HomeMy WebLinkAbout09-2294IN 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.
CAROLE F. CHENEY,
Defendant.
TO DEFENDANT
NO.. OR- dagq Civil (erw
TYPE OF PLEADING:
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
ATT RNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANT IS:
213 South 18`h Street
Camp Hill, PA 17011
V EY FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
213 South 18`h Street
Camp Hill, PA
(CITY, TOWNSHIP) (WARD)
A RNEY FOR PLAINTIFF
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
.46istine 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
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
NO..
CAROLE F. CHENEY,
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
CAROLE F. CHENEY,
Defendant.
NO..
CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its
attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage
Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio
43219 and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendant, Carole F. Cheney, is an individual whose last known address is
213 South 18th Street, Camp Hill, Pennsylvania 17011.
3. On or about April 30, 2004, Defendant executed a Note in favor of The
Washington Savings Bank, FSB ("WSB") in the original principal amount of $107,600.00. A
true and correct copy of said Note is marked Exhibit "A," attached hereto and made a part hereof.
4. On or about April 30, 2004, as security for payment of the aforesaid Note,
Defendant made, executed and delivered to WSB a Mortgage in the original principal amount of
$107,600.00 on the premises hereinafter described, said Mortgage being recorded in the Office
of the Recorder of Deeds of Cumberland County on May 5, 2004, at Mortgage Book Volume
1864, Page 1555. 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. WSB assigned all of its right, title and interest in and to aforesaid Mortgage to
Plaintiff pursuant to a certain Assignment of Mortgage recorded in the Office of the Recorder of
Deeds of Cumberland County on October 22, 2004, at Mortgage Book Volume 712, Page 2345.
6. Defendant is the record and real owner of the aforesaid mortgaged premises.
7. Defendant is in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendant
is due for the October 1, 2008 payment.
8. On or about December 2, 2008, Defendant was mailed a combined Act 91 and
Act 6 Notice, via certified mail, return receipt requested, and by first class mail, in compliance
with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974,
41 P.S. '101, et seq.
9. The amount due and owing Plaintiff by Defendant is as follows:
Principal $ 98,292.64
Interest to 3/20/09 $ 3,046.55
Late Charges to 3/20/09 $ 173.90
Escrow Deficiency to 3/20/09 $ 0.00
Corporate Advances $ 42.00
Unapplied funds ( $ 746.50 )
Attorney's fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $1 04,608.59
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $104,608.59 with interest thereon at the rate of $15.15 per diem from March 20, 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: t-? ?9o _
Kri'neu, 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"
r
Multistate NOTE Loan ID • Pp2778ad
t4HA r'aae Nn
441-7497153-703
April 30th, 2004
rnalel Camp Hill, PA
lr1tYl
(Snatcl
213 South 18th Street, Camp Hill, PENNSYLVANIA 17011
(Prmpcrty Addrenl
1. PARTIES
"Bnrrower" meant each person signing at the end of this Note, and
means The Washington Savings Hank, FSH the persml's successors and assigns. "Lender"
and ILs successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received fmm Lender, Borrower promises to pay the principal sum of One Hundrad
Seven Thousand Six Hundred- - - - - _ _ _ _ _ _
(1.1 S $ 107,600.00 ? - - - -' _ - - - Drnllarc
plms interest, to tlne nder of Lender interest will be charged on tmpaid principal, from
the date of disbursement of the loan proceeds by Lender, at the rate of Five and five eighths
pelcemt ( 5.625 %) per year until the full annmmlt nt principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's prmnlse to pay is secured by a mortgage, deed of trust nr similar security instrument that is dated the
same date as this Note and called the "Security Instrument " The Security Instrument protects the Lender fmm losses
which might result if Borrower defaults raider this Note
4. MANNER OF PAYMENT
(A) Time
Bnrnnwer shall make a payment of principal and interest to Lender oil the first day of each month beginning on
June lot, 2004 Any principal and interest remaining nn the first day of 1taY. 2034
will be dice on that date, which is called the "Maturity Date "
(B) Place
Payment shall be made at 4201 Mitchellville Road, Ste. 300, Bowie, Maryland 20716
or at such place as Lender may designate in writing by notice to Bnrniwer.
(C) Amount
Each mmithly payment of principal and merest will be in the amnunt of U.S. $ 619.41 This amount will
be pan nt a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and
other items in the order described in die Security hntrnment
(D) Allonge to this Note for Payment Ark)uctmenis
If an allomge providing for payment adjustments is executed by Borrower together with this Nnte, the covenants of
the allmnge shall be incnrpnrated into and shall amend and supplement the cnvenants of this Note as if the allnnge were a
part of this Note (Check applicable hnx)
Graduated Payment Allonge ? Other (specify)
Growing Equity Ailomge
S. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, whine( charge or penalty, nn the
first day nt any nomth Lender shall accept prepayment nn 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 regulatinns nt die
Secretary If Bnrimwer 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(Q of this Note by the end of Fifteen calendar days after the payment is due, Lender may collect
a late charge in the annount of Four percent ( 4.600 %) of the nverdue
annount of each payment.
(B) Default
If Borrower detaults 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 tint to exercise this option without waiving its rights in the
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event of any subsequent default in many circumstances regulations issued by d>e secretary will limit Irender?a rights to
require immediate payment in full in the case of payment defaults. Note does not authorize acceleration when not
permitted by HUD regulations. As used in this Note, "Secretary" means Thisthe Secrcary of Housing and Urban
Development or his or her designee
(C) Payment of Costs and Expenses
It Lender has required immediate payment in hull, as described above, Lender may require Bnrrnwer to pay costs
and expenses including reaannable and customary attorneys' fees for enforcing this Nnte to the extent not prohibited by
applicable law, Such tees and enstc shall bear interest from the date of disbursement at the same rate ac the principal of
dhi., Note,
7. WAIVERS
Bnrrnwer and any other person who hat obligations under this Note waive the right% of presentment and nonce of
dishonor, "Presentment" mearw the right to require Lender to demand payment of aninunts due. "Notice of d>.chnnnr"
means the right to require Lender to give notice to other persons that amnimtc due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different inethnd, any nonce that must be given to Bnrrnwer under this Note will be
given by delivering it or by mailing it by first class mail to Bnrrnwer at the property address above or at a different
address it Bnrrnwer has given Lender a entice of Borrower's different address
Any notice that trust he given to Lender under this Note will be given by first class mail to Lender at the address
Gated in Paragraph 4(8) nr at a different address if Borrower is given a notice of that different address,
4. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one persnn signs this Note, each person if fully and personally obligated to keep all of the pmmhses
made in this Note, including the promise to pay the full amount owed Any person who is a guarantor, surety nr
endorser of this Note is also obligated to do these things Any permn who takes nver these obligations, including the
nbhgatinns of a guarantor, surety nr endorser of this Nnte, is also obligated to keep all of the promises made in this
Note Lender may enfnrce its rights under this Note against each perstin individually or against all signatories together
Any one person signing thus Nnte may he required to pay all of the amounts owed under this Nnte,
BY SIGNING BELOW, Bnrrnwer accepts and agrees to the terms and covenants contained in this Nnte.
Carole F. Chance/ (Seal)
( l -Borrower
PAY TO THE ORDER OF Chase Manhattan Mortgage Corp. (Seal)
WITHOUT RECOURSE -Borrower
THE I T "GI BANk FS8
RV- n
E zabeth A. Mannion (Seal)
Mortgage Origination Manager -Borrower
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ELAINE Ioji'LliNA5ST SECRETARY
(Sean
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
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Exhibit "B"
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RECORD AND RETURN TO
THE WASHINGTON SAVINGS BANK, FSB
4201 MITCHELLVILLE ROAD, SUITE 300
BOWIE, MD 20716
Chenev,CGT%
" F RT P. ZIEGLER I q Y09sk R5
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DEEDS
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Parcel Number: -C;?q
[Space Above Thb Line For Recording Datal
Commonwealth of Pennsylvania MORTGAGE FHA Can No.
441-7497153-703
Loan ID # pp2778ad
THIS MORTGAGE ("Security Instrument") is given on April 30th, 2004 The Mortgagor is
Carole F. Cheney
("Borrower"). This Security Instrument is given to The Washington Savings Hank, FSH
which is organized and existing under the laws of THE UNITED
STATES OF AMERICA , and whose address is 4201 Mitchellville Road, Ste.
300, Bowie, Maryland 20716 ("Lender"). Borrower owes Lender the
principal sum of one Hundred Seven Thousand Six Hundred and no/100- - - - - - - - - - -
- - - - - - Dollars (U.S. $ 107, 600.00 ). 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 May lst, 2034 . 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 the Lender the following described
property located in Cumberland County, Pennsylvania:
See attached Exhibit "A"
FHA Pennsylvania Mortgage - 4/96 Initials'
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gystans.com
Ppa»q nn 8K 1864PG 1555
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which has the address of
Pennsylvania 17011
[Zip Codel
213 South 18th Street,
Istreetl
("Property Address");
Loan ID # pp2778ad
Camp Hill
[City)
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 seized 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 vharges, 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
prendum 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 may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed 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. Section 2601 er seq. and implementing regulations, 24 CFR Part 3300, 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).
Initials: CC_
PAFM2G - 02252002 Page 2 or a www.MortgageBankingSysctems.com
SK 1864PG 1556
Loan ID # pp2778ad
3. Application of Payments. All payments under paragraphs I 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 hazards, 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 improvements on the Property, whether now in existence or subsequently erected, against
loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by
Lender. The insurance policies and any renewals shall be held by Lender and shalt 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
trade 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.
5. 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 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 Lender 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
Initials: r7ell
PAM13G - 02252002 Paee 3 of R www.MortgageP.ankingSystenis.com
BKI864PG1557
Loan ID # pp2778ad
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
govertunental 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 payment.-. or the payments required by paragraph 2, or fails to perform any other
covenants and agreemenL-. contained in this Security Instrument, or there is a legal proceeding that may significantly
affect Leader'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 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 payntent 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.
8. 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 payment
defaults, require inunediate payment im 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 Gam-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-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.
Initials: CG
PAFM4G - 022S2oo2 Page 4 of 8 www.Mortgagetlenldnesystems.com
BK 1864PG 1558
Loan ID # pp2778ad
(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 prerniurn 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 attorneys' 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 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.
Initials
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4 1 , .
Loam ID N pp2778ad
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 Environmentaf Law and the following substances: gasoline, kerosene, other flanunable or toxic petroleum products,
toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive
materials. As used in this 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 unconditiotrally 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.
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
tide evidence.
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 C' Act') (12 U.S.C. 3751 of seq.) 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.
Initials:
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Loan ID # pp2778ad
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 sheriffs 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 Instrumwnt. If one or more riders are executed by Borrower and recorded together
with this Security Instrument, the covenants 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. [Check applicable box(es)]
? Condominium Rider ? Growing Equity Rider ? Other [specify]
? Planned Unit Development Rider ? Graduated Payment Rider
BY SIGNING BELOW, Borrower accepts and agrees to the terns contained in this Security Instrument and in any
rider(s) executed by Borrower and recorded with it.
Witnesses:
hv?.?Z?lnt[y.?
(Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
PAFW17G - 02252002 Page 7 of 8 www.MortgageBankbigSystems.com
BKI864PG1561
(Seal)
-Borrower
'OI/ Loan ID # pp2778ad
Certificate idatce /- '
I, CZ'." W ?Y , do hereby certify that the correct address of the within-
named Lender is 4201 Mitchellville Road, SEe. 300, Bowie, Maryland 20716
Witness my hand this 30th day of April, 2004
-Agent of Lender
COMMONWEALTH OF PENNSYLVANIA, L N) W an d, County ss:
On this, 30th day of April, 2004 , before nu, the undersigned officer, personally appeared
Carole F. Cheney
known to me (or satisfactorily proven) to be the person(s) whose name(s) is subscribed to the within
instrument and acknowledged that HE executed the saute for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission Expires:
Noariel Seal
Glenda M. Weft vft. Notary Public
Camp FEIN Sm. Currberiand County
MY Caffl csion Expires Dec. 27.2006
Member. %Msyhrania Association Of Notaries
PAFM8G - 02252002
Recorder of Deeds
1 CertiFy this to be reeorde
In Cumberland d
County PA
Initials:
Page 8 of 8 -.MortgageBaakingSystems.com
SKI864PG1562
. I/ /
FIRST AMERICAN TITLE INSURANCE CO.
r
I
Commitment Number: CHE87-04
SCHEDULE C
PROPERTY DESCRIPTION
The land referred to in this Commitment is described as follows:
ALL that certain tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland and State of
Pennsylvania, bounded and described in accordance with a survey and plan thereof dated June 20, 1963,
prepared by D. P. Raffensperger, Registered Surveyor, Camp Hill, PA., as follows:
BEGINNING at a point on the eastern line of South 18th Street, said pant being one hundred twenty (120) feet in
a southerly direction from the southern line of Second Street, said point being on the dividing line between Lots
No. 129 and 130 on the hereinafter mentioned plan of lots; THENCE along said line North fifty-nine (59) degrees
thirty (30) minutes East, one hundred forty-two (142) feet to the western line of a twenty (20) feet wide alley;
THENCE along the western line of said alley South thirty (30) degrees thirty (30) minutes East, forty (40) feet to
a pant on the dividing line between Lots No. 130 and 131; THENCE along said line South fifty-nine (59) degrees
thirty (30) minutes West, one hundred forty-two (142) feet to a point on the eastern line of South 18th Street;
THENCE along the eastern line of South 18th Street North thirty (30) degrees thirty (30) minutes West, forty (40)
feet to the point, the Place of BEGINNING.
BEING Lot No. 130 of the Plan of "Greater Harrisburg", recorded in Plan Book No. 1, Page 20, Cumberland
County records.
ALTA Commitment
Schedule C
(CHE87.04.PFDlCHE87404/8)
6u1864PG1563
VERIFICATION
Whitney K Cook As Secretary, and duly authorized representative
of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation deposes and says,
subject to the penalties of 18 Pa. C.S.A. Section `4904, relating to unsworn falsification to
authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her
knowledge, information and belief.
CHASE HOME FINANCE LLC, s/b/m/t
Chase Marlbkttan Mortgage Corporation
Whitney K , Assistant Secretary
0
PUT ],,TICE
IF THE -?-
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2029 APR 13 PM 1: 55
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Sheriffs Office of Cumberland County
R Thomas Kline ????tttir of cuin61"r, Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFF CE OF T"< S"ERtFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/17/2009 08:27 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 17,
2009 at 2027 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Carole F. Cheney, by making known unto Carole F. Cheney personally, at
213 S. 18th Street, Camp Hill, Cumberland County, Pennsylvania, 17011, its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $53.62
April 21, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Del y Je ri
Docket No. 2009-2294
Chase Home Financial v Carole F. Cheney
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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.
NO.: 09-2294-Civil
TYPE OF PLEADING
CAROLE F. CHENEY,
Defendant.
I hereby certify that the
address of Plaintiff is:
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:
3415 Vision Drive
Columbus, OH 43219
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
the last known address of
Defendant is:
213 South 180' Street
Camp Hill, PA 17011
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
GRENEN & BIRSIC, P.C.
Attorneys for Plaintiff
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.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
TO: PROTHONOTARY
SIR:
PRAECIPE FOR DEFAULT JUDGMENT
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant, Carole F. Cheney, in the amount of $106,666.15, which is itemized as
follows:
Principal $ 98,292.64
Interest to 5/20/09 $ 3,973.78
Late Charges to 5/20/09 $ 242.96
Escrow Deficiency to 5/20/09 $ 1,005.96
Corporate Advances $ 97.31
Unapplied Funds ($ 746.50)
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $106,666.15
with interest on the principal sum at the rate of $15.15 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.
BY:
Kristine M. Anthou, Esquire
Attorney for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant was not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copy.
Sworn to and subscribed before me
this ?) S+ day of 2009.
/ k-4
Notary Pubic
COMMONWEALTH OF PENNSYLVANIA
Nobel Seal
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IN THE COURTOF COMMON PLEAS OF CUMI3L:Itl,AND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
CAROLE F. CHENEY,
Defendant.
TO: Carole F. Cheney
213 South 18`h Street
Camp Hill, PA 17011
DAT OF NO'I'ICI?: May 8, 2009
NO.: 09-2294
IMPORTANT NOTICE
YOU ARE' IN 1)1.'I-AUI:1' I31;CAIJSIi YOU 11AVI FAILED TO E'N ER A WRIT-I'1 N
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE' IN WRITING WITII T'IIE COURT
YOUR D1:1- I:NS}S OR OBJECTIONS TO T'I IF' CLAIMS SET FORT'II AGAINSTYOU. UNLHSS
YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY 131,
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT I IAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOTAFFORD TO I LIRE A LAWYER, THIS OFFICF MAY BE A13111; T'O
PROVIDE. YOU WITII INFORMATION ABOUT AGENCIES TI IATMAY OFFER LEGAL
SI RVICI?S'fU la.i(i1BLE PERSONS AT A Rl)l( I I1UR NO ':?I .
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.
13y: L ? - - -L? Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Carole F. Cheney
213 South 18th Street
Camp Hill, PA 17011
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on 5(4 &r
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $106,666.15
with interest on the principal sum at the rate of $15.15 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
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
VS.
Carole F. Cheney
( ) Confessed Judgment
(X ) Other (Default Judgment)
File No. 09-2294-Civil
Amount Due $106,666.15
Interest $ 1,694.34 (5/21/09 to sale)
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)
213 South 18th Street, Camp Hill, PA 17011
(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 toy Signature: C. ?? ???CL? ?c C?(
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 CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
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 Carole F. Cheney located at 213 South 18th
Street, Camp Hill, PA 17011 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF CAROLE F. CHENEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
BOROUGH OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 213 SOUTH
18TH STREET, CAMP HILL, PA 17011. DBV 262, PAGE 4222. PARCEL #01-22-0536-348.
1. The name and address of the owner or reputed owner:
Carole F. Cheney 213 South 18th Street
Camp Hill, PA 17011
4 .,
2. The name and address of the Defendant in the judgment:
Carole F. Cheney 213 South 18th Street
Camp Hill, PA 17011
3. The name and last known address of everyjudgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
[PLAINTIFF]
Capital One Bank, USA, N.A.
Pennsylvania Department of Revenue
c/o Patenaude and Felix, A.P.C.
c/o Gregg Morris, Esquire
213 East Main Street
Carnegie, PA 15106
Bureau of Compliance
Lien Section, P.O. Box 280948
Harrisburg, PA 17128-0948
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
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, FA 17128-1230
Department of Welfare
F.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.
Kristine M. A hou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS Sf DAY OF ? ? l 2009.
Not Public
COMMONWEALTH OF PENPN$YLVANIA
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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.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
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 owner of the property located at 213 South
18th Street, Camp Hill, PA 17011 is Defendant, Carole F. Cheney, who resides at 213 South 18th
Street, Camp Hill, PA 17011, to the best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME TH DAY OF 2009.
Not ublic
COMMONWEALTH OF PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
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 December 2, 2008, Defendant was mailed a
combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first class
mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983
and Act 6 of 1974, 41 P. S. '101, et seq.
fl-
/C- -6z10(----.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS 2JS?' DAY OF 2009.
Notaryublic C
rQ?W?NWEALTH OF PENNSYLVANIA
Nobft saw
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2509 H."Y 2 E i?i
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.: 09-2294-Civil
Plaintiff,
VS.
CAROLE F. CHENEY,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Carole F. Cheney
213 South 18th Street
Camp Hill, PA 17011
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 Carole F.
Cheney is the owner or reputed owner:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF CAROLE F. CHENEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF
CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED
THEREON A DWELLING BEING KNOWN AND NUMBERED AS 213 SOUTH 18TH
STREET, CAMP HILL, PA 17011. DBV 262, PAGE 4222. PARCEL #01-22-0536-348.
-sk
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.
Carole F. Cheney,
Defendant,
at Execution Number 09-2294-Civil in the amount of $108,360.49.
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.
Bye gu- c
Kristine?M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
LONG FORM DESCRIPTION
ALL that certain tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland
and State of Pennsylvania, bounded and described in accordance with a survey and plan thereof
dated June 20, 1963, prepared by D. P. Raffensperger, Registered Surveyor, Camp Hill, PA., as
follows:
BEGINNING at a point on the eastern line of South 18th Street, said point being one hundred
twenty (120) feet in a southerly direction from the southern line of Second Street, said point being
on the dividing line between Lots No. 129 and 130 on the hereinafter mentioned plan of lots;
THENCE along said line North fifty-nine (59) degrees thirty (30) minutes East, one hundred
forty-two (142) feet to the western line of a twenty (20) feet wide alley; THENCE along the
western line of said alley South thirty (30) degrees thirty (30) minutes East, forty (40) feet to a point
on the dividing line between Lots No. 130 and 131; THENCE along said line South fifty-nine (59)
degrees thirty (30) minutes West, one hundred forty-two (142) feet to a point on the eastern line of
South 18th Street; THENCE along the eastern line of South 18th Street North thirty (30) degrees
thirty (30) minutes West, forty (40) feet to the point, the Place of BEGINNING.
BEING Lot No. 130 of the Plan of "Greater Harrisburg", recorded in Plan Book No. 1, Page 20,
Cumberland County records.
HAVING erected thereon a two and one-half story frame dwelling house known as No. 213 South
18'' Street.
BEING the same premises which Delores J. Bockelkamp, widow, by Deed dated April 30, 2004
and recorded in the Office of the Recorder of Deeds of Cumberland County on May 5, 2004, at
Deed Book Volume 262, Page 4222, granted and conveyed unto Carole F. Cheney.
GRENEN & BIRSIC, P.C.
Parcel No. 01-22-0536-348
By:
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2294 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 CAROLE F. CHENEY
(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 $106,666.15 L.L. $.50
Interest from 5/21/09 to Date of Sale - $1,694.34
Atty's Comm % Due Prothy $2.00
Atty Paid $172.62 Other Costs
Plaintiff Paid
Date: 5/26/09
Curtis R. Long, Prothono
(Seal) By:
Deputy
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC, PC
ONE GATEWAY CENTER
NINTH FLOOR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
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.: 09-2294-Civil
vs.
TYPE OF PLEADING
CAROLE F. CHENEY,
Pa. R.C.P. RULE 3129.2(c)(2)
Defendant. PURSUANT TO RULE 3129.1
LIENHOLDER AFFIDAVIT C
SERVICE
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/It Chase
Manhattan Mortgage Corporatio
COUNSEL OF RECORD FOR
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.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC, s/b/#n/t Chase
Manhattan Mortgage Corporation, being duly sworn according to law, deposes and rakes the
following Affidavit regarding service of the notice of the sale of real property on all
named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as f?llows:
1. By letters dated June 11, 2009, undersigned counsel served all person (other than
the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1
with a notice of the sale of real property by ordinary mail at the respective addresses set forth in
the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pur?uant to Rule
3129.1 and Certificates of Mailing and any letters, if returned as of this date, are ma*ed Exhibit
"A", attached hereto, and made a part hereof.
I verify that the facts contained in this Affidavit are true and correct based up+n my
personal knowledge, information and belief.
GRENEN & BIRSIC, P.C.
Kristine A Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS3 DAY OF 2009.
N tary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiano, Notary Public
City Of PKWburgh, AAe"v County
My Corruris ilon E)#m Jan. 6, 2012
Member, Pennsylvania Association of Notaries
EXHIBIT "A"
• •
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage
the above action, sets forth as of the date the Praecipe for the Writ of Execution
SYLVANIA
Plaintiff in
filed the
following information concerning the real property of Carole F. Cheney located at 413 South 18th
Street, Camp Hill, PA 17011 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF CAROLE F. CHrNEY OF, IN
AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
BOROUGH OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 13 SOUTH
18TH STREET, CAMP HILL, PA 17011. DBV 262, PAGE 4222. PARCEL #01-2 -0536-348.
1. The name and address of the owner or reputed owner:
Carole F. Cheney 213 South 18th Street
Camp Hill, PA 17011
• i
2. The name and address of the Defendant in the judgment:
Carole F. Cheney 213 South 18th Street
Camp Hill, PA 17011
3. The name and last known address of every judgment creditor whose judgment i$ a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
[PLAINTIFF]
Capital One Bank, USA, N.A.
Pennsylvania Department of Revenue
c/o Patenaude and Fe
c/o Gregg Morris, Es
213 East Main Street
Carnegie, PA 15106
Bureau of Compliant
Lien Section, P.O. B,
Harrisburg, PA 1712
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
5. The name and address of every other person who has any record lien. on the
Cumberland Domestic Relations
P.O. Box 320
Carlisle, PA 17013
PA Department of Revenue
Commonwealth of Pennsylvania
Bureau of Compli&
P.O. Box 281230
Harrisburg, PA 171
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.P.C.
280948
1230
and
has any
NONE
•
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
ME THIS O St DAY OF Ot 2009.
Not Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNS'
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
TYPE OF PLEADING
CAROLE F. CHENEY,
Pa. R.C.P. RULE 3129.2(c)
Defendant. AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
FILED ON BEHALF OF PLAID
Chase Home Finance LLC, s/b/rr
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR 'f
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
(LVANIA
Chase
Sale date: 9/2/09
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNS
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff, NO.: 09-2294-Civil
vs.
CAROLE F. CHENEY,
Defendant.
Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE
DEFENDANTS/OWNERS
YLVANIA
Kristine M. Anthou, Esquire, Attorney for Plaintiff, Chase Home Finance LL?, 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 prove v in this
matter on September 2, 2009 as follows:
1. Carole F. Cheney is the owner of the real property and has not entere4 an
appearance of record.
2. By letter dated June 11, 2009, the undersigned counsel served Defend4nt, Carole
F. Cheney, with a true and correct copy of Plaintiffs notice of the sale of real propert? by
certified mail, restricted delivery, return receipt requested, addressed to 213 South 18jh Street,
Camp Hill, PA 17011. On or about June 15, 2009, the signed certified mail receipt,"
to Plaintiff, indicating the Defendant was served with the Notice of Sheriff's Sale. A
correct copy of the returned certified mail receipt, is marked Exhibit "A", attached he
made a part hereof
returned
and
and
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
BY:L"? Vlt' (
Kristine NT 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.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Eitzabeth M. Paiam, Notary Public
City Of Ph b jo, Akoiany CoulMy CommMm EVft Jan. 0, 2012
Member, PanndylvaMla A6906160on Of NoWas
EXHIBIT "A"
Postal
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item 4 It Restricted Delivery, is desired.
¦ Print your name and address on the reverse X
so that we can return the card to you. 8. Received by (Rinred
¦ Attach this card to the back of the mailpiece,
or on the front N space permits.
I. ArV*Ad&mmd to:
c.ral? ? C?ntv??cy
213 SauAi? lW a.
PA 1-in
2. Article Number
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PS Form 3811, February 2ow
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