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HomeMy WebLinkAbout09-1891IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CHASE HOME FINANCE LLC, s/b/m/t Chase _ Manhattan Mortgage Corporation, ?v L L ?? NO.: Plaintiff, `i Vs. LINARDI GOLIW, FRANCISCA HERMAWAN, a/k/a FRANCISCA HERMANWAN, andor current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 TYPE OF PLEADING CIVIL ACTION-COMPLAINT IN EJECTMENT Defendants. TO DEFENDANTS 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: 401 Kunkle Lane hanicsbur 7050 ATITORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS _HamRden Township (CITY, BORO, TOWNSHIP) (WARD) ATTO EY FOR PLAINTIFF 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 9'h Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. LINARDI GOLIW, FRANCISCA HERMAWAN, a/k/a FRANCISCA HERMANWAN, andor current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 Defendants. NO.. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service 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, NO.: O q- IM ?1'r'rw VS. LINARDI GOLIW, FRANCISCA HERMAWAN, a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 Defendants. CIVIL ACTION, COMPLAINT IN EJECTMENT Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Ejectment, as follows: 1. Plaintiff is a lending institution duly authorized to conduct business in the Commonwealth of Pennsylvania with a place of business located at 3415 Vision Drive, Columbus, OH 43219 2. The Defendants, Linardi Gouw, Francisca Hermawan, a/k/a Francisca Hermanwan, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 are individuals whose last known address is 401 Kunkle Lane, Mechanicsburg, PA 17050. 3. On or about December 10, 2008, the real property and improvements thereon commonly known as 401 Kunkle Lane, Mechanicsburg, PA 17050 (hereinafter "Premises") were sold to Plaintiff pursuant to the Sheriffs Sale in Cumberland County. A true and correct copy of the Cumberland County Sheriff's deed dated January 12, 2009 and recorded in the Recorder office of Cumberland County, Pennsylvania at Instrument Number 200901281, which contains the legal description of the Premises is marked as Exhibit "A", attached hereto and made a part hereof. 4. At the time of the Sheriff Sale, Defendants were occupying the Premises. 5. Plaintiff, by virtue of said Sheriffs Sale, is the owner of the Premises and therefore right to immediate possession and title to the Premises is in Plaintiff and not in Defendants. 6. On March 2, 2009, counsel for Plaintiff sent written notice to the Defendants to vacate the Premises on or before March 17, 2009. A true and correct copy of said Notices are marked Exhibit "B", attached hereto and made a part hereof. 7. Defendants are unjustly and unlawfully occupying, using and enjoying the Premises without right and to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant(s) for possession of the Premises known as 401 Kunkle Lane, Mechanicsburg, PA 17050, together with such other relief as this Honorable Court may deem necessary. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire PAID. #77991 Attorneys for Plaintiff 9`h Floor, One Gateway Center Pittsburgh, PA 15222 (412) 281.7650 VERIFICATION The undersigned, and duly authorized representative of Plaintiff, 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 in Ejectment are true and correct to the best of his/her information, knowledge and belief. Whitney K. Secretary RECEIVED MAR 0 3 2009 Exhibit A 1 a-8 I e-, 1111iiii Tax Parcel No. 10-22-0527-133 Know all Men by these Presents That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand paid, do hereby grant and convey to Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation Real Estate Sate No. 42 Writ No. 2008-2108 Civil Term Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation VS Linardi Gouw and Francisca Hermawan a/k/a Francisca Hermanwan Attorney Kristine Anthou LEGAL DESCRIPTION ALL that certain lot or tract of land situated in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the eastern side of a proposed fifty (50) foot right-of-way and corner of land now of Elmer A. Brice and Janet A. Brice, his wife; thence along said land of Elmer A. Brice and Janet A. Brice, his wife, North 76 degrees East eighty (80) feet to 1 ands now or formerly of John C. Kunkel; thence South 23 degrees East one hundred eighty-one and five-tenths (181.5) feet to a point at comer of land now of Frank Brice, Sr. and Verna B. Brice, his wife; thence along said land of Frank Brice, Sr. and Verna B. Brice, his wife, South 76 degrees West eighty (80) feet to the Eastern side of a proposed fifty (50) foot right-of-way; thence along said Eastern side of said right-of-way North 23 degrees West one hundred eighty-one and five-tenths (181.5) feet to a point, the place of beginning. KNOWN and numbered as 401 Kunkle Lane, Mechanicsburg, PA 17050. PARCEL No. 10-22-0527-133 BEING the same premises which Jeanne E. Marshall, by deed dated August 15, 2006 and recorded in the Office of the Recorder of Deeds of Cumberland County on August 31, 2006, at Deed Book Volume 276, Page 2107, granted a conveyed unto Linardi Gouw and Francisca Hermawan. The same having been sold by me to the said grantee on the 10th day of December Anno Domini Two Thousand and Eight (2008) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 22nd day of August Anno Domini 2008 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eight (2008) Number 2108 at the suit of Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation against Linardi Gouw and Francisca Hermawan aWa Francisca Hermanwan. In Witness Wereof, I have hereunto affixed my signature this 1 2th day of January Anno Domini Two Thousand and Nine (2009) Commonwealth of Pennsylvania, ss. County of Cumberland R. Thomas Kline, S eriff Before the undersigned, Curtis R. Long, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Arno Domini Witness my hand and seal of said Court, this 12th day of Jan, Two Thousand and Nine (2009) ?c %kit 44 •c A NOTARIAL SEAL PROTHONOTARY, NOTARY RIBLIC ^ 1?LISLE CUMBERLAND COUNTY COUM()"'SE "°Y COMMISSION EXPIRES JANUARY 4, 2> t nce' And post Office address of the 'Within Grantee is 3415 Vision Drive Columbus, OR 43219 7 Solicitor ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1COURTHOUSESQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200901281 Recorded On 1/16/2009 At 8:34:50 AM * Instrument Type - DEED-SHERIFF'S Invoice Number - 35444 User ID - MBL * Grantor - GOUW, LINARDI * Grantee - CHASE HOME FINANCE LLC * Customer - CUMBERLAND COUNTY SHERIFF * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CUMBERLAND VALLEY SCHOOL $0.00 DISTRICT HANPDEN TOWNSHIP $0.00 TOTAL PAID $49.50 * Total Pages - 5 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D DS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 11111111111 Exhibit B GRENEN & BIRSIC R. ATTORNEYS AT LAW ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PENNSYLVANIA 15222 'ILL (412) 281.7650 FAX (412) 281-7657 March 2, 2009 VIA CERTIFIED MAIL. RETURN RECEIPT REQUESTED/ FIRST CLASS MAIL. POSTAGE PREPAID Linardi Gouw or Current Occupant(s) 401 Kunkle Lane Mechanicsburg, PA 17050 RE: NOTICE TO VACATE Dear Linardi Gouw Or Current Occupant(s): As you may be aware, this firm represents Chase Home Finance, LLC in connection with the above-captioned matter. As you may also be aware, Chase purchased the property at a sale conducted by the Sheriff of Cumberland County on December 10, 2008. Accordingly, Chase is now the record title owner of the property. Our client has recently informed me that you remain on this property. The purpose of this letter is to notify you that you must vacate the premises on or before fifteen (15) days from the date of this letter. If you fail to vacate the premises on or before that date, Chase will institute formal legal action to have you removed from the premises. I trust that such will not be necessary. If you have any questions, please feel free to contact me. Very truly yours, ( //// 1?4 D'C_ Kristine M. Anthou KMA/1s GRENEN & BIRSIC, Y.?. ATTORNEYS AT LAW ONE GATEWAY CENTaR, NINTH FLOOR PrmBURm, PENNSYLVANIA 15222 "ILL (412) 281.7650 FAX (412) 281.7657 March 2, 2009 VIA CERTIFIED MAIL. RETURN RECEIPT REQUESTED/ FIRST CLASS MAIL. POSTAGE PREPAID Francisca Hermawan aka Fransisca Hermanwan or Current Occupant(s) 401 Kunkle Lane Mechanicsburg, PA 17050 RE: NOTICE TO VACATE Dear Ms. Hermawan Or Current Occupant(s): As you may be aware, this firm represents Chase Home Finance, LLC in connection with the above-captioned matter. As you may also be aware, Chase purchased the property at a sale conducted by the Sheriff of Cumberland County on December 10, 2008. Accordingly, Chase is now the record title owner of the property. Our client has recently informed me that you remain on this property. The purpose of this letter is to notify you that you must vacate the premises on or before fifteen (15) days from the date of this letter. If you fail to vacate the premises on or before that date, Chase will institute formal legal action to have you removed from the premises. I trust that such will not be necessary. If you have any questions, please feel free to contact me. Very truly yours, , Kristine M. Anthou KMA/ls =F F 0 rq Ir Postage M Cerditd Fee r? O (Endorsement R?eq dra O Restricted Delivery Fes 0 (Endorsement Required) rn :0 Total Postage 6 Fees 3,fre®f Apt NoN_?1_. or PO Box No. } U.S. POSTAL SERVICE CERTIFICATE OF MAILING Aflix tee here in stamps MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT Of e Of PROVIDE FOR INSURANCE-POSTMASTER I , current Received From: E S, Grenen & Birsic. P.C. .` ?G9 One Gateway Center. 9a Floor. Pittsburgh. PA 15222 _ s a One piece of ordinary mail addressed to: 4 ? p? Linardi Gouw 1. or Current Occupant(s) C) ` C 401 Kunkle Lane Mechanicsburg, PA 17050 ?y? `?° 3817, January 2001 rDE AL SERVICE CERTIFICATE OF MAILING iPoc fee here Q.. D FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT m r? R INSURANCE POSTMASTER Curfent 0 U From: W, a `+Z, Grenen & Birsic P.C.?? Rl ' t.7i111rK?. 7p One Gateway Center, 96 Floor Pittsbu PA 1 , C3 tEndors«rwrr? 2. 6 nt One piece of ordinary mail addressed torTom Poe w a Fees 5-; L AN$ ancisca Hermawan aka Fransisca Hermanwan 91 Current Occupant(s) °--h`ys?•= 1 Kunkle Lane or PO 07ur r` +...oL..?-.-.c ...................._ echanicsburg, PA 17050 IAVV Form 3817, January 2001 O C") rv ca F'V cn C, r 1? (on Sheriffs Office of Cumberland County R Thomas Kline ?'to'j' 01 ClUrrbrt,rr? Edward L Schorpp Sheriff ' Solicitor Ronny R Anderson Jody S Smith Chief Deputy rr^ - .hn,fr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/26/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Occupant, 401 Kunkle Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050, but was unable to locate him/her in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Occupant. House is vacant. 03/26/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Linardi Gouw 401 Kunkle Lane, Mechanicsburg, Cumberlanc County, Pennsylvania, 17050, but was unable to locate him in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Linardi Gouw. House is vacant. 03/26/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Fransica Hermawan, 401 Kunkle Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050, but was unable to locate her in his bailiwick he therefore returryS the within Complaint as not found as to the defendant, Fransica Hermawan. House is vacant. SHERIFF COST: $84.00 SO ANSWERS, April 02, 2009 R THOMAS KLINE, SHERIFF Docket NO. 2009-1891 Chase Home Financial LLC v Linardi Gouw F1L?-0F !CE T THE PROTI-=, .'!OTMY 2009 APR - 3 PM 3: 3 7 { 'tlp.+ t? wrVINNTY r' J? tl ?iti yI Fd?J ljY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, CIVIL DIVISON NO.: 09-1891 vs. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants. TYPE OF PLEADING: MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT TO SPECIAL ORDER OF COURT CODE- 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, Nine West 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.: 09-1891 VS. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants. MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation, by and through its attorneys, Grenen & Birsic, P.C., and files the within Motion for Special Service of Civil Action - Complaint in Pursuant to Special Order of Court, under Pennsylvania Rule of Civil Procedure 430 as follows: 1. On March 25, 2009, Plaintiff filed a Civil Action, Complaint in Ejectment against the Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, and/or current tenants of 401 Kunkle Lane, Mechanicsburg, PA 17050, at the above term and number. 2. On or about March 25, 2009, Plaintiff delivered to the Sheriff of Cumberland County a copy of the Civil Action, Complaint in Ejectment, with instructions that it be served upon Defendant at the last known address being 401 Kunkle Lane, Mechanicsburg, PA 17050. 3. On or about April 2, 2009, the Sheriff of Cumberland County notified Plaintiff that they were unable to serve Defendants at 401 Kunkle Land, Mechanicsburg, PA 17050, with a copy of the Complaint since the house appeared vacant. A true and correct copy of the Sheriff s return is marked Exhibit "A", attached hereto and made a part hereof. 4. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, is marked Exhibit "B", attached hereto and made a part hereof. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Sheriff of Cumberland County to post a copy of the Complaint on the property at 401 Kunkle Land, Mechanicsburg, PA 17050, and permit the Plaintiff to serve the Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, and/or current tenants of 401 Kunkle Lane, Mechanicsburg, PA 17050, by mailing a true and correct copy of the Complaint by certified mail, return receipt requested and by first class mail, postage pre-paid to 401 Kunkle Land, Mechanicsburg, PA 17050. Service of the Complaint shall be deemed complete and valid upon posting and mailing by the Plaintiff. GRENEN & BIRSIC, P.C. BY. t?a Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT "A" Sheriffs Office of Cumberland County R Thomas Kline L 0111'r of clunb"1"14# Edward L Schorpp Sheri jSolicitor Ronny R Anderson Jody S Smith Chief Deputy QFFicE OF -HE `14ERiFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/2612009 R. Thomas Kline, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant to wit: Occupant, 401 Kunkle Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050, but was unable to locate him/her in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Occupant. House is vacant. 03/26/2009 R. Thomas Kline, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant to wit: Linardi Gouw 401 Kunkle Lane, Mechanicsburg, Cumbedanc County, Pennsylvania, 17050, but was unable to locate him in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Linardi Gouw. House is vacant. 03/26/2009 R. Thomas Kline, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant to wit: Fransica Hermawan, 401 Kunkle Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050, but was unable to locate her in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Fransica Hermawan. House is vacant. SHERIFF COST: $84.00 SO ANSWERS, April 02, 2009 R THOMAS KLINE, SHERIFF Docket NO. 2009-1891 Chase Home Financial LLC v Linardi Gouw EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants. NO.: 09-1891 AFFIDAVIT PURSUANT TO PA. R.C.P. 430 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, of GRENEN & BIRSIC, P.C., attorneys for Plaintiff, deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, named in the above-captioned matter: 1. On or about May 11, 2009, Plaintiff mailed to the United States Postmaster at Mechanicsburg, Pennsylvania 17050, a certain Request for Change of Address or Boxholder Information Needed for Service of Legal Process for the Defendants. 2. On or about May 18, 2009, Plaintiff received a response from the aforementioned United States Postmaster stating that there is a change of address order on file and that mail is deliverable at PO Box 696, New Cumberland, PA 17070. A true and correct copy of said response is marked Attachment "1 ", attached hereto and made a part hereof. 3. Examinations were made using a nationwide computer database; said examination failed to yield any useful information regarding the whereabouts of the Defendants. 4. The Defendant is not listed in the Hampden Township Area telephone directory. 5. A search of the Cumberland County Voter Registration records revealed that Defendant is not registered to vote in Cumberland County. 6. The Plaintiff sent a local agent to 401 Kunkle Lane, Mechanicsburg, PA 17050, and said agent was able to confirm that the premises is still occupied. Finally, affidavit deposes and says that the last known physical address of the Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, is 401 Kunkle Lane, Mechanicsburg, PA 17050. Kristine M. Anthou, Esquire SWORN TO AND SUBSCRIBED BEFORE me this day of 40,t? , 2009. Notary Public COMMONWE&TH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Public City of Pittabwo, Allegheny County My Commission Expires June 2, 2011 Member, Pennsylvania Association of Notaries Attachment "1" 49 Date April 23, 2009 Postmaster Mechanicsburg, PA 17050 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) for the following: Name: Linardi Gouw Address: 401 Kunkle Lane NOTE: The name and last known address are required for change of address information. The name, if known. and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii).There is no lee for providing boxholder infon-nation. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute):____-_ 3. The names of all known parties to the litigation: Chase Home Finance LLC, et al. vs. Gouw and Hermawan 4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5. The docket or other identifying number if one has been issued: 2009-1891 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING 1'111.: SUI3NIISSION OF FAl-SI: INFORMATION 10 OB"CAIN AND USI: CI1 ANGF OF ADDRESS INFORMATION OR BOXHOLDLR INFORMATION FOR ANN' PURPOSE OTHER IIIAN "fill: SERVICE OF 1.1:GAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGA HON COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINF. OF UP TO $10,000 OR IMPRISONMLNT OR (2) TO AVOID PAYMENT OF THE. FEE FOR CIIANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BO-1-1 I (TTTLL 18 U.S.C SECTION 1001). 1 certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. r? Signs ure Laura DellAntonio Printed Name Grenen & Birsic, P.C., One Gateway Center, Ninth Floor, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE: USE ONLY No change of address order on the Not known at address liven. _ Moved, left no forwarding address No such address 0-STMARK NT:1h''?I t , tom 13OXIIOLDER'S NAME d S t Rl_ -A ADDRESS ?. G Gay tM?-'10 r1Q._C_L_ - -- _ Q f`Y ..070-7 p Postmaster Mechanicsburg, PA 17050 Date April 23, 2009 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) firr the following: '.dame: Fransica flermawan Address: 401 Kunkle lane NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). "There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se niust cite statute):- 3. The names of all known parties to the litigation: Chase Home Finance LLC, et al. vs. Gouw and Hermawan 4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5. The docket or other identifying number if one has been issued: 2009-1891 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING 11IE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USF CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SI:RVIC E OF LEGAL PROCESS IN CONNECTION WITH ACTUAL. OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF U)' TO $10,000"OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Signature Laura DellAnlonio Printed Name Grenen & Birsic, P.C., One Gateway Center, Ninth Floor, Pittsburgh, PA 15222 (412) 281-7650 FOR POSE OF1ICf: USf: ONLY change of address order on tile. ______Not known at address given. -_-Moved, left no forwarding address No such address POSTMARK NEW ADDRESS OR BOXHOLDER'S NAIL an S`4EG ? lXet??S t"7w-7 ,,, CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of Complaint in Ejectment Pursuant to Special Order of Court was. mailed to the following on this day of APA 2009, by first class U.S. Mail, postage pre-paid: Linardi Gouw 401 Kunkle Land Mechanicsburg, PA 17050 Francisca Hermawan a/k/a Francisca Hermanwan 401 Kunkle Lane Mechanicsburg, PA 17050 Current Tenants 401 Kunkle Lane Mechanicsburg, PA 17050 GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Nine West Pittsburgh, PA 15222 (412) 281-7650 2003 VAY 2 Al,', i i : 2 u} t,+U tic' l Y 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. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants NO.: 09-1891 ISSUE NUMBER: TYPE OF PLEADING: AMENDMENT TO MOTION FOR SERVICE OF COMPLAINT IN EJECTMENT TO SPECIAL ORDER OF COURT CODE- 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 Nine West 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, CIVIL DIVISION a9• t?°t1 NO. vs. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants AMENDMENT TO MOTION TO OPEN SHERIFF'S SALE Plaintiff, Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys, GRENEN & BIRSIC, P.C., and files the within Amendment To Motion for Service of Complaint in Ejectment to Special Order of Court as follows: On or about March 25, 2009, Plaintiff filed a Complaint in Ejectment. 2. The Sheriff has attempted to serve the Defendants, but has been unsuccessful. 3. Plaintiff is filing a Motion for Service of Complaint in Ejectment to Special Order to post the notice of Complaint filing at the Defendants' Premises located at 401 Kinkle Lane, Mechanicsburg, PA 17050. 4. Pursuant to Cumberland County Local Rule 208.3(a)(2), no Judge has ruled upon any other issue in this case or any related matter. 5. Pursuant to Cumberland County Local Rule 208.3(a)(9), the Defendants are pro se and no attorney has entered an appearance of record on behalf of the Defendants. WHEREFORE, Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation, respectfully requests that the Motion for Service of Complaint in Ejectment to Special Order is approved by the Court so the Plaintiff may post notice of the Complaint in Ejectment at 401 Kinkle Lane, Mechanicsburg, PA 17050. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Pa. ID #77991 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 Chase CIVIL DIVISION Manhattan Mortgage Corporation, Plaintiff, NO.: 07-1572 VS. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Amendment to Motion for Service of Complaint in Ejectment to Special Order was mailed to the following on this 'lZ day of by first class mail postage prepaid on the following: Linardi Gouw 401 Kunkle Land Mechanicsburg, PA 17050 Francisca Hermawan a/k/a Francisca Hermanwan 401 Kunkle Lane Mechanicsburg, PA 17050 Current Tenants 401 Kunkle Lane Mechanicsburg, PA 17050 GRENEN & BIRSIC, P.C. BY: ?.(xzLe Kristine M. Anthou, Esquire PA ID #77991 Attorneys for Plaintiff One Gateway Center, 9`h Floor Pittsburgh, PA 15222 (412) 281-7650 Ff4 !, OF THE u IV MAY 2 2 2009+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE HOME FINANCE LLC s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 09-1891 vs. LINDARDI GOUW, FRANCISCA HERMAWAN a/k/a FRANCISCA HERMANWAN, and/or current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050, Defendants. COURT AND NOW, to wit, this a I Aday of upon consideration of the within Motion for Special Service of the Complaint in Ejectment Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff is hereby directed to serve Defendants, Linardi Gouw, Francisca Hermawan a/k/a Francisca Hermanwan, and/or current tenants of 401 Kunkle Lane, Mechanicsburg, PA 17050, with a true and correct copy of Plaintiffs Complaint, by causing Cumberland County to post the real property, being 401 Kunkle Land, Mechanicsburg, PA 17050, and Plaintiff is permitted to serve the Defendants, by certified mail, return receipt requested and by first class mail, postage pre-paid at 401 Kunkle Land, Mechanicsburg, PA 17050. Service on the Defendant shall be deemed complete and valid upon such posting and mailing by the Plaintiff. Ivo 40gol ` O Z9 pM 1 2? oml?ll 6,?, -0 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. LINARDI GOUW, FRANCISCA HERMAWAN, a/k/a FRANCISCA HERMANWAN, andor current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 Defendants. NO.: 09-1891 TYPE OF PLEADING Praecipe to Reinstate Civil Action - Complaint in Ejectment FILED ON BEHALF OF PLAINTIFF: Chase Home Fniance LLC s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, vs. LINARDI GOUW, FRANCISCA HERMAWAN, a/k/a FRANCISCA HERMANWAN, andor current tenants at 401 Kunkle Lane, Mechanicsburg, PA 17050 Defendants. NO.: 09-1891 PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN EJECTMENT TO:PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Ejectment with respect to the above- referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: Kristirie M. Anthou, Esquire Attorneys for Plaintiff OS _ , '7L!Y TH= T/t 2009 JUL i 0 ' 2:149 410.00 PO ATTI i ? y - , - I tocc09 e aa7 8ss