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HomeMy WebLinkAbout09-1295Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 ?Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 195431 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff V. WILLIAM E. BARRICK, JR. ARLENE F. BARRICK 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM CI ?i l NO. ay- la 9? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 195431 NOTICE You have been sued in Court. If you wish to defend against the claims 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. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 195431 1. Plaintiff is CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: WILLIAM E. BARRICK, JR. ARLENE F. BARRICK 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 03/12/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book No. 1801, Page 4069. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 195431 6 7. 8. The following amounts are due on the mortgage: Principal Balance $76,715.70 Interest $2,550.99 08/01/2008 through 02/27/2009 (Per Diem $12.09) Attorney's Fees $1,300.00 Cumulative Late Charges $172.72 03/12/2003 to 02/27/2009 'Cost of Suit and Title Search 750.00 Subtotal $81,489.41 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $81,489.41 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 195431 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $81,489.41, together with interest from 02/27/2009 at the rate of $12.09 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: 016?? La ce T. Phelan, squire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire f Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Attorneys for Plaintiff File #: 195431 LEGAL DESCRIPTION ALL THAT CERTAIN plot of ground situate on the east side of the Salem Church Road in the Township of Hampden, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the center line of the public road known as Salem Church Road, said point being located fifty-three and five-tenths (53.5) feet measured northwardly along said center line from the northerly line of land of the United States Government and being also fourteen hundred sixteen and ninety-five one-hundredths (1416.95) feet measured northwardly along said center line from the northerly line of land now or formerly of Jacob S. Rupp; thence north two (2) degrees fifty-four (54) minutes east along said center line of one hundred (100) feet to a point; thence south sixty-five (65) degrees twenty-four (24) minutes east along line of lands now or formerly of Steward E. Myers, five hundred (500) feet to a point on the westerly line of a fifty (50) foot right-of-way; thence south two hundred (2) degrees fifty-four (54) minutes west along said right of way, one hundred (100) feet to a point; thence north sixty-five (65) degrees twenty- four (24) minutes west along the northerly line of another fifty (50) foot right-of-way, five hundred (500) feet to a point in the center line of the Salem Church Road, the place of BEGINNING. The above described lands are sold and conveyed subject to the following reservations and restrictions which shall run with the land and be binding upon the parties, their heirs and assigns: File #: 195431 1. No dwelling shall be erected upon the lot hereby conveyed which shall cost less than $4,000.00 over and above the cost of excavation and foundation. 2. No second hand materials shall be used in the construction of any building to be erected on said lot which shall be exposed to the weather, and no asbestos slate surfacing or composition of any dwelling except for roof covering. 3. No building of any kind shall be erected on the lot hereby conveyed within sixty feet from the center line of the Salem Church Road, nor within sixty feet from the center line of the said fifty foot right-of-way, lying to the east of the property above described. 4. No chicken house or hog, pen or other building except the dwelling and private garage not to exceed two-car capacity, shall be erected within 150 feet from the center line of this aid public road and said fifty foot right-of-way lying to the east of the property herein conveyed. 5. No merchandising or selling of manufacturing of any commodity shall be conducted upon said lot. 6. No building shall be erected within ten feet of any adjoining property line. Parcel No. 10-20-1838-012 PROPERTY BEING: 116 SALEM CHURCH ROAD File #: 195431 VERIFICATION I hereby state that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: a a1 t g1 b1 A rney for Plainti File #: 195431 0 C'a't r? b. gig CD r c? ..._ ?? m Sheriffs Office of Cumberland County R Thomas Kline Map of caprbt Edward L Schorpp Sheri 4t# Solicitor Ronny R Anderson *k$- Jody S Smith Chief Deputy OF" OF THE SKRI" Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/09/2009 10:13 AM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2009 at 1013 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William E. Barrick, Jr. by making known unto David Hetzel person in charge, at 116 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/09/2009 10:13 AM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2009 at 1013 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Arlene F. Barrick by making known unto David Hetzel person in charge, at 116 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST`. $53.90 (PAID) SO ANSWERS, March 18, 2009 2009-1295 Chase Home Finance LLC VS William E. Barrick, Jr. R THOMAS KLINE, SHERIFF By? Deputy Sheriff ca co PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. CIVIL-09-1295 CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: Francis S. Hallinan, Esquire Date: 4/3/09 PHS #: 195431 I VERIFICATION Whitney K. Cook hereby states that he/she is Assistant Secretary of CHASE HOME FINANCE LLC, servicing agent for Plaintiff, CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: DATE: 4 Title: *ant Secretary Company: CHASE HOME FINANCE LLC Loan: 1764019048 File #: 195431 RECEIVED 0 2 ZZ PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. CIVIL-09-1295 : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a strue and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: WILLIAM E. BARRICK, JR 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 ARLENE F. BARRICK 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: a Francis S. Hallinan, Esquire Date: 4/3/09 FIL --GF'ICE OF THE PROT;HI)NDTARY 2009 APR -6 AM 11= 5 6 )Uwy PE NI64 VANIA Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION VS. WILLIAM E. BARRICK, JR ARLENE F. BARRICK 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. CIVIL-09-1295 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against WILLIAM E. BARRICK, JR, and ARLENE F. BARRICK, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $81,489.41 Interest - 02/28/2009 to 04/20/2009 $628.68 TOTAL $82,118.09 I hereby certify that (1) the addresses of the Defendant(s) are as shown above. and (2) that notice has been given in accordance with Rule 237.1, co atta hed. i 0J /? Daniel G. Schmieg, E Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. .7? DATE: PHS # 195431 PRO PROTHY Phelan Hallinan & Schmieg, LLP By: Daniel G. Schmieg, Esquire Identification No. 62205 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION VS. WILLIAM E. BARRICK, JR ARLENE F. BARRICK : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. CIVIL-09-1295 VERIFICATION OF NON-MILITARY SERVICE Daniel G. Schmieg, Esquire, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant WILLIAM E. BARRICK, JR is over 18 years of age and resides at 116 SALEM CHURCH ROAD, MECHANICSBURG, PA 17050-2834. (c) that defendant ARLENE F. BARRICK is over 18 years of age and resides at 116 SALEM CHURCH ROAD, MECHANICSBURG, PA 17050-2834. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /'1 -11 Daniel G. Schriiieg, E Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised CHASE HOME FINANCE LLC, SB/M TO CUMBERLAND COUNTY CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS VS. : CIVIL DIVISION WILLIAM E. BARRICK, JR ARLENE F. BARRICK No. CIVIL-09-1295 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 Notice is given that a Judgment in the above captioned matter has been entered against you on By: LlE- If you have any questions concerning this Darnel G. Schmieg, Ese Attorney or Party Filin 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY" PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 (215_) 563-7000 CHASE HOME FINANCE LLC, S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISON Plaintiff NO. CIVIL-09-1295 v CUMBERLAND COUNTY WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendants TO: WILLIAM E. BARRICK, JR IPA, 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 6 DATE OF NOTICE: April 7, 2009 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE` USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 (10) 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 or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 AROLINE V. Q O Legal Assistant PHS # 195431 PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISON Plaintiff NO. CIVIL-09-1295 v CUMBERLAND COUNTY WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendant(s) C C TO: ARLENE F. BARRICK p r 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 DATE OF NOTICE: April 7, 2009 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 (10) 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 or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 t ROLINE V. INO Legal Assistant PHS # 195431 PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE HOME FINANCE LLC, S/BJM TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISON Plaintiff v WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendant(s) TO: ARLENE F. BARRICK 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 DATE OF NOTICE: March 31, 2009 fi?,?c0 r Pj THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 (10) 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 or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 NO. CIVIL-09-1295 CUMBERLAND COUNTY Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 CAROLINE V. CINQ O Legal Assistant PHS # 195431 PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff V. WILLIAM E. BARRICK, JR ARLENE F. BARRICK Defendant(s) TO: WILLIAM E. BARRICK, JR 116 SALEM CHURCH ROAD MECHANICSBURG, PA 17050-2834 DATE OF NOTICE: March 31, 2009 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISON NO. CIVIL-09-1295 CUMBERLAND COUNTY lie CApy THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 (10) 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 or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 CAROLINE V. CIN O Legal Assistant PHS 4 195431 FILE') # D LE firs 1 f 'j.lll*tC,,,Tif:i 1< -+ i 20H APR 22 A, 1 11' 3 + 1 o ? Jy.vb ?' ??.f7 cki+ o6 o