HomeMy WebLinkAbout09-0096
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
TYPE OF PLEADING:
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
TO DEFENDANT
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE REOF
ATTO EY FOR PLAINTIFF
COUNSEL OF RECORD FOR THIS
PARTY:
,Kristine M. Anthou, Esquire
Pa. I.D. #77991
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANT IS:
18 Altoona Avenue
Enola, PA 17025
PSC 78, Box 6726
APO, AP 96326 ' ~
_ C~~ ~.~
AT I:Y FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
l8 Altoona Avenue
East Pennsboro Two.
(CI ORO, TOW SHIP) (WARD)
.r_ ~~aU
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650 ,
ATT(T~RNEY FOR PLAINT
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..
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
NO.: 0 9- O D 9 G C-urt~l ~-t~
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its
attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage
Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio
43219 and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendants, Mark Edwin Biddle and Margret Biddle-Saunders, Personal
Representatives of the Estate of Edwin Gregory Biddle, a/k/a Edwin G. Biddle, are individuals
whose last known address are 18 Altoona Avenue, Enola, Pennsylvania 17025 and PSC 78, Box
6726, APO, AP 96326, respectively.
3. On or about April 3, 1987, Song Suk Biddle and Edwin G. Biddle, executed a
Note in favor of Meritor Mortgage Corporation-East in the original principal amount of
$57,500.00. A true and correct copy of said Note is marked Exhibit "A," attached hereto and
made a part hereof.
4. On or about April 3, 1987, as security for payment of the aforesaid Note, Song
Suk Biddle and Edwin G. Biddle made, executed and delivered to Meritor Mortgage
Corporation-East a Mortgage in the original principal amount of $57,500.00 on the premises
hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of
Cumberland County on April 7, 1987, at Mortgage Book Volume 858, Page 1099. 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. Meritor Mortgage Corporation-East assigned all of its right, title and interest in
and to aforesaid Mortgage to Plaintiff pursuant to a certain Assignment of Mortgage recorded in
the Office of the Recorder of Deeds of Cumberland County on March 7, 1994, at Mortgage Book
Volume 467, Page 817.
6. On August 3, 1997, Song Suk Biddle Died.
7. Song Suk Biddle and Edwin G. Biddle were the owners of the aforesaid
mortgaged premises, until the time of her death, at which time title vest in Edwin G. Biddle by
operation of law.
8. On March 25, 2008, Edwin G. Biddle Died.
9. On or about April 2, 2008, Defendants, Mark Edwin Biddle and Margret Biddle-
Saunders, filed a petition for Grant of Letters of Administration. A true and correct copy of the
docket is marked Exhibit "C," attached hereto and made part hereof.
10. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the April 1, 2008 payment.
11. On or about November 17, 2008, Defendants were 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.
12. The amount due and owing Plaintiff by Defendants is as follows:
Principal $32,884.04
Interest to 12/29/08 $ 2,326.02
Late Charges to 12/29/08 $ 220.68
Escrow Deficiency to 12/29/08 $ 0.00
Corporate Advances $ 42.00
Attorney's fees $ 850.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $38,822.74
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $38,822.74 with interest thereon at the rate of $7.64 per diem from December 29, 2008, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
GRENEN & BIRSIC, P/C?.
Kristi M. Anthou, Esquire
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
~ •
EXHIBIT "A"
" ~ ~
'225 ~ •
' VA Fan 26.63360 (Homo ~ PENNSYLVANIA
aeviwd March Is~a. u. Op.
tional Section 1810. Tltk 39. LH~ 434-115
US.C. Acapubk to Federal Nr
tbinl Mortaaae Auoektbn.
', 221576-2 MOI{TGAGE NOTE
CAMP HILL ,Pennsylvania.
a s7,soo.oo
APRIL 3 , 19 SZ
FOR VALUE 12ECE1vEp, the underaigried, t r
EDWIN G BIDDLBt'1~XifDAn? t.s
SONG SUR BIDDLH , hereinttitxr•called•the Maker, promises to pay to
T ~ ~T h 1~• .y~•• Al ?~ wpn ~,.
MBRITOR NORTGAGB'~b~aeATfIO~gEl18T';~~~ROA~'6'C$~!#TNUT STRB8T3, PBILADBLPBIA, PA 19107
s corporation organized, andsexiating under the laws of theC~ONWEALTH OF PBNNSYLVANIb or order,
hereinafter designated a8 the Payee, the principal surq of piggy gg~p THOUSAND FIVB HUNDRBD ii
00/100 "-" ~ .-u j ~ .,•-•---. ~-,-- a•--•'~F T,;_:I , Dollars (S 57,500.00 )
with interest from date at the rate of ~IG11T app Ot18=HALF per centum ( 8.500 `~')
per annum on the unpaid balance unti paid. The said principal and interest shall be payable at the office of
MHRITOR MORTGAGB •CORPORIITiON-EA~T;=760pt1f%$$ROUL' RD, SPRINGFIELD PA 19064
or such place as t{te holder may designate in
writing in monthly installments of FOUR HUNDRHD FORTY TWO b 13/100
Dollars (S 442.13 )~
commencing on the first day of JU , 19 B7 ,and on the first day of each month there-
after 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 lfAY 2017
Privilege u reserved to prepay at any time, without premium or tee, the entire indebtednea ar any
part thereof not leas than.the,amount.of one installment, or One Hundred Dollars (=100.00), whichever is
lea. Prepayment in• •full"shi><1 be •taedited on the date received. Partial prepayment, other than on an
instaUrnent due date; need•not`be credited until the next following installmentdue 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 Fayee
a Mortgngo secured upon certain prrmiues aituuted in the County of CUMBHRLAND
Commomvenlth of Pennsylvania.. more particularly described in the 141ortguge. All of the terms, cove-
nants, provisions, conditions, stipulations attd agreenteltfa contained iit said Mortgage to be kept and
performed by the Maker :are hereby made a putt of this Nole to the same extent and with the same
force and effect-as if they were fully sat forth he~in, :tali the Isiaker co~•enxrtta and agrees to perform
the same, or causo the some tli•be'kept and Ixrfortned, strictly in accordance with the terms :-nd pt•o-
visiona thereof.
The whole of the principal seta or any patt thet•euf, 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 dua and payable immedit-tely, e•ithvut notice or dOntand, 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 which, 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, to be due and payable.
The Maker does hereby empower any attorney of any court t~f record within ~lhe United States
or elsewhere to apltear for bfaker, with or without a declaration filed, and confess judgment or judg-
ments 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 Aortgage, and all arrcaragea of interest there-
on, together with costa of suit, attorney's commission of g,000~. fur collection, and a release of all
errors, on which judgment execution or executions may issue forthwith. The Maker hereby waives
the right of inquisition on all property levied upon to collect the indebtedness evidenced hereby and
daea voluntarily condemn the same and authorizes the Prothonotary to enter such condemnation, and
waives and releases all laws, now in force err hereafter enacted, relating to exemption, appraiaement
or stay of execution.
The agreements het•ein contained shall bind, and the benefits and advantages shall inure to, the
respective successors and assigns of the parties hereto. Wherever uxed, the singular number shall in-
clude the plural, the plural the singular, and the use of any gender shall be applicable to all genders.
IN WITNESS WHERP.OF, the Maker has caused these presents be executed under seal the day and
year first above written. ,
Signed, Sealed and Delivered -- .. _ -
.. ~~ - --.-....... (SEAL)
in the Presence of: .....................................:......................°-----•-••(S
`~.,n ,~ ~ ~ //~ SONG SUK BIDDLH EAL)
/~ n ,J ~ ~ .~•.~ ~ ~ ~~~ ........--• .....................:.... (SEAL
....--s.d.xl.~.l\1.9~.,1~./ ................................... cT~~-.~~~_~Z~,.../SEALI
Tests Is To CEaTtF,r..that this is the Note described in and secured by Mortgage of even date here
with secured on real estait~ situate>'if>..~,.~~b~. ~~ "County, Commonwealth of Pennaylv:.iia.
t' VALERIE 8. STACKN ,~(~[ ~J~/~~ •
_ f~W .........................................
It, UY COMMI$Slpp EXAIa~ LMpy,•~ 19Y ~'~ Notary Prblie.
MMC 2Y5 aw. 0/os la ~ CUMBERtA-rp COUNTY, FA ~i,; .
~, ~~ sTa: a
..,.
. ~ .
•
Pay to the order o! ~ ~~
Without rsoourN.
ImlITOII 1[pMG-Ci COWOVt2 -Z
sre ne eery. oe Pres ds
/ ~ ~ ~ l~~'
~i ~~ i
/~I a coa , Aes steal Ssa
WITHOUT RECOURSE
PAY TO THE ORDER OF
MELLON MOlrPC~GE COMPANY
w~a~, a~wC'st
~ ~
~-
~ ALL TtiA`1' CER'PAIN piece or parcel of land situate in Enola, East Pennsboro
f Township, Cwnberland County, Pennsylvania, more particularly bounded and
~ described in accordance with a survey by Michael C. D'Angelo, dated August
j 1, 1978, as follow, to wit:
BEGINNILdG at a point in the easterly line of Altoona Avenue at the distance
of 190 feet (erroneously set forth in prior deed as 200) north of cwnberland
Ro:,d; thence along the said Altoona Avenue North 10 degrees 20 minutes West,
50 feet; thence North 79,degrees 40 minutes East, 125 feet; thence South
10 degreES 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
,`
BEING KNOWN AS 18 Altoona Avenue, Enola, PA.
-BEING -the .same -p~i~es which [carry E. King and Sandra L. King, his wife,
by their deed dated April 3, 1987 and which is intended to be recorded
herewith in the Ctanberland CoLmty Recorder of Deeds Office, granted and
crnveyed tmto Edwin B. Biddle and Song Suk Biddle, his wife, r'brtgagors herein.
s
BooK b5~ ~acEll U3
• ~
EXHIBIT "B"
1
YA Faso ]H77o (Now. Loaa)
RaMaoe Jaea le7f. Uw Oodoeal~
8aetloa 1110. Tltlo 'sd,U.9.C.
Aagta4N rp F.a .noaol
MoRpp Ave«4tloa,
PLH# 434V)~SIA
221576-2 ~ MORTGAGE
THIS INDENTURE, made the 3RD day o f APRIL ~ ~
year of our Lord ale thottsmd Rhte hmdrcd and eighty-seven gE~~ EDWIN G
BIDDLE AND SONG SUK BIDDLE (hereinafter called Mortgaggoor)) and
MERITOR MORTGAGE CORPORATIOA-BAST, AVENUE OF THB ARTS BLDG, ]!ROAD b CHESTNUT STBBETS,
a corporation organized end exWingg under the laws of the Commonwealth of Pennsylvania, and having Its principal office
and post-office address in PHILADELPHIA, PA 19107 (herclna(ter called Mortgagee):
VYIITVESSETH: Tlut the Matpga ro secure the payment of
FIPTY SEVER THOUSAND I+IVE Hi1NDRBD 6 00/100
p~ (s 57 ,500.00 )~ ~~ interet from date, ^t the rate of EICHT AND ONE-HALF pu ~~
( 8.500x,) per ~~ an ~ mpaW balance mtil pa1d, u provided is a Nae of awn lots herewith, from the
Matpgor to the Mortpga, in moathly itutaBnuttu of FOUR HUNDRED FORTY TWO b 13/100
D~~ (g 442.1 ~~ cormtteadag on the first day of
JUNE , 19 87 ,and condnuing eilerafter oa the Ant day of each month wen atarh
debt b fully paid, except that, if Rot sooner paid, UJe Anal payment theroof duA be dw sad payable en Use Ant daYOf
MAY 2017 , ~d dso to ecure tiu petfamaooe of aB twvenaan, agrecrosab and conditlons herdR
coRtalned, does by thou preeaU grant, Darpht eB, uaign, releae, earvey sad eonArm to the Mortpps, ALL the foDow-
ing daeribsd red property dtwte in the TOWNSHIP of EAST PSNNSBORO Couary of
CUMBERLAND and Commonwealth of Pennglvania, to wih.
BEING MORE PARTICULARLY DESCRIBED ACCORDING TO A LEGAL DESCRIPTION ATTACHED HERETO AND
MADE A PART HEREOF.
SEB ATTACHED LEGAL DESCRIPTION
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Should the Veterans Admioistntiaa for any reason fail a refuse to f»Ire the guarantee io the maximum arRaatt per-
milted of the lwR secured by thb trortgap wader the proHsiom of the Ser+ricemat's Readjwtmeat Aet of 1944, a amend-
ed, wlthta dxry days of the date hereof, the mortpge hmein msy a its option deckre aU sums secured by this mortPP
immediately dw arW payabk.
TOGETHER with aU sad singular tlu buildlap, itRproverrwlp, sad A:turca oa Wd prcmku, u weD u di addUfoaa
or improvements now or hereaftu made to said prernisu, ctne4, alleys, passage, ways, watsn, water course, dghes,
Ubcrties, prlvUege, hercditameats, sad appurtenance whatsoever thereRRto belonghtg, or to any vela appertaining, and the
rewrdaq and remaioden, rents, issue, and profits thereof, and in addition thereto Ute foDowbtg described houuhold
applimoe, whkh arc, and shaE be domed to be, Axturea and a part of the refry, std arc s portion of the security for the
indebtedness herein ntaatfoned, namely,
RANGE/OVEN, W/W CARPET
provided, however, that the Mortpgor slug be eaUtkd to cdkct and retain the said reR4, roue, sad proA4 until default
hsrcueder:
TO HAVE AND TO HOLD said property, hereby granted, with the appurtenance, unto said Mortgage to its own
use forever:
eoox 858 rilcl:1099
MMC:zo a«.eiesr~
i
~ Thk Indentwe ,however, subject to the fdiowing covenants, conditio~ments and stipuktians, and
the Mortpgor covrna~ agrac:
1. That the Mortpgor will promptly pay the principal of and interest on the indebtedness evidenced by the said
{ Note, at the limes and in the manner therein provided, catch ptivikge reserved to prepay at any time, without premium or
fee,the entire indcbtednea or soy part thereof not ku than the amount of one inualhnent,or one hundred dollan (SI00.00),
wNehever is lea. Prepayment in full shall be credited an the date rcaived. Pullet prepayment, other than on an instalhrteat
due date, need not be eredlted 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 Mortpp,.the Morlpgor shall pay to the Mortppe a trustee (under
the terms of this trwt u hereinafter stated) in addition to and concurrently with, each monthly installment of principal
and interest untll said Nou is fully paid, the following sums:
(a) A sum equal to the ground rents, if any, next due, plus the premiums flat will next become due and paya-
ble on poUdec of lire and other hazud insurance, pica taxes, assessments, and sewer and water rents, next due
on the premises covered by thk Matpge (all u estimated by the Mortpgee, and of which the Mortpgor b
ndilkd) less all cams already paid therefor divided by the number of mantM to' ekpte before one month prior
to the date when such ground rents, premiums, taxes,assasrnents, and sewer and water rrnts, will become due,
such cams to De held by Mortpgee in trust w pay said ground rrntt, premiums, taxes, assessments, and sewer
and water rents.
(b) The aggrcpte of the amounts paysbk punuant to subparagraph (a) and those payable an this debt shall
be paid in a single payment euh month, to be applkd to the following items in the order staled:
(1) ground rents, taxes, asasamrnls, sewer and water rents, fire and other hazard iawranee premiums;
(II) interest on this debt; and
(111) amortization of the principal of this debt.
Any deflcirncy in the amount of any such aggrcple monthly payment shall constitute an event of default hereunder
and under said Note, unku made good by Morlpgor prior to the due date of the next weh payment. At Mortppe't
option, Mortpgor will pay a 'late charge" not exceeding fow per eentum (4~r) of any instaUmrnt when paid more
than 6fleen (1 S) days after the due date thereof to cover the extra expense involved in handling detlaquent paymenq,
but such "late sharp" shall not be payable out of the proceeds of any sale tMde to uUsty the indebtednea seared
hereby, antes such proceeds of any sale made to ulidy the indebtedneu secured hereby, unka such prooecdt are
wffidrnt to diuharp the entire Indebtednea and all proper cats and expenses secured thereby.
3. !f the total of the paymrnts made by Mortpgor, under (a) of puagraph 2 prctxding, shall excoed the amount
of payments usually made by Mortgagee as trustee for ground rents, axes, assessments, rawer or water rents, or insurance
prcmlums, a the case may be, such ezceu shall be credited on tubsequrnt payments to be made by Matpgor for such
items a, at Mortpsee's option, as trustee, thatl be refunded Io Moripgor. !f, however, wch montNy paymenq shill not
be wffldenl to pay such items whrn the ume shall became due sad payable, then Mortpgor shall pay to Mortppt u
trwta my amount necessary to make up the defidrncy within thirty (30) days afkr writtrn notice from Mortppe stating
the amotatt of the dctidenry, whleh notice tnty be given by mall. !f al say Ume Mortpgor shall tender to Mortpgte, is
aceordasttx with the provisions hereof, the fuU payment of the rntirc indebtednea rcpretentsd hereby, Morlppe, u trustee,
shall in computing the amount of wch indebtedneu, credit to the account of Mortpgor any txedlt bdanoe remaining under
the providons of (s) of parcgrcph 2. tf there s1u0 be a default under any of the providans of the Note sad this Mortpp
ssaring the same, which results in a public sale of the premiss covered thereby, or if Usk to the properly k othetwise
uquircd by the Mortpgee after the default, the Mortgagee, as trwtee, shall apply, at the t(me of the commencement of such
proceedings or a1 the time the property is otherwise uquircd by the Morlppe, the bahwtx then remaining to the credit of
Mortpgor under (a) of paragraph 2, u a credit on the interest accrued and unpaid, and the bakna on the prindpd then
remaining unpaid on the Note.
4. Mortpgor shall pay to Matpgee all ground rents, loxes, assessrrteni:, sewer and water rents, and all other
durges and daims assessed or levied at any time by any kwful authority upon the prcmiset covered by thb Mortpp whidt,
by any present or future law or laws, dull have priority in Ikn « payment to the debt rcpresrnted by said Note sad tscurcd
by Ibis Morlpge, and provision for the payment of which is not otherwise made herein, such payment to be arde by
Mortpga within thirty (30) days after deatand by Mortppe, uating the amount.
5. The principal indebtednea hereby evidenced and secured rcpraents money usually used for the aequkiUon of
or for improvements to the premius secured by said Mortgtp.
6. Mortpgor will continually maintain hazard insuransx of such type or types and amounu u the Mortpgee may
from time to time requirc,on the improvernrnts now or hereafter on raid prcmhes,and except when payment for all weh pre-
miums has theretofore been made under {a) of paragraph 2 hereof, w01 pay promptly when due any prcmluau Iltercfor. All
inwrcnoa dull be arricd k companks approved by Mortpgee and the polides and rcnewak thereof dsaG be hdd by Mortp•
gee and love altuhed thereto loo payable douses in favor of and in form aeeeptable to Mortppe. fn event of loo, Mortppo
will ghro immediate notice by mail to Mortpgee, and Mortpgee may make proof of loo if not made promptly by Mortpgor.
Each tnsurrna company concerned is hereby authorized and d[rected to make payment for such loo dirccdy to Martppe
instead of to Mortpgor and Mortpgee jointly. The insuranrx praaedt, or any aprt thereof, may be applied by Mortpgee
at its option either to the reduction of the indebtedneu or to the restoration or repair of the property damapd. In the tole
and absdule dberetion of Morlpgee, in event of foreclosure of the Mortpp or tuntfer of title to the mortppd property in
partial or toW extinguishment of the Note hereby secured, all right, title, and interest of Mortpgor in and to any inwrana
policip then in force shall past to the purchaser or grantee or dull be canceled and the cancellation proceeds, if any, ra
tamed by Morlpgee. Full power is hereby given to Mortpgee to settle or compromise all ckimt under such po6des sail to
demand, rewire and receipt for all moneys becoming payable thereunder.
7. Mortpgor shall not execute or Ne of record any instrument which imposer a restriction upon the sale or oea-
pancy of the property herein described on t!rc bait of race, color or creed.
8. Morlpgar will not suffer any lien superior to the lien created by this Mortpp b attach to or to be enforced
against the premises covered by this Mortpp. Mortpgor dtaU not commit or permit wale; and shall mairttatn the property
in u good condition as at pretsnt, reasonable wear and tear excepted. Upon any failure so to maintain, Mortppe, at its
option, auy sate reasonable nulnlenance work to be performed al the ccsl of Morlpgor.
~ °~ ~ eooK fi58 ~aci! 110U
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' ~~ ~ ~ '. ~
9. Mortgagee shi~lfive the right to pay any ground rents, taxes, assessrrunts, sev~lfand water rents, and111 other
charges and claims Nbieh Mortgagor has sgreet to pay under the terms hereof, to advance and pay any sums of mdriey-that
in its judgment may be ttecessuy to perfect or to preserve the title of the premixs covered by this Mortgage, or for fnsura~ce
premiums or for any authorized nutntcnance work. Any amount or amounts so paid or advanced shall be added to the
prindpal debt, shall bear interest at the rate provided for in the principal indebtedness from the date of payment or ad~ange,
and shall be xcured by this Mortgage ratably with said principal debt and interest thereon. Mortpgee, at its option, also
shall be entitled to be subrogated to any lien, claim, or demand paid by it, or diuhargd with money advanced by it ittd
xcured by this Mortgage. The payments and advances so made shall be payable in approximately equal monthly pay~tteots
eztrnding ovar wch periods as may be agreed upon by the Mortgagor and Mortpgee, but not beyond the due date of the
final installment of the principal debt. In evrnt of failure to agree on date of maturity, the whole of the sum or sums's~pitid
or advanced shall be due and payable thirty (30) days after demand by Mortppe.
10. The Ikn of this Mortpgee shall remain in full force and effect during postponement or extension of the t of
payment of the indebtedness, or any part hereof, which it xcures.
I1. Upon the request of Mortgagee, Mortgagor shall execute and deliver a wpplemrntal Note ar Notes for thetium~r
sums advanced or paid by Mortgage for the alteration, modernization of improvement of the mortgaged property mide,at
Mortgagor's request; and for maintenance of said property, or ground rents, taxes, uxssments, xwer and water rents, and ill
other ehsrps and claims asusxd or levied against said property by any lawful authority, or for any other purpose elxwbeie
authoriud hereunder. Said Note or Notes shall be xcured by this Mortgage on a puny with and as fully u if the amounts
stated in such Note or Notes were part of that stated in the Note hereby xcured. Said wpplemental Note ar Notes shall bear
interest at the rate provided for in the principal indebtedneu 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 wm or sums so advanced or paid shall be due and payable thirty (30) days after demand by Mortpgee; but in
no event shall any such maturity or due date extend beyond the due date of the final installment of the principal debt.
12. If the Indebtedness xcured hereby be guaranteed or inwred under Title 38, United States Code, such Title and
Regulations iswed 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 catnection with said indebtedneu which are inconsistent
with said Title or Regulations are hereby amended to conform thereto.
13. lf, at any time, a Writ of Execution (Money judgment) or other execution is properly iswed. upon ~a judgment
obtained upon said Note, or if sn Action of Mortgage Foreclowre or any other appropriate action or proceeding~to foreclax
a moAgage is instituted upon or under this Mortpge, an attorney's commission of five per centum (5%) of said principal debt
shall be payable, and recovered in addition to all principal and interest and all other recoverable sums thrn due, olpther
with costs of suit.
14. If an defuiency in the amount of any aggreptc monthly psymrnt mentioned in (b) of pusgnph T shall not be
made good by Mortgagor prior to the due date of the next wch payment, or if default be made at any time in any of the
covenants and ageements herein, or in the Note xcured, then and in every such ax, the whole principal debt shall, at the
option of Mortpgee, become due and payable immediately. Payment thereof and all interest accrued thereon, with an
attorney's commission as hereinbefore mrntioned, may be enforced and recovered at once, anything herein contained io the
contruy notwithstanding.
In the event of any breach of any covenant, condition, or agreement of said Note, or of this Mortgage, it shaLL be lawful
for Mortgage to enter upon all snd'singular the land, building, and other rights, corporeal and incorporeal, granted by this
Mortpge, and to take posxssion of the same, and of the fixtures and equipment therein, and to have, hold, manage, kax to
any person or pcrsans, use and operate the same in such parcels and on such terms and for wch periods of time as Mortpgee
may deem proper in its sole discretion, Mortgagor agreeing that he shall and will, whenever requested by Monppe so to do,
assign, transfer, and deliver unto Mortgagee any kax or wbkax;and to collect and receive all rents, issues, and profits of
uid mortpged premises and every put thereof; for a0 of which aid Note shall be s sufficient wursnt whether or not wch
kax or subkax hu bern assigned; snd to make from time to time all reasonable alterations, renovations, repairs, and repla~e-
ments thereto. After deducting the cast of such alterations, renovations, repair, replacemmu, and the expmxs inddent to
taking and re Wning possession of the mortgaged property, the matngemrnt and operation thereof, and to keeping the same
properly insured, to apply any residue of such rents, issues, and profits to the payment of (a) all ground rents, taxes, chuges,
claims, asxssments, xwer and voter rents, snd any other liens that may be prior in Ben or payment to the debt secured by
this Mortpge, with interest thereon, (b) premiums for said insurance, with interest thereon, (c) the interest and prinapal due
and secured by this Mortgap with all costs and attorney's fees; in such order or priority u Mortpgee may determine, any
statute, law, custom, or use to the contrary notwithstanding.
Tht taking of posxasion of the mortgagized premises by Mortgages, as herein provided, shall not relieve any default by
Mortgagor, or prevrnt the enforcement of any of the remodies provided by uid Note or this Mortpp.
The rcmcdks provided by said Note and this Mortgage or any other indebtedness therein provided or xcured by this
Mortgage, snd for the performance of the covenants, conditions, and agreements of acid Note ae this Mortpge are cumulative
snd concurren-, and may be pursued singly, or successively, or together, at the sole discretion of Mortgage, snd may be
pursued singly, or waessively, or together, at the sole discretion of Mortppe, and may be exercixd as often u occuion
therefor shall occur.
PROVIDED, that in cox default shall be made in the paymrnt of any installment of principal and interest, or any other
payment hereinabave ar in the conditions of said recited Note provided for, or in the keeping and performance by the Mort•
gagor of any covenantor agreement contained therein or in this Mortpge to be by said Mortpgor kept snd performed, in the
manner snd at the time specified for the performance thereof, wch default will entitle Mortgagee forthwith to bring and sue
out an Action of Mortpg Foreclowre upon this Indenture of Mortpge, or to institute any other appropriate action or pro•
cesdiag to foreclox a mortpg, and to proceed thereon to judgment and execution, for recovery of said principal debt or
sums snd all interest thereon snd all other sums hereby xcured, together with an attorney's commission for collection, u
aforesaid, snd costs snd expenxs of such proceeding, and to purwe any and all other appropriate legal or equitable remedks
in such cases provided without further stay of execution or other process, any law, usage, or custom to the contrary notwith•
standing. Mortpgor expressly waives snd relinquishes all benefit that may accrue by virtue of any and every law made or to
be made exempting the mortgaged premises ar any other premises or property whatever, real or personal, from attachment,
B00!( ~5~ PAGi:11O1
levy, or sale under e~ any part of the proceeds arising from any sak thersof, tit of any uay of exesu-
tion or otacr process. Mor hereby waira and relinquishes unto and in favor of the M e,all benefit under all law:
now in effect or hereafter pained !o relieve the Mortgagor in any manner from the obligations assumed in the Note for which
this Indenwrc a security.
BUT PROVIDED ALWAYS, neverthcleu, clot if said Mortgagor shall pay or nose to be paid unto the raid Mortgage,
the aforesaid debt secured by this Mortgage, when and in the manner hercinbefore mentioned and appointed for payment of
the name, together with interest and all other vents hereby secured, then and from Uuneeforth, this Indenture, and the euste
hereby granted, as wdl as said recited Note, shall case, dercrmine, and become void, anything hereinbefore or in said Nots
contained to the coatnry notwithstanding.
if this Mortgage is exeated by morc than t-ns person as Mortgagor, the liabt7ity of each shall be joint and rerenl.
The covananu, conditions, and provislau contained in said Note, or in this Mortgage, shall bind, and the benefits and
advantages thereof shag inure to, the rcspsetive hein, executors, adminlurabn, sueseoors, rendess, and asdgns of tha polies
hereto or thereto; and whenever used !n said Note or in this Mortgage, the singular number shall include the Plural. the plural
the singular, the use of my gender dnB be appliabk to all gcnden, and the term "Mortgages" shag include any pays of tlu
indebtedness represented by said Notes, or fecund by this Mortgage, or any uansfcree thereof, whether by operatlan of law
or otherwise.
IN WITNESS WHEREOF, Mortpgor Mrcuato scts his hand and seal. Daud the day and yeu Ilrst hsreinabove written.
SIGNED, SEALED AND DEWVER,ED
IN THE PRESENCE OF:
~f/?~l.C/l.c~LlAA1:[2,[~i1 r2~c.,c,0'4
('=~~ ~~ ;SEAL)
EDSJIII G BIDDLE
~~~ ~ rSEAL)
SONG ~]i~LE~ ~,~~~'~"
REAL)
CERTIF1CAl'E OF RESII~NCE
~ 1, the Subscriber, do hereby certify that the correct address of Ne within-Warned Mortgagee is MERITOR MORTGAGE
~ CORPORATI011-BAST,AVENUE OF TUE ARTS BLDG,HROAD 6 CBESTAUT STREETS, PHILADELPSLA. PA 19107
Witaeu mY hand this THIRD daY of APRIL ~ 19 87
Arent of ortraree
COMMONWEALTH OF PENNSYLVANIA )
a
COUNTY OF CUMBERLAND )
On this THIRD day of APRIL , A.D., 19 87 before rrte,
$~BS ,,pQT~ BLIC arse ~ abon•named HDifiN G
~1ov~tlliii 141 of Mortgage to be net and
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same to be recorded as such. TREIR ~
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WITNESS my hand and seal, the day and yeu aforesaid. iY ~ ~•.O';
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PLEASE RECORD AND RSTURN T0:
MERITOR MORTGAGE CORPORATION-EAST Jdy CDnlatidgt gtpjrp _ .~;~i
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P. 0. BOg 4965
LANCASTER
PA 17604 ,
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SCHEDULE s
Poliq Number 39-0052-02-003917
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ALAI X6518
This policy doa not insure against loss or damage by reason of the following:
1. Encroachments, overlaps, boundary line disputes and any matters which
would be disclosed by an accurate survey and inspection of the premises.
2. Possible additional tax assessment by reason of new construction or
improvements pursuant to the provisions of the Acts of Assembly relating
thereto, not yet due and payable.
3. Subject to the provisions of the Federal Flood Relief .Act of 1973. Company
assumes no liability by reason thereof.
4. The lien of School taxes for the year 1987 and alI taxes thereafter,
not yet due and payable.
5. Subject to conditions as set forth in Plan Book I, page 51.
Countersigned
Authorized story
C. Wa a Keech
Sehedul• S of thi: Pelie~r eee:ists of l pages.
EXHIBIT "C"
10-03-'08 14;12 F~30M- T-947 P004/007 F-713
ZOW~60` i1e No 21-2008-03'I1
File No 2008-00371
Decedent BTDDLE EDWIN GREGORY
Per~81" Repz-e~entaty~ te}
CORRESPONDENT
Fop g 717-265-2&35
67x
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Apo ._----~--9636 --- -- -----------------
_._..._.-...-r- 717-732-9117
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•10-83-'08 14;11 FBOM-
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Fila No 2008-00371
Decedent B7DDLE EDWIN GREGORY
T-947 P002/007 F-713
PA File No 21-2008-0371
Date of Death 3/25/Z008
Filing Date ~/OZ/2008
Residence Code S EAST PENN3gOR0 TOWNSHIP
Estate Type 0 OTHER
Letters Granted N NO ~TT8R5
Certification-Needed ay 0/00/0000
status Report-Needed Dy 0/00/0000
1~ssessment Received 0/00/0000
Personal Representative 9 CORRESPONDENT
Report To State
Letters Granted
Certification-Filed
6tatuc 12eport-Filed
Date
0/00/0000
0/00/0000
0/00/0000
0/00/0040
Fiie out G/04/ooao
•`v~~~u 10-03-' 08 14;11 FBOM-
~~cate I~tquiry
F~.le No 2008-003')1
Decedent SIDOI.g EDvtIN GREGORY
T- 947 P003/007 F-713
PA File DTo 2l-2006-0371
Also Krlowa Ae (AKA
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File No 20ae-ao371
Decedent RIDDLE EDWIN GREGpItY
~,y~.a~:~ inquiry
Docket Entries
T-947 P005/007 F-713
PA File No 21-2008-0371
Dace
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4/02/2006 PETITION FOR GRANT OF LETTERS OF ADMxNIBTRATION
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4/09/2408 DECREE OF gTH~E REC3ISTER OF WILLS DATED 04 0~2/=0N8 YT xT HEREBY DECREED
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File Nv 2008-0 0372
Decedent RIDDLE EDDIIN GRRGORX
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VERIFICATION
Ctndy a sn~Ith ,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 Fin~nc~e LLC, s/b/m/t
Chase Nj~hattan M gage Corporation
~y a ,Assistant Secretary
*~
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RECEIVE D
OEC 3 U Z~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DNISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
vs.
Mark Edwin Biddle and Margret Biddle-Saunders,
Personal Representatives of the Estate of Edwin
Gregory Biddle, a/k/a Edwin G. Biddle
( )Confessed Judgment
' (X) Other (Default Judgment)
File No. 2009-00096
' Amount Due $39,246.14
Interest $11,735.28 (2/17/09 to saleZ
' Atty's Comm
Costs
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,
or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding
filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of CLIMB]
debt, interest and costs, upon the following described property of the defendant(s)
r
PRAECIPE FOR ATTACHMENT EXECUTION
Co ~nty, for
o
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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).
O (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 ~~i, .,,~ ~ ~ Signature: / ~/
..,/ 1. ~~ c :~~ 4 •~_ l ~"I "t (.~ ,._
s
~a4 • oo P4 ~.t..H Print Name:
Kristine M. Anthou
'y~ •~` L~f g~ Address: One Gateway Center, 9`" Floor
~y
(~7i 3 ~. .. e r ~,~01~~ef~'d .
,~,g ,S'U ,r << Pittsburgh, PA 15222
i, s(
/`'f •~
<~ Attorney for:
Plaintiff
«
a U " ~~ Telephone: (412) 281-7650
_ Supreme Court ID No.:
88- ~ ~~
~i73 77991
. (over)
C~'~ ra sa.9 p
~~od~fDlv73 ~ ll)rr-~-o-P~kc~f
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.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Enola, East Pennsboro Township,
Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a
survey by Michael C. D'Angelo, dated August 1, 1978, as follows, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance of 190 feet
(erroneously set forth in prior deed as 200) north of Cumberland Road; thence along the said Altoona
Avenue North 10 degrees 20 minutes West, 50 feet; thence North 79 degrees 40 minutes East, 125
feet; thence South 10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING Known as 18 Altoona Avenue, Enola, PA.
BEING the same premises which Harry E. King and Sandra L. King, by Deed dated April 3, 1987
and recorded in the Office of the Recorder of Deeds of Cumberland County on April 7, 1987, in
Deed Book 32-0, Page 918, granted and conveyed unto Edwin G. Biddle and Song Suk Biddle. At
the time of Song Suk Biddle's death, title vest solely in Edwin G. Biddle, by operation of law. At the
time of Edwin G Biddle's death, title vest in Mark Edwin Biddle and Margret Biddle -Saunders,
Personal Representatives of the Estate of Edwin G. Biddle.
GRENEN & BIRSIC, P.C.
~_ .~ ~ ~, f<Cc~
By._(k-~ ~` C~,~ ~ ~. ~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
Parcel #09-14-0832-302 (412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
c-n
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C`J
ty ~=y ~ ~~ E~'?
c~
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 Mark Edwin Biddle and Margret Biddle -
Saunders, Personal Representatives of the Estate of Edwin G. Biddle located at 18 Altoona
Avenue, Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
O, PAGE 918, PARCEL NUMBER 09-14-0832-302.
! .
1. The name and address of the owner or reputed owner:
Mark Edwin Biddle
Margret Biddle-Saunders
18 Altoona Avenue
Enola, PA 17025
PSC 78, Box 6726
APO, AP 96326
2. The name and address of the defendants in the judgment:
Mark Edwin Biddle
Margret Biddle-Saunders
18 Altoona Avenue
Enola, PA 17025
PSC 78, Box 6726
APO, AP 96326
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.
John A. Pokrzyk and
Ann L. Pokrzyk
PLAINTIFF
c/o Robert C. Saidis
627 Gutshall Road
Boiling Springs, PA 17007
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, et al.
Beneficial Consumer Discount CO
D/B/A Beneficial Mortgage of PA
PLAINTIFF
4910 Carlisle Pike, Suite 104
Hampden Center
Mechanicsburg, PA 17050
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
Commonwealth of Pennsylvania
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
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:
Cumberland County Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
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:
Tenant(s)
18 Altoona Avenue
Enola, PA 17025
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.
c < ~ ~---
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
` _,
ME THIS --~- DAY °~ 2010.
^~ ~ ..
~. ~~ c~~~
Notary Public
con~~i~c~N~~v~~~c~~ r~~=~ ~~~wNS~~~~,~^~tr~
Notarial Seal
Elizabeth M. Paiana, Notary Public
City rJf Pittsbtxgh, Allegheny Co~Y
My C',nxnrrtissiortExphes Jan. 6, 2012
~,~s'ntrzr, -3N•nrsvlvas~i~ ~ssociati®n 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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
CIVIL DIVISION
NO.: 2009-00096
Defendants.
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
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Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who
being duly sworn according to law deposes and says that the owners of the property located at 18
Altoona Avenue, Enola, PA 17025 are Defendants, Mark Edwin Biddle and Margret Biddle
Saunders, Personal Representatives of the Estate of Edwin Gregory Biddle, a/k/a Edwin G.
Biddle, whose last known address is 18 Altoona Avenue, Enola, PA 17025 and PSC 78, Box
6726, APO, AP 96326, respectively, to the best of her information, knowledge and belief.
-~ ~~C Vic- < ~~.-c_~ )t ~~~ ~c,. c: /c_ ~~
SWORN TO AND SUBSCRIBED BEFORE
,A~IE THIS I ~-1~1 DA ~ F ~~'~ ,~, 2010.
~.
~ ~ ~~
Notary Public
COMMONWEALTH OF' PENNSYLVANIA
Notarial Seal
Elizabeih M. Paiano, Notary Public
City Of Pittsburgh, ANegheny County
~.~y Commi^.~sion E~irPS Jan. 6, 2012
F ~ ..~ _' n syfv~~,ea A s.,c ~1cn at ~!~?aeies
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
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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 or about November 17, 2008,
Defendants were 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
r
ME THIS_ DA OF 2010.
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Notary Public
COMMON'JVa=AL12~ t3F ~ vNiVaY1_VF+IVfA
Netariai Sal Public
City Of Pittsburgh, AN NAY COUMY
~, Cornn>ission Expires Jan. 6.2012
Member, pennsylvanla Assoclstlon of Notarlee
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.: 2009-00096
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of ~
EDWIN GREGORY BIDDLE, a/k/a n
~ ~,
EDWIN G. BIDDLE, ~ ~; z'e ~ ~
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Defendants. !-~,.
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NOTICE OF SHERIFF'S SALE OF REAL ESTATE r'~;
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TO: Margret Biddle-Saunders
PSC 78, Box 6726
APO, AP 96326
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 September 8, 2010, at 10:00 A.M., the following described real estate, of which Mark Edwin
Biddle and Margret Biddle -Saunders, Personal Representatives of the Estate of Edwin G. Biddle
are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED 1N THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
O, PAGE 918, PARCEL NUMBER 09-14-0832-302.
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.
Mark Edwin Biddle and Margret Biddle-Saunders,
Personal Representatives of the Estate of Edwin
Gregory Biddle, a/k/a Edwin G. Biddle,
Defendants,
at Execution Number 2009-00096 in the amount of $50,981.42.
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
CE 1ASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DlV[SION
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a1k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
LONG FORM DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Enola, East Pennsboro Township,
Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a
survey by Michael C. D'Angelo, dated August 1, 1978, as follows, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance of 190 feet
(erroneously set forth in prior deed as 200) north ofCumberland Road; thence along the said Altoona
Avenue North 10 degrees 20 minutes West, 50 feet; thence North 79 degrees 40 minutes East, 125
feet; thence South 10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING Known as 18 Altoona Avenue, Enola, PA.
BEING the same premises which Harry E. King and Sandra L. King, by Deed dated April 3, 1987
and recorded in the Office of the Recorder of Deeds of Cumberland County on April 7, 1987, in
Deed Book 32-0, Page 918, granted and conveyed unto Edwin G. Biddle and Song Suk Biddle. At
the time of Song Suk Riddle's death, title vest solely in Edwin G. Biddle, by operation of law. At the
time of Edwin G Riddle's death, title vest in Mark Edwin Biddle and Margret Biddle -Saunders,
Personal Representatives of the Estate of Edwin G. Biddle.
GRENEN & BIRSIC, P.C.
Parcel #09-14-0832-302
,~ =
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
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
CIV[L DIVISION
NO.: 2009-00096
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Mark Edwin Biddle
18 Altoona Avenue
Enola, PA 17025
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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 September 8, 2010, at 10:00 A.M., the following described real estate, of which Mark Edwin
Biddle and Margret Biddle -Saunders, Personal Representatives of the Estate of Edwin G. Biddle
are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
O, PAGE 918, PARCEL NUMBER 09-14-0832-302.
The said Writ of Execution has been issued on a jud~nent in the mortgage foreclosure action of
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation,
Plaintiff,
vs.
Mark Edwin Biddle and Margret Biddle-Saunders,
Personal Representatives of the Estate of Edwin
Gregory Biddle, a/k/a Edwin G. Biddle,
Defendants,
at Execution Number 2009-00096 in the amount of $50,981.42.
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: ~ ~Cf~ .~ < < ,. ~ ~1~: <<
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
CEIASE HOME FINANCE LLC, s/b/m/t CIV[L DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff;
NO.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Enola, East Pennsboro Township,
Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a
survey by Michael C. D'Angelo, dated August 1, 1978, as follows, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance of 190 feet
(erroneously set forth in prior deed as 200) north of Cumberland Road; thence along the said Altoona
Avenue North 10 degrees 20 minutes West, 50 feet; thence North 79 degrees 40 minutes East, 125
feet; thence South 10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING Known as 18 Altoona Avenue, Enola, PA.
BEING the same premises which Harry E. King and Sandra L. King, by Deed dated April 3, 1987
and recorded in the Office of the Recorder of Deeds of Cumberland County on April 7, 1987, in
Deed Book 32-0, Page 918, granted and conveyed unto Edwin G. Biddle and Song Suk Biddle. At
the time of Song Suk Riddle's death, title vest solely in Edwin G. Biddle, by operation of law. At the
time of Edwin G Riddle's death, title vest in Mark Edwin Biddle and Margret Biddle -Saunders,
Personal Representatives of the Estate of Edwin G. Biddle.
GRENEN & BIRSIC, P.C.
,~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
Parcel #09-14-0832-302 (412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
CIVIL DIVISION
NO.: 2009-00096
TYPE OF PLEADING
cv
0
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
SALE DATE: September 8, 2010
Pa. R.C.P. RULE 3129.2(c)(2) w
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
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,
NO.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/kla
EDWIN G. BIDDLE,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVI
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:
1. By letters dated June 14, 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.
2. By letters dated May 28, 2010, 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:`-? ?-
Kristi e M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS DAY OF ? ^x , 2010.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial S,w
Patricia A. Townser-'. v;,b 1c
City of Pittsburgh, .: s?nty
? PAY Commission EK_t':?., zsf, x k, 2611
Member, Pennsylvania N #gooi , nr of Notaries
• s
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
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 Mark Edwin Biddle and Margret Biddle -
Saunders, Personal Representatives of the Estate of Edwin G. Biddle located at 18 Altoona
Avenue, Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
0, PAGE 918, PARCEL NUMBER 09-14-0832-302.
0 0
1. The name and address of the owner or reputed owner:
Mark Edwin Biddle 18 Altoona Avenue
Enola, PA 17025
Margret Biddle-Saunders PSC 78, Box 6726
APO, AP 96326
2. The name and address of the defendants in the judgment:
Mark Edwin Biddle 18 Altoona Avenue
Enola, PA 17025
Margret Biddle-Saunders PSC 78, Box 6726
APO, AP 96326
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.
John A. Pokrzyk and
Ann L. Pokrzyk
PLAINTIFF
c/o Robert C. Saidis
627 Gutshall Road
Boiling Springs, PA 17007
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, et al.
Beneficial Consumer Discount CO
D/B/A Beneficial Mortgage of PA
PLAINTIFF
4910 Carlisle Pike, Suite 104
Hampden Center
Mechanicsburg, PA 17050
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
Commonwealth of Pennsylvania
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
0 6
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:
Cumberland County Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant(s)
18 Altoona Avenue
Enola, PA 17025
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 2010.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
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 Mark Edwin Biddle and Margret Biddle
Saunders, Personal Representatives of the Estate of Edwin Gregory Biddle, aWa Edwin G.
Biddle, located at 18 Altoona Avenue, Enola, PA 17025, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVENUE, ENOLA, PA 17025. MBV
32-0, PAGE 918, PARCEL NUMBER 09-14-0832-302.
The name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
East Pennsboro Twp.
98 S. Enola Drive
Enola, PA 17025
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 unworn falsification
to authorities.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, l?squire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN ,T,Oh}AND SUBSCRIBED BEFORE ME
THIS ?-{ DAY OF 2010.
Notary Public
COMMONW ,A fibd 9F PENNSYLVANIA
Noterlal 8"
Petricle A. TawnwW, Nogry Public
City of Plttsburgh, Altephany county
M Commission ex 'm June 2, 2011
Member, Pennsylvania Association of Notaries
U.S. POSTAL SERVICE CERTIFICATE OF MAIL
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N,
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic. P.C.
One Gateway Center, 9m Floor, Pittsburgh. PA 15222
One piece of ordinary mail addressed to:
East Pensboro TW .
98 S. Enola Drive
4 I' a .
Enola PA 17025
PS Form 3817, January 2001
A ii{.. fm 1- ,
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`ar.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
CIVIL DIVISION
NO.: 2009-00096
TYPE OF PLEADING
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
'S
G3
N
r?
w
c?
Defendants.
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: September S, 2010
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.: 2009-00096
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes
the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this
matter on September 8, 2010 as follows:
Mark Edwin Biddle and Margret Biddle Saunders, Personal Representatives of
the Estate of Edwin Gregory Biddle, a/k/a Edwin G. Biddle, are the owners of the real property
and have not entered an appearance of record.
2. On August 26, 2009, this Court entered an Order authorizing Plaintiff to serve
Defendant, Mark Edwin Biddle, Personal Representative of the Estate of Edwin Gregory Biddle,
aWa Edwin G. Biddle, by posting the property and serving the Defendant by certified mail and
first class mail to address 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 June 14, 2010, the undersigned
counsel served Defendant, Mark Edwin Biddle, Personal Representative of the Estate of Edwin
Gregory Biddle, a/k/a Edwin G. Biddle, 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 Mark Edwin Biddle at 18 Altoona Avenue, Enola, PA 17025. A true and
correct copy of the U.S. Postal Service form 3800, Article Number 7010 0290 0001 4383 8932,
and the Certificate of Mailing, evidencing service by certified mail and first class mail on the
Defendant, Mark Edwin Biddle, Personal Representative of the Estate of Edwin Gregory Biddle,
a/k/a Edwin G. Biddle, are marked Exhibit "B", attached hereto and made a part hereof.
4. On June 21, 2010, the Sheriff's Office of Cumberland County posted the property
located at 18 Altoona Avenue, Enola, PA 17025. A true and correct copy of the Sheriff's return
of Service is marked Exhibit "C", attached hereto and made a part hereof.
5. By letter dated July 16, 2010, the undersigned counsel served Defendant, Margret
Biddle Saunders, Personal Representative of the Estate of Edwin Gregory Biddle, a/k/a Edwin G.
Biddle, with a true and correct copy of Plaintiffs notice of the sale of real property by certified
mail, restricted delivery, return receipt requested, addressed to Margret Biddle Saunders at 4778
Catterick Ct., Fairfax, VA 22032.
6. On or about July 28, 2010, Plaintiff received the certified mail envelope
indicating that the certified mail was refused. A true and correct copy of the returned envelope,
is marked Exhibit "D", attached hereto and made a part hereof.
7. Pursuant to Rule 403(1) of the Pennsylvania Rules of Court, Plaintiff shall have
the right to serve mail by First Class Mail.
8. On or about August 3, 2010, Plaintiff mailed the Notice of Sheriff's Sale via first
class mail, postage prepaid with Plaintiff's return address to Defendant, Margret Biddle
Saunders, Personal Representative of the Estate of Edwin Gregory Biddle, a/kla Edwin G.
Biddle, at her last known address being 4778 Catterick Ct., Fairfax, VA 22032. A copy of Postal
Form 3817, Certificate of Mailing is marked Exhibit "E", attached hereto and made a part hereof.
9. To date the first class mail has not been returned to Plaintiff.
10. Pursuant to Rule 403(1) of the Pennsylvania Rules of Court, service is deemed
complete and valid.
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.
Kristine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN ?T,O? AND SUBSCRIBED BEFORE ME
THIS DAY OF '2010.
3P Notary Public
_:ONIMONWEALTH OF PENNSYLVANIA
Notarial Seel
cla A. Townsend, Notary Public
"itY of Pittsburgh, Allegheny county
'Ay Commission Expires June 2, 2011
MW-bber, Pennsylvania Association of Notaries
r
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
ORDER OF COURT
AND NOW, to wit, this day of 2009, upon
ccnsideration of the within Motion for Service of the Notice of Sheriff's Sale Pursuant to
Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Plaintiff
is permitted to serve Defendant, Mark Edwin Biddle, Personal Representative of the Estate of
Edwin Gregory Biddle, &Wa Edwin G. Biddle, by first class mail; postage pre-paid and certified
mail at 18 Altoona Avenue, Er- )la, Pennsylvania 17025 and by posting of the handbill in
accordance with Pa. R.C.P. 3129.2(b). Service on the Defendant shall be deemed complete and
valid upon mailing and postinb in accordance with this order.
BY THE COURT:
R?C?
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U.S. POSTAL SERVICE CERTIFICATE OF MAIL11
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES N07
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic. P.C. _
One Gateway Center, 9th Floor, Pittsburgh, PA 15222
One piece of ordinary mail ad0awed to:
tia oQ
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PS Form 3817, January 2001
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Jody S Smith 04 Chief Deputy 01414
Richard W Stewart
Solicitor OFFICE OF THE SHERIFF
Chase Home Finance LLC s/b/m/t
Case Number
vs.
Mark E Biddle (et al.) 2009-96
SHERIFF'S RETURN OF SERVICE
06/21/2010 06:55 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 21,
2010 at 1851 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 Mark E. Biddle & Margret Biddle-Saunders, located at, 1 f
Altoona Avenue, Enola, Cumberland County, Pennsylvania according to law.
06/21/2010 06:55 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 21,
2010 at 1851 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: Mark E. Biddle, by posting upon the
property of Mark E. Biddle, located at, 18 Altoon Avenue, Enola, Cumberland County, Pennsylvania,
pursuant to Court Order.
SHERIFF COST: $908.42
July 01, 2010
SO ANSWERS,
4z V U?Z?--
RON R ANDERSON, SHERIFF
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
CIVIL DIVISION
0
er
NO.: 2009-00096 5
c
N
TYPE OF PLEADING yt
SUPPLEMENTAL AFFIDAVIT
PURSUANT TO RULE 3129.1
FILED ON BEHALF OF PLAINTIFF:
Defendants.
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
SALE DATE: September 8, 2010
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
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 Mark Edwin Biddle and Margret Biddle
Saunders, Personal Representatives of the Estate of Edwin Gregory Biddle, a/k/a Edwin G.
Biddle, located at 18 Altoona Avenue, Enola, PA 17025, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS I8 ALTOONA AVENUE, ENOLA, PA 17025. MBV
32-0, PAGE 918, PARCEL NUMBER 09-14-0832-302.
I. The name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
East Pennsboro Twp.
98 S. Enola Drive
Enola, PA 17025
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.
_I
BY,
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 DAY OF
2010.
r
Notary Public
GOMMONWIEALTH OF PENNSYLVANIA
Notarial Seal
?etric1--i' Townsend, Notary Public
City of Pittsburgh, Allegheny Cojnty
h9y Gommisston Expires June 2, 2011
Member. Penrsylvani Rtsociation of Notaries
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S>Smith
Chief Deputy
Richard V/ Stewart
Solicitor
Chase Home Finance LLC s/b/m/t
. Case (Number
vs.
Mark E-.Biddle (et al.) 2009-96
SHERIFF'S RETURN OF SERVICE
06/21/2010 06:55 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 21,
2010 at 1851 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 Mark E. Biddle & Margret Biddle-Saunders, located at, V
Altoona Avenue, Enola, Cumberland County, Pennsylvania according to law.
06,/21/2010 06:55 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 21,
2010 at '1851 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: Mark E. Biddle,, by posting upon the
property of Mark E. Biddle; located at, 18 Altoon Avenue; Enola, Cumberland County, Pennsylvania,
pursuant to Court Order.
09/07/2010 As directed by Kristine M Anthou, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/6/2010
10/06/20'10 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 October 6, 2010 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 Ninth Street, Cleveland, OH 44199, being the buyer in this
execution, paid to Sheriff Ronny R. Anderson, the sum of $
SHERIFF COST: $907.74 SO ANSWERS,
r.
November 08, 2010 R Nl R ANDERSON, SHERIFF
'N13_3
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN' GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
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 Mark Edwin Biddle and Margret Biddle
Saunders, Personal Representatives of the Estate of Edwin G. Biddle located at 18 Altoona
Avenue, Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
0, PAGE 918, PARCEL NUMBER 09-14-0832-.302.
5
1. The name and address of the owner or reputed owner:
Mark Edwin Biddle 18 Altoona Avenue
Enola, PA 17025
Margret Biddle-Saunders PSC 78, Box 6726
APO, AP 96326
2. The name and address of the defendants in the judgment:
Mark Edwin Biddle 18 Altoona Avenue
Enola, PA 17025
Margret Biddle-Saunders PSC 78, Box 6726
APO, AP 96326
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. PLAINTIFF
John A. Pokrzyk and c/o Robert C. Saidis
Ann L. Pokrzyk 627 Gutshall Road
Boiling Springs, PA 17007
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, et al. PLAINTIFF
Beneficial Consumer Discount CO 4910 Carlisle Pike, Suite 104
D/B/A Beneficial Mortgage of PA Hampden Center
Mechanicsburg, PA 17050
,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
Commonwealth of Pennsylvania Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
Ar
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:
Cumberland County 'Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant(s)
18 Altoona Avenue
Enola, PA 17025
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 1 _ DAY t 1. 2010.
Notary Public
CC?IVi1 ONv?EALTH CF P NtVSYL`JAi?la?
Notanal Seal
Elizabeth m. Paiano; Notary , Public
City ()f Plttsbu'gh, AlleMMY County
M,y Comfnission Expires Jan.' 6, 2012
E?r,?y?y?ni? association of Notaries
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.
MARK EDWIN BIDDLE .and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
LONG FORM DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Enola, East Pennsboro Township,
Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a
survey by Michael C. D'Angelo, dated August 1, 1978, as follows, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance of 190 feet
(erroneously set forth in prior deed as 200) north of Cumberland Road; thence along the said Altoona
Avenue North 10 degrees 20 minutes West, 50 feet; thence North 79 degrees 40 minutes East, 125
feet; thence South 10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING Known as 18 Altoona Avenue, Enola, PA.
BEING the same premises which Harry E. King and Sandra L. King, by Deed datedApril 3, 1987
and recorded in the Office of the Recorder of Deeds of Cumberland County on April 7, 1987, in
Deed Book 32-0, Page 918, granted and conveyed unto Edwin G. Biddle and Song Suk Biddle. At
the time of Song Suk Biddle's death, title vest solely in Edwin G. Biddle, by operation of law. At the
time of Edwin G Biddle's death, title vest in Mark Edwin Biddle and Margret Biddle -Saunders,
Personal Representatives of the Estate of Edwin G. Biddle.
GRENEN & BIRSIC, P.C.
Parcel #09-14-0832-302
F
KristineM. 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.: 2009-00096
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Mark Edwin Biddle
18 Altoona Avenue
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 September 8, 2010, at 10:00 A.M., the following described real estate, of which Mark Edwin
Biddle and Margret Biddle -Saunders, Personal Representatives of the Estate of Edwin G. Biddle
are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF MARK EDWIN BIDDLE
AND MARGRET BIDDLE-SAUNDERS, PERSONAL REPRESENTATIVES OF THE
ESTATE OF EDWIN GREGORY BIDDLE, A/K/A EDWIN G. BIDDLE, IN AND TO THE
FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, AND
COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING
BEING KNOWN AND NUMBERED AS 18 ALTOONA AVE., ENOLA, PA 17025. MBV 32-
0, PAGE 918', PARCEL NUMBER 09-14-0832-302.
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.
Mark Edwin Biddle and Margret Biddle-Saunders,
Personal Representatives of the Estate of Edwin
Gregory Biddle, a/k/a Edwin G. Biddle,
Defendants,
at Execution Number 2009-00096 in the amount of $50,981.42.
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
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
Vs.
MARK EDWIN BIDDLE' and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
LONG FORM DESCRIPTION
ALL THAT CERTAIN piece of parcel of land situate in Enola, East Pennsboro Township,
Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a
survey by Michael C. D'Angelo, dated August 1, 1978, as follows, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance of 190 feet
(erroneously, set forth in prior deed as 200) north of Cumberland Road; thence along the said Altoona
Avenue North 10 degrees 20 minutes West, 50 feet; thence North 79 degrees 40 minutes Bast, 125
feet; thence South 10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING Known as 18 Altoona Avenue, Enola, PA.
BEING the same premises which Harry E. King and Sandra L. King, by Deed dated April 3, 1987
and recorded, in the Office of the Recorder of Deeds of Cumberland County on April 7, 1987, in
Deed Book 32-0, Page 918, granted and conveyed unto Edwin G. Biddle and Song Suk Biddle. At
the time of Song Suk Biddle's death, title vest solely in Edwin G. Biddle, by operation of law. At the
time of Edwin G Biddle's death, title vest in Mark Edwin Biddle and Margret Biddle =Saunders,
Personal Representatives of the Estate of Edwin G. Biddle.
GRENEN & BIRSIC, P.C.
Parcel #09-14-0832-302
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 09-96 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 MARK EDWIN BIDDLE and MARGRET BIDDLE-SAUNDERS, Personal Representatives
of the Estate of EDWIN GREGORY BIDDLE, a/k/a EDWIN G. BIDDLE
(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 $39,246.14 L.L.
Interest from 2/17/09 to Date of Sale -- $11,735.28
Atty's Comm % Due Prothy $2.00
Atty Paid $q,73,88 Other Costs
Plaintiff Paid
Date: 4/16/10
David D. Buell, Prothonotary
(Seal) By:
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC, PC
ONE GATEWAY CENTER
NINE WEST
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Deputy
TRUE COPY FROM RECORD
in TestirT ony wher&t 7. I here unto set my hwd
an the, seas of S;Rld
t" ,, attatllsle, Pa.
1 has I cn*?` " 'ash ot... 2010
_
" ` lProftnotary
Telephone: 412-281-7650
Supreme Court ID No. 77991
On June 14, 2010 the Sheriff Ievied,upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA,
Known and numbered as, 18 Altoona Avenue,
Enola, more fully described on Exhibit
"A" filed with this writ .and by this reference
incorporated herein:
Date: June 14, 2010
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,
viz:
July 16, July 23, and July 30, 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.
)iksa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
30 da of July, 2010
Notary
C::
!NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
Writ No. 2009-96 Civil
Chase Horne Finance LLC
s/b/m/t C:rase Manhattan
Mortgag-- Cocporaton
vs.
Mark E, Biddle Personal
Representative of the Estate
of F," in Crezorv Biddle,
a/k/-r Eds-in G. Bi•ddie
Margret Diddle-Saunders
Persona: Renrese.tative of the
Estate of Edwir Cregor r Biddle,
a./ k./ a L n G, Biddle
Bitty.- Enstirlc Aathau
Ai_', THAT CERTAIN piece of
paccel of ?arid situate in. Enola; East
Pennsboro Tovrns'hi.n, Cumberland'
Co=, rtp, Pc_itsi.,an a, more par-
dcularly bounded and described in
accordance si>zth a survey be \-lichaei
C. D'Angelo, dated August 1., -1978,
as follow,. -o wit
BFGIbiNIaiG at a point in the
masterly line of itoana Avenue of
the distance of 190 feet (e-roneol-isly
set forth in prior deed as 200) north
of Cumberla:rd Ro??.r; thence along ; -
'he said Altoor, _- Avenue Nor-h 10
degrees 20 minute: Nest, 50 feet;
thence North 7S= degrees 40 ites
East, 125 teet; thence South 10
degrees 20 minutes East 50 feet;
and thence South 79 degrees 40
minutes Lest, 125 feet to the place
of BEGINNING.
BEING Kzro,Nn as 1-8 Altoona Av-
enue, Enola, TA.,
BEING the smile premises which
I-iarn, E King and Sandra king,
h y Deed dated Anrii 3, 1.987' acid re_
cord 6 zr_ t` r of tree Recorder
of Deeds of Cumbenand County on
April 7, 1987. in Deed, Book 32-0,
Page 91.3, granted and cor,evcd
unto Edv m G. 2icidle and Song
Suk Biddle_ At tilt time of Song Suk
Biddle's dep_-, n, ritlc vest solely in F d-
,\--in G. Biddle, b,- operation of la,,. At
the t_±re of G Biddle's death,
title -,,e sr :r- _ark _,d,vjj,, Biddle and
M'a-grer Biddle -Saunders; Personal
Representatives of the Estate of Ed-
win G. Bn'3die.
*T')e Patriot-News Co.
2? 20 Technology PkWy
Suite 300
;Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
1(4c Patr1*ot*yXtws
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
Holly Blain, 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:
07/09/10
07/16/10
07123/10
Sworn to bscribed before me t1lis 05 da f August, 2010 A.D.
j
Notary Public
COMMONlAIF,4LTH OF PENN VAN
N? al Sea
Sherrie L Kisner? Notary Public
Lower Paxton Tw
?Y Commission P , Dauphln County
Member, Pennsyl+,anii Nov. 26, 201i
rx ia,ion of Notaries
Writ No. 20W96 Civil Term
:base moms Finance LLC afb/
rvJt Chase Manhattan Mortgage
Corporation
Vs
Mark E. Biddle Personal
Representative of the Estate of
Edwin Gregory
Biddle, a/k/a Edwin G. Biddle
Margret Biddle-Saunders
Personal Representative of the
Estate of Edwin Gregory
Biddle, aWa Edwin G. Biddle
Atty: Kristine Anthou
ALL THAT CERTAIN piece of parcel of land
ituate in Enola, East Pemtsboro Towndtip,
Cumberland County, Penrs!lvania.' more
puticularly txnunded turd drscribe?i in accordance
kvith a survey be Michael C. D'Angelo, dated
uaest 1, 1975, as follows. to win:
BEGINNING it'.. point In the .asteth line of
'Altoona Avenue at the distance of 190 feet
(erroneously set forth in prior deed as. 200) north
of Cumberland Road: thence along the said
Altoona Acme Nw-oi 10 decree, 20 minutes
West 50 feat; rhentc North N dcjcc? 4")
runutes East. 125 feet: thence South 10 degrees
20 minutes East- 50 feet: and thence South 74
degrees 40 nnnnes Wcst,1'Y feet to the place
ai BEGINNING.
BEING Known as I S Altoona Avenue Enola.
PA.
BEING the sanie premises which Hann E. Kinc
and Sandra L. King. bvDeed dated April 3,19`?
and recorded in the Office of the Recorder cif
Deeds of Cumberland County on April T 199.
it. Deed Book 32-0, Page 918, ,ranted and
conveyed unto Edwin G. Biddle and Song, Suk
Biddle. At the thine of Song Suk Biddle's deatl
title vest solely in Edwin G. Biddle. by operation
of law. At the time of Edwin G Riddle's death.
title ?`cet in Mark Edwin Biddle and M rust
Biddle -Saunders, Pcisonal Representatives of
the Estate of Edwin G. Biddle.
d
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I 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 6th day of October A.D., 2010, under and by virtue of a writ Execution issued on the 16th
day of April, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 09
Number 96, at the suit of Chase Home Finance LLC s/b/m/t Chase Manhattan Mtg Corp against Edwin
Gregory Biddle aka Edwin G, Estate is duly recorded as Instrument Number 201032586.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this __day of
O corder of Deeds
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.: 2009-00096
TYPE OF PLEADING
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
Motion to Amend Caption nunc pro tune
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
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?F`{:
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.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
MOTION TO AMEND CAPTION NUNC PRO TUNC
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 to Amend Caption Nunc Pro Tunc as follows:
On or about January 8, 2009, Plaintiff filed a Complaint in Mortgage Foreclosure
against the Defendants, Mark Edwin Biddle and Margret Biddle Saunders, Personal
Representatives of the Estate of Edwin Gregory Biddle a/k/a Edwin G. Biddle, to foreclose on
property known as 18 Altoona Avenue, Enola, PA 17025 ("premises") based on a mortgage
executed by Edwin Gregory Biddle a/k/a Edwin G. Biddle in favor of Plaintiff on April 3, 1987.
A true and correct copy of said mortgage is marked as Exhibit "A", attached hereto and made a
part hereof.
2. On April 2, 2008, Defendants filed a Petition for Grant of Letters of
Administration at File Number 21-20008-0371. A copy of said petition, marked Exhibit "B", is
attached hereto and incorporated herein.
3. On or about April 9, 2008, an order was entered requiring Defendants to post a
bond before the Letters of Administration would be granted.
4. Defendants did not post the bond required, but it is believed and therefore averred
that Defendants are the sole heirs of the Estate of Edwin Gregory Biddle.
5. Plaintiff desires to amend the caption to identify Defendants, Mark Edwin Biddle
and Margret Biddle Saunders, as the sole heirs of the Estate of Edwin Gregory Biddle a/k/a
Edwin G. Biddle, rather than personal administrators of the Estate of Edwin Gregory Biddle
a/k/a Edwin G. Biddle.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the
caption in this action to list the Defendants as heirs to the Estate.
GRENEN & BIRSIC, P.C.
BY:
Kristine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion to
Amend Caption and Order of Court was mailed to the following on this rat day of
2011, by first class, U.S. Mail, postage pre-paid:
Mark Edwin Biddle
18 Altoona Avenue
Enola, PA 17025
Margret Biddle Saunders
18 Altoona Avenue
Enola, PA 17025
GRENEN & BIRSIC, P.C.
BY:
Kristine M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
EXHIBIT "A"
Form Jane 36-4336 (Home Low)
Revfwd fuze 1 197915. Uw Opdonal,-
R* P LH 434Yi 15IA
Section 1610. Tide $4.U.S.C.
Acceptable tp FeM ational
Mortgage Awocietion.
221576-2 111 MORTGAGE
THIS INDENTURE, made the 3RD day of APRIL in the
you of our Lord one thousand nine hundred and eighty-eeven BE-fnEN EDWIN G
BIDDLE AND SONG SUK BIDDLB (hereinafter called Mortgagor) and
MERITOR MORTGAGE CORPORATION-EAST, AVENUE OF THE ARTS BLDG, BROAD b CHESTNUT STREETS,
a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, and having its principal office
and post-office address in PHILADELPHIA, PA 19107 (hereinafter called Mortgagee):
WITNESSETH: That the Mortgagor to secure the payment of
FIFTY SEVEN THOUSAND FIVE HUNDRED b 00/100
Dollars ($ 57 .500.00 ), with interest from date, at the rate of EIGHT AND ONE-HALF per centu m
( 8.50096) per annum on the unpaid balance until paid, a provided in a Note of evert date herewith, from the
Mortgagor to the Motgagee, in monthly installments of FOUR HUNDRED FORTY TWO b 13500
Dollars. ($ 442.14, commencing on the first day of
JUNE , 19 87 , and continuing thereafter on the Ant 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 dayof
MAY 2017 , 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 follow-
ing described real property situate in the TOWNSHIP of EAST PENNSBORO County of
CUMBERLAND and Commonwealth of Pennsylvania, to wit:
BEING MORE PARTICULARLY DESCRIBED ACCORDING TO A LEGAL DESCRIPTION ATTACHED HERETO AND
MADE A PART HEREOF.
Sh
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SEE ATTACHED LEGAL DESCRIPTION
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Should the Veterans Administration for any nasal fail or refuse to issue the guarantee in the maximum amount per-
mitted of the loan secured by this mortgage under the provisions of the Servicemen's Readjustment Act of 1944, as amend.
ed, within sixty days of the date hereof, the mortgagee herein may at its option declare all sums secured by ft mortgage
immediately due and payable.
TOGETHER with all and singular the buildings, improvements, and fixtures on said premises, u well as all additions
or improvements now or hereafter made to said premises, streets, alleys, passages, ways, waters, water courses, rights,
liberties, privileges, hereditament:, and appurtenances whatsoever thereunto belonging, or in any wise appertaining, and the
reversions 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 put of the realty, and are a portion of the security for the
indebtedness herein mentioned, namely,
RANGE/OVEN, W/W CARPET
provided, however, that the Mortgagor shall be entitled to collect and retain the said rents, issues, and profits until default
hereunder:
TO HAVE AND TO HOLD said property, hereby granted, with the appurtenances, unto said Mortgagee to its own
use forever:
b00K 858 FACE 1099
MMC 220 Rev. 6/66 )tr
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 indebtednessor any part thereof not less than the amount of one installment, or one hundred dollars ($100.00),
whichever is less. 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 shall pay to the Mortgagee as trustee (under
the terms of this trust as hereinafter stated) in addition to and concurrently with, each monthly installment of principal
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 paya-
ble 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
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, 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:
(1) ground rents, taxes, assessments, sewer and water rents, fire and other hazard insurance premiums;
(11) interest on this debt; and
(111) 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 said 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 (496) of any installment when paid more
than fifteen (15) days after the due date thereof to cover the extra expense involved in handling delinquent payments,
but such "late charge" shall not be payable out of the proceeds of any We made to satisfy the indebtedness secured
hereby, unless such proceeds of any sale made to satisfy the indebtedness secured hereby, unless such proceeds are
sufficient to discharge the entire indebtedness and all proper costs and expenses secured thereby.
3. If the total of the payments made by Mortgagor, under (a) of paragraph 2 preceding, shall exceed the amount
of payments actually made by Mortgagee as trustee for ground rents, taxes, assessments, sewer or water rents, or insurance
premiums, as the cue 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. If, however, such monthly payments shag not
be sufficient to pay such items when the same shall become due and payable, then Mortgagor shall pay to Mortgagee u
trustee any amount necessary to make up the deficiency within thirty (30) days after written notice from Mortgagee stating
the amount of the deficiency, which notice may be given by mail. If at any time Mortgagor shelf tender to Mortgagee, in
accordance with the provisions hereof, the full payment of the entire indebtedness represented hereby, Mortgagee, a trustee,
shag 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 shag be a default under any of the provisions of the Note and this Mortgage
securing the same, which results in a public sale of the premises covered thereby, or if title to the property is otherwise
acquired by the Mortgagee after the default, the Mortgagee, as trustee, shag apply, at the time of the commencement of such
proceedings or at the time the property is otherwise acquired by the Mortgagee, the balance then remaining to the credit of
Mortgagor under (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 shag 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, 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) days after demand by Mortgagee, stating the amount.
5. The principal indebtedness hereby evidenced and secured represents money actually used for the acquisition of
or 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 may
from time to time require, on the improvements now or hereafter on said premises, and except when payment for all such pre-
miums has theretofore been made under (a) of paragraph 2 hereof, will pay promptly when due any premiums therefor. Ail
insurance shag be carried in Companies Approved by Mortgagee and the policies and renewals thereof shag be held by Mortga-
gee and have attached thereto loss payable clauses in favor of and in form acceptable to Mortgagee. In event of loss, Mortgagor
will give Immediate notice by nail 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 Mortgagee jointly. The insurance proceeds, or any aprt thereof, may be applied by Mortgagee
at its option either to the reduction of the indebtedness or to the restoration or repair of the property damaged. In the sole
and absolute discretion of Mortgagee, in event of foreclosure of the Mortgage or transfer of title to the mortgaged property In
partial Or total extinguishment of the Note hereby secured, all right, title, and interest of Mortgagor in and to any insurance
policies then in force shall pass to the purchaser or grantee or shall be canceled and the cancellation proceeds, if any, re-
tained by Mortgagee. Full power is hereby given to Mortgagee to settle or compromise all claims under such policies and to
demand, receive and receipt for all moneys becoming payable thereunder.
7. Mortgagor shag not execute or file of record any instrument which imposes a restriction upon the sale or occu-
pancy 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 to attach to OF to be enforced
against the premises covered by this Mortgage. Mortgagor shag not Commit or permit waste; and shall maintain the property
in as good condition as at present, reasonable wear and tear excepted. Upon any failure so to maintain, Mortgagee, At its
option, may cause. reasonable maintenance work to be performed at the test of Mortgagor.
BOOR 858 PACE 1100
r «
9. Mortgagee shall have the right to pay any ground rents, taxes, assessments, sewer and water rents, and"Lll other
charges and claims which Mortgagor has agreet to pay under the terms hereof, to advance and pay any sums of money-that
in its judgment may be rRcessary to perfect or to 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 Fhe
principal debt, shall bear interest at the rate provided for in the principal indebtedness from the date of payment or adranfe,
and shall be secured by this Mortgage ratably with said principal debt and interest thereon. Mortgagee, at its option, Aso
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 may be agreed 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`,?''pwd
or advanced shall be due and payable thirty (30) days after demand by Mortgagee. i
10. The lien of this Mortgagee shall remain in full force and effect during postponement or extension of the thn?of
payment of the indebtedness, or any part hereof, which it secures.
11. Upon the request of Mortgagee, Mortgagor shall execute and deliver a supplemental Note or Notes for thetum?r
sums advanced or paid by Mortgagee for the alteration, modernization of improvement of the mortgaged property mide,at
Mortgagor's request; and for maintenance of said property, or ground rents, taxes, assessments, sewer and water rents, and ill
other charges and claims assessed or levied against said property by any lawful authority, or for any other purpose elsewhere
authorized hereunder. Said 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 indebtedness 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 shall any such maturity or 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 38, 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 OF Regulations are hereby amended to conform thereto.
13. If, 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 proceeding'ta foreclose
a mortgage is instituted upon or under this Mortgage, an attorney's commission of five per centum (5%) of said principal debt
shall be payable, and recovered in addition to all principal and interest and all other recoverable sums then due, otgether
with costs of suit.
14. If an 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 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, anything herein contained io 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 lawful
for Mortgagee to enter upon all and singular the land, buildings, and other rights, corporeal 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 that he shall and will, whenever requested 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 premises and every part thereof; for all of which said Note shall be a sufficient warrant whether or not such
lease or sublease has been assigned; and to make from time to time all reasonable alterations, renovations, repairs, and replace.
menu thereto. After deducting the cost of such alterations, renovations, repairs, replacements, and the expenses incident to
taking and retaining possession of the mortgaged property, the management and operation thereof, and to keeping the same
properly 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 priority as Mortgagee may determine, any
statute, law, custom, or use to the contrary notwithstanding.
The taking of possession of the mortgagized premises by Mortgages, 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 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 discretion of Mortgagee, and may be
pursued singly, or successively, or together, at the sole discretion of Mortgagee, and may be exercised as often as occasion
therefor shall occur.
PROVIDED, that in case default shall be made in the payment of any installment of principal and interest, or any other
payment hereinbbove or in the conditions of said recited Note provided for, or in the keeping and performance by the Mort-
gagor 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 specified for the performance thereof, such default will 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 pro-
ceeding 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 costs 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 notwith.
standing. 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 premises or property whatever, real or personal, from attachment,
eoox 858 PACE 1101
levy, or sale under execution, or any part of the proceeds arising from any sale thereof, and all benefit of any stay of execu-
tion or otter 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 Indenture is security.
BUT PROVIDED ALWAYS, nevertheless, that if said Mortgagor shall pay or cause to be paid unto the said Mortgage,
the aforesaid debt secured by this Mortgage, when and in the manner hereinbefore mentioned and appointed for payment of
the same, together with interest and all other sums hereby secured, then and from thenceforth, this Indenture, and the estate
hereby granted, as well as said recited Note, shall case, 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 shall be joint and several.
The 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, vendors, and assigns of the parties
hereto or thereto; and whenever used in said 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 all 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
IN THE PRESENCE OF:
(.11..1 -1-A CJt. C&--(?
/ ;SEAL)
EDWIN G BIDDLE
(SEAL)
SONG BID LE `
+?? ? ?- (SEAL)
(SEAL)
CERTIFICATE OF RESIDENCE
I, the Subscriber, do hereby certify that the correct address of the within-named Mortgagee is MERITOR MORTGAGE
CORPORATION-EAST,AVENUE OF THE ARTS BLDG,BROAD & CHESTNUT STREETS, PHILADELPHIA, PA 19107
(\ Witness my hand this THIRD day Of APRIL 1987
Ann( of orrsesee
C OMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND )
On this THIRD day of APRIL , A.D., 19 87 , before no,
$?83 B J?jo,.AA?Q ,n,??'{??BLIC came the above-narned EDWIN G .
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same to be recorded as such. ?` '.: y''•,,
WITNESS my hand and seal, the day and year aforesaid. !Y ; •.O ',
PLEASE RECORD AND RETURN TO:
MERITOR MORTGAGE CORPORATION-EAST My commission expires [O
P. 0. BOX 4965
PA 17604
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FORM 3625 8.3181
SCHEDULE B
Policy Number 39-0052-02-003917
too"
ALAI #6518
This policy does not insure against loss or damage by reason of the following:
1. Encroachments, overlaps, boundary line disputes and any matters which
would be disclosed by an accurate survey and inspection of the premises.
2. Possible additional tax assessment by reason of new construction or
improvements pursuant to the provisions of the Acts of Assembly relating
thereto, not yet due and payable.
3. Subject to the provisions of the Federal Flood Relief Act of 1973. Company
assumes no liability by reason thereof.
4. The lien of School taxes for the year 1987 and all taxes thereafter,
not yet due and payable.
5. Subject to conditions as set forth in Plan Book 1, page 51.
Countersigned
Authorized atory
C. Wa a Keech
Schedule 6 of this Policy consists of 1 Pages.
.s
!11
ALL THAT CERTAIN piece or parcel of land situate in Enola, East Pennsboro `
Township, Cumberland County, Pennsylvania, more particularly bounded and
described in accordance with a survey by Michael C. D'Angelo, dated August
1, 1978, as follow, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance
of 190 feet (erroneously set forth in prior deed as 200) north of cumberland
Road; thence along the said Altoona Avenue North 10 degrees 20 minutes West,
50 feet; thence North 79.degrees 40 minutes East, 125 feet; thence South
10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING KNOWN AS 18 Altoona Avenue, Enola, PA.
.BEING -the -same -premises which Harry E. King and Sandra L. King, his wife,
by their deed dated April 3, 1987 and which is intended to be recorded
herewith in the Cumberland County Recorder of Deeds Office, granted and
conveyed unto Edwin B. Biddle and Song Suk Biddle, his wife, mortgagors herein.
soon 858 PACEII03
EXHIBIT "B"
12-01-'10 11:22 FROM-
Oat-01-2010 11:32am From-
T-023 P0003/0004 F-869
T-099 P.003/004 F-996
FETITION FOR PROBATE AND GRANT OF LETTERS
REGISTER OF WILLS OF Cumbcftd COUNW, PENNSYLVANIA
Estate or Edwin t3mwy $iddlo Filowu0t a -u2/- 6200 (097/
also 1Csowa so
41246077
bar
DaCased Soda) kouft Nwn
Mdtiolux(s), who;sfare is ymnc of age or Older, apply(in) for.
(CCSVPMFE 'A' ar'S' SELDWd
? A. Probate and Groat of EaUm Ttapmentary and aver dot Pedtiorrr(s) is I we die roomed in dw
last win orthe Dwadent doled and wdioil(s) dared
Mw-h w,rclreae&wwKvt.td„vammrlaltea,dpwhgr rotJ A
Now as fbl lows. Decedent did not merry, was not divoroed. And did sa have a mild born or adopted after execrates o1S? C
fbr probate, ww not the vlati»t ors 1a111riE and wu serer atg esied a itreapsiMal d pm m 094" A
® 8, Crag of LaMm 01Adndsisvedoa
(4(tgWNV0W ClOr &A a6; d 1LCta.; jMI,fI kk Ift,' dLwwu dbssWm dtw t? rr3
en
po itioneda) saw a proper earth hoc I have usaresiaed that Dowdent left as Wiu and v s survived by" twwwwg spouse (ir emy) and heiro: (tf
AcbMiplJfrO!?OA, O.Ra O? d b a.6 r Q., enter dw of W N in $ft**w A abaw aww a m"*6le IFrd of toles.)
Decedent was domiciled a death in Catagr. haviv" vtitb bis I bcr Ion prinoW raidbaao a
R
f0fswaadmw. Jbwoto somw mow Am s*WN
DwAdest then 65 years of aec, died oa 2S Marsh 2008 a M t= Humor Medical CooW. PA
Decedent at death owned property with estimated vshm as follows:
(If domiCUCd is PA) An ptaMAI peopelb'
Of not doratoitW In PA) Petaond property ;n Petsoay)vamts i-
(Ifact domiciled in PA) permed property in Couaty
value ormal eatwo is Pawwylvama
situated a folbwo: %- A RV r
Whersfora, rowisaer(e) FCWKdlJlly rcWcKs) dw probate of fm last will wut Codioilta) pneratae with Ihie Padtion and rho grant of t eaaa in she approprieee form w
the wden;p"
ApfMAW." F" 10.13.06 Wage 1 Of 2
(COIMPLBTE AVAU CASH- A&wk a"vwd oliedt i1mo %aery.
12-01-'10 11;22 FROM-
T-023 P0004/0004 F-869
Doc-01-2010 11:33aa From- T-000 P.004404 F-606
Bath of Personal Representative k7d
•
{
N r 1 r,
-?•:a
COMMONWEAMA OF PI NNSYLVANIA
"V
ss :
COUNTY OF CuatWuA +
; , m?
Tito Pelitienw(s) abovs-wined swwAs) of i?a tr,(s) tint d e slatamonts io thr fbrgvu? Pdition arc tniFs rnd uaneia bes[ of
the lmowisd6c Bad b hif of Politi*nKs) add [burs, as persottnl rW=cntttd*s) of the Decedont. Petitioner(s) will well and b*
administu the estate amtding w lava.
Swom to or atfvmW and maboeeibed
before me the da - , dry of
Firths Register ??w,rr.?Pe?so+?a?Jt?/rrrsvnan+e
File NumberL o2/- aMR -- Q.3Zf
Ratate of Edwin stay Biddle . Deceawd
Social Security Number: 417-6&0879 Date of Domh:25 MWA 800ti
ANTI NOW, _ ---j in owidwition ofibe foregoing Petition, sstisfacsory proof
having beets presented "re mc, IT TS DZCItFI?D drat Losses
an hateby granted to
in the above awe
and that the iawment(s) datod
deurtbed in the Petition be admitted to probate and filed of record as the last Will (arid Codicil(s)) of Decedont.
FEES
Letters , ... S....?.......,_?.? of tt?rx,
short c"docatc(s) .. . SAMMM sipawre:
Stenunciation(s) .......... $ -,.. Momey Ntaste
..S
S Supmne Court I.D. No.:
..a
S Addmw: ?.
.s?
TOTAL .............. T_ 0.00
rdem FW.02 re,: !0-13.06 Put 2 of 2
CHASE HOME FINANCE LLC,
s/b/m/t CHASE MANHATTAN
MORTGAGE CORPORATION,
Plaintiff
V.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS
Personal Representatives of the
Estate of EDWIN GREGORY
BIDDLE, a/k/a EDWIN G. BIDDLE
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009 - 0096 CIVIL TERM
ORDER OF COURT
?.>
K, CD r.r
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,
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y
AND NOW, this 9TH day of FEBRUARY, 2011, a Rule is issued upon the
Defendants to Show Cause why the Motion to Amend the Caption Nunc Pro Tunc should
not be granted.
Rule returnable twenty (20) days after service.
,y the Court
Edward E. Guido, J.
Kristine M. Anthou, Esquire
Margret Biddle Saunders t rpo
? Mark Edwin Biddle "? AKd
:sld
..?q.
! E D - l E (F i €?'{ p
E vp 1 7 VN?ry tiIM t
I mn 18 FM I: 39
r;UMppEWWR 5YLVAN A TY
IN THE COURT OF COMMON PLEAS OF CUMBERLANb MUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
) CIVIL DIVISION
NO.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
Defendants.
TYPE OF PLEADING
Motion to Make Rule Absolute and
Permit Plaintiff to Amend Caption
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, 9th 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.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
MOTION TO MAKE RULE ABSOLUTE AND
PERMIT PLAINTIFF TO AMEND CAPTION
AND NOW, comes Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan
Mortgage Corporation ("Plaintiff'), by and through its counsel, Grenen & Birsic, P.C., and files
this Motion to Make Rule Absolute and Permit Plaintiff to Amend Caption and in support
thereof states as follows:
1. 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. Defendants, Mark Edwin Biddle and Margret Biddle-Saunders, are individuals
whose last known address is 18 Altoona Avenue, Enola, PA 17025.
3. On February 9, 2011, this Honorable Court issued a Rule upon the parties to the
within matter to show cause why Plaintiff should not be permitted to amend the caption in the
instant matter.
4. On February 10, 2011, the Prothontary duly served the aforesaid Rule upon
Defendants.
5. The aforesaid Rule was returnable on or before March 2, 2011.
6. The return date for the Rule has passed and the Defendants have not filed or
served any response in objection.
WHEREFORE, Plaintiff requests this Honorable Court issue an Order allowing Plaintiff
to amend the caption in the instant matter to read as follows:
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.: 2009-00096
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS, Sole
Heirs of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
Respectfully submitted,
GRENEN & BIRSIC, P.C.
BY: ?.
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Attorneys for Plaintiff
One Gateway Center, 9th Floor
Pittsburgh, PA 15222
(412) 281-7650
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion to
Make Rule Absolute and Permit Plaintiff to Amend Caption was mailed to the following on this
day of h Ah111- , 2011, by first class, U.S. Mail, postage pre-paid:
Mark Edwin Biddle
18 Altoona Avenue
Enola, PA 17025
Margret Biddle Saunders
18 Altoona Avenue
Enola, PA 17025
GRENEN & BIRSIC, P.C.
BY:j'??? C sZw
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Attorneys for Plaintiff
One Gateway Center, 9th Floor
Pittsburgh, PA 15222
(412) 281-7650
I r.
3
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.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
NO.: 2009-00096
C
rnw 3C rn-1
5=
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r r13
r-n :0C)
C:) v
s°
p rs ? C-)-»
Cs r-?
ORDER OF COURT
AND NOW, to wit, this 4;60,6 day of ;;/? , 2011, upon
consideration of Plaintiff's Motion to Make Rule Absolute and Permit Plaintiff to Amend
Caption, it is hereby ORDERED, ADJUDGED and DECREED that the caption of this action is
hereby amended to read as follows:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS, Sole
Heirs of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
CIVIL DIVISION
NO.: 2009-00096
Defendants.
I `
Copies of this Order shall be served by Plaintiff upon Defendants, Mark Edwin Biddle and
Margret Biddle-Saunders.
Kr ieAC e M. Anihou,
Mark Edwin 3k?dle
BY THE T
Moi'd
b0 3e_9
D
J.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
r
CIVIL DIVISION = -'
'
'
NO.: 2009-00096 -?•?? - J
'
.?, cam-.;
TYPE OF PLEADING
Amended Motion to Amend Captiet? nUu c
pro tunc
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
Beth L. Slaby, Esquire
Pa. I.D. #209503
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 2009-00096
VS.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
AMENDED MOTION TO AMEND CAPTION NUNC PRO TUNC
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 to Amend Caption Nunc Pro Tunc as follows:
On or about January 8, 2009, Plaintiff filed a Complaint in Mortgage Foreclosure
against the Defendants, Mark Edwin Biddle and Margret Biddle Saunders, Personal
Representatives of the Estate of Edwin Gregory Biddle a/k/a Edwin G. Biddle, to foreclose on
property known as 18 Altoona Avenue, Enola, PA 17025 ("premises") based on a mortgage
executed by Edwin Gregory Biddle a/k/a Edwin G. Biddle in favor of Plaintiff on April 3, 1987.
A true and correct copy of said mortgage is marked as Exhibit "A", attached hereto and made a
part hereof.
2. On April 2, 2008, Defendants filed a Petition for Grant of Letters of
Administration at File Number 21-20008-0371. A copy of said petition, marked Exhibit "B", is
attached hereto and incorporated herein.
3. On or about April 9, 2008, an order was entered requiring Defendants to post a
bond before the Letters of Administration would be granted.
4. Defendants did not post the bond required, but it is believed and therefore averred
that Defendants are the sole heirs of the Estate of Edwin Gregory Biddle.
On February 9, 2011, this Honorable Court issued a rule upon the defendants to
show why the Motion to Amend the Caption Nunc Pro Tunc should not be granted.
6. On March 29, 2011, upon consideration of Plaintiff s Motion to Make Rule
Absolute and Permit Plaintiff to Amend Caption, this Honorable Court issued an Order
amending the caption.
7. However, Plaintiff inadvertently did not include the phrase "Nunc Pro Tunc" in
its Order nor does Plaintiff believe that Defendant Margret Biddle-Saunders was properly served.
Plaintiff is respectfully requesting that this Court re-issue the Rule to Make Absolute so that
Plaintiff may amend its order to "Order Nunc Pro Tunc" and obtain proper service.
Plaintiff desires to amend the caption to identify Defendants, Mark Edwin Biddle
and Margret Biddle Saunders, as the sole heirs of the Estate of Edwin Gregory Biddle a/k/a
Edwin G. Biddle, rather than personal administrators of the Estate of Edwin Gregory Biddle
a/k/a Edwin G. Biddle.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the
caption in this action to list the Defendants as heirs to the Estate and Re-Issue the Rule to Make
Absolute.
GRENEN & BIRSJC, P.C.
BY: / ( ?.
Kn tine M. Anthou, Esquire
Beth L. Slaby, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
0 0
oli",
EXHIBIT "A"
VA Yom 24&"34
¦«wt+.eteta.u..ocw.r? PLiI# 43VNU
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tt.eu.. seta n s?usc
A«eebW r? re ee.w
Menem Aancia"em •.
221576-2 VP MORTGAGE
THIS INDENTURE, made to 3RD day of APRIL in do
yew of our Lord one thousand nine hsodred and sighty-seven BETWEEN LDWIN G?1o?o?) d8
RIDDLE AND SONG SDIt RIDDLE (hereinafter pUedAUT 81AN t.
MBRITOR MORTGAGE CORPORATION-BAST' AVENUE OF THE ARTS BLDG, ale 6 CHBS EE
a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, and having its principal office
and post-office address in PHILADELPHIA, PA 19107 (hereinafter called Mortgagee):
WITNFSSETH: That the Mortgagor to secure the paymentof
FIFTY SEVEN THOUSAND FIVE HUNDRED b 0
DoHata (S 57 -500 - 00 ), with interest from date, at dw rate of EIGHT AND ONE-HALF
( 8.500%) per annum on the tmpald balance anW pyd. ,e e, d in a Note of ewesherswhh, par cautum,
from the
Mortgagor to the Mortgage, In monthly Inttdismu of FOUR RED FORTY TWO b 13/100
per, (S 442.14, g oo the brat day of
JUNE , 19 87 , and continuing thwafter on the Pint day of each month tmtg ansh
debt Is fully paid, except that, if not sooner paid, the find payment thined shad be due and pay" on dw nut dayof
MAY 2017 , and also to secure the performance of all covenants, agreeraents and condidow hereto
contained, does by due presents grant, bargain, all, assign, release, ooavey and confirm to the Mart
Ing described red property situate in the TOWNSHIP Of EAST PENNSBORO ?'ALLthe follow.
CUMBERLAND and Commonwealth of Fe County of
rmaylrartle. 10 oft,
BEING MORE PARTICULARLY DESCRIBED ACCORDING TO A LEGAL DESCRIPTION ATTACHED HERETO AND
MADE A PART HEREOF.
SEE ATTACHED LEGAL DESCRIPTION
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Should the Veterans Administration for arty mum fail or refuse to Issue the guarantee in the maximum amount per.
mit ted of the loan secured by this mortgage under the provisions of the Servicemen's Readjustment Act of 1944, as amend.
ed, within sixty days of the date hereof, the mottgegn herein may at Its option declare all sums secured by this mortgage
immedistsly due and payable.
TOGETHER with all and singular the buildings, Improvements, and fixtures on said premises, as well as all additions
or improvements now or hereafter made to acid premier, streets, alleys, pug"", ways, waxen, water eourw, rights,
liberties, privileges. henditaments, and appurtenances whatsoever t)ureunto bdoogh%. or in any wise appertaining, and the
reversions and remainders, rents, bum, and profits thereof, and In addition thereto the following described household
appliances, which an, and shall be deemed to be, fixtures and a part of the n lly, and an a portion of the security for the
indebtedness herein mentioned, namely,
RANGE/OVEN, W/W CARPET
provided, however, that the Mortgagor "be entitled to collect and retain the aid rests, hm". and profits until default
honmeder:
TO HAVE AND TO HOLD said property, hereby granted, with the appurtanances, unto said Mortgagee to its own
use forever:
boat 858 FACE1099
MMC 220 n.v. Use jtr
This Indenture la mTSe, 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
lee, the entire hdebtednessor any put thereof not less than the amount of one installment, or one hundred dollar (SI tp.00),
whichever is less. Prepayment in full dull be credited on the date received. Partial prepayment, other than on an instalment
due date, need not be credited until the next following installment due date or thirty days after such prepayment, whichever
is tuber.
2. To more fully protect the security of this Mortpp,. the Matppr shall pay to the Mortppe se trustee (under
the terms of this trust as hereinafter stated) In addition to and concurrently with, each monthly installment of principal
and interest until said Note is fully pad, the following sums:
(a) A sum equal to the ground rents, if any, next due, plus the premiums that will next become due and paya-
ble on policies of lire and other hazard insurance, plus taxes, aaesmtmts, and sewer and water rents, next due
on the premises covered by this Mortpge (all a estimated by the Mortgagee, ad of which the Mortgagor Is
notified) Ins ail sums already paid therefor divided by the number of months to'ekpse before one month prior
to the date when such ground rents, premiums, taxes,asaaments, and sewer and water rents, will become due,
such sums to be held by Mortgagee in trust to pay said ground rents, premiums, taxes, assesments, and sewer
and water ants.
(b) The aggrepts of the amounts payable pursuant to subparagraph (a) and those payable an this debt shall
be paid in a single payment each month, to be applied to the following items In On order stated:
(1) ground rents, taxes, assuenrents, sewer and water rents, fire and other hazard insurance premiums;
(11) interest on this debt; and
(111) 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 said Note, unleu made good by Mortgagor prior to the due date of the next such payment. At Mortppe's
option, Morlpgor will pay a 'late charp" not exceeding four per centum (4%) of any instalment when paid more
than fifteen (15) days after the due date thereof to cover the extra expense Involved In handling delinquent payments,
but such 'late charge" shall not be payable out of the proceeds of any sale made to satisfy the indebtedness secured
hereby, unless such proceeds of any sak made to satisfy the indebtedness secured hereby, unless such prooaeda are
sufficient to discharge the entire Indebtedness and all proper costs and expenses secured thereby.
3. If the total of the payments made by Mortgagor. under (a) of paragraph 2 preceding, stall exceed the amount
of payments actually made by Mortgagee as trustee for ground rents, taxes, usesmtents, sewer or water rents, or lasurena
psemksms, as the can may be, such excess shell be credited on subsequent payments to be made by Mortgagor for such
items or, at Morlgape's option, as trustee, shall be refunded to Mortgagor. If, however, such monthly payments shall not
be sufficient to pay such items when the same shill become due and payable, then Mortgagor shall pay to Mortppe as
trustee any amount necessary to nuke up the deficiency within thirty (30) days after written notice from Mortgagee stating
the amount of the deficiency, which notice may be given by null. If at say lime Mortgagor shall tender to Mortgagee, in
accordance with the provisions hereof, the full payment of the entire indebtedness represented hereby, Mortgagee, as trustee,
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 then shall be a default under any of the provisions of the Note and this Mortg p
securing the same, which results in a public ale of the premises covered thereby, or if title to the property is otherwise
acquired by the Mortpps after the default, the Mortgage, as trustee. shall apply, at the time of the commencement of such
proceedings or at the time the property is otherwise acquired by the Mortppe, the bakaa then remaining to the credit of
Mortgagor under (a) of paragraph 2, u 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 =and 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, shall have priority in ben 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 nude by
Mortgagor within thirty (30) days after demand by Mortgagee, stating the amount.
S. The principal indebtedness hereby evidenced and secured represents money actually used for the acquisition of
or for Improvements to the premises secured by said Mortpp.
6. Mortgagor will continually maintain hazard Insurance of such type or types and amounts as the Mortgagee may
from time to time requin,on the Improvements now or hereafter on said premises,and except when payment for in such pro-
mlums has theretofore been made under (a) of paragraph 2 hereof, will pay promptly when due any premiums therefor. All
insurance shall be carried in companies approved by Morlgape and the polities and renewals thereof shall be held by Mortga-
gee and have attached thereto loss payable clauses in favor of and in form acceptable to Morlgape.In event of lost, Mortgagor
wig give Immediate notice by mail to Mortppe, and Mortgagee may make proof of loss l( not made promptly by Moappe.
Each Insurance company concerned is hereby authorized and directed to nuke payment for such loss directly to Mortgagee
instead of to Mortgagor and Mortgagee jointly. The insurance proceeds, or any apFt thereof, may be applied by Mortgagee
at its option either to the reduction of the indebtedness or to the restoration or repair of the property damaged. In the sole
and absolute dbattton of Mortgagee, in event of foreclosure of the Mortpp or transfer of title to the mortgaged property In
partial or total extinguishment of the Note hereby secured, all Fight, title, and Interest of Mortgagor in and to my hweance
policies then in fora shall pan to the purchaser or grantee or shall be canceled and the cancellation proceeds, if any, re-
tained by Mortppe. Full power is busby given to Morippe to settle or compromise all chins under such policies and to
demand, receive and receipt for a)1 moneys becoming paysbk thereunder.
7. Mortgagor shall not execute or Ne of record any instrument which imposes a restriction upon the ark or occu.
panty of the property herein described on the basis of Fact, color or creed.
S. Mortpg>r will not suffer any hen superior to the Ilan created by this Mortpp to attach to or to be enforced
against the premises covered by this Mortgage. Mortgagor shall not commit or permit waste; and than maintain the property
In as good condition as at present, reasonable wear and tear excepted. Upon any failure so to maintain, Mortgagee, at its
option, may aura reasonable maintenance work to be performed at the test of Mortgagor.
eoo? S5? PACE1100
01
W 60 • '.
9. Mortgagee shall have the right to pay any pound rents, taxes, assessments, sewer and water rents, and'kll other
charges and claims hiRdch Morip{or has agrees to pay under the terms hereof, to advance and pay any sums of mdriei-that,
in its judgment may be decessary to perfect or to preserve the title of the premises covered by this Mortgage, or for fnsutVa
premiums or for any authorized maintenance work. Any amount or amounts so paid or advanced shall be added to 4he
principal debt, shall bear interest at the rate provided for in the principal indebtedness from the date of payment or adla`
and shall be secured by this Mortgage ratably with said principal debt and interest thereon. Mortgagee, at its option; .
shall be entitled to be wbropted to any lien, claim, or demand gaud by it, or discharged with money advanced by 'I d
secured by this Mortgage. The payments and advances to made shall be payable in approximately equal monthly paylneots
extending over such periods as may be agreed 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 apse on due of maturity, the whole of the sum or sumsa?`pt?id
or advanced shall be due and payable thirty (30) days after demand by Mortgagee.
10. The lien of this Mortgagee shall remain in full force and effect during postponement or extension of the t of
payment of the indebtedness, or any part hereof, which it secures.
11. Upon the request of Mortgagee, Mortgagor shall execute and deliver a supplemental Note or Notes for the m r
sums advanced or paid by Mortgagee for the alteration, modernization of improvement of the mortgaged property mide?t
Mortgagor's request; and for maintenance of said property, or pound rents, taxes, assessments, sewer and water rents, and ill
other charges and claims assessed or levied against said property by any lawful authority, or for any other purpose elsewbele
authorized hereunder. Said Note or Notes shall be secured by this Mortgage an a parity with and as fully u if the amounts
stated in such Note or Notes were put of that stated in the Note hereby secured. Said supplemental Note or Notes thail best
interest at the rate provided for in the principal indebtedness 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 OF sums so advanced or paid shall be due and payable thirty (30) days after demand by Mortgagee; but in
no event shall any such maturity or 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 38, United States Code, such Title and
Regulations Issued thereunder and in effect on the date hereof shall govem the rights, duties and liabllltles of the parties
hereto, and any provisions of this or other instruments executed in connection with said indebtedniat which tae inconsistent
..t I
with said Title or Regulations are hereby amended to conform thereto.
13. If, at any rime, 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 OF any other appropriate action or proceeding-to foreclose
a mortgage is instituted upon or under this Mortgage, an attorney's commission of five per centum (5%) of said principal debt
shall be payable, and recovered in addition to all principal and interest and all other recoverable sums then due, otgether
with costs of wit.
14. If an deficiency in the amount of any aggregate monthly payment mentioned in (b) of paragraph 2 sinall not be
made good by Mortgagor prior to the due date 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, anything 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 lawful
for Mortgagee to enter upon all and'singular the land, buildings, and other rights, corporeal 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, law 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 that he shall and will, whenever requested by Mortgagee so to do,
usipn, transfer, and deliver unto Mortgagee any leans or sublease; and to collect and receive all rents, lam, and profits of
said mortgaged premises and every put thereof; for all of which Sell Note shall be a sufficient warrant whether or not such
lease or sublease has bean assigned; and to nuke from time to time all reasonable alterations, renovations, repairs, and replace.
menu thereto. After deducting the cost of such alterations, renovations, repaim, replacements, and the expenses incident to
taking and retaining possession of thi mortgaged property, the management and operation thereof, and to keeping the same
properly Insured, to apply any residue of such rents, issues, and profits to the payment of (a) all pound rents, taxes, charges,
claims, assessments, sewer and water rents, and any other liens that may be price in ben or payment to the debt sawed 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 priority as Mortgagee may determine, any
statute, law, custom, or use to the contrary notwithstanding.
The taking of possession of the mortg agized premises by Mortgages, as herein provided, shall not reileve any default by
Mortgagor, or prevent the enforcement 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 discretion of Mortgagee, and may be
pursued singly, or successively, or together, at the sole discretion of Mortgagee, and may be exercised as often as occasion
therefor shall occur.
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 Mort•
gagor 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 specified for the performance thereof, such default will 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 pro.
ceding 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 costs 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 notwith-
standing. Mortgagor expressly waives and relinquishes all benefit that may aaruc 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.
BOOK 858 FACE 1101
6 ANSI.
levy, or sale yader execution, of any part of the pmeseds arising from any gala thateof, and fit of any stay of exscu-
tion or other process. Mortpga hereby waives and alinquidws unto and in favor of the Mor pro,aU benefit trader all laws
now In offset or hereafter passed to relieve the Mortgagor in any manner from the obdpsions assumed In the Note for which
this Indenture is security.
BUT PROVIDED ALWAYS, nevertheless, that if said Mortgagor shall pay of cause to be paid unto the sold Mortpp,
the aforesaid debt teetered by this Mort". when and in the mensor herelabefore monitored and appointed for payment of
the am. topthor with interest and all other sums hereby accused, Uses and ham thatcefeeth, this Indenture, and the estate
hereby granted, as wed as said recited Note, shall ease, dots trains, and become void, anything hereinbefors or in acid Note
contained to the contrary notwithstanding.
If this Mortgage is executed by more than one person a Mortgagor, the Ilabr'lity of each shad be joint and several.
The covenants, conditions, and provisions contained in aid Note, or in this Moripp, shad bind, and the benefits end
advantages thereof shad inure to, the respective hair, executors, administrators, successors, vendeea, and wi0u of the parties
hereto or thereto; and whenever used in said Note or in this Mortpp, the singular number shall include the phmal. the plural
the singular, the use of any grader shad be applicable to ad geaden, and the term "Mortpgw" shad Include any pays of den
indebtedness represented by said Note, or secursd by this Moripp, or my transfers thereof, whether by operation of law
or otherwise.
IN WITNESS WHEREOF, Moripgor hereunto sets his hand and seal. Dated the day sad year tint hereinabove written.
SIGNED, SEALED AND DELIVERED
IN THE PRESENCE OF:
?l/h 11 c n?JtJAA o?1-
('? SEAL)
--4 ?- - EDWIN G BIDDLE
(SEAL)
SONG ?]l? BIDj) ???,,?,, ;SEAL)
y2 islr? (SEAL)
CERTIFICATE OF RESILIENCE
1, the Subscriber, do hereby certify that the correct address of the within-named Morippe it MERITOR MORTGAGE
C73 CORPORATION-EAST,AVENUE OF THE ARTS BLDG,BROAD 6 CHESTNUT STREETS, PHILADELPHIA, PA 19107
rIN Witness my hand this THIRD day of APRIL - 19 87
Agent of oapsss
C OMMONWEALTH OF PENNSYLVANIA)
ss
COUNTY OF CUMBERLAND )
On this THIRD day of APRIL , A.D., 19 87 before me,
S BS 8 ??ELIC ems the abovearamed EDWIN G
of Mortgsge to be sat and) the
• • "fi`..
some to be recorded a such. THEIR
? ,t?ttti • • r ''
WITNESS my hand and seal, the day and you aforesold. . >r :' ' O
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PLEASE RECORD AND RETURN TO:
MERITOR MORTGAGE CORPORATION-EAST My commission 0 '
P. 0. BOX 4965
LANCASTER, PA 17604 k + s. gTACKNICIi '
I VALtRIE
ICY ON owa ow. 114 go
GUMiKSWHO QWtm- PA
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LOAN FORM
• FORM 3625 R.318(
-- SCHEDULE B
Policy Numb*r 39-0052-02-003917
too.
ALAI #6518
This policy does not insure against loss or damage by reason of the following:
1. Encroachments, overlaps, boundary line disputes and any matters which
would be disclosed by an accurate survey and inspection of the premises.
2. Possible additional tax assessment by reason of new construction or
improvements pursuant to the provisions of the Acts of Assembly relating
thereto, not yet due and payable.
3. Subject to the provisions of the Federal Flood Relief Act of 1973. Company
assumes no liability by reason thereof.
4. The lien of School taxes for the year 1987 and all taxes thereafter,
not yet due and payable.
5. Subject to conditions as set forth in Plan Hook 1, page 51.
Countersigned
1
??- Era
Authorized atory
C. Wa a Keech
Schodulo s of this Policy consists of 1 Pages.
i
j
i
ALL THAT CERTAIN piece or parcel of land situate in Enola, East Pennsboro
Township, Cwnberland County, Pennsylvania, more particularly bounded and
described in accordance with a survey by Michael C. D'Angelo, dated August
1, 1978, as follow, to wit:
BEGINNING at a point in the easterly line of Altoona Avenue at the distance
of 190 feet (erroneously set forth in prior deed as 200) north of cumberland
Road; thence along the said Altoona Avenue North 10 degrees 20 minutes West,
50 feet; thence North 79•degrees 40 minutes East, 125 feet; thence South
10 degrees 20 minutes East, 50 feet; and thence South 79 degrees 40 minutes
West, 125 feet to the place of BEGINNING.
BEING K14OWN AS 18 Altoona Avenue, Enola, PA.
.BEING -the .same .premises which Harry E. King and Sandra L. King, his wife,
by their deed dated April 3, 1987 and which is intended to be recorded
herewith in the Cumberland County Recorder of Deeds Office, granted and
ccnv+eyed unto Edwin B. Biddle and Song Suk Biddle, his wife, Mortgagors herein.
BOOK 658 PACE1103
•
EXHIBIT "B"
12-01-'10 11;22 FROM-
Omt-01.2010 11:322m From,
T-023 P0003/0004 F-869
T-090 P.003/004 F-095
PETITION FOR PROBATE AND GRANT OF LETTERS
REGISTER OF WILLS OF cumbalmct COUNW, PENNSYLVANIA
Estate of 1164" tare try akww File>'tv"w u2/- e? 008 (03 7/
also koorw a
Peotio =*N v4w Wws li yaat atap oroidw, M*Mia) Or
(COMPLETE War 7' 1ELOWd
? A. Probde mwd Grsat of L, M m Tosptsowy and nw that ?Wdo ta(s) b / tae dtc saaod is die
tact WW of the 17sou%K dad tad oo6al(o) MW -tnt
deist m kRww dreae+I w" N. NAW Nsmwt, dw h granndW. ew,J
ExaW u lollows, Decedow dW not won, vles sot dtwep end did sa lwve s dtitd bor. ar adopted
!br pobate, war not the viotiro of $ WIN" and Was spur agpld mw at bmwmomw ptmmm
® a, Cart d lwmtm of Adtaisiew+saleo
Wr rrfnr of Rt lA.ata: lir' IwMt aiwa7oe drene?e U 3f
Petitwmws) aw • popor sma bw / hew alas Waed dW Deatdat let ae pile sed enes 1Wv6m by do follmwias mom (if sey) mdd hoits: W
Ad+afulierorio? or a or db.s.c?e., steer detr q/'1Yilf iA Sdeyfarw anew o?d aaaeptsle /ip $?ira.)
DwAdast war dtwtielied 49 death i m r - Cou W. PuMimade wM bie / bar Im pW*W "dew ea
J,s Avarua. Ilada rA_ Feet iseaeawn loses bl.. MMMYeilh P I M
/ttll??wtedista ereaAeeb? erowmt ?roiksiotertN
DeoedwL then ?? yts.es of see. died oe 23 Uw ch 2= „t )KiMos Medtnl CmoeG>E PA
Dom*w at dcadt wmsed pm" mm eadtratrd vahm as fa ML
(if no domWbd M PA) Aermw pt-Pally in Pa"N ob
Rttwt daoisikl is PA) Palmd Paopatty io Canty ?..
Vgae of tool mm in powaylvem s $
siautad u *Dow, J1 ALi Wt.1A ill P'
whemr^ rooteawts) terpoetrully ra ppr4s) the probe ordw Int WIN aad Cedio(W pno+aM with mk P40flos sod dw rwt orL.d m is ow a ppnrprim tore, to
am uedeei "
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AppmAWW mu 10. 13.01 ftgc I oft
12-01-'10 11;22 FROM-
T-023 P0004/0004 F-869
Dec-01-2010 11:33an From- T-000 P.OO AU F•810
® '{ ?7
Oath of Personal Rep?e?entatiVe
COMM 014WEALT14 OF PBNMSYLVAM A tv ?:
ro c:; t?
Ss
COUNTY OF Cat 600d r-n
The Polkionw(s) abovaaataod swell(s) of t?&MM dart tha xlatawoats in the tbrgouyt Fdition are L oo wM*w b`="6'P'
wt knowledge mod belisf of PoWoRw(s) add QK as petsoaal eeprmoatmdvds) of the DwodaK poWoul(s) wlit wdl aad truly
administer the ?stlte accotdiesw I". `
Swom to or stormed and subeotibed - _ r
bePom me the A day of + w
1=8 .A ,r
tha RmgtstR
?pwMe ?«+o»nl Jttl?nrstrs
G
FucwWnbw-
Palate of Rama Onpoff DW% . Dow4sed
3oeld 6ewrity Number: 4t 2- 0M Date of Daadt:SS MwA XW
AND NOW, _. - - - - - - - . ?."?, in oonsww"on ortbe lbmp tts 1P"otltbn. sukhtsw Proof
having been preacntad bslbte too, IT 13 DZC1tM dW Lsaw
are hereby V2Md to
in dte above: estate
aad that the inwwnc Kt) dstod
dearibed in ibe Potltion be admitted to probate and tiled orreewd at the had WW (and Oodkil(s)) of DecedML
FM
Lotted ............... S
Short Cmtitknc(s) ........ 5?
Rentateiatioo(s) .......... .S
s
E
^Ibw ql *Vb
Attorney Naaae:
suptento Court I.D. No.;
S Address:
..s
TOTAL .............. S ODD
Form PW-02 nn: IQI.t_06 pop 2 Of 2
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Amended
Motion to Amend Caption nunc pro tunc was mailed to the following on this day of
2011, by first class, U.S. Mail, postage pre-paid:
Mark Edwin Biddle
18 Altoona Avenue
Enola, PA 17025
Margret Biddle Saunders
18 Altoona Avenue
Enola, PA 17025
Margret Biddle Saunders
4778 Catterick Court
Fairfax, VA 22032
GRENEN & BIRSIC, P.C.
BY:
90
Klistine M. Anthou, Esquire
Beth L. Slaby, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS,
Personal Representatives of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
CIVIL DIVISION
NO.: 2009-00096
rna) .y
'
=M t
ri
<n r- N C.7
cD
v -Tj
-1 C
C 2_1
ORDER NUNC PRO TUNC
AND NOW, to wit, this f day of , 2011, upon
consideration of the within Amended Motion to Amend Caption nunc pro tunc, it is hereby
ORDERED, ADJUDGED and DECREED that the caption of this action is hereby amended to
read as follows:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MARK EDWIN BIDDLE and
MARGRET BIDDLE-SAUNDERS, Sole
Heirs of the Estate of
EDWIN GREGORY BIDDLE, a/k/a
EDWIN G. BIDDLE,
Defendants.
C'rero+ &m PC
W" adwin Biddle
ka nro wale &orders
CIVIL DIVISION
NO.:2009-00096
BY E COU
J.