HomeMy WebLinkAbout09-0668IN 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.
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
Defendant.
NO.: Chi - &(P9 Civil lerr,
TYPE OF PLEADING:
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
TO DEFENDANT
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
ATTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANT IS:
814 Green Acres Street
Mechanicsburg, PA 17055
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
814 Green Acres Street
Monroe, PA
(CITY, BORO TOWNSHI (WARD)
I _?\?'o
ATTORNEY FOR 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
V/Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
NO..
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 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,
Plaintiff,
vs.
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
NO.: U q_ 66f Cv;d T?
Defendant.
CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its
attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage
Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio
43219 and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendant, Angela L. Pearl, a/k/a Angela T. Pearl, is an individual whose last
known address is 814 Green Acres Street, Mechanicsburg, Pennsylvania 17055.
3. On or about December 14, 2001, Defendant executed a Note in favor of Plaintiff
in the original principal amount of $101,500.00.
4. On or about December 14, 2001, as security for payment of the aforesaid Note,
Defendant made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $101,500.00 on the premises hereinafter described, said Mortgage being recorded in the
Office of the Recorder of Deeds of Cumberland County on December 18, 2001, at Mortgage
Book Volume 1742, Page 4284. A true and correct copy of said Mortgage containing a
description of the premises subject to said Mortgage is marked Exhibit "A," attached hereto and
made a part hereof.
5. Defendant is the record and real owner of the aforesaid mortgaged premises.
6. Defendant is in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendant
is due for the July 1, 2008 payment.
7. On or about August 16, 2008, Defendant was mailed a combined Act 91 and Act
6 Notice, via certified mail, return receipt requested, and by first class mail, in compliance with
the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41
P.S. '101, et seq.
8. The amount due and owing Plaintiff by Defendant is as follows:
Principal $92,038.50
Interest to 1/9/09 $ 3,373.99
Late Charges to 1/9/09 $ 20.37
Escrow Deficiency to 1/9/09 $ 347.48
Corporate Advances $ 0.00
Attorney's fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $99,580.34
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $99,580.34 with interest thereon at the rate of $15.13 per diem from January 9, 2009, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
GRENEN & BIRSIC, P.C.
BY.
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
Exhibit "A"
'01-14-'09 17:33 FROM-
{DM 10 T 01 ?&#
IGINAL
Record and Return to:
CHASE MANHATTAN MORTGAGE CORPORATION
1500 N 19TH STREET
MONROIC Lh 71201
ATTENTION: FINAL CERTIFICATIONS
ft" Of >!eaRw"Ble
THIS MORTGAUB ("Ssmmity lower w*) is gives oR
The Matt"w ie
ANGELA L PEARL, MARRIED
MORTGAGE
T-095 P002/007 F-532
PRA cam Ne.
4416778926703
17902980
1179029805
December 14, 2001
whose eddna is
814 GREEN ACRES STREET, MEC[ANICSSURG, PA 17055
.Mm mm'). This Sena ft is glum b
CHASE MANHATTAN NORTGA4$ CORPORATION
"6'eh,e sx6atiisd l aoda tbo lows of the State of New Jersey , sad whose
addtem is 343 THORNAT+I+ ST
EDISON, NJ 08837 .('Leedom'). Ronowar am Lgadw theptooipai sum of
One Hundred One Thousand, Five Rundred and 00/100
DoUm (U.S. $ 101,500.00 ). T6: debt is widasood by Btatwws v Note 4" the wn dM as this &why
January 1, 2032 prnvwm for This mummy ptUmt U, vM ms faB debt. N am paid sttsiin, due sod ptq" as
8eatrity hwwmK swjm w Lmdesr (a) dw nVaymcm of &a dept evwmnod by
do Now. wilt dRt&W. sad AU Mowsh. tarumaims mod mqdVlqWms of dw Natty, (b) LLs pgrmau of all 0dw wms, with luWaL
edvmwd vender p»W* 7 to psotaot do nmdly of ms 8oauity bomsz4 sad (e) dw pssforwW of Baesnvea sa "W a sdd
WIMON ft id tie Swuft Imteu aug sad 69 Nob. Foc his purpow, Bottowar dos hereby mo+tt;at a. ? sad wwq to
L
owing da mnlW pmpwty loomed is
CUMBERLAND Couaiy. Pmoaylvmda:
See Attached Lagal Description
1 CU r1l
Cb
? r
rs
-4 try ?
r^ r
is
whlah hu dke sddras Of
814 MUM ACRES STREET, M8C1WXCSBURG, PA 17055
TMRT! 1$R Wit'H tilt tbo imp[ovemsw now or he saw eroated on the paopmV, surd all etussmRU, s qww mss, and
fttusea Raw OF haadteT a pset of the ptnpffW. AN nplaeaUNIM and add doom shill also be *ova" by his Seclu* Eashnrnmt.
AB of the dbm wing is eefarnd to in this SawdW hu;bmumlt as the "Ropmq."
BORROWER 100VI°N'Att'1'S dint )lerrowat is lnwtldly seised of the Mob booby noarGyed send his t?1 dsht t0 asortgage,
Sant and aonvay she PUVcftY sad that do Pmptaty U umocamblad, Wm*t for Oftumbnoom of:sooty. Boero$wr watrhtda and
wUl ddfeod gawsuy the title to the Property q dm on dabm snd dam mew, wb)eat to my Nwu*fMM of noatd.
PONK.IYLVAIM FM ),epR9' 4W 8?(1 7 4 2 PG +? 2 8 4
04701 (7^) 0"U M 11%) PAW 1 OF 5
•01-14-'09 17:33 FROM- T-095 P003/007 F-532
71`1x8 SOCURM INVMVM Jar e0egWM waif of COYa MU fOrn UGW use and non-amfeea covenants win i3mihd varlsum
by 3misdiction to coudime a unitom security imtmmeat Covetous rent property.
Borrower ad Lgoda mcu" ad spec s-Mms:
UNIFORM CAVkWAISM;
1. Payment of Principal, b twat and Late Chav& Burrower ahdl pay when due the principal of, and intaest on, *0
debt evidenced by the Note and lens a1mr, ea doe under the i1'ow
t. Msmfily Payment of flaxen, Ism moe, and Other ChoW. Borrower dull indmisimemi momtttly Meant.together
with the prindvd and inttrrax a set forth in the Nom and my laic deargp, a am for (a) taxes and apocial asessaim laviod or to
be levicd agai eat me Property, (b) lesdrold payments or ground tau on the property. ad (c) pros siewu fir imisaum royuiro,duoda
Paragraph 4. In my Year In which the Linder most pay it mortm Iaacnooa pawning to the Secretary of Housing and Urban
13-ciopmrat (63m4tuy'), or in sw yew in whtep euc6 premium would have bem rsgxhod if Louder Kill hold the security
ls4vnxut, each motift payment dull also iwh& dther: ()) a am for the woad mortgage isura m prm*m to be paid by
Ltndet ro tee Secrotary, or (lb a maghly charge irate ad a[ a mrutgage faaersaa paYanipw it this Seeaariry htatraneot id held by the
Setriptry, is a reasonable aarnwt to be dewmdoed by fate Secmtay. 6lroept Ibr mw mommy large by the Semmmy, *m items
acs tolled 'Buxow Items' and the dams paid to Leader ate called 'Escrow Ands'.
Leadaa my, at cry time, collect and hold mono lot RKSVw Rims in m aggse#rae mumPAL not to mmood she smaximmin
amount that may be required for Borrower's acmw account under the Real Brtate Sadamosat Pmoodues Act of 1974.12 U.S.C.
} 2601 a Mnq. and implememdog invoariom, 24 CPR Pitt ISM, s they may bo amended Eomt dm to lima ('RI SPA"), amp dust
the cushion or roemn pamaftred by RBSPA for tmmticipated daturemmesla or disbarments berme the Bamweee psympOs at
av4UMe in die account mry not be based on smonnts due for the mortgage imurlmrse peemiwn.
If the -man hold by Ieandear for Escrow Rona t5wrid me am== permitted to be hold by ii WA. Linder abail account
to Liomm r for the excess funds s roquin d by RBSPA. U the amounts of funds held by L,aader a any time are mot u(5cieat to
pay the Escrow Items when due. Icoder may modify the Borrower and require Boamw to make lip the shortage as perinkt d by
It MA,
7be 6dcrow Funds are pledged as additional s m* for all soma secured by this Security 1asummat. If Borrower tmdaed
to Lender the fig payment of all such alms, Bomwer's mace mt"be ermdilnd weth the bdsce namblog; ft all losta(laatit items
(at), (b) and (i) ad any mortgage bmraoo prwouat WrAtusem the Under has not become ob](gasd to pay to fhs Timmy, and
Iamder dull pramptly mhmd any owns funds to Borrower. h ma ibumly prior to a fadaclodms oak of the
Prmpary or Its oorphioitlca
by L.eoaer. borrower, at.eount thrall be m1milted with my bduce ranalalog Im all Wadi mm tine *= (a). (b) and (c),
1. Appnegfoa of Pa,Ymam. All payments under Parsptltus 1 ad 2 AM be Wiled by Lender as follows
OM, to de mattgage Insurance premhhm to be paid by Linda to dw Secretary or to the moonily rdtrge by the Secretary
instead of the tacmtbly mortgage marmuce pramiom
rte. to my taxes, specid asossmaim laichold payments or grand leers. and the, flood and other band insurance
mcankuns. as required:
JELL to MUM dire EMU the NOW
Jam, to m ttia rdon of the principal of the Now. and
, to Late cWps am under the Note.
4. Mae, !load and Otba Huard houramuas. Borrower chill Jam all huprovemmats on tee Pmpaty, wbatber now in
existence or atbsngoedly sound, *gal= my ban*, tandtls and ama ogeacim, Including Are, Ahr which Irma r ngdms
Isauamo. This iasurmoe ehtdl be maintained in the atnown and for the periods gm 1044M nquires. 8orrotwr"alp (mmni
all idrpmvendemo on the Property. wdhemw sow is encloUm or kftoq mdy esmcte'. agaimt Wes by Hoods lothe atM required
by the Sometary. All famrance shall be carried writ com pania mptun d by Linda. 71m ham mem polices and soy remwala shall
be held by Linder and shall include Wren payshk o1musce ins favor of, and in a ibrm aocWtable to. Lander.
In the event of ion. Dom m shall give Lends hamediae nine by mil. Lander tnsy mkm proof of ion if not made
promptly by Borrower. Bair hlsursmoa company concerned it booby danhortmed amd direimd q matte pgmdmt for such loan directly
to Lender, instead of to Borrower and to Leader Jointly. All or my pert of the Insurance p mssds mtyr be spoked by Leader. at W
option, either (a) to the Witudon of the indebtedness under the Note ad this Srcmitr Immtsmr. Ana ro air AdIngae t maxmts
applied in the order In h mWmph 3. and tuna to prapaymmt of prfocfp#l, or (b) to tea rI' "' , slsq or repair of Chi 4tod Wg property.
Any appiiu md= of Omproeesds to Qkt principal ehm sot tamed or poslpoae the due ddtus of the mommly pytnnae wmA as reilmad
to in PmSWh 2, or tdhmp die account of such payments. Any exias insurance proceeds over ma anatrml rot dW to pgy all
ootatmdigg ladebmdoea wWcr the Nate and this Security Immammt shalt be paid to the amity AWy co0dog ill am.
In the event of foreclosure of Na Seoarity lottruonent or otter Ceadbr of title to then Propm[ty did embssuld la the
indebdedaest, all right. dth ad interest of Borrower in and to hnntram policies in toga hdtail pass to the purchaser.
S. ocavam y, hemrvatiom, Mafnimoance and p1rubm l m of then Ropaedri 11m, vwnR's Loma Appllgtlsr Lseaaholds.
8oavwtr dha11 ooinpy. estabUsh, turd mss fire Fa arty s Borrower's pt:iaiipal reddcm wlmim sissy days filer tie &motion of
this Security Imnament (or within sixty days of a last ads or transfer of the Property) and rail condoms to Occupy the Property
as Borrower's principal roridcmm for at lest one year after the Oft of occopmay. -bm Leader determiss fha ragtrimement wall
cause nmdsehudaiip for Borrower. or w4m doamsumg cim:tet mnoes exia which as beyond Dome et's oamaw. Botworw a oil
notify Lenders of any eammina ug ebeamtamn. Ilarmwa shall mat co®gic waste or destroy, damage or m t=Uly dnp die
?perty yr aliov tlba property one deariaraoe, rraaoglubk wee and tray adoepted. Ieadddr m?1' iagrea the property If tDe
is vacant or abandoned or the Wes is In defwlt. Leader mry Walt. ressabke anion to protect and preserve smh vaimm or abaop dog d
Property. Bormwer " also be is ddW& If Borrower. during to ion application p mom, gave MIAWWW WN or hmm m
(atormtrom or amepmu to Lmft (or fWed to psvvidiLoadcr wits entry inaten l iataaAm dov) in comnectlon wilb due loos evWacod
by dw Note. Including. but not limited to. eepresenteiom commmiq Bot:anverI oocmpmcy of the Property s a prime%* raddemrs.
If thin Scmulty Imtrranent is on R liaarhoid, Botrower stall cmWY with the psrrvialama of die Imm It Borrower acgdta foe dde
to then Property, the iwehold and in title shall not be merged notes Larder Wm to the meW in wrMiag.
6. Candemmmom. 'ibc proaeede of any awed or chins far darmages, dbm Of oonnegarmtiet. in oonmaaim with any
=ndemmatim or other taking of spy pat of the Property. or fbr eomveyamce in place of condemnation, we hereby assigned ad shall
be paid to Linder to the extant of me fall amount of the imdebledocas ma rands attpaid coder the Note mod mks Security last meat.
Leader dbdl apply such pmoeeds to due roduaWa of ft h d&mftmsd under the Plan sad Ods SKa* Inu mm ass, ant to my
drliogmew a wants applied is the odder prvvWw is Paragraph 3, and On to propaywat of primtpd. Any 1pptlaatioa of me
proceeds to the pdWpd allU not extend or posooae the dine dome of the monthly payments, which are regn, m is PUNSWit 2.
or ohmge tie amamt of such paymeais. Any execs proeotdc over m ammmi minin d to pay all outusa g iadd tednm :raft
T3aNm.v4W4 m t+ioamatl ?K 174 2 PG 4285
43701 p/9d) at.0..1196) PAGE 2 OF S
01-14-'09 17;33 FROM-
T-095 P004/007 F-532
the Note od this Security Instrotent shall be paid to the amity bWay entitled thesamo.
7. Chou" de Barren- turd hvisedm or Cmdse'a Rlglsb in an h opedr. Ilwwwor doll pay all VwemmedW of
musdeW 01114ee, fine and Itnpositicat Wet are sot inlnded in Paragraph 2. ljierncwar ahAB Per these obligWOU on time directly
to the entity which is owed the payment. V ftdlnro to pay would adversely alliact lenda le hamest is the Pr qww, upon Lnader'a
roquat Bturomrr shall promptly ihraiah to Leader receipt evidgW g these Pero, .
If B(Mrrowrr fhils m mice three pttyeaoats or to Poymeab ngWM by Paragraph 2, or btiji to perform soy other coveemu
("'? yr a One is a n legal eproceading xto l nn ??y ).dIAww ietyy domid p y
whawt w is oveme iry to p otuct the Yom of the Property and Leader's rights in Are Prop", inc wilt payaxnt of taxes, haaard
insurance and other items mentioned in PAngnph 2.
Any smornb disbursed by Leader WWW Wig Paragraph doll become an additiaoal dabs of borrower and be seared by thin
SUUdty hA U OM. '!bean amounts aLau bear iaturvot fume the data of disbumment, at the ldotn rate, and at the option at the
Lvedur, shall be im medistely due and payable.
Borrower Ahsll pt+adnptly diadmige any lien *high has priority over ado SvMty hLt&wwW hales Bereowa. (a) agree inn
'a'AH09 to tin PaY-M of the olhligation e»I - by ILO Oat In a i ati m x00 PW6 to Leader; (b) woloote in good to* the lion by,
a debauch sib enforcement of We ilea 1% Ind pmoeedinp Which in the Ymiar's opinion operate to prover the sobteemeat
of the lies; or (c) anoures from Wes holder of the lien. an gxaco eat sukfa wy to Lattice wbadivatimp dw lira to thin seeority
losuumum. If Leader doowenigaae that my part of We Ptope ty is dubjeat to alien wbidt may Again ptia dly over Wig SwAity
Lutrtaneat, Latch easy give Borsdwar a netlee idectifyisg the lino. Bonoww shall wary the liveor tape meat more of the nation
as froth above within 10 dope of the 0vMg of moft.
S. Fees. Under may collect has and dnqes as wriwd by the so mwery.
9. G mamb for Aeceivratim of Debi?
(a) Detnmlt. Laden may, except ae United by rapdabons issued by the Sa dary In the ease of payowd dekdu,
require immediate payment in fort of au auma eemrad by thin Stem ty hgtrrmm if.
4) Borrower dchalte by filling to poly in full any m eddy payment required by We Swift Inot<umm a
prior to Or on rite due date of Ilse next monthly palyment, or
(u) A dmanure WIAS, for A Period of thirty dsya, 10 PeZ$nm M' other O Uptiora COMMWd
bile Without Creft App end. Iamdea 44 if potmitiod by Appmrabte I- (imiadiga sortie 341(4) of the
Gwen -St Gam min Depwitmy JwAalons Act of 1982, 12 U.9.C. 170(j•3(d)) and wiW the prior Wpmvd of do
SO try, require immedloo payment in full of all sums wmpvd by Ibis &=a* bsortmamt if
(i) All or part of the: Property, or a btadMd WWM in a twat owning ail or pat of the Proprty, is sold
or alb-mos taodfe W (o&K than by devise or dmx W, and
00 Tla properly is M OGAIW by We poodu er or grantee as his or her principal roddeaoe, or the
purl-& or araataa does so occupy the Pmpety, but his or her mft lug not been rpPrcvM it
swordtmoo wM the rcgwmw ma of the Sttctebcy.
(C) No'91 AI*w. m drmmdmou eoew that world permit Lcv4wm nwgm mmouf re paymm in felt, bat LaWK
does not requirs MIA pAyments. Leader does not waive its IWW with twapeot to srbsequot events.
(d) ReymiABAnx of HUD 8eai'etn7. 1n thrusy eireooutaama reerdaaoa+ isslWd by the anvaary win li0t i?cadsr's
rijOw in the roe of payment ddnlb to require immediate psymeot Ire NJ and ft Wow if not paid. M& Swm*
Imxhmment does not outhOlin a ccelustion or fbmadomwe it not ptamimed by nguladams of As Saco wy.
(e) Me pp Not lman.ad. Borrower agrees tile{ if this Stoulty Iaetrwr W said else tom ass no da mhW to
be eligible for inioneow unci f to National Hoaxing Act within 60 dWI hem the dame begot. Under may, it its
option againe Immediate pWmw is full of all am named by this Sanity Instnsmmt. A written stmone t of
any arshwi-d agent of the Sewday daar4 wtbsocla t to 60 days fawn Ws dais bend, decllnlog to lawn We
Snauaty IN= = tend else Not, elbll be deatmd ewmdadve proof of rush indigilddly. NowidmaOding the
fluregohhg. thin optMaw mot be owdoed by Leader wben the ouvat7tbilky of humanoa In solely due to Leader's
fadlatre to remit a mor4w insurance premium to the Secretary.
19. adn , Be- rrowhas o right to be rdnoWed It Under but required fmsediate pwymmt in full because of
Borrower's failure to pay m amount duo under Its NOW or this .Sootrily ImtetmhraL Thin rlgbc applies saran oiler flowiuaare
pmendioga are institumEd. 7b a&uwe the Swift hishument, borrower shall leader in a jump see all amptmte wgvkW to k*
DoMwor's account tita= ineludtng, to the fencer they we **Wm of Borrower tender this am ft Imwamoat, bredmhm on
ad reasonable and cmtnomagr aueaney'o fba mod egwm properly soociafod with do hrccluwre psmeediag. tipam nintaptm eg
by Bottoacr, this So mrity hatrument and the ohliptlons am It arena aLau emom m in qffCt at if Leader Ind set required immediame
pA]mmt in &H. Hewn, Loader is net vcgelmd to petmit reia:mtemaot if: Q Lender hat moepted reinaminmsat afba We
= menncoment of fbtoclosere procad-m9a within two yore immediately prccediog tin oamaat of a ermrmt feredoepra
pteaes *. (ir7'cl-bwment will predtde ibreOlONU ea dif mvx Grounds in the there, or (lii) tettntebarent will advaaely, affil
the priority of the tin crested by this soearity bwWn eqt.
11. 1l dIrdwer met Rnleuedi FnrDerranes by Lewder ad a Waver. Hsocadon of the time of pttyatest or moa&ation
of ammrtb MtiOn of the cams oomvd by We SOCKIdly BUOUmtmt gnnmA by Lander * aqy attention In inamraat of Borrower sludl rte
Operate CD fdoew Ate liability of the oriotol borrower or llmw*ct'¦ 1111006180r it imaea<. L=Ww ebtdl net bs ngahW to mmxace
pmeeedbW against my wcawaor in iwarcot or stow to extend tine for paytmeot or odwwise waft amartirataon d the rums
scoured by rids .-9wA ty brIMU at by moon of my demand made by Ws Original Bmuwnr or borrower's tutmnors in imttunt.
Any h1bMIM by Lender in enerdliug any Sight or remedy ahem net be a waiver of or prscieft the erwdu of aiy right Or remedy.
Lx. Sugoveora nerd Assizes )Homed; 49W And ormal Limum , Co.6ig=L The oweauaras and ap o mmts of this
Scarify lant ummtt shall bind and benefit the ricces ors and a:dsms of Louder and bemmtsa, erbjtst to the ptovlxlana of ParaMO
9(b). borrower`: twwanmta And ograemeata shAU be joint sue enveal. Any borrower wbo co-dVa this Sw4rity bmmmut but doe
cot execute the Noce; (a) is co-suing Win Seca ft fostmmmt only to mwo4 e. Sr" and Oomvey dkat bormwer's Iaw ri in the
Propesty under We twos of this Security butrmpt; (b) is not personally Obliprtd to pay the am second by Mis Security
homumosa. And (0) Agraea th8t I.OWW and any OAaer Bofluwer MW 89tH 00 aatead, modify, larbrar Or MWW MY aooOnixnO(1atona
with ngud to the terms of ft Security lastruxuat or the Now without than botnwc'a 00mamt.
13. Naioo. Any Hotta b BoMMw puovjdod for in this .out XUY baau ncet ring be ihven by dd verlog It or by mating
it by fiat class mail umlaan WpHc4ibk jaw rrgw= use of aped- n wftd. The Woke doll be direamd io the Property Addnw or
Wy ahcr adgeese Borrower designates by notice Io Lender. Any motion to Lender &Uj be given by firer Cleat sell tO IAWW'a
address MW heado or any addnu Under designees by moth 10 Benrow- Any notice provided for in tWa Saamlq bstrtment
ft'N taYt.VAMA FMA aorrwt;n BII 17 4 2 PG 8 6
C-3701 CIft) ot.&m 3/96) pAGII 3 OP i
'01-14-'09 17:34 FROM-
T-095 P005/007 F-532
shall be dnmsd to blue boon given, so Borrower or Leader wban given an provided in this Pawspit.
14. $wvwr4M Lows WwaWIW. This 8eaaity katrummt ninth ba p "uW by FSdaal law sod ma law of the
jwdeftdon in which the Piapedy is haohtnd. Im the govt then my ptoyjmim or clams of this Semrfty buftum last or then DIM notables
with appl WA@ law, mush aonttkt dWI mot of m odm provisions d WE Security hom aht or the ?tote which em be pvm elect
without the Conflicting Provision. To this and the provisiotu of aim Security imaammear and the Nose sot declared to be aava0W.
IS. Borrmwarem Copy. Harrower shall be pivm one aomfmenud copy of Ox Note and of this Smamity fmmummat.
16. Iiiwm r&m Subelmm. Hormwnr shad nm arose or pewit the meen e, uam, dispoed, mtaeeta, or wleame of any
Hwxddom Mr-mm on or in file Propary. Bormwm ball not do, nor allow smycme elms so do, nydft aftedu then Prmuly
th
at b in vlehdm of malt &Mz'oummzql Lew. The pmoedint two semcoom ehati not rppty to the praamm, ass, w amp on me
PnVwW of
tmimtensose ll quanddes of Hmrdetmt Sobsemoom that arc Sca mmyy mwp dud to to sppsoprb is to normal mmidcoliml um sea
to of dbe pk0my.
Hommer abau peon" give Leader wduen odes of my iavest4ndom, aimht0. dmand, Loa* at other modem by any
govuMenttl or regalasory Stacey or private party iavol ft the Property and my Humdoum .9AMMoe or DaYLmOmr itsl Law of
which borrower ha am d Imowledgm. K Borrower Iwo. or It notified by my Bowenmmtal or reedwrt vAudgr, that any
rmoval or other remediuim of my flarmtdmut $tbammcee W%3 ft rho Property q neceumey, Borrowrs eha4 promptly unite all
of ommy romodiml mteiona in aeeordmee wish Bovimmuc d Lary.
As and in d& pxwWh Id, "Humdous SWatamea" are those wbsuom 4 0mal as tome or hmmrdou aubmtmm by
Enviro?haol Law and fbe Eollmviot sub.tamra: gmeoGum, kstmsese, other Ilatmmnabk er loidc petroleum ptttdmcq, Ooaic pesticides
and barbfcidra, voiatpe solvcM, matedds coutcbtiog ssbmw or 1brmddd**, and ndiwaive meed-ls. As used the pacagrapb
16, "Envirommmmal Law' roam fade ml Iwo Sad lava of the jar uftdom whale trim Ropatty is heated that :plate to haft safety
or mvironmental protection.
NOWUN FORM COVENANTS. Bormwer and Leader Amber commod mod mm as follows:
17. Ar lsommmt of Rents. Borrower tmm.dw®py a algos and um w(om to Lawlor mat litre ram and mvmuem of do
Pmpaty. Borrower autborim a Lender or ImiWa m mu to collect the rem mod wvemmn and herby dmacts emrb toot of the
Proflmty to Jay the rents to header or Lemder's atmrs. flomamm, prior to Lendeep up" to bomawcr of Borrower's InrhmA of my
cavuem or mgromu mt in rile Smutty ywamment, Borrower ball collect and receive dl minis tend mvemoa of the Poq=W a toots
ft the bandit of Leader and Borrower. M assignment of cob Medium an almolote armigmmmi and not in ssa(plMW for
additiommt security wdy.
It Under given mouse of knack to pot omm (4) all rmu received by Butrum shall be bald by Sormwor ere trmsten for
beteflt of Leader only, to be applied to the mm sewed by the Smu ty Imtmmnst; (b) Lauder dull b*aWdM to oWact and receive
ell of the reou of the Property. and (o) tack tenmmt of the Property whop pay all wo On and muptdd to Landry or Lmda'm aamt
on Leodta'a wrka m demand to the tmtmmm.
Bormthmr bait eat axeastsd any prior miom d of doe me m and hm. not and veld mot i , A m my max wen would pseveot
Lou* from asnrddag lu rq un tender WE Paapaph 17.
Lmder mha11 we be mgnimd to aoter upon, take control of or maintain the Pmpetty before or aAa grins modoe ofbwch
to Earrower. However. Lander a a ju&ddly nppodmtad m elver may do so mt mW time mere im a broach. Atq application of rams
a W not cure or waive any dabA or invalidate any other AgW or remedy of Leader. 'thin assignment of rots of the PtopeM mall
tmmionm whom the debt meaaod try the Seomity Imam= in paid In full-
Is. ftmkasms ft taut. H Iwmtier nW4eam lnm milmte p"und in loll under pmrmpopi P. Lander may Rmmdm
tibia Seem* Immum s by Jttdt:lal p vondb& Lmtiar AM be meted to ae led all tStpesamsa barred bt pmwtlog the
rmadlm pmrlded In this pamorarh !S, Irdudlegs but not On" 6% atlavmge' Are and cowN of tale avidiwce to the ad®t
Pwmhtbed by applicable bow.
N d c LmmdR s hmeret in this Sftu y Imsrmmant is held by the Suntary Std the Smts+tur! rmgtdre immmdhte
payment in ran under PM trs* 9, the Smmreho sway ktvLs Iba u- jtldkial power of male previcled it aim dingle lhmly
Mmttgnge I6muku mle Act rot 1914 ("Acth (12U.S.C. 3751&w) by talmentim? a tbndottnae aomsva? deNtt tttnd umtter
then Amt to commmwe fntt clemum and a ail she Pr*Wq m pmvllled in tM Att. Nothut in the par eft mule mm shsB
daindve the Hamm=y of ow rldldm ot)s-win rwmlWA to a Laden under tram Ommgratpy M or appileabbr bor.
19. Rdame. Upon pR memt of all r- secoW by this Secw* 1nsoumm4 thin Security Immummeot ad gin senate
conmed mind tarmwata mod bwome void. After much eocurrewoe, loader shall dwlhge and mdisfy thin Smmdty lmdnwman without
charge to f mnmw. Bommm nheil pay any remrdattnn may.
26. Walverm. Ba m w. to to elraant pem*md by ap fZilemble law. waives and relcum my error m deffRlrm in proeeedlup
to goAur+m tilt Saahrity foetponm, mod hereby ways flea Wumtt of my promemt an h Mm laws provfdiup for gW of memdon,
cxWn ion of lime. amuWtk m b m aMd mm. Iny mod a*, toed bommuad nmerWHOP.
21. Aet Prrbd. Barrower'm time so rafnarlde provided im parmgrmph it) shall calmd to oom hour prior to the
commmcemmt of biddies at a sbaifts unit or amen smto puranmt to thin Swp ty Imttnhmapt,
ZL. F md Mace! Matgttge, if orgy of the debt n umd by mia .9wz* boument is its to Bm own to
to the Property, title Smowity hum== shell ben a phuchame money aartsmp. m9 fink:
t]. lasa+eat Rate After ludPrAt. Bpnower agtoa that the Inteuat pre payable oiler a jadpoent Is entered an doe Note
or in an modem of n mt`mte Arreebmmm d M be the rote payable ftm them to lbme uada the Note.
14. Rid ens to file Sxtmity Ias mmut. If (alto or mop rides mp snouted by Borrower and r wWW emtebY wlh this
.Secuity losttrpwtttmuctt,, t oogcovEmanls and agramemtn of Sad m ich rifler Ad be Inowp mad i? and Ship mwmd and muppfeQlmat dw
o V gollowin9 rider aroma B art oa had m) were s part of thin 3ecmrlty htattroaest.
NO RY EPJ9 ATTACHED
e' M3YLVAMA FRA MONMAM 8K 17 4 2 PG 4 2 8 7
C.3701 (71%) PWP)-m U%) PAGO 4 OF
91-14-'09 17;34 FPO[- T-095 P006/007 F-532
By SKWNG =LOW, Rota aoapte Sod Wm w tbo fermi wW?dn d in d& Searity L>rttlm1e11t and is my ac*)
ex coal by Bormww and reoonded with it,
The Rom m" atIMN Out a true copy of lb noort" iL boon raWved.
am It
COMMONWEALTH OF P8lWSYLVMIA
es:
COUNTY OF CUMBERLAND
On" 14th &WOf DeC*Mb6r, 2003.
,befogs me, fie
eubbomibw, a Notiey PubHo in ad for the Co?omwsibh of lbomeyiv=K mditg m
M &ELA L RftfL H W
and aohavAodpd tba witibl [odniamC of Mankato to be ftir ast and deed, and desired tie acme to be teocrdod u nkh.
WTrM= my bind end soil, the day and yar ahm otd.
)&dd ,,xL k1 uIatla- m
ty? A*& 2% ?
1BHHmyAm A rm hfokTrjAw 011 7 4 2 PG 4 2 8 8
0.3701 CIIM Ohpbrr WO PAM 5 W 3
'01-14-'09 17,34 FROM-
MIT «A„
T-095 P007/007 F-532
All. THAT CERTAIN tot or parcel of kud, shunts in the Township of Monroe,
bertand County, Pennsylvania, bounded and described In secod &uft wttb a survey
ad plain thereof made by John C. hrlihart, Registered surveyor, dated October 10,
IT, as Maws:
11 40MMG at a point on the Northerly side of a 30 foot wide private doter-way
k*wa as Green Acres $tred, which said potat Is distaat Sa feet, amore or IM,
Squib 73 degrees, 30 adnotes Wds
it along said Northerly side of said rift-ot=
Its intersection with the Westerly dde of Longmesidew S&MI thence shag the
side of said right-o[ way South 73 degrees M adauto Wert 160 feet to a stake
land for nedy of George Wertz, now Marts Wort thea?ee.aleag acid bad
oat West 180 hd to a corner of load now or late of Michad ftm; Manes
F:4d
had North 73 degrees 30 wina+tes Bast 1410 feet to a stake at a com of 100
no1W or late of COI A: $adkih. theme along said iand'$outh 9 degree3 East too fed to
thT point and place of )$BGYNMG.
1r VXNG thoreo erected a one dory frame ranch type dwelling known as Not $14
G Adzes. Stript.
r
I Certify this to b6-recorded
In. Cumberland County PA
Recorder of Deeds
8KI742PG4289
VERIFICATION
Whitney K. Cook , Assistant Secretary, and duly authorized representative
of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation deposes and says,
subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her
knowledge, information and belief.
CHASE HOME FINANCE LLC, s/b/m/t
Chase attan Mortgage Corporation
00
Ul i
00
0
RECEIVED JAN 2 9 20
SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00668 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC ET AL
VS
PEARL ANGELA L ET AL
GERALD N WORTHINGTON
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
PEARL*ANGELA L A/K/A ANGELA T PEARL the
DEFENDANT at 0018:12 HOURS, on the 11th day of February-, 2009
at 814 GREEN ACRES STREET
MECHANICSBURG, PA 17055
TODD PEARL
by handing to
HUSBAND OF DEFENDANT
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.00
Affidavit .00
Surcharge 10.00
.00
37.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
02/12/2009
GRENEN & BIRSIC
By. - L I
Deputy Sh ff
of A. D.
rr i
'f
^ f
' t ,i
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.
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
Defendant.
I hereby certify that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
the last known address of
Defendant is:
814 Green Acres Street
Mechanicsburg, PA 17055
GRENEN & BIRSIC, P.C.
NO.: 09-668-Civil
TYPE OF PLEADING
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
Defendant.
CIVIL DIVISION
NO.: 09-668-Civil
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant, Angela L. Pearl, aWa Angela T. Pearl, in the amount of $100,673.12, which
is itemized as follows:
Principal $ 92,038.50
Interest to 3/16/09 $ 4,372.57
Late Charges to 3/16/09 $ 114.57
Escrow Deficiency to 3/16/09 $ 347.48
Corporate Advances $ 0.00
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $1003,673.12
with interest on the principal sum at the rate of $15.13 per diem (as may change from time to
time in accordance with the terms of the Note) from March 16, 2009, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
BY:
Kristine M. Anthou, Esquire
Attorney for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant was not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copy.
Sworn to and subscribed before me
this day of 2009.
otary ublic
COMMONWEALTH OF PENNSYLVANIA
L EVOIbO M pap, NOWY Punic
EMM?
wni• A••o WO" •
Member. ???
0 i
IN THI- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ANGELA L. PEARL a/k/a
ANGELA T. PEARL,
Defendant.
TO: Angela L. Pearl, a/k/a Angela T. Pearl
814 Green Acres Street
Mechanicsburg, PA 17055
DATE OF NOTICE: March 4, 2009
NO.: 09-668-Civil
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
'L'OLL FREE (800) 990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
GRENEN & BIRSIC, P.C.
P
By:
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ANGELA L. PEARL wVa
ANGELA T. PEARL,
NO.: 09-668-Civil
Defendant.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Angela L. Pearl, aWa
Angela T. Pearl
814 Green Acres Street
Mechanicsburg, PA 17055
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on jwe
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $100,673.12
with interest on the principal sum at the rate of $15.13 per diem (as may change from time to
time in accordance with the terms of the Note) from March 16, 2009, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
( ) Confessed Judgment
Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
vs.
( ' ) Other
File No. 09-668-CIVIL
Amount Due $100,673.12
Angela L. Pearl a/k/a Angela T. Pearl : Interest
$ 3,103.98
: Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
for debt, interest and costs, upon the following described property of the defendant(s)
County,
Please see attached description
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(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 414-lof Signature: --
Print Name: Kristine M. Anthou
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
Plaintiff
(412) 281-7650
77991
(over)
OF
?.JI- T,;-!' 2009 F"i; 14 PH !:28
CU
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3#7. o o CaF-
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15(o. oo -PO ATN
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127** aa301
--!?E WA4 Of E.Y, 4Mb"?
-A4
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.
ANGELA L. PEARL, a/k/a
ANGELA T. PEARL,
Defendant.
NO.: 09-668-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in
the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property of Angela L. Pearl a/k/a Angela T. Pearl
located at 814 Green Acres Street, Mechanicsburg, PA 17055 and is more fully described as
follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ANGELA L. PEARL, A/K/A
ANGELA T. PEARL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF MONROE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF
PENNSYLVANIA. HAVING ERECTED THEREON A ONE STORY FRAME RANCH
STYLE DWELLING KNOWN AND NUMBERED AS 814 GREEN ACRES STREET,
MECHANICSBURG, PA 17055. DBV 249, PAGE 3291, PARCEL NUMBER 22-24-0783-160
1. The name and address of the owner or reputed owner:
Angela L. Pearl a/k/a
Angela T. Pearl
814 Green Acres Street
Mechanicsburg, PA 17055
2. The name and address of the defendants in the judgment:
Angela L. Pearl a/k/a
Angela T. Pearl
814 Green Acres Street
Mechanicsburg, PA 17055
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t PLAINTIFF
Chase Manhattan Mortgage Corporation
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
James C. Costopoulos
Monroe Township Municipal Authority
Monroe Township Municipal Authority
PLAINTIFF
10 Courthouse Avenue, Suite 103
Carlisle, PA 17013
1220 Boiling Springs Road, Suite 121
Mechanicsburg, PA 17055
c/o Bogar & Hipp
1 West Main Street
Camp Hill, PA 17011
5. The name and address of every other person who has any record lien on the property:
Cumberland Domestic Relations
PA Department of Revenue
Commonwealth of Pennsylvania
P.O. Box 320
Carlisle, PA 17013
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
t? t
r
6. The name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
None
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF 2009.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seed
Epzabetlt M. Pabino, Notary PUb#c
My?E 41, 2D12
Member, Pennsylvenla Asswistlon of Notaries
OF Tjjr-
2009 APR 14 P 1: 28
r F? ? F
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.
ANGELA L. PEARL, a/k/a
ANGELA T. PEARL,
Defendant.
NO.: 09-668-CIVIL
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who
being duly sworn according to law deposes and says that the owner of the property located at 814
Green Acres Street, Mechanicsburg, PA 17055 is, Defendant, Angela L. Pearl a/k/a Angela T.
Pearl, who resides at 814 Green Acres Street, Mechanicsburg, PA 17055, to the best of her
information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS 4-DAY OF 2009.
< J#AtYa4M?-
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notaft Seel
ENzabelh M. Pehtnn, NWO Public
my? e
Member, Pennsvlvonla A"001 Ion of Notaries
ALED--? "rFi , f ; P
.?em.
JF TF PR"# :,NMIAPY
2009 APR 14 P 1: 28.
114
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.
ANGELA L. PEARL, a/k/a
ANGELA T. PEARL,
Defendants.
NO.: 09-668-CIVIL
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEQ.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for the Plaintiff, who
being duly sworn according to law deposes and says that on or about August 16, 2008, Defendant
was mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and
by first class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act,
Act 91 of 1983 and Act 6 of 1974, 41 P.S. `101, et seq.
SWORN TO AND SUBSCRIBED BEF RE
ME THIS Y OF 2009.
44, (7-1, 1 - 0, / W.
otary Public
COMMONWEALTH OF PENNSYLVANIA
Notarlal Seal
ENzabeth M. PaWW, Notary Pubdc
City of Plumbtrgh, ANd"Iy County
My Cd7'n1lssion EVkW Jan. 6, 2012
Member, Pennsylvania Association of Notaries
'TARY
OF THE: P"1117)"
2009 APP 14 PH 4: 28
t
-t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
NO.: 09-668-CIVIL
Plaintiff,
Vs.
ANGELA L. PEARL, a/k/a
ANGELA T. PEARL,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Angela L. Pearl a/k/a Angela T. Pearl
814 Green Acres Street
Mechanicsburg, PA 17055
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 2, 2009, at 10:00 A.M., the following described real estate, of which Angela L.
Pearl a/k/a Angela T. Pearl is the owner or reputed owner:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ANGELA L. PEARL, A/K/A
ANGELA T. PEARL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
TOWNSHIP OF MONROE, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF
PENNSYLVANIA. HAVING EREC'T'ED THEREON A ONE STORY FRAME RANCH
STYLE DWELLING KNOWN AND NUMBERED AS 814 GREEN ACRES STREET,
MECHANICSBURG, PA 17055. DBV 249, PAGE 3291, PARCEL NUMBER 22-24-0783-160
r..
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.
Angela L. Pearl a/k/a Angela T. Pearl,
Defendant,
at Execution Number 09-668-CIVIL in the amount of $103,777.10.
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.%r?
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
l-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA
CHASE IIOMI FINANCE: LLC, s/b/m/t CIVIL, DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ANGELA L. PEARL, a/k/a
ANGELA T. PEARL,
Defendant.
NO.: 09-668-CIVIL
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or parcel of land, situate in the Township of Monroe, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by
John C. Brilbart, Registered Surveyor, dated October 10, 1964, as follows
BEGINNING at a point on the Northerly side of a 20 foot wide private right-of-way known
as Green Acres Street, which said point is distant 568 feet, more or less, measured South 75 degrees,
30 minutes West along said Northerly side of said right-of=way from its intersection with the
Westerly side of Longmeadow Street; thence along the Northerly side of said right-of-way South 75
degrees 30 minutes West 160 feet to a stake in line of land formerly of George Wertz, now Merle
Wertz; thence along said land North 9 degrees West 180 feet to a corner of land now or late of
Michael Panza; thence along said land North 75 degrees 30 minutes East 160 feet to a stake at a
corner of land now or late of Carl A. Banks, thence along said land South 9 degrees East 180 feet to
the point and place of BEGINNING.
BEING Tax Parcel Number 22-24-0783-160
HAVING thereon erected a one story frame ranch type dwelling known as No. 814 Green
Acres Street.
BEING THE SAME PREMISES which James J. Bruzga and Suzanne R. Bruzga, husband
and wife, by Deed dated December 14, 2001, and recorded in the Office of the Recorder of
Cumberland County on December 18, 2001 at Deed Book Volume 249, Page 3291, granted and
conveyed unto Angela T. Pearl, married.
GRENEN & BIRSIC, P.C.
By:
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-668 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC s/b/m/t CHASE
MANHATTAN MORTGAGE CORPORATION, Plaintiff (s)
From ANGELA L. PEARL a/k/a ANGELA T. PEARL
(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 $100,673.12 L.L. $.50
Interest -- $3,103.98
Atty's Comm % Due Prothy $2.00
Atty Paid $156.00 Other Costs
Plaintiff Paid
Date: 4/14/09
41
Curtis R. L Arothon , r y
(Seal) By:
Deputy
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC PC
ONE GATEWAY CENTER, NINTH FLOOR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991