HomeMy WebLinkAbout09-2040IN 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.
KELVIN R. JONES and
BRENDA D. JONES,
Defendant.
NO.: QQ- No4o CIV???CI"Ill
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
1AWY FOR PLAINTIFF
1 HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANT IS:
175 West North Street
Carlisle, PA 17013
ATTO Y FOR PLAINTIF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
175 West North Street
Carlisle Borough
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
(CITY, BORO, TOWNSHIP) (WARD)
ATTO REY FOR PLAINTIFF
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..
KELVIN R. JONES and
BRENDA D. JONES,
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,
NO.: O9- 20gdf'
Plaintiff,
VS.
KELVIN R. JONES and
BRENDA D. JONES,
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 Defendants, Kelvin R. Jones and Brenda D. Jones, are an individuals whose
last known address is 175 W. North Street, Carlisle, Pennsylvania 17013.
3. On or about July 31, 2003, Defendants executed a Note in favor of Plaintiff in the
original principal amount of $61,588.00. A true and correct copy of said Note is marked Exhibit
"A," attached hereto and made a part hereof.
4. On or about July 31, 2003, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $61,588.00 on the premises hereinafter described, said Mortgage being recorded in the Office
of the Recorder of Deeds of Cumberland County on August 5, 2003, at Mortgage Book Volume
1827, Page 4693. A true and correct copy of said Mortgage containing a description of the
premises subject to said Mortgage is marked Exhibit "B," attached hereto and made a part hereof.
5. Defendants made, executed and delivered to Plaintiff a Loan Modification
Agreement, amending the fixed interest rate of said Note and Mortgage. Said Agreement was
recorded in the Office of the Recorder of Deeds of Cumberland County on January 25, 2007, at
Mortgage Book Volume 733, Page 4310, and then Re-recorded on October 15, 2007 in
Document Number 200738580.
6. Defendants are the record and real owners of the aforesaid mortgaged premises.
7. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the September 1, 2008 payment.
8. On or about January 3, 2009, Defendants were mailed a combined Act 91 and Act
6 Notice, via certified mail, return receipt requested, and by first class mail, in compliance with
the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41
P.S. '101, et seq.
9. The amount due and owing Plaintiff by Defendant is as follows:
Principal $65,357.13
Interest to 03/11/09 $ 2,196.55
Late Charges to 03/11/09 $ 381.01
Escrow Deficiency to 03/11/09 $ 0.00
Corporate Advances $ 155.00
Attorney's fees $ 1,300.00
Unapplied Funds -($ 499.65)
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $71,390.04
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $71,390.04 with interest thereon at the rate of $9.85 per diem from March 11, 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:
Kris ine M. Anthou, 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"
17906014
1179060146
ORIGINAL
NOTE
175 W NORTH ST, CARLISLE, PA 17013
Q___
FHA Case No.
4417317119703
July 31 , 2003 0.m
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns, "Lender" means
CHASE MANHATTAN MORTGAGE CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
Sixty-One Thoutiand, Five Hundred Eighty-Eight and 00/100
Dollars (U.S. $ 61, 588.00 ), plus interest, to the order of Lender. Interest will be charged on
unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of
Five and One-Half
percent ( 5.500 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as
this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which might result if
Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
September 1, 2003 . Any principal and interest remaining on the first day of
August, 2033 , will be due on that date, which is called the maturity date.
(B) Place
Payment shall be made at 200 OLD WILSON BRIDGE RD
COLUMBUS, OH 43085
or at such other place as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 349.69
Three Hundred Forty-Nine and 69/100
This amount will be part of a larger monthly paymmnt required by the Security Instrument, that shall be applied to principal,
interest and other items in the order described in the Security instrument.
(D) Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge
shall be incorporated into and shall amend and supplement the covenants of this Note as if the a)longe were a part of this Note.
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first
day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a
partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing
to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(c) of this
Note by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of
4$
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the
Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued
interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many
circumstances regulations issued by the Secretary will limit Lender's right to require immediate payment in full in the case of payment
defaults. This Note does not authorize acceleration when no permitted by HUD regulations. As used in this Note, "Secretary" means
the Secretary of Housing and Urban Development or his or her designee.
FHA MULTISTATE FIXED RATE NOTE
C-7302 (I Ift Page I of 2 (Replaces 1/96) }t ,
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above; Lender may require Borrower to pay costs and expenses
including reasonable and customary attorney's fees for enforcing this Note to the extent not prohibited by applicable law. Such
fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require
Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by
delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has
given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in
Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed, Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser
of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against
each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the
amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
KE VI R JONES BRENDA D JONES
WAIPA 0- %01
FHA MULTISTATE FIXED RATE NOTE
C-7302 (11t9o) Page 2 o(2 (Reptacen 1/90)
EXHIBIT "B"
ORIGINAL
State of Pennsylvania MORTGAGE
Record and Return to:
CHASE MANHATTAN MORTGAGE CORPORATION
1500 N 19TH STREET
MONROE LA 71201
ATTENTION: FINAL CERTIFICATIONS
THIS MORTGAGE ("Security Instrument") is given on
The Mortgagor is
KELVIN R JONES,
BRENDA D JONES, HUSBAND & WIFE
whose address is
175 W NORTH ST, CARLISLE, PA 17013
Instrument is given to
CHASE MANHATTAN MORTGAGE CORPORATION
T P. s
`??R or aEFo?
"?-RLAND COUNTY-P,',
'03 RUG 5 Phi 1 58
FHA Caw No.
4417317119703
X 17906014
1179060146
,("Borrower"). This Security
which is organized and existing under the laws of the State of New Jersey
and whose address is 343 THORNALL ST
EDISON, NJ 08837 ,("Lender"). Borrower owes Lender the
principal sum of
Sixty-One Thousand, Five Hundred Eighty-Eight and 00/100
Dollars (U.S. $ 61, 588.00 ). This debt is evidenced by Borrower's Note dated the same
date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid
earlier, due and payable on August 1, 2033
This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest,
and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest,
advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of
Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does
hereby mortgage, grant and convey to Lender, the following described property located in
CUMBERLAND County, Pennsylvania:
PENNSYLVANIA FHA MORTGAGE
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July 31, 2003
BKI827PG4693
See Attached Legal Description
which has the address of
175 W NORTH ST, CARLISLE, PA 17013
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property..
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances
of record. Borrower warrants and will defend generally the title to the Property against all claims and demands,
subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with
limited variations by jurisdiction to constitute a uniform security instrument covering real property.
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS:
1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and
interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Taxes, Insurance, and Other Charges. Borrower shall include in each monthly
payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes
and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the
Property, and (c) premiums for insurance required under Paragraph 4. In any year in which the Lender must pay
a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year
in which such premium would have been required if Lender still held the Security Instrument, each monthly
payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the
Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by
the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the
Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds".
Lender rnay, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed
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the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement
Procedures Act of 1974, 12 U.S.C. § 2601 et seg. and implementing regulations, 24 CFR Part 3500, as they may
be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated
disbursements or disbursements before the Borrower's payments are available in the account may not be based on
amounts due for the mortgage insurance premium.
If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA,
Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by
Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and
require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If
Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance
remaining for all installment items (a), (b) and (c) and any mortgage insurance premium installment that Lender has
not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower.
Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be
credited with any balance remaining for all installments for items (a), (b) and (c).
3. Application of Payments. All payments under Paragraphs 1 and 2 shall be applied by Lender as
follows:
First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge
by the Secretary instead of the monthly mortgage insurance premium;
Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other
hazard insurance premiums, as required;
Third, to interest due under the Note;
Fourth, to amortization of the principal of the Note; and,
Fifth, to late charges due under the Note.
4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property,
whether now in existence or subsequently erected, against any hazirds, casualties and contingencies, including fire,
for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that
Lender requires. Borrower shall also insure all improvementsion the Property, whether now in existence or
subsequently erected, against loss by floods to the extent requirediby the Secretary. All insurance shall be carried
with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall
include loss payable clauses in favor of, and in a form acceptable to, Lender.
In the event of loss. Borrower shall give Lender immediate notice by mail. Lender may make proof of
loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to
make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of
the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under
the Note and this Security Instrument, first to any delinquent amounts applied in the order in Paragraph 3, and then
to prepayment of principal, or (b) to the restoration or repair of the damaged property. Any application of the
proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to
in Paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required
to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally
entitled thereto.
In the event of foreclosure of this Security Instrument or other transfer of title to the Property that
extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass
to the purchaser.
S. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or
PENNSYLVANIA FHA MORTGAGE
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BK 1827PG4695
transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least
one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for
Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify
Lenders of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially
change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect
the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action
to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during
the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to
provide Lender with any material information) in connection with the loan evidenced by the Note, including, but
not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this
Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires
fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in
writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or other taking of any part of the Property, or for conveyance in place of
condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness
that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction
of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order
provided in Paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall
not extend or postpone the due date of the monthly payments, which are referred to in Paragraph 2, or change the
amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under
the Note and this Security Instrument shall be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's'Rights in the Property. Borrower shall pay all
governmental or municipal charges, fines and impositions that are not included in Paragraph 2. Borrower shall pay
these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect
Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts
evidencing these payments.
If Borrower fails to make these payments or the payments required by Paragraph 2, or fails to perform any
other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may
significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to
enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property
and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in
Paragraph 2.
Any amounts disbursed by Lender under this Paragraph shall become an additional debt of Borrower and
be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note
rate, and at the option of the Lender, shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which
in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien
an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that
any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may
give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set
forth above within 10 days of the giving of notice.
& Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceleration of Debt.
(a) Default. Lender may, except as limited by regulations issued by the Secretary in the case of
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payment defaults, require immediate payment in full of all sums secured by this Security
Instrument if:
(i) Borrower defaults by failing to pay in full any monthly payment required by this
Security Instrument prior to or on the due date of the next monthly payment, or
(ii) Borrower defaults by failing, for a period of thirty days, to perform any other
obligations contained in this Security Instrument.
(b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including
section 341(d) of the Garn-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 j-3(d))
and with the prior approval of the Secretary, require immediate payment in full of all sums
secured by this Security Instrument if:
(i) All or part of the Property, or a beneficial interest in a trust owning all or part of the
Property, is sold or otherwise transferred (other than by devise or descent), and
(ii) The property is not occupied by the purchaser or grantee as his or her principal
residence, or the purchaser or grantee does so occupy the Property, but his or her credit
has not been approved in accordance with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate payment
in full, but Lender does not require such payments, Lender does not waive its rights with respect
to subsequent events.
(d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary
will limit Lender's rights in the case of payment defaults to require immediate payment in full and
foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if
not permitted by regulations of the Secretary.
(e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under the National Housing Act within 60 days from the
date hereof, Lender may, at its option require immediate payment in full of all sums secured by
this Security Instrument. A written statement of any authorized agent of the Secretary dated
subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the
Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this
option may not be exercised by Lender when the unavailability of insurance is solely due to
Lender's failure to remit a mortgage insurance premium to the Secretary.
10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in
full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right
applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender
in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations
of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorney's fees and
expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security
Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment
in full. However, Lender is not required to permit reinstatement if. (i) Lender has accepted reinstatement after the
commencement of foreclosure proceedings within two years immediately preceding the commencement of a current
foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii)
reinstatement will adversely affect the priority of the lien created by this Security Instrument.
11. Borrower not Released; Forbearance by Lender not a Waiver. Extension of the time of payment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor
in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor
in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to
extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason
of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender
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in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,
subject to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any
Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security
Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this
Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c)
agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with
regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering
it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be
directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to
Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by
notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to
Borrower or Lender when given as provided in this Paragraph.
14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the
law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security
Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security
Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of
this Security Instrument and the Note are declared to be severable.
15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or
release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do,
anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall
not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are
generally recognized to be appropriate to normal residential uses and to maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other
action by any governmental or regulatory agency or private party involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by
any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances
affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with
Environmental Law.
As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous
substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde,
and radioactive materials. As used the paragraph 16, "Environmental Law" means federal laws and laws of the
jurisdiction where the Property is located that relate to health, safety or environmental protection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and
revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and
hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to
Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument,
Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and
Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security
only.
PENNSYLVANIA FHA MORTGAGE
C-3701 (1/02) (Replaces 6/00) PAGE 6 OF 8
8KI827PG4698
If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower
as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall
be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all
rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act that
would prevent Lender from exercising its rights under this Paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property before or after giving
notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is
a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of
Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument
is paid in full.
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9,
Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all
expenses incurred In pursuing the remedies provided in this paragraph 18, including, but not limited to,
attorneys' fees and costs of title evidence to the extent permitted by applicable law,
If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires
immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale
provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 etas .) by
requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the
Property as provided In the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights
otherwise available to a Lender under this Paragraph 18 or applicable law.
19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence. Lender shall discharge and satisfy
this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs.
20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future
laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead
exemption.
21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one
hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note.
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded
together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were
a part of this Security Instrument.
The following riders are attached:
NO RIDERS ATTACHED
PENNSYLVANIA FHA MORTGAGE
C-3701 (1/02) (Replaces 6/00) PAGE 7 OF 8
OK 1827PG4699
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument
and in any rider(s) executed by Borrower and recorded with it.
The Borrower certifies that a true copy of the mortgage has b received.
'tp
KELVIN R JONES BRENDA D JONES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF C V Mbek CV1\ Jl
ss:
On this 31st day of July, 2003
before me, the
subscriber, a Notary Public in and for the Commonwealth of Pennsylvania, residing in
came the above-named subscriber(s),
KELVIN R JONES,
BRENDA D JONES, HUSBAND & WIFE
and acknowledged the within indenture of Mortgage to be their act and deed, and desired the same to be recorded
as such. WITNESS my hand and seal, the day and year aforesai .
NOTARIAL SEAL y co si expires
Kathy L. Mummert, Notary Public
Borough of Carlisle, Cumberland Co., PA
My Commission Expires Aug. 11, 2003
??
PENNSYLVANIA FHA MORTGAGE
3701
C
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BK 1827PG4700
• , Y
Legal Description
ALL THAT CERTAIN tract of land with the improvements thereon erected
situated in the Fourth Ward of the Borough of Carlisle, Cumberland County,
Pennsylvania, as shown on a property survey plan for Carlisle Housing Opportunities
Corporation dated July 28, 2003, prepared by Larry V. Neidlinger P.E.R.S., of Carlisle,
Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173
and 175 W North Street; thence along West North Street, North 83 degrees 59 minutes
00 seconds West 22.04 feet to a point; thence by North West Street, North 06 degrees
10 minutes 00 seconds East 125.28 feet to an iron pin set; thence by land now or
formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet
to an iron pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to
an iron pin; thence by dividing line between173 and 175 W North Street, North 83
degrees 59 minutes 00 seconds West 18.03 feet to an iron pin; thence by the same
South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
CONTAINING 0.0791 acres or 3,446.44 square feet.
I Certify this to be recorded
In Cumberland County PA
u, III
?-? r ^-A ^r of Deeds
8KI827PG470
?M`'-'<0 A
VERIFICATION
Whitney K. Cook Assistant Secretary, and duly authorized representative of Chase
Llome 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 Mmihq?ttan Mortgage Corporation
Whitney K. gOfik- Assistant Secretary
?s1
OF T29 ApR _ l 12.36
,?118.50 PQ ATV
co tvlq Q 1
e olasolo7
Sheriffs Office of Cumberland County
R Thomas Kline i'OS M, at G10 rr/, Edward L Schorpp
Sheriffs Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFF CE c c T s?'ERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/14/2009 08:55 AM - Timothy Black, Deputy Sheriff, who being duly swom according to law states that on April 14,
2009 at 0855 hours, he served a true copy of the within Complaint in Mortgage F reclosure upon the
within named defendant, to wit: Brenda D. Jones by making known unto Kelvin R. Jones, husband of
defendant, at 175 W. North Street, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at
the same time handing to him personally the said true and correct copy of the sa e.
04/14/2009 08:55 AM - Timothy Black, Deputy Sheriff, who being duly swom according to la , states that on April 14,
2009 at 0855 hours, he served a true copy of the within Complaint in Mortgage F reclosure upon the
within named defendant, to wit: Kelvin R. Jones by making known unto Kelvin R. ones personally, at 175
W. North Street, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $48.92
April 14, 2009
SO ANSWER ,
R THOMAS K INE, SHERIFF
Docket No. 2009-2040
Chase Home Finance v Brenda Jones
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
I hereby certify that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
NO.: 09-2040-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
the last known address of
Defendants is:
175 West North Street
Carlisle, PA 17013
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
GRENEN & BIRSIC, P.C.
Atto eys for Plaintiff
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.
KELVIN R. JONES and
BRENDA 1). JONES,
Defendants.
NO.: 09-2040-Civil
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Kelvin R. Jones and Brenda D. Jones, in the amount of $72,649.99, which is
itemized as follows:
Principal $65,357.13
Interest to 5/20/09 $ 2,883.10
Late Charges to 5/20/09 $ 454.30
Escrow Deficiency to 5/20/09 $ 448.94
Corporate Advances $ 206.17
Unapplied Funds ($ 499.65)
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $72,649.99
with interest on the principal sum at the rate of $9.85 per diem (as may change from time to time
in accordance with the terms of the Note) from May 20, 2009, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
B `?&?
Kristine M. Anthou, Esquire
Attorney for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants were not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copies.
Sworn to and subscribed before me
this 2IS+ day of 2009.
?C
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notartal Seal
CRY Of Pi?G. KoWey, Notary Pd*
R
ugh. Ale$" Cotnly
W in n Emkas June 2,2011
2011
Membw, PennsylvanN Association of Notanes
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE IIOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
TO: Kelvin R. Jones
175 West North Street
Carlisle, PA 17013
DATE OF NOTICE: May 5, 2009
NO.: 2009-02040
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI'CI'EN
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 AC'I'WI'I'111N'1'I N DAYS FROM THI: DATE OF THIS NOTICE:, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A IIE:ARTNG AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHT'S.
YOU SHOULD TAKE TI IIS NO'1'1(`I: 'I'O A LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, G0'1'0 OR '1'1?I.I:PIIONI? '1'111: OFFIC I: S1:T' FORTH BELOW. THIS OFFICI- AN
PROVIDE YOU WITH INFORMATION ABOUT (TIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE' A LAWYER, THIS OFFICE MAY BE ABLE'I'O
PROVIDE YOU WITH INFORMATION ABOUTAGENCIES 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
GRENEN & BIRSIC, P.C.
li v • /L
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
FIRST CLASS MAIL, POSTAGE PREPAID (412) 281-7650
0 0
IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASI-'IIOMI? FINANCI: LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
KELVIN R. JONF'S and
BRENDA D. JONES,
Defendants.
TO: Brenda D. Jones
175 West North Street
Carlisle, PA 17013
DATE OF NOTICE: May 5, 2009
NO.: 2009-02040
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE. YOU HAVE FAILED TO ENTER A WRI'f"I'EN
APPEARANCE PERSONALLY OR 13Y A"1"I'ORNEY AND FILL, IN WRITING WTTII'THF' COURT
YOUR DEFENSES OR OBJECTIONS TO TI IE CLAIMS SIT FOKFI I AGAINST YOU. UNLESS
YOIJ AC"I' WI'1'111N "1'1-'N DAYS FROM '1'111: DA'1'l: Ol' 'I'RIS NOTICE?, A JUD(iMl?N'1' MAY 131-'
ENTERED AGAINSTYOU WITHOUT A HEARING AND YOU MAY LOSE: YOUR PROPERTY OR
OTIIER IMPORTAN"1' RIGI ITS.
YOU SHOULD T'AKI T111S NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, G0'1'O OR TELEPHONE THE OFFICE: SET FORTH BELOW. 'Tins 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
FIRST CLASS MAIL, POSTAGE PREPAID
GRENEN & BIRSIC, P.C.
By:
Attorneys-tor I'laintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
,,IF THE
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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,
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Kelvin R. Jones
175 West North Street
Carlisle, PA 17013
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on slhw /d
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $72,649.99
with interest on the principal sum at the rate of $9.85 per diem (as may change from time to time
in accordance with the terms of the Note) from May 20, 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.
. . .
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.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Brenda D. Jones
175 West North Street
Carlisle, PA 17013
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on slatpLo
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $72,649.99
with interest on the principal sum at the rate of $9.85 per diem (as may change from time to time
in accordance with the terms of the Note) from May 20, 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.
0
Deputy
o%-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
vs.
Kelvin R. Jones and Brenda D. Jones
TO THE PROTHONOTARY OF SAID COURT:
( ) Confessed Judgment
(X ) Other (Default Judgment)
File No. 09-2040-Civil
Amount Due $72,649.99
Interest $ 1,1Q7.54 (5/21/09 to sale)
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,
or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding
filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for
debt, interest and costs, upon the following described property of the defendant(s)
175 West North Street Carlisle PA 17013
(Please see attached legal description)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue Writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
? (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 021 Signature: Qzl-? L
Print Name: Kristine M. Anthou
Address: One Gateway Center, 9' Floor
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: (412) 281-7650
Supreme Court ID No.: 77991
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NO.: 09-2040-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 Kelvin R. Jones and Brenda D. Jones located
at 175 West North Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST
NORTH STREET, CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #05-20-1798-117.
1. The name and address of the owners or reputed owners:
Kelvin R. Jones
175 West North Street
Carlisle, PA 17013
a
Brenda D. Jones 175 West North Street
Carlisle, PA 17013
2. The name and address of the defendants in the judgment:
Kelvin R. Jones 175 West North Street
Carlisle, PA 17013
Brenda D. Jones 175 West North Street
Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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 [PLAINTIFF]
Manhattan Mortgage Corporation
Cumberland County Redevelopment 428 First Street
Authority of Cumberland County Carlisle, PA 17013
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
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.
,(- X
Kristine M. Ant ou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME T S ?? DAY OF 2009.
?.O- Cl, t' ?? -
NNotar? Public
COMMONWEALTH OF PENNSYLVANIA
Notw N Seal
CRY a gk Ale" W Cou*
_ MY Comml?ion EOW June 2, 2011
i ?, en ee6 t i Notener
,r
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.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NO.: 09-2040-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, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that the owners of the property located at 175 West
North Street, Carlisle, PA 17013 are Defendants, Kelvin R. Jones and Brenda D. Jones, who reside
at 175 West North Street, Carlisle, PA 17013, to the best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF 2009.
Notary Public U
c0'! -M NWEALTH OF PENNSYLVANIA
NoWW Seel
R"Mm G.
t I"" A*r Cotslly
j _ "'°?!ntrnres}, X2,2011
Panns0vanid Ass ooleNon of Notaries
r Ti"jam `
2009 MAY 26 AN 10: ' 9
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.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NO.: 09-2040-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, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on January 3, 2009, Defendants were mailed a
combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first class
mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983
and Act 6 of 1974, 41 P.S.'101, et seq.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS DAY OF ff 2009.
Notaryublic
COMMONWEALTH OF PENNSYLVANIA
Rabe 0. 'k(N t'V. N'091V Pubk
my • titr,r'1At,` ;?r; F.x ?r. .tur)e 2, 2041
Mr3m?a , f~an.y:vanla rtscaafation of fVotanes
OF TH!:
20Ei9 ilAY 26
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.: 09-2040-Civil
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Kelvin R. Jones
175 West North Street
Carlisle, PA 17013
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
One Courthouse Square
Carlisle, PA 17013
on September 2, 2009, at 10:00 A.M., the following described real estate, of which Kelvin R.
Jones and Brenda D. Jones are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST NORTH STREET,
CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #05-20-1798-117.
The said Writ of Execution has been issued on a judgment in the mortgagee foreclosure action of
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation,
Plaintiff,
vs.
Kelvin R. Jones and Brenda D. Jones,
Defendants,
at Execution Number 09-2040-Civil in the amount of $73,757.53.
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:c, ` 4,6 / A,
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
-ft
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.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situated in the Fourth Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, as shown on a property survey plan for Carlisle
Housing Opportunities Corporation dated July 28, 2003, prepared by Larry V. Neidlinger P.E.R.S., of
Carlisle, Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173 and 175 W North Street;
thence along West North Street, North 83 degrees 59 minutes 00 seconds West 22.04 feet to a point; thence
by North West Street, North 06 degrees 10 minutes 00 seconds East 125.28 feet to an iron pin set; thence by
land now or formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet to an iron
pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to an iron pin; thence by dividing
line between 173 and 175 W North Street, North 83 degrees 59 minutes 00 seconds West 18.03 feet to an iron
pin; thence by the same South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
BEING known and numbered as 175 W. North Street, Carlisle, PA 17013.
CONTAINING 0.0791 acres or 3,446.44 square feet.
This property must remain owner-occupied for a period of 25 years.
BEING the same premises which Carlisle Housing Opportunities Corporation, A Pennsylvania non-profit
corporation, by Deed dated July 31, 2003 and recorded in the Office of the Recorder of Deeds of Cumberland
County on August 5, 2003, at Deed Book Volume 258, Page 2712, granted and conveyed unto Kelvin R.
Jones and Brenda D. Jones.
GRENEN & BIRSIC, P.C.
Kristine . Anthod, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. 05-20-1798-117
S.
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.: 09-2040-Civil
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Brenda D. Jones
175 West North Street
Carlisle, PA 17013
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
One Courthouse Square
Carlisle, PA 17013
on September 2, 2009, at 10:00 A.M., the following described real estate, of which Kelvin R.
Jones and Brenda D. Jones are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST NORTH STREET,
CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #05-20-1798-117.
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.
Kelvin R. Jones and Brenda D. Jones,
Defendants,
at Execution Number 09-2040-Civil in the amount of $73,757.53.
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.
B . & c_/ ? ?
Kristine M. Antho , Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t Chase CIVIL DIVISION
Manhattan Mortgage Corporation,
Plaintiff,
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situated in the Fourth Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, as shown on a property survey plan for Carlisle
Housing Opportunities Corporation dated July 28, 2003, prepared by Larry V. Neidlinger P.E.R.S., of
Carlisle, Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173 and 175 W North Street;
thence along West North Street, North 83 degrees 59 minutes 00 seconds West 22.04 feet to a point; thence
by North West Street, North 06 degrees 10 minutes 00 seconds East 125.28 feet to an iron pin set; thence by
land now or formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet to an iron
pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to an iron pin; thence by dividing
line between 173 and 175 W North Street, North 83 degrees 59 minutes 00 seconds West 18.03 feet to an iron
pin; thence by the same South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
BEING known and numbered as 175 W. North Street, Carlisle, PA 17013.
CONTAINING 0.0791 acres or 3,446.44 square feet.
This property must remain owner-occupied for a period of 25 years.
BEING the same premises which Carlisle Housing Opportunities Corporation, A Pennsylvania non-profit
corporation, by Deed dated July 31, 2003 and recorded in the Office of the Recorder of Deeds of Cumberland
County on August 5, 2003, at Deed Book Volume 258, Page 2712, granted and conveyed unto Kelvin R.
Jones and Brenda D. Jones.
GRENEN & BIRSIC, P.C.
B `? c r 7C? iC ?L
Kristine . Anthod, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. 05-20-1798-117
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2040 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 KELVIN R. JONES and BRENDA D. JONES
(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 $7;649.99 L.L. $.50
Interest from 5/21/09 to Date of Sale - $1,107.54
Atty's Comm %
Due Prothy $2.00
Atty Paid $167.92 Other Costs
Plaintiff Paid
Date: 5/26/09
Curtis R. L g, Prothonotary
,
(Seal) 4-1p.
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
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.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NO.: 09-2040-Civil
TYPE OF PLEADING
Pa. R.C.P. RULE 3129.2(c)
AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Sale date: 9/2/09
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes
the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this
matter on September 2, 2009 as follows:
Kelvin R. Jones and Brenda D. Jones are the owners of the real property and have
not entered an appearance of record.
2. By letter dated June 11, 2009, the undersigned counsel served Defendant, Kelvin
R. Jones, with a true and correct copy of Plaintiffs notice of the sale of real property by certified
mail, restricted delivery, return receipt requested, addressed to 175 West North Street, Carlisle,
PA 17013. On or about June 15, 2009, the signed certified mail receipt was returned to Plaintiff,
indicating the Defendant was served with the Notice of Sheriff s Sale. A true and correct copy
of the returned certified mail receipt, is marked Exhibit "A", attached hereto and made a part
hereof.
3. By letter dated June 11, 2009, the undersigned counsel served Defendant, Brenda
D. Jones, with a true and correct copy of Plaintiffs notice of the sale of real property by certified
mail, restricted delivery, return receipt requested, addressed to 175 West North Street, Carlisle,
PA 17013. On or about June 15, 2009, the signed certified mail receipt was returned to Plaintiff,
indicating the Defendant was served with the Notice of Sheriff s Sale. A true and correct copy
of the returned certified mail receipt, is marked Exhibit "B", attached hereto and made a part
hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
Kristine CM. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS DAY 2009.
10?sx I C-A A
otary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Public
Elizabeth M. Paiano, Notary
City Of PKs=O, AAegherty Cotxtty
My Commission Fires Jan. 6.2012
7Ndei,bar, Pennsylvania Association of Notaries
EXHIBIT "A"
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,_ it',,:
cGI-,N 2j I ii Z: ?U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
CIVIL DIVISION
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
Sale date: 9/2/09
TYPE OF PLEADING
Pa. R.C.P. RULE 3129.2(c)(2)
PURSUANT TO RULE 3129.1
LIENHOLDER AFFIDAVIT O
SERVICE
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b//t Chase
Manhattan Mortgage Corporatio
COUNSEL OF RECORD FOR THIS
PARTY: I
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC,
Chase
Manhattan Mortgage Corporation, being duly sworn according to law, deposes and akes the
following Affidavit regarding service of the notice of the sale of real property on all persons
named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as f?Ilows:
1. By letters dated June 11, 2009, undersigned counsel served all persons (other than
the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rue 3129.1
with a notice of the sale of real property by ordinary mail at the respective addresses set forth in
the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pur uant to Rule
3129.1 and Certificates of Mailing and any letters, if returned as of this date, are mar ed Exhibit
"A", attached hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based
personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
BY: J CCU
Kristine . Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth F
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS DAY OF 2009.
Ai)tary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seat
Elizabeth M. Patera, Notary PublC
City of Pitfsburgh+ AAegh" CoM
Corf? FxpM.Inn. 8.2012
Member, v ennoylvrrnlrt Aggodation of Notaries
my
EXHIBIT "A"
s
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN YLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
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 wa? filed the
following information concerning the real property of Kelvin R. Jones and Brenda D. lJones located
at 175 West North Street, Carlisle, PA 17013 and is more fully described as
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JON S AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPE TY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN TEE
BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 75 WEST
NORTH STREET, CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #05-20-1798-117.
1. The name and address of the owners or reputed owners:
Kelvin R. Jones 175 West North Street
Carlisle, PA 17013
Brenda D. Jones
•
175 West North Street
Carlisle, PA 17013
2. The name and address of the defendants in the judgment:
Kelvin R. Jones
Brenda D. Jones
175 West North Street
Carlisle, PA 17013
175 West North Street
Carlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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 [PLAINTIFF]
Manhattan Mortgage Corporation
Cumberland County Redevelopment 428 First Street
Authority of Cumberland County Carlisle, PA 17013
5. The name and address of every other person who has any record lien on the
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-
Department of Welfar
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the
whose interest may be affected by the sale:
NONE
7. The name and address of every other person whom the plaintiff has knowledge
interest in the property which may be affected by the sale:
a record lien
1230
and
has any
NONE
9 0
I verify that the statements made in the Affidavit are true and correct to the est of my
personal knowledge, information and belief. I understand that false statements her in are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to uthorities.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
MET S DAY OF 2009.
Notar? Public
COMMONWEALTH OF PENNSYLVANIA
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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 (X) Other (Default Judgment)
Manhattan Mortgage Corporation File No. 09-2040-Civil
Amount Due $72,649.99
vs. ,
Interest $ 4,544.02 (5/21/09 to sale)
Kelvin R. Jones and Brenda D. Jones Atty's Comm
Costs
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,
or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding
filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for
debt, interest and costs, upon the following described property of the defendant(s)
175 West North Street Carlisle PA 17013
(Please see attached legal description)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue Writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
^ (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 ~~~ 9 ~~~ `~ Signature: ~~~~~(~"~{-+~C~'-~~~.~.,1~
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Print Name: Kristine M. Anthou
Address: One Gateway Center. 9`~ Floor
Pittsbur¢h, PA 15222
Attorney for: Plaintiff
Telephone: (4121281-7650
Supreme Court ID No.: 77991
(over)
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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.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situated in the Fourth Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, as shown on a property survey plan for Carlisle
Housing Opportunities Corporation dated July 28, 2003, prepared by Larry V. Neidlinger P.E.R.S., of
Carlisle, Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173 and 175 W North Street;
thence along West North Street, North 83 degrees 59 minutes 00 seconds West 22.04 feet to a point; thence
by North West Street, North 06 degrees 10 minutes 00 seconds East 125.28 feet to an iron pin set; thence by
land now or formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet to an iron
pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to an iron pin; thence by dividing
line between 173 and 175 W North Street, North 83 degrees 59 minutes 00 seconds West 18.03 feet to an iron
pin; thence by the same South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
BEING known and numbered as 175 W. North Street, Carlisle, PA 17013.
CONTAINING 0.0791 acres or 3,446.44 square feet.
This property must remain owner-occupied for a period of 25 years.
BEING the same premises which Carlisle Housing Opportunities Corporation, A Pennsylvania non-profit
corporation, by Deed dated July 31, 2003 and recorded in the Office of the Recorder of Deeds of Cumberland
County on August 5, 2003, at Deed Book Volume 258, Page 2712, granted and conveyed unto Kelvin R.
Jones and Brenda D. Jones.
GRENEN & BIRSIC, P.C.
By. .Ly ~ ~..
Kristin M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. OS-20-1798-117
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NO.: 09-2040-Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
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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 Kelvin R. Jones and Brenda D. Jones located
at 175 West North Street, Carlisle, PA 17013 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST
NORTH STREET, CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #OS-20-1798-117.
1. The name and address of the owners or reputed owners:
Kelvin R. Jones
175 West North Street
Carlisle, PA 17013
Brenda D. Jones 175 West North Street
Carlisle, PA 17013
2. The name and address of the defendants in the judgment:
Kelvin R. Jones 175 West North Street
Cazlisle, PA 17013
Brenda D. Jones 175 West North Street
Cazlisle, PA 17013
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
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 [PLAINTIFF]
Manhattan Mortgage Corporation
Cumberland County Redevelopment 428 First Street
Authority of Cumberland County Cazlisle, PA 17013
5. The name and address of every other person who has any record lien on the property:
Cumberland Domestic Relations
P.O. Box 320
Carlisle, PA 17013
PA Department of Revenue
Commonwealth of Pennsylvania
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Department of Welfaze
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
NONE
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which maybe affected by the sale:
NONE
I verify that the statements made in the Affidavit aze true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein aze made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
,~~
Kris M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS ~V~~ DAY OF 2010.
Notary Public
coririoNw~Tr+ of ~snva~-
Elizabeth r'-• Cagnon~ Notat'Y Pub
pty of pyh, AIk9h~Y ~ ~
Cow 6cplres Tan. 6, N0~
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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, NO.: 09-2040-Civil
vs.
KELVIN R. JONES and c~ ~,
BRENDA D. JONES, ~„
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Defendants.
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AFFIDAVIT OF LAST KNOWN ADDRESS
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COMMONWEALTH OF PENNSYLVANIA
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)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that the owners of the property located at 175 West
North Street, Carlisle, PA 17013 are Defendants, Kelvin R. Jones and Brenda D. Jones, who reside
at 175 West North Street, Carlisle, PA 17013, to the best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS __~~ DAY OF 2010.
Notary Public
caMMONw~.TM of ~snwwrn
tVonnat seat
FJizabetl~ M. Gagnon, NAY
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len. 6, 2012
Member, pennsM+aMa Assadatbn of Notaries
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
N0.:09-2040-Civil ~~ ~ r
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AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEQ.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on January 3, 2009, Defendants were mailed a
combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first class
mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983
and Act 6 of 1974, 41 P.S. §101, et seq.
SWORN TO AND SUBSCRIBED BEFORE .
ME THIS ,_ DAY OF 2010.
Notary Public
ooMw+~onwen~TM of rE~snvarv-
Nourlal seal
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Member. PennsMeMa Maogada-
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
CIVIL DIVISION
NO.: 09-2040-Civil
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Kelvin R. Jones
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175 West North Street
Carlisle, PA 17013
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
One Courthouse Square
Carlisle, PA 17013
on December 8, 2010, at 10:00 A.M., the following described real estate, of which Kelvin R. Jones
and Brenda D. Jones are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST NORTH STREET,
CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #OS-20-1798-117.
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.
Kelvin R. Jones and Brenda D. Jones,
Defendants,
at Execution Number 09-2040-Civil in the amount of $77,194.01.
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 aze 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.
B~ (_ C.y~c
Kristine . Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
ti
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.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
LONG FORM DESCRII'TION
ALL THAT CERTAIN tract of land with the improvements thereon erected situated in the Fourth Wazd of
the Borough of Cazlisle, Cumberland County, Pennsylvania, as shown on a property survey plan for Cazlisle
Housing Opportunities Corporation dated July 28, 2003, prepazed by Larry V. Neidlinger P.E.R.S., of
Cazlisle, Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173 and 175 W North Street;
thence along West North Street, North 83 degrees 59 minutes 00 seconds West 22.04 feet to a point; thence
by North West Street, North 06 degrees 10 minutes 00 seconds East 125.28 feet to an iron pin set; thence by
land now or formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet to an iron
pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to an iron pin; thence by dividing
line between 173 and 175 W North Street, North 83 degrees 59 minutes 00 seconds West 18.03 feet to an iron
pin; thence by the same South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
BEING known and numbered as 175 W. North Street, Carlisle, PA 17013.
CONTAINING 0.0791 acres or 3,446.44 squaze feet.
This property must remain owner-occupied for a period of 25 yeazs.
BEING the same premises which Carlisle Housing Opportunities Corporation, A Pennsylvania non-profit
corporation, by Deed dated July 31, 2003 and recorded in the Office of the Recorder of Deeds of Cumberland
County on August 5, 2003, at Deed Book Volume 258, Page 2712, granted and conveyed unto Kelvin R.
Jones and Brenda D. Jones.
GRENEN & BatSIC, P.C.
Kristin M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. OS-20-1798-117
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
CIVIL DIVISION
NO.: 09-2040-Civil
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Brenda D. Jones
175 West North Street
Carlisle, PA 17013
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TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
on December 8, 2010, at 10:00 A.M., the following described real estate, of which Kelvin R. Jones
and Brenda D. Jones are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF KELVIN R. JONES AND
BRENDA D. JONES OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON
A DWELLING BEING KNOWN AND NUMBERED AS 175 WEST NORTH STREET,
CARLISLE, PA 17013. DBV 258, PAGE 2712. PARCEL #OS-20-1798-117.
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.
Kelvin R. Jones and Brenda D. Jones,
Defendants,
at Execution Number 09-2040-Civil in the amount of $77,194.01.
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 Sheriffwithin ten (10) days from the date when
the Schedule of Distribution is filed by the Office of the Sheriff.
GRENEN & BIRSIC, P.C.
~~-L
Kristine . Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t Chase CIVIL DIVISION
Manhattan Mortgage Corporation,
Plaintiff,
NO.: 09-2040-Civil
vs.
KELVIN R. JONES and
BRENDA D. JONES,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situated in the Fourth Ward of
the Borough of Carlisle, Cumberland County, Pennsylvania, as shown on a property survey plan for Carlisle
Housing Opportunities Corporation dated July 28, 2003, prepared by Larry V. Neidlinger P.E.R.S., of
Carlisle, Pennsylvania, being bounded and described as follows:
BEGINNING at a point on West North Street at the dividing line between 173 and 175 W North Street;
thence along West North Street, North 83 degrees 59 minutes 00 seconds West 22.04 feet to a point; thence
by North West Street, North 06 degrees 10 minutes 00 seconds East 125.28 Feet to an iron pin set; thence by
land now or formerly of Betty L. Stanton, South 83 degrees 59 minutes 00 seconds East 40.77 feet to an iron
pin set; thence South 07 degrees 14 minutes 34 seconds West 37.29 feet to an iron pin; thence by dividing
line between 173 and 175 W North Street, North 83 degrees 59 minutes 00 seconds West 18.03 feet to an iron
pin; thence by the same South 06 degrees 10 minutes 00 seconds West 88.00 feet to a point, the place of
BEGINNING.
BEING known and numbered as 175 W. North Street, Cazlisle, PA 17013.
CONTAINING 0.0791 acres or 3,446.44 square feet.
This property must remain owner-occupied for a period of 25 years.
BEING the same premises which Carlisle Housing Opportunities Corporation, A Pennsylvania non-profit
corporation, by Deed dated July 31, 2003 and recorded in the Office of the Recorder of Deeds of Cumberland
County on August 5, 2003, at Deed Book Volume 258, Page 2712, granted and conveyed unto Kelvin R.
Jones and Brenda D. Jones.
GRENEN & BIRSIC, P.C.
Kristin M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. OS-20-1798-117
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2040 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 KELVIN R. JONES & BRENDA D. JONES
(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 $72,649.99 L.L.
Interest from 5/21/09 to Date of Sale -- $4,544.02
Atty's Comm % Due Prothy $2.00
Atty Paid $960.15 Other Costs
Plaintiff Paid
Date: 8/3/10
David D. B ell, Prothonotary
(Seal) By;
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC, PC
ONE GATEWAY CENTER, 9'~" FLR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
Deputy
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
OFF CE : T-.E -iRIFF
FILEO-OFFICE
OF THE PRr9TH,0t10l ie;
2010 SEP 23 PM 3: L a
"UMBERLAHD Cp0,.0 i
r ENNSYf VA 0' A
Chase Home Finance LLC
Case Number
vs. 2009-2040
Brenda D. Jones (et al.)
SHERIFF'S RETURN OF SERVICE
09/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Kristine Anthou on 912/10
SHERIFF COST: $94.28
September 23, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
4- * -2o73
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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