t~sN