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Home My WebLink About09-3103Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 204960 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 V. Plaintiff WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 6q- 3103 OCUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 204960 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 204960 Plaintiff is CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/16/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book No. 1807, Page 1866. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 204960 6. The following amounts are due on the mortgage: Principal Balance $60,350.67 Interest $1,914.56 11/01/2008 through 05/12/2009 (Per Diem $9.92) Attorney's Fees $1,300.00 Cumulative Late Charges $39.22 04/16/2003 to 05/12/2009 Cost of Suit and Title Search 750.00 Subtotal $64,354.45 Escrow Credit $0.00 Deficit $836.59 Subtotal 836.59 TOTAL $65,191.04 7 8. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 204960 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10, The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $65,191.04, together with interest from 05/12/2009 at the rate of $9.92 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: Lawr> nce T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Attorneys for Plaintiff File #: 204960 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT SITUATE IN VILLAGE OF BOWMANSDALE, TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, BEING DESCRIBED AS FOLLOWS: BEGINNING AT A CORNER OF LOT 6 AND WEST MAIN STREET; THENCE BY SAID LOT, NORTH 18 DEGREES WEST, A DISTANCE OF 150 FEET TO SUMMIT ALLEY; THENCE BY SAID ALLEY, SOUTH 72 DEGREES WEST, A DISTANCE OF 40 FEET TO LOT 8; THENCE BY SAID LOT, SOUTH 18 DEGREES EAST, A DISTANCE OF 150 FEET TO MAIN STREET; THENCE BY SAID STREET, NORTH 72 DEGREES EAST, A DISTANCE OF 40 FEET TO THE PLACE OF BEGINNING. BEING LOT 7 IN THE GENERAL PLAN OF THE VILLAGE OF BOWMANSDALE, OF WHICH THE ABOVE DISTANCE IN FEET IS UNDERSTOOD TO BE MORE OR LESS, HAVING THEREON ERECTED A 2 AND ONE-HALF STORY FRAME DWELLING KNOWN AND MUNICIPALLY NUMBERED AS 12 WEST LISBURN ROAD, BOWMANSDALE PA 17008 AND BEING PARCEL ID: 42-30-2114-005. The Real Property or its address is commonly known as 12 W LISBURN RD, MECHANICSBURG, PA 17055. The Real Property parcel identification number is 42-30-2114- 005. The Real Property tax identification number is 42-30-2114-005. PARCEL NO. 42-30-2114-005 PREMISES BEING: 12 WEST LISBURN ROAD File #: 204960 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is: outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true .and"correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. lOi3y A orney for Plaintiff DATE: `5 3 -D 9 O FILM; :1=i?;F 01^ THE: F'C, X?'0}ARY 2009 MAY 15 8912: ?, 8 CUVI' Jib Y 479. So PIO AWY ci:v 806d1f eaas1,7q Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy 05/26/2009 07:33 PI 2009 at within nc at 12W same tir SHERIFF COST: $37 May 27, 2009 2009-31 Chase I ?Op et EapIbrr r v OFF" OF SHERIFF Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant SHERIFF'S RETURN OF SERVICE A - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 21, 1933 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the Imed defendant, to wit: William K. Coleman, by making known unto Corey Byrne, adult in charge :st Lisburn Road Bowmansdale, Cumberland County, Pennsylvania 17055 its contents and at the ie handing to him personally the said true and correct copy of the same. 00 Finance LLC William K. Coleman SO ANSWERS, R THOMAS KLINE, SHERIFF B Deputy Sheriff _ c a -.- < s: . J. . Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. WILLIAM K. COLEMAN Defendant(s) PHS #: 204960 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION ' 3f03 NO.09-3WO3 CIVIL TERM : CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Halli & Schmieg, LLP Attorney P aintiff By: Lawreri T. elan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Date: 06-18-09 PHS #: 204960 VERIFICATION Cindy A. Smith hereby states that he/she is Assistant Secretary of CHASE HOME FINANCE LLC, servicing agent for Plaintiff, CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to uns orn falsification to authorities. Name: ,/Qiindv A. Smith DATE: 51151 U:ai T Assistant Secretary Company: CHASE HOME FINANCE LLC File #: 205309 Boyle Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff VS. WILLIAM K. COLEMAN Defendant(s) : NO. 09-31003 CIVIL TERM : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 Phelan HallinpqA Schmieg, LL?P?j Attorney intiff 2????v J BY: Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Date: 06-18-09 t-?( t- ?'- :'! r?r 71,E i??Y/ ??(? ., .... r .'r.. t; , awl ???+\''. _?. Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ~auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff CHASE HOME FINANCE LLC, S/B/M CUMBERLAND COUNTY TO CHASE MANHATTAN . MORTGAGE CORPORATION COURT OF COMMON PLEAS vs. CIVIL DIVISION 69-3!03 WILLIAM K. COLEMAN No. 8~-3~9A3 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against WILLIAM K. COLEMAN, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $65,191.04 Interest - 05/13/2009 to 07/01/2009 $496.00 TOTAL $65,687.04 I hereby certify that (1) the Defendant's last known address is 12 WEST LISBURN ROAD, BOWMANSDALE PA 17055-5840, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 1,tiwrence "I'. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shee 1 R. Shah-Jani, Esq., Id. No. 81760 J ne R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: __!~~(~~j~9 PHS # 204960 ~ PROTHONOTARY CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff v. COURT OF COMMON PLEAS CNIL DNISON NO. 09-31003 CNIL TERM CUMBERLAND COUNTY WII,LIAM K. COLEMAN Defendant(s) TO: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 .ry~FCOpO' DATE OF NOTICE: June 11, 2009 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WII,L BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 204960 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (7171249-3166 By: Lawrence T. Phelan, Esc . No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chr'isovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 204960 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 09-31003 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney, hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant WILLIAM K. COLEMAN is over 18 years of age and resides at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. HALLINAN & SCHMIEG, LLP ' L'~wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sh etal R. Shah-Jani, Esq., Id. No. 81760 mne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATIDN OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED ADISCHARGE INBANKRUPTCY, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** FIi~ED~-~"~t== r~";~ 2Q~3 JUl. -- 6 Po=i i ~ s i ~ 1'~.0o P iD A~-T~y ~~ s a3 is~ 1~1-c.e~, I~lck~-C~~f (Rule of Civil Procedure No. 236) -Revised CHASE HOME FINANCE LLC, SB/M TO CUMBERLAND COUNTY CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS vs. WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 CIVIL DIVISION No. 09-31003 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on (o p BV~ r>r.'nT TT~7 ~ If you have any questions concerning~is matter please contact: HALLINAN & SCHMIEG, i L,~wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shee 1 R. Shah-Jani, Esq., Id. No. 81760 J me R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff a '` PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN COURT OF COMMON PLEAS MORTGAGE CORPORATION Plaintiff CIVIL DIVISION . 3io3 ~~ N0.09-3~A83 CIVIL TERM WILLIAM K. COLEMAN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 07/02/2009 to Date of Sale ($ 10.80 per diem) TOTAL say•ao v ~--"'~Y c,l~~~'15137 ,2~3-y 5 3g'/ ~18:Sd ca~BF g ~y,od ~~ ~ i~ ~~ s~y,oo N ~~i3,7~ ~~~. y soL. D6 due Co CUMBERLAND COUNTY $65,687.04 5 670.00 71 357.04 C) ^`' c. ~~ a ~-;,= ~°: - c . - ` ~, -.~ r^"~~ C~ ,~ -v r--;- ~- ~^ S '~` ' '- i'! 7 _••~ -- . ~=" _~ „ l~ i~! „~' [%JL~ Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ La ence T. Phelan, Esq., Id. No. 32227 rancis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Note: Please attach description of property. PHS # 204960 z~z Od ~a w~ a~ a Oa ~H O U o° ~~ 0 ~w ~U z 0 H 0 a 0 U C7 H z~ F N w U O U W a w U W O ~ W A" d~ x U > a_^ O ~' U ~~ A a O v wa Oo ~' o w O~ G4 ~ a Ti o ~, o0 QO¢ wza:a O]¢ ~aA 3 Q~z a a 3~a~a 0 N V'1 V) OHO b ,.., M ~ ~' ~ ~ pp 00 M p~ ~ O M~O~O C~ OOMO ,~_,~O~zNN O p.~Z o oz ozo~oc`+'.N,~;,~o o c ° c oz -'~~bb~b~ZZZo`OOzbbWbb~ o~ dr ~ ww•oW.~~y ~b ~ww;~wW ~ ~www ~. °' `~F~xv~ °~ H ~ a~ a ~ ap ~ci! A >a a~~~~U c ~.a A~~v ;a>tia~~;U °UQ w ^ ^^^^~^0^^0~0~~^ ~ ~. s LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale, Township of Upper Allen, County of Cumberland, and Commonwealth of Pennsylvania, being more particulazly bounded and described as follows, to wit: BEGINNING at a corner on Lot #6 and West Main Street; thence by said lot, North eighteen (18) degrees West, a distance of one hundred fifty (150) feet to Summit Alley; thence by said Alley, South seventy-two (72) degrees West, a distance of forty (40) feet to Lot #8; thence by said Lot, South eighteen (18) degrees East, a distance of one hundred fifty (150) feet to Main Street; thence by said Street, North seventy-two (72) degrees East, a distance of forty (40) feet to the place of BEGINNING. BEING Lot #7 in the general plan of the Village of Bowmansdale, of which the above distance in feet is understood to be more or less, having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road, Bowmansdale, PA 17008. UNDER AND SUBJECT, NEVERTHELESS, to an Easeirieiri Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 690, at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES IS VESTED IN William K. Coleman, single man, by Deed from Bonnie S. Davis, single person, dated 04/16/2003, recorded 04/23/2003 in Book 256, Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PARCEL N0.42-34-2114-005 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza , ~~ .~ ~~ F; ~` -'~' ' ~ ~~ ~ 1 ~ 1 ~'' '~ ,-~~lY Philadelphia, PA 19103 215-563-7000 ~~~~ ~~~ ~ ~ ~~ ,~+ ~ ~ CHASE HOME FINANCE LLC, SB/M TO C~-.M~NI-~A~'; MORTGAGE CORPORATION r~:,a;y,LL~`l.11f"-t;~,j,r!, Plaintiff v. WILLIAM K. COLEMAN Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION • 3/6,3 N0.09-3~A93 CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ~ancis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff v. WILLIAM K. COLEMAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION • 31 ~i3 N0.09-313 CIVIL TERM CUMBERLAND COUNTY PHS # 204960 AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 12 WEST LISBURN ROAD, BOWMANSDALE PA 17055-5840 , . l . Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) WILLIAM K COLEMAN 12 WEST LISBURN ROAD ~~`- r..~ ~` i BOWMANSDALE, PA 17055-5840 ~ t' ~ ~ t.._ ~ -- r-- :z-~~-~'_ 2. Name and address of Defendant(s) in the judgment: ~~ Name Address (if address cannot be reasonably , rn ascertained, please so indicate) x~ -~s ° .''~ SAME AS ABOVE =-,~` ' =~ e~. ' . ,. :._, 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real prop~ty td~e soh ~ Name Address (if address cannot be '"' ~` reasonably ascertained, please indicate) GENERAL MOTORS ACCEPTANCE 570 CROOKS ROAD CORPORATION TROY, MI 48007 GENERAL MOTORS ACCEPTANCE 1400 KOPPERS BUILDING CORPORAITON PITTSBURGH, PA 15219 C/O WILLIAM T. MOLCZAN, ESQUIRE CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 JP MORGAN CHASE BANK, N.A. 436 SEVENTH AVENUE, STE. 1400 C/O WELTMAN WEINBERG & REIS CO LPA PITTSBURGH, PA 15219 JP MORGAN CHASE BANK, N.A. 8333 RIDGEPOINT DRIVE IRVING, TX 75063 CHASE HOME FINANCE, LLC 3415 VISION DRIVE COLUMBUS, OH 43219 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JP MORGAN CHASE BANK, NA 1111 POLARIS PARKWAY COLUMBUS, OH 43240 JP MORGAN CHASE BANK, NA P.O. BOX 11606 LEXINGTON, KY 40576-1606 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit aze true and correct to the best of my personal knowledge or 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 falsificatica~to authorities. Julv 12, 2010 By: _(~ ~~-'' Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 [~ ands S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ` CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff 3 /0 3 N0.09-31~3'CIVIL TERM vs. WILLIAM K. COLEMAN CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~ ~ ~:; ;,,: - TO: WILLIAM K. COLEMAN '' ~-~ ;= f ~; 12 WEST LISBURN ROAD = ~~ `' °- m BOWMANSDALE, PA 17055-5840 `~ `~~ ~ ' ^~ .a . :~ r-^ ~- - **THIS FIRM IS A DEBT COLLECTOR ATTEMP'T'ING TO COLLECT A DEBT AND ANY INFORM~'IOIFi~BTt~NED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE H~BA ~RU~'CY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 is scheduled to be sold at the Sheriff s Sale on 12/08/Z010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $65,687.04 obtained by CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in. compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 21230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5 . You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale, Township of Upper Allen, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a corner on Lot #6 and West Main Street; thence by said lot, North eighteen (18) degrees West, a distance of one hundred fifty (150) feet to Summit Alley; thence by said Alley, South seventy-two (72) degrees West, a distance of forty (40) feet to Lot #8; thence by said Lot, South eighteen (18) degrees East, a distance of one hundred fifty (150) feet to Main Street; thence by said Street, North seventy-two (72) degrees East, a distance of forty (40) feet to the place of BEGINNING. BEING Lot #7 in the general plan of the Village of Bowmansdale, of which the above distance in feet is understood to be more or less, having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road, Bowmansdale, PA 17008. UNDER AND SUBJECT, NEVERTHELESS, to an Easement Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 690, at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES IS VESTED IN William K. Coleman, single man, by Deed from Bonnie S. Davis, single person, dated 04/16/2003, recorded 04/23/2003 in Book 256, Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PARCEL N0.42-30-2114-005 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-3103 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From WILLIAM K. COLEMAN (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$65,687.04 L.L. Interest INTEREST FROM 07/02/2009 TO DATE OF SALE ($10.80 PER DIEM) - $5,670.00 Atty's Comm Atty Paid $>iy3.77 Plaintiff Paid Date: JULY 16, 2010 (Seal) REQUESTING PARTY: Deputy Name FRANCIS S. HALLINAN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP, 1617 JFK BOULEVARD, SUITE 1400, ONE PENN CENTER PLAZA, PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62695 Due Prothy $2.00 Other Costs AFFIDAVIT OF SERVICE (FNMA) i iFF CUMBERLAND COUNTY r to)NIE FINANCE LLC, SB/M TO CHASE MANHATTAN %(,F. CORPORATION PHS # 204960 D SERVICE TEAM/ kxc W 1 ! AM w ?/ 7 °i t i t MK. COLEMAN COURT NO.: 09-34W CIVIL TERM t ? M K. OQ-310 3 t ttN i?, WILLIAM K. COLEMAN AT: TYPE OF ACTION %,N IS F LISBURN ROAD XX Notice of Sheriffs Sale to irwMANSDALE, PA 17055-5840 SALE DATE: 12/08/2010 SERVED 0t made known to WILLIAM K. COLEMAN , Defen?ant on the 1 s,rday of Lt CS s 7 20 (,$, at k P.M., at 40'1 AwsoM tlEtvue?p9bc1l ?Pn In the manner described below: personally served. family member with whom Defendant(s) reside(s). tionship is ;:barge of Defendant's residence who refused to give name or relationship. /Clerk of place of lodging in which Defendant(s) reside(s). nt m person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. ,9e 365 Height 6_ Weight 150 Race U-) Sex A Other tit?t.p L(_ , a competent adult, being duly sworn according to law, depose and state that I personally N and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned and at the address indicated above. 5? v ale ?,- u uCST,Cs-n 6 N use (s+SF a c? ;ubscribed D?ND^?tp'" eG 407-L(S6 IU '+UEN?£. y s ?S day /?/lFl-1?G513uG-Fs-( ?.?} Z CL Z. n. 206. Lo >- ¢ - By 1- p ?? P&"tjOTSERVE"D ,_7 0 tLI -n z a f 2 at _ o'clock M., Defendant NOT FOUND because: rn ant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) riswer on at at ..cc Refused alld subscribed his day By: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Halkinan, Esq., Id. No. 62695 Daniel C. Sehmim Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R Shah-Jana, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren IL Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Muleaby, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalame P. Mkos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R Dann, Fsq., Id. No. 206779 Andrew C, Bramblat, Esq., ki. No. 208375 one Pem Center at Suburban station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 191031814 (215)563-7000 PLAINTIFF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE C-BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2007-RPI DEFENDANT DEBORAH L. FETTROW DAVID S. FETTROW A/K/A DAVID S. FETTROW, JR SERVE DEBORAH L. FETTROW AT: 231 SOUTH SIDE DRIVE NEWVILLE, PA 17241 PHS # 158775 SERVICE TEAM/ kxc COURT NO.: 07-5298-CIVIL TERM TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 12/0812010 SERVED Served and made known to1 DEBORAH L. FETTROW , Defendant on the 0 day of Ut 20 10, at o'clock A. M., at a'(31 .Sod ntslca }It1EW vlt 4,&P4 in the manner described below: _ Defendant personally served. V Adult family member with whom Defendant(s) reside(s). Relationship is BRM APR, _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other: Description: Age /I405 Height i' I Weight 200 Race 14)_ Sex M Other I, " /116 LA_ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and sub before his day KiNIBERLY CURTY of?, 20 JCT.4R?' PUBLIC sTArl', o r W W' JERSEY No B [ MY CCFddi1SSIU?;N E tii=1RFS MARCH 7,2013 NOT SERVED - -- ?_ On the d r of 20_, at - o'clock M., Defendant NOT FOUND because: 7acantl f _/ Bad Address - Moved ` Does Not Reside (Not Vacant) - N6-?!disA7e-ron at --a(.. Service Refused Other: Sworn to and subscribed before me this day of ?. By: Notary: AFFIDAVIT OF SERVICE CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Iawrt= T. P11daa, Fsq, It VO. 32227 Fraotit S. Ha0lnaa, Faq, Id, No. OW Deed G. Sdmdm FS16Id. No. 623K Mkbtk 61. Bmadrad, Eaq, M N. 69849 JudM T. Romano, Feq, tt No. 58745 5110" R. %8bja1, Fsq, It No 81760 J,Ww R. D"q, Fag, Id. Nu.87077 tA*m R TaW4 Fsq., Id. Na 93337 Vick Sti-awa, Esq, N. Na 282331 Jag B. Jones. Esq, Id. No. 86657 Pftu J. MukA y. Esq., M. Na 61791 Ajxl w L S*ady Ep., Id. %a 81439 Jainr WGe0924 Faq., Id. Nw 90134 CNW.alana P. F1im4 Esq., I& N. "DO Jai" 1. Galduwn, Rq, It No 203047 C-,k-y It Der, Fsq, Id. Ns 2!6719 Aodraw C. Bnaalktt K N. 208375 Ow Pow Cadarae Sbwbm Scotian 1617 jWw F. Kraasly Bled, S1dlo 14M P%*W.% 4 PA 191031814 (215)563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE C-BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES PHS # 158775 SERIFS 2007-RPI DEFENDANT SERVICE TEAM/ kotc DEBORAH L. FETTROW COURT NO.: 07-5298-CIVIL TERM DAVID S. FETTROW A/WA DAVID S. FETTROW, JR SERVE DAVID S. FETTROW A/K/A DAVID S. FETTROW, JR AT: TYPE OF ACTION 231 SOUTH SIDE DRIVE XX Notice of Sheriffs Sale NEWVILLE, PA 17241 SALE DATE: 12/08/2010 SERVED r-? ?erved and made known to DAVID S. FETTROW , Defendant on the 3'day of J K 1- 20 LO, at &L O , o'clock P. M., at 231 5%n M sat ba, Af Fw utuE, Q4, in the manner described below: Y Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: ^ , Desc=41-1 Age _ 40 gg s Height 5 t Weight 20 O Race W Sex AA Other I, AU h-, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscOked before me this day iC?P??6El)?NV CONTY of 20 OUBLIC P:i`E ;ER5EY F ST L eED No NOT SMY COMMtSSlCiRES MARCH 7, 2013 On VVnt , 20at - o'clock M., Defendant NOT FOUND bec- Bad Address _. Moved Does Not Reside (Not Vacant) at ` at Service Refused Other: Sworn to and subscribed before me this day of I . By: Notary: ATTORNEY FOR PLArfrOT lawrmw T. Fbd=. Eg4Id. Na. 32227 Frames S. NaNnan, Esq, Id. 14&626% Dadd G. Schiq. Esq, Id. No. 62216 Mlcide M. Btafmrd, Eaq., Id. Na. 69849 Ja ft T. Ramona, Eey, It Nm. 59745 Sledal R Slab-Jani, Esq, Id. Na 81768 J®ia R Davey, bri., Y. Nm. Mn Lmm R Talmo, Eaq, Id. No. 93337 Vivek SdwAava, Eel, M. No. 202331 Jay S. Jeri, Fsq, It Ne.86667 Peter J. Nakahy, Evq, hL Na 61791 Andrew L Spwaci, Fsq, K Na 84439 Jaime McGaiiaea, Eaq, iL Nm. 90134 Chdnva6nte P. F%kma E q, hL No. 94620 Jmian L Gddma4 Fsq., ld. Na 20.5047 Caartamy L Dana Erq, Id. Na 206779 Andrew C. Bramhku, Fsq., hL No. 29IMS 1(16m1ee ?ccenter at Smbrrban SWkm Yardy Blwt, Sld1e 1480 PYiladelpW PA 191031814 _ (215) 5637008 PLAINT9F DEUTSCHE BANS NATIONAL TRUST COMPANY AS TRUSTEE FOR THE BENEFIT OF THE CERTMCATE H0L )ERS OF POPULAR ABS, INC. MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2007-A DEFENDANT JAMES E. GALL DAWN E. GALL SERVE JAMES E. GALL AT 624 HOLLY PINE MOUNT HOLLY SPRINGS, PA 17066.1905 PAS # 234172 NICE TEAM! kzc COURT NO.:10-2106-CIVII. TERM TYPE OF ACTION IIX NWm of Sberffs SWe SALE DATE: 12PMM10 SERVED ?} Served and made known to JAMES E. GALL , Defendant on ?t e? day of J U L , 2012, at Q; 7-5 . o'clock8_. M., at -24 t6 i ee r kica Wa y% the manner described below: _ Defendant personally served. a[ Adult family member with whom Defendant(s) reside(s). Relationship is WIPE- . _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendants company. Other Description: Age 46 ? Height 51Weight 16 6 Race --!!Q- Sex 44 Other I, PsA AIA D_ MP 1, L- a competent adult, being duly sworn according to law, depose and state that I personally handed a taste and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and su bed i ---_• _ t before this day Kir4SEFLYCUITY _1 4 of "T 2 PUBLIC N By: iERSEY NOT ERVED VY ('() IVISS`f !N 1: %: IRt S MARCH 7, 2013 On the _ y o , 20_, at -o'clock M., Defendant NOT FOUND because: _ Vac y ad•Address .-Moved _ Does Not Reside (NotYacarrt} _ No Arts at at Service Refused Other. Sworn to and subscribed before me this day of _. By: Kl11fnR[y. AITORNEYFOR U VMW? r4*ftbgjLNLnW i , &8Wb%ftr,ldN&QW awma s"a tA, x NL aw Mletde a !alter!. t?.1i Na 6s6s JiT.N?rSLF,tl. Nwlf766 BMaW LBYY?Jr?dFrli.DlLU7f6 ]dr R D?wr, 6+, li. Naf1rR't lairs L'tYMr, N4. k NL XUJ7 YkaR Sfi'rrti ? li Nw 312171 Jq L Jre, Bq, K NL11667 r4irJA*A9kj6&4, Y.NL 61AN A W nw L 8?ef, 6q., tt NL ?167? l? e d k6i r a S td,,, J L Nw f ?1'i 1 Or[wwilrlelliYtij?, liNL91631 7oi? 1 Cdirq ly, lilies ]tlN7 Gr1rp R 14rq,, li NL 71i'/1f pMie?C td NL3MM Nil7J 4 ~ 9?We?lIN tlitii li •A IH6 e+ , p16)Sq.76N AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTOF DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR THE BENEFIT OF THE CERTiFICATEHOLDERS OF POPULAR ABS, INC MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2007-A DEFENDANT JAMES K GALL DAWN E. GALL SERVE DAWN E. GALL AT 624 HOLLY PIKE MOUNT HOLLY SPRINGS, PA 19065-1905 PHS A 234172 SERVICE TEAM/ lac COURT NO.: 10-2106-CIVIL TERM TYPE OF ACTION %% Notice of S1lffffs Sale SALE DATE: 12/OOI2010 SERVED Served and made known to , D N t zAi L . Defendant ,p day of (? L .20 1-0 at 9' 15 , d clock Q. M., at LL 1 K 6 in the manner described below: ? Defendant personally served. MT LL`( PO-1 NGs r _ Adult family member with whom Defendant(s) reside(s). _ Other: y- Descrription: Age 40 Height ?,3 ` Weight 160 Race U) Sex F Other I, 7WV/11-0 MQ LA- a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sak in the manner as set forth herein, issued in the optioned case on the date and at the address indicated above. Sworn to and Mrnibed before to is day of n _ KiI??Evi?LY CEJ271 N B '?'CTr1Ry PUBLIC S! MIT X F WW ;LRSEY NOT SERVED ( ?qY C?? 1MIS??f ? v F `', ` H?S I ?MRCH 7, 2013 2Q ,__, at ___-. o'clock . M.; Defendant NOT FOUND O7tthe. Yan Bad Address z__ Does•Not Reside (Not Vacant) No Answer on at at _ Service Refused Other: Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager&lerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Sworn to and subscribed before me this day of By. Notary; ATTORNSYPOR 1..?r.w+..4.>aNwamr P,.? s. agar., a4. Y tie erns 4ddC: d?R ?, Y Na f2r16 ?adideAL lnitri, 6F, rd.Nw ? ,?rdMYT. Si?ti fy„ K Nw SSTAS 9YMd R SriJrl, fal.li N4 d755 kebaRDPq 0% N ftf PTr Lwe R Titi rib,15. Nw 9317 Vk& sA""V%P4,1 L NL?sO W1 J4 L J@m ft%SL Na arer NMerjMdn '&1 IS.NL4rM AuhmL911 1 Big. AL W AM ]NregU.KPN.fN:M P.PNWW&ft"XNL"W J?irRr -- 64,11N?ZWW C="RDw%bij &N&M1 A?ewC?. IiNwj am s?i or- rr l . J P1I I %" 6PA 191B18H aM SSl.•15N AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WELLS FARGO BANK, N.A., S/B/M TO WELLS FARGO BANK SOUTHWEST, N.A., F/K/A WACHOVIA MORTGAGE, FSB DEFENDANT ERIC B. CEJA SERVE ERIC B. CEJA AT: 208 EDENDERRY WAY ENOLA, PA 17025-3414 PHS # 234618 SERVICE TEAM/ kxc COURT NO.: 10-2244 CIVIL TERM TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 12/08/2010 SERVED Served and made known to ERIC B. CEJA , Defendant on the ? day of U.1. 20 16 , at 43+-, o'clock j>. M., at )L0$ F-DFAAYW-41, CVaGA , PQ , in the manner described below: Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Ageo bS Height S=b ` Weight 14 0 Race W Sex M Other I, Pg94 -4D AQ LL , a competent adult, being duly sworn according to taw, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and suriser bed before me this day of '? 20 Q KIMBERLY CURTY Not r ` By: NOTARY PUBLIC ?PCIL4 I NOT SERVED STATE OF NF W JERSEY On t , 20at _ o clock M., Defendant NOT FOi 'dY CtMMiSS10V 1;`;+'lItE6 MARCH 1, 2J13 ant - Bad Address _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: AFFIDAVIT OF SERVICE CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. @ardnan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetai P- Shah•Jani, Esq., Id. No. 81760 Jenne R. Davey, Esq., Id. No. 870,77 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L Spdvack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. FBakos, Esq., Id. No. 94620 Joshua L Goldman, Esq, Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Brambk[t, Es q., id. No. 208375 One Penn Center al Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 191031814 (215) 563-7000 I? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, S/B/M TO CHASE CUMBERLAND COUNTY MANHATTAN MORTGAGE CORPORATION Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION` rr, m -{ ..., ?. ? WILLIAM K. COLEMAN " - '-') No.: 09-3103 CIVIL TEFJAi r"- -- ! "'' Defendant(s) ' AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) .. -• =+' PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that addre forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mail g ( "Orr 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is tac d hereto Exhibit "A" L nce 'rPhelan, Esq.,Yd. No. 32227 VFr cis S. Hallinan, E sq., d. No. 62695 iel G. Schmieg, Esq., Id. No. 62205 hele M. Bradford, Esq., Id. No. 69849 th T. Romano, Esq., Id. No. 58745 tal R. Shah-Jani, Esq., Id. No. 81760 ne R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq,, Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: Attorney for Plaintiff `6 I ?I IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 204960 w w O w d w 1300` dIZ qszLIp4 gOLS VOL gv Inc ? S?7, ?? ?? 163 1 IN) a? d ti O ,s d a Q o I d a ,e o m 00 'q es a Is V4 a ?z y o o+.. ?i a w?.+' a gd t?tva vi•? u '21 0- , A a ,.l *4 0.1 pA ?Q coaai0?7 pw,5:p,a??ge?rn?71t A°?„CLWyt7?Q C F??.GGi e°?i? xw ? ? o? ??.? o ? ? o.C ?•o c? ?? ???Q o ??VVap,,•xD?W ?o0Cl,,zE'??pU? * * * 1 * a * * * * v r aA cd N G M ? c~as ? cam.. ? ? N ?QO a 0 Ill ?I 1 ?r 6P it! a Ip a r, d a C?. 2 a ? u 3 x? I a ?? n? x? •r• E 016 t -4000 diz ?oa? OLOZ 9LlC1C 95ZLLW40ZO r p N` 0 N a A 6a. Ell a 8 9 p . fh o z' r O O „ E., d O pOy w ? ? '`?' G a. v a ?w a4 i-Azew OV d ??."' p a? w f, ?o awl; dMdl?oA to d Caw w aaQtc°z?w? ?aao 3 x, ?daQW?m?GC?pw mO'p$ d * {t K * .K ? X qc 'K N i? ,K •X ? * ; Y '? w0 jj .. .Z Q 0 • g016 L 3L10O dIZ 90ZLa tr000 OtiOZ tr0ACN ozg'Z(?V s IM Z O to Awmwwwl? ? ?. z N I 9 d ? 4 CIA w w Wa O Oa?w du p O 4 w (}'" C7 Q ?, ?a ?ZICNQ w da ?Qw wa vFO>a xw ° °x ..3????OaHlcn cdr v.? Sdp0 Np?pw5'.0 ?-- R w•?x?•,z vM a"Dpa?z?Ucnr,w?,V3,?v06 .n E N % 'K V C N at fn ? Q E V V L 'C3 ? V ? N y O 0 T N ? 3 Go ?? ? c E v c ? ? O u ? ? u G ? y Vi ?-'• u W c ? O q y ? m m c u L _ T C ?. U O a X G ? Y. N ?- W ^~' d y ti ? V V pOp > O .OV. 0 0" V 'O y N w 4 P ?tH O N O O N O „p 0 p 'G w N O ?a A 7 OVf a F > ? O c ? F .- N °_ u a cv°?i M d w H I f ? m z? ` u F U V Ou ' z r y a° K W 0 U Q v 0. ? F 3 v -X % •K % % -K -K % % % % % -K % -K % % % % -X % -X •k i? % % ? C L' `v v a d N M et ?fi M "t ?fl ?p r-, 00 ?I CHASE HOME FINANCE LLC, S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION Plaintiff CIVIL DIVISION V. NO. 09-31003 CIVIL TERM WILLIAM K. COLEMAN CUMBERLAND COUNTY Defendant(s) PHS # 204960 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840. I. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) 2. 4. WILLIAM K. COLEMAN Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) HEATHER PLANK VAN TASSELL 2225 MILLENNIUM WAY C/O TIMOTHY A. SHOLLENBERGER, ESQ. ENOLA, PA 17025 SHOLLENBERGER & JANUZZI, LLP JPMORGAN CHASE BANK, N.A. 1400 KOPPERS BUILDING C/O PATRICK T. WOODMAN, ESQ. 436 SEVENTH AVENUE WELTMAN, WEINBERG & REIS CO, LPA PITTSBURGH, PA 15219 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANVOCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, 11.0. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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. o for Plaintiff ela Hallman &Schmieg, LLI La rence T. Phelan, Esq., Id. n. 32227 Wncis S, Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 r J ith T. Romano, Esq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ??i ti'',- 41 LI!!Il ?fFt/?y! OFFCEn --I:= ERI! a E= II. D-OFFICC r.`-_ THE PROTHC? OTAR'-I Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Home Finance LLC vs. William K. Coleman 2011 APR I I AM 10: 30 CUMBERLAND COUNT i' PENNSYLVANIA Case Number 2009-3103 SHERIFF'S RETURN OF SERVICE 10/13/2010 11:32 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on 10-13-10 at 1128 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of William K. Coleman, located at, 12 West Lisburn Road, Bowmansdale, Cumberland County, Pennsylvania according to law. 10/18/2010 04:13 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: William K. Coleman but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, William K. Coleman, property at: 12 West Lisburn Road, Bowmansdale, PA 17055, has been vacant since June 2010, defendant did not leave a forwarding at post office. 12/02/2010 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/28/2011 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 4/4/11. SHERIFF COST: $684.73 April 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF eK-..d S137L (Ci i??.ll'1'?7iai49 S?F,n`(. -(ESE.^, S:li(. IIt(;. t CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGA IE CORPORATION Plaintiff ' v. WILLIAM K. COLEMAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-? CIVIL TERM CUMBERLAND COUNTY PHS # 204960 AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) WILLIAM K. COLEMAN Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) GENERAL MOTORS ACCEPTANCE 570 CROOKS ROAD CORPORATION TROY, MI 48007 GENERAL MOTORS ACCEPTANCE 1400 KOPPERS BUILDING CORPORAITON PITTSBURGH, PA 15219 C/O WILLIAM T. MOLCZAN, ESQUIRE CUMBERLAND COUNTY ADULT PROBATION 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 JP MORGAN CHASE BANK, N.A. 436 SEVENTH AVENUE, STE. 1400 C/O WELTMAN WEINBERG & REIS CO LPA PITTSBURGH, PA 15219 JP MORGAN CHASE BANK, N.A. 8333 RIDGEPOINT DRIVE IRVING, TX 75063 CHASE HOME FINANCE, LLC 3415 VISION DRIVE COLUMBUS, OH 43219 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JP MORGAN CHASE BANK, NA 1111 POLARIS PARKWAY COLUMBUS, OH 43240 JP MORGAN CHASE BANK, NA P.O. BOX 11606 LEXINGTON, KY 40576-1606 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained,.please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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 falsificati to authorities. July 12, 2010 By. Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 CI-Fr?ancis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 CHASE HOME FINANCE LLC, SB/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION Plaintiff : CIVIL DIVISION NO. 09-31003 CIVIL TERM VS. CUMBERLAND COUNTY WILLIAM K. COLEMAN Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $65,687.04 obtained by CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in. compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale, Township of Upper Allen, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a corner on Lot #6 and West Main Street; thence by said lot, North eighteen (18) degrees West, a distance of one hundred fifty (150) feet to Summit Alley; thence by said Alley, South seventy-two (72) degrees West, a distance of forty (40) feet to Lot #8; thence by said Lot, South eighteen (18) degrees East, a distance of one hundred fifty (150) feet to Main Street; thence by said Street, North seventy-two (72) degrees East, a distance of forty (40) feet to the place of BEGINNING. BEING Lot #7 in the general plan of the Village of Bowmansdale, of which the above distance in feet is understood to be more or less, having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road, Bowmansdale, PA 17008. UNDER AND SUBJECT, NEVERTHELESS, to an Easement Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 690, at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES IS VESTED IN William K. Coleman, single man, by Deed from Bonnie S. Davis, single person, dated 04/16/2003, recorded 04/23/2003 in Book 256, Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PARCEL NO. 42-30-2114-005 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-3103 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 TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From WILLIAM K. COLEMAN (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$65,687.04 L.L. Interest INTEREST FROM 07/02/2009 TO DATE OF SALE ($10.80 PER DIEM) - $5,670.00 Atty's Comm % Atty Paid $x'23.77 Plaintiff Paid Date: JULY 16, 2010 (Seal) REQUESTING PARTY: Name FRANCIS S. HALLINAN, ESQUIRE Deputy Address: PHELAN HALLINAN & SCHMIEG, LLP, 1617 JFK BOULEVARD, SUITE 1400, ONE PENN CENTER PLAZA, PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62695 Due Prothy $2.00 Other Costs -,. On September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 12 West Lisburn Road, Bowmansdale, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 a By: otu?"?)? Real Estate Coordinator 4 R ie Patriot-News Co. 020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ZhePatriot-News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existirg under the laws of the Com,nonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Markel: Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania. owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid-, that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since- That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, placE! and character of publication are true-, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in anJ for said County of Dauphin in Miscellaneous Book °M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 2009-3103 Civil Term 10/15110 Chase Home Finance LLC, S/B/M to Chase Manhattan 10/22/10 Mortgage Corporation Vs 10/29/10 Wllllam Coleman ; Atty: Daniel el G Schmleg By virtue of a Writ of Execution N0.09-31003 CIVIL TERM Cffi6E HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE Sworn--to andk cribed b me this 10 cl ? November, 2010 A, D. COITORATION / - vs. WILLIAM K COLEMAN owner(s) of property situate in the Township - ? - of Upper Allen, Cumberland County. Notary Public Penn ylvania, being (Muricipahty) 12 WEST LISBURN ROAD. COMMONWEALTH t]F BOWMANSDALE, PA 17055-580 PENNSYLVANIA ?- Parce I No. 42-30-2114-005 Naar4o Seal (Acreage or street address) Sherrie L KJsrler Notary public Improvements thereon: RESIDENTIAL Lower Paxton Twp,, Dauphln County i DWELLING M' Commission Expires Nov. 26, 2011 JUDGMENT AMOUNT. $65.687.04 6^ Membe?r,'?nn'VVP . a Association of Notaries PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 5 da of November 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2009-3103 civil Chase Home Finance LLC, S/B/M to Chase Manhattan Mortgage Corporation VS. William K. Coleman Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-31003 CIVIL TERM, CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN, owner of property situ- ate in the Township of Upper Allen, Cumberland County, Pennsylvania, being 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840. Parcel No. 42-30-2114-005. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $65,687- .04. 24 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff CHASE HOME FINANCE LLC, Court of Common Pleas' SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Civil Division Zrn C-- Plaintiff =r- r Vs Cumberland County ?' CC:) --? WILLIAM K. COLEMAN No. 09-3103 CIVIL TERM ZC .?_ Defendant v Q PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P.. 2352 TO THE PROTHONOTARY: Kindly substitute JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION the current Plaintiff in the foreclosure action by virtue of a corporate merger, whereby CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION is now JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION. Kindly amend the information on the docket accordingly. -e r=; r= . Date: I LINAN & SCHMIEG, LLP B W awrence . an, sq.,Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089L2-` Attorneys for Plaintiff PHS # 204960 $ a? n Vl% ?Cor L.-P ,161'%.)H: 1=60Ulevard, Suite 1400 One Peon Curter Plaza Phil3C!0Ipliia., PA 1910.3 215_' ^3_7000 ---- CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MOR'T'GAGE CORPORATION Plaintiff Vs WILLIAM K. COLEMAN Defendant Attorney For Plaintiff G Z Court of Common Pleas f3' p- Civil Division tL© =t'. =6 Cumberland County y. No. 09-3103 CIVIL TERM PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M to CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION located at 10790 Rancho Bernardo Road, San Diego, CA 92127. Date: TA JUNAN & SCHMIEG, LLP t 1 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308%_-2 Attorneys for Plaintiff PHS # 204960 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION. Date: 7awrence LLINAN & SCHMIEG, LLP By. / T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089I'l---- Attorneys for Plaintiff PHS # 204960 PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215 563-7000 CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County WILLIAM K. COLEMAN No. 09-3103 CIVIL TERM Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe to mark judgment to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 Date: ' I ! BY: Lawrence T. Phelan, Esq., No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 30891 PHS # 204960 Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff v. WILLIAM K. COLEMAN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 07/02/2009 to Date of Sale ($10.80 per diem) TOTAL Note: Please attach description of property. PHS # 204960 l./ ~a~ ~~'~'~ a~ 3~. do CC3 ~ ~~. ~~ «„ ~ ~. so ~, „ 1 y. (:7D ~-~. a ~ , ~~ «„ ~y , cUb ~ „u ~. COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-3103 CIVIL TERM CUMBERLAND COUNTY 65 687.04 14 515.20 80 202.24 Phelan Hallman & Schmieg, LLP Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff a s ~~~ ~~. tea. ~ ~~~~~~ U a a w U W W -"1'', W V O z ~o N ~ ~ O ~~ F ~.., O , UV ~ O~ w ~~ aH ~~ ~o ~ ~ w~ zd Oa F ~F z d OV ~ OV W ~~ U U z ~UG~ C 70~ H w ~~ x ~~ V O H U ~~ ~. ~ C 0 ~ H ~ a ~ 3 w O w ~ ~ ~ ~ Q U `'' a ~ ~, 3 a -c 0 ~ ~ a~ ~ ~ Q"Q w W ~ a O~¢ a~ ~ xa~ a ~Hz a~~ 3~°~ w 0 h a° a M O ~z ~E ~ v v' ~w~ ~ ? ~~ oa 3" '~ w x ,, ~~ ~ ~~o a~¢ LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale, Township of Upper Allen, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a corner on Lot #6 and West Main Street; thence by said lot, North eighteen (18) degrees West, a distance of one hundred fifty (150) feet to Summit Alley; thence by said Alley, South seventy-two (72) degrees West, a distance of forty (40) feet to Lot #8; thence by said Lot, South eighteen (18) degrees East, a distance of one hundred fifty (150) feet to Main Street; thence by said Street, North seventy-two (72) ..degrees Easy a distance of forty(4ftjfeet tofihe placeof BEGINNIhT6. BEING Lot #7 in the general plan of the Village of Bowmansdale, of which the above distance in feet is understood to be more or less, having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road, Bowmansdale, PA 17008. UNDER AND SUBJECT, NEVERTHELESS, to an Easement Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 690, at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES VESTED 1N William K. Coleman, single man, by Deed from Bonnie S. Davis, single person, dated 04/16/2003, recorded 04/23/2003 in Book 256, Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PARCEL N0.42-30-2114-005 PHELAN HALLINAN & SCHMIEG, LLP Meredith Wooters, Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 ` ~ 4 ~,_, ~ ~.,!;; ,'._ One Penn Center Plaza Philadelphia, PA 19103 ,,~ ~ ~ 4 _'! ~ ~k ~~,~`1 r ~"~' 215-563-7000 ~~~~ JPMORGAN CHASE BANK, NATIONAL AS~Crf ~..~T~rd~v, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff v. WILLIAM K. COLEMAN Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-3103 CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( } the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Ph lan Hallinan & Sc ~mieg, LLP Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff v. WILLIAM K. COLEMAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION . NO.: 09-3103 CIVIL TERM CUMBERLAND COUNTY . PHS # 204960 AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE;,LLC, ~B/M:TO CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, se~s~orth.as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property locatedal~i2 VST LISBURN ROAD, BOWMANSDALE, PA 17055-5840. ~ `~ ~`- `°~' ;;: 1,41 ' 7 1. Name and address of Owner(s) or reputed Owner(s): - =_' ~''' -_ Name Address (if address cannot be reasonably ..~~> ascertained, please so indicate) "r 7 ~ ~- ~- ~ "- = WILLIAM K COLEMAN 12 WEST LISBURN ROAD ' =-~ ;~} 1~ BOWMANSDALE, PA 17055-5840 Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) HEATHER PLANK VAN TASSELL 117 E MAIN ST APT 2 MECHANICSBURG, PA 17055-3817 HEATHER PLANK VAN TASSELL 2225 MILLENNIUM WAY C/O TIMOTHY ALLEN SHOLLENBERGER, ENOLA, PA 17025 ESQUIRE JPMORGAN CHASE BANK, NA JPMORGAN CHASE BANK, NA JPMORGAN CHASE BANK, NA C/O PATRICIA L. BLAIS, ESQUIRE JPMORGAN CHASE BANK, NA C/O PATRICIA L. BLAIS, ESQUIRE JPMORGAN CHASE BANK, NA C/O PATRICK THOMAS WOODMAN, ESQUIRE 1111 POLARIS PARKWAY COLUMBUS, OH 43240 8333 RIDGEPOINT DR IRVING, TX 75063 436 SEVENTH AVE STE 1400 PITTSBURGH, PA 15219 160 N SPRAGUE AVE PITTSBURGH, PA 15202 436 SEVENTH AVE STE 1400 PITTSBURGH, PA 15219 GENERAL MOTORS ACCEPTANCE CORPORATION 4 GENERAL MOTORS ACCEPTANCE CORPORATION C/O MEMBERS FIRST FCU, GARNISHEE GENERAL MOTORS ACCEPTANCE CORPORATION C/O WILLIAM THOMAS MOLCZAN, ESQUIRE CUMBERLAND COUNTY ADULT PROBATION 570 CROOKS ROAD TROY, MI 48007 5000 LOUISE DRIVE PO BOX 40 MECHANICSBURG, PA 17055 436 7TH AVE 1400 KOPPERS BUILDING PITTSBURGH, PA 15219 1 COURTHOUSE SQUARE CARLISLE, PA 17013 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JPMORGAN CHASE BANK, NA JPMORGAN CHASE BANK, NA C/O RETAIL LOAN SERVICING JPMORGAN CHASE BANK, NA C/O VALERIE JARAMILLO, PROCESSOR 1111 POLARIS PARKWAY COLUMBUS, OH 43240 PO BOX 11606 KY2-1606 LEXINGTON, KY 40576 1820 E SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) UPPER ALLEN TOWNSHIP UPPER ALLEN TOWNSHIP C/O ROBERT O LIVINGSTON, ACTING TOWNSHIP MANAGER 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055-5604 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE 228 WALNUT STREET, SUITE 220 U.S. ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG, PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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. Date: ~ ~'`~ t ~ ~ By: Phelan Hallman & Schmieg, LLP Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, COURT OF COMMON PLEAS SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO.: 09-3103 CIVIL TERM vs. CUMBERLAND COUNTY ::; WILLIAM K. COLEMAN = «_~ ~...:~ Defendant(s) ;:' G<~ =~ t'~ ~~ E'3 ,.,.e ~._ .~ _. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY - ~~ ~, ~,. ~ ~; .. ,.: TO: WILLIAM K. COLEMAN - _ "' 12 WEST LISBURN ROAD ~ ~=~-~ ~- BOWMANSDALE, PA 17055-5840 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 is scheduled to be sold at the Sheriff's Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $65,687.04 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale, Township of Upper Allen, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a corner on Lot #6 and West Main Street; thence by said lot, North eighteen (18) degrees West, a distance of one hundred fifty (150) feet to Summit Alley; thence by said Alley, South seventy-two (72) degrees West, a distance of forty (40) feet to Lot #8; thence by said Lot, South eighteen (18) degrees East, a distance of one hundred fifty (150) feet to Main Street; thence by said Street, North seventy-two (72) degrees East, a distance of forty (40) feet to the place of BEGINNING. BEING Lot #7 in the general plan of the Village of Bowmansdale, of which the above distance in feet is understood to be more or less, having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road, Bowmansdale, PA 17008. UNDER AND SUBJECT, NEVERTHELESS, to an Easement Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Miscellaneous Book 690, at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES VESTED IN William K. Coleman, single man, by Deed from Bonnie S. Davis, single person, dated 04/16/2003, recorded 04/23/2003 in Book 256, Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PARCEL N0.42-30-2114-005 SHORT DESCRIPTION By virtue of a Writ of Execution N0.09-3103 CIVIL TERM JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN owner(s) of property situate in the TOWNSHIP OF UPPER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 12 WEST LISBURN ROAD. BOWMANSDALE. PA 17055-5840 Parcel No. 42-30-2114-005 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $65,687.04 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 09-3103 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From WILLIAM K. COLEMAN (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: $65,687.04 L.L.: Interest FROM 7/2/2009 TO DATE OF SALE ($10.80 PER DIEM) - $14,515.20 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,545.00 Other Costs: Plaintiff Paid: Date: l' 1Y26/i2 . ~ ~~ David D. B ell, Prothonota (Seal) Deputy REQUESTING P,A.RTY; Name: MEREDITH WOOTERS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD. ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Te 1 ephone: 215-563-7000 Supreme Court ID No. 307207 Phelan Hallman, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb( & ,,phelanhallinan.com 215-563-7000 ? s FEES 21 A RNEY FOR PLAINTIFF '. )r,BERL.AND COUNTY `dS`t'LVA, 411A JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. WILLIAM K. COLEMAN Defendant Court of Common Pleas Civil Division CUMBERLAND County No.: 09-3103 CIVIL TERM MOTION TO MAKE RULE ABSOLUTE JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: A Motion to Reassess Damages was filed with the Court on January 17, 2013. 2. In accordance with Cumberland County Local Rule 208.3 (9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on January 10, 2013 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. A Rule was issued by the Honorable M.L. Ebert, Jr. on or about January 23, 2013 directing the Defendant to show cause by February 12, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto. made part hereof, and marked Exhibit B. 204960 4. The Rule to Show Cause was timely served upon all parties on February 6, 2013 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. Defendant failed to respond or otherwise plead by the Rule Returnable date of February 12, 2011 WHEREFORE. Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. Phelan Hallinan, LLP DATE: , 2 112-0 /h By: XJthan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 204960 Exhibit "A" 204960 PHLLAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan I lallinan. L f-P Representing Lendcrs in Pennsylvania and New Jersey January 10'x', 2013 WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 RE: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE, LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION v. WILLIAM K. COLEMAN Premises Address: 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055 CUMBERLAND County CCP, No. 09-3103 CIVIL TERM Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by January 15`x', 2013. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. 4 Very tr,adti yours, ) Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Enclosure 204960 ? ?;?? ?t Ptvr ooc* oo o jj? ? a d o h? C> E?'5 z?"?'? can ? ? a n. "? G" C UCOdU Aq cn U. 't rr a adv Z> a a=Paz"??°314 * I v j e? ??- 4! zdo_ Exhibit "B" 204960 JPMORGAN CHASE BANK, N.A., IN THE COURT OF COMMON PLEAS OF S%B/M 7-0 CHASE HOME CUMBERLAND COUNTY, PENNSYLVANIA FINANCE, LI C, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION PLAINTIFF V. WILLIAM K. COLEMAN DEFENDANT NO. 09-3103 CIVIL ORDER OF COURT AND NOW, this 23`d day of January, 2013, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before February 12, 2013; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, .'*. M. L. Eber Melissa Cantwell, Esquire Attorney for Plaintiff William Coleman Defendant w bas Exhibit "C" 204960 I 4 - Phelan Hallman, I,LP ' Melissa J. Cantwell, Esq., Id. No.30" ?TT0tZNFY FOR N-AINTIPF 1617 .117 Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Mel sa.Cantwell(?i?phelanhallman.com 21 5-563-7000 I('1?Irtkt??1N(`li,? t,1I?r NAlIONA)_. Y ti :? )t '1. Ai It tr, .'I'>; I?s1 I t ?t `I1.-1; Ht ???fii Court of Common Pleas I-IN;A .`t"1?. f f t'. ,tl;r"?k! I O CIi.1M?: 1°? i 1 0 1 "l .\ Ntlt )l !'t ?,r1(;I t "r tIC''t tl; Civil Division Plaintiff : CUMBERLAND County vs. ` No.: 09-3103 CIVI1, I'ERM WILLIAM K. COLEMAN Defendant <:.'l:K`IIE't?'A`1'tt)N tlF Sih:>€?Vlt'I=". I hereby certify that a true and correct copy of the Court's January 23, 2013 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. WILLIAM K. COLEMAN WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 407 ALISON AVE MECHANICSBURG, PA 17055-6657 DATI : Pirclan Hallinan, LLP _ By: VIk J. Cantwell, Esq, Id. No.308912 Attorney for Plaintiff 204960 PHELAN HALLINAN, LLP Attorney for Plaintiff Ir n nv One Penn Center Plaza � ' 1617 JFK Boulevard, Suite 1400 C"1-!M ' ,L AN pl,Tv Philadelphia, PA 19103 l S Y L'E'A N I A Jonathan.Lobb@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME CUMBERLAND COUNTY FINANCE, LLC, S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO. 09-3103 CIVIL TERM V. WILLIAM K. COLEMAN Defendant MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff;by its counsel, Phelan Hallinan, LLP,petitions this Honorable Court for an Order directing service of the Notice of Sale upon the above-captioned Defendant, WILLIAM K. COLEMAN, by certified mail and regular mail to WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 and posting 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 and publication pursuant to PA.R.C.P. 3129.2 (D) and in support thereof avers the following: 1. A Sheriffs Sale of the mortgaged property involved herein has been scheduled for June 5, 2013. 2. Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 3129.2 requires that the Defendant be served with a notification of Sheriffs Sale at least thirty(30) days prior to the scheduled sale date. 3. Attempts to serve Defendant, WILLIAM K. COLEMAN, with the Notice of Sale at the mortgaged*premises, 12 WEST LISBURN ROAD;BOWMANSDALE,PA 17055-5840, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". No service was made as the property is vacant. 4. Attempts to serve Defendant, WILLIAM K. COLEMAN, with the Notice of Sale at 407 ALISON AVENUE, MECHANICSBURG, PA 17055-6657 , have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". No service was made as the Defendant is unknown. 5. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit"B". 6. Plaintiff contacted the Prothontary's Office and as of March 5,2013,no Judge his piously entered a ruling in this case. , 7 In"ante with CUMBERLAND County Local Rule 208.3(9),NOW , tt a copy of its Proposed Motion for Special Service and Order to the Defendani on- March 5, 2013 and requested Defendant's concurrence. Plaintiff did not receive any written response from the Defendant. A true and correct copy of Plaintiffs March 5, 2013 letter and postmarked certificate of mailing pursuant to Local Rule 208.3(9) attached hereto, made part hereof, and marked Exhibit "C". 8. Plaintiff submits that it has made a good faith effort to locate the Defendant, WILLIAM K. COLEMAN, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests.that the allowance of service of the Notice of Sale upon Defendant in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE,PA 17055-5840 and posting 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 and by publication. Phelan Hallinan, LLP DATE: _ By _ J an 90Lobb, Esq., Id. No.312174 o orney for Plaintiff ,;.. PHELAN HALLINAN, LLP Attorney for Plaintiff One Penir Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 Jonathan.Lobb @phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME CUMBERLAND COUNTY FINANCE, LLC, S/B/M TO CHASE COURT OF'COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO. 09-3103 CIVIL TERM V. WILLIAM K. COLEMAN Defendant PLAINTIFF'S MTMORANDUM OF JAW, Pursuant to Pennsylvania Rude:of aVil Procedure Rule;$129:2, 9 airy in a foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the Sale of the mortgaged premises. Specifically, Pa.R.C.P. Rule 3129.2(c)provides in applicable part as follows: The written notice shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the notice shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402(a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph(A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original.process without further application to the court. Because the whereabouts of Defendant, WILLIAM K. COLEMAN, are unknown, a reasonable investigation of his/her last known address was made in accordance with Pa.R.C.P. 430(a). Pennsylvania Rule of Civil Procedure Rule 430(a)provides as follows: (a) If service cannot be made under the applicable rule the Plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and.extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A sheriff's return of"not found" or the fact that a defendant has moved without leaving a new forwarding addrena ,,; . ci t e videFnce of concealment. Gonzales v. Polis,'238 Pa.Super. 362,157 AN 00(1976). Notice of intended adoption mailed to last known address t a"mod faith effort" to discover the correct address. Adopt an of : -105,3677 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives,neighbors, friends, and employers of the defendant, and(3) examinations of.local telephone directories, voter registration records, local tax records and motor vehicle records. As indicated by the return of service,hereto as Exhibit "A", the process server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Reasonable Investigation,marked as Exhibit "B". WHEREFORE, Plaintiff-respectfully requests the'allowance of-service of the Notice of Sale upon Defendant in accordance with Pa.R.C.P. Rule 430 by certified and regular mail.to WILLIAM K:COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE, PA. 17055-5840 and-posting 12 WEST LISBURN ROAD; BOWMANSDALE, PA 17055-5840 and by publication pursuant to PA.R.C.P. 3129.2. Phelan Hallinan, LLP DATE: By: 4,!2 i an Lobb, Esq., Id. No:312174 ttorney for Plaintiff PHELAN HALLINAN, LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard,.Suite 1400 Philadelphia, PA 19103 Jon athan.Lobb cr phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME CUMBERLAND COUNTY FINANCE, LLC, S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO. 09-3103 CIVIL TERM V. WILLIAM K. COLEMAN Defendant CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the foregoing Motion for Service of Notice of Sale Pursuant to Special Order of Court,Proposed Order, Memorandum of Certifittion of Service and Exhibits in the above captioned matter were sent by first class mail, postage prepaid to the following interested parties on the date indicated below. WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 Phelan Hallinan, LLP DATE: By: Jo an obb, Esq., Id. No.312174 torney for Plaintiff EXHIBTT "A " ` AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S&M CHASE HOME FINANCE,LLC,SIBIM TO CHASE MANHATTAN PHS M 204960 MORTGAGE CORPORATION DEFENDANT SERVICE TEAM/bb WILLIAM K.COLEMAN COURT NO.:09-3103 CIVIL TERM SERVE WILLIAM K.COLEMAN AT: TYPE OF ACTION 12 WEST LISBURN ROAD XX Notice of SherlWs Sale BOWMANSDALE,PA 17055-5840 SALE DATE: March 6,2013 SERVED Served and made known to WILLIAM K.COLEMAN,Defendant on the_day of ,20 at ,o'clock_.M.,at in the manner described below: _Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age Height Weight Race Sex Other 1, a competent adult,hereby verify that I personally handed a true and curreet copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unsworn falsification to authorities. DATE:_ NAME: PRINTED NAME: TITLE: NOT SERVED On the Acnant of b�ER,20.12,at o'clock M.,I,daSl 1��,,,a cornpetent adult hereby state th use: kVacant —Does Not Exist _ Moved _Does Not Reside(Not Vacant) No Answer on _at at _Service Refused Other: I un this statement is mads subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatia✓�a oraues. BY: _(3__ � -- PRINTED NAME:_ �l1ALl► N�OLI� ATTORNEY FOR PLAINT'F Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallinan,Esq.,Id.No.62695 Daniel G.Schmieg,Esq..Id.No.62205 Michele M.Bradford,Esq,,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenne R.Davey,Esq.,Id.No.87077 Lauren R Tabas,Fsq.,Id.No.93337 Jay B.Janes,Esq..id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R,Dunn.Esq..Id.No.206779 Allison F.Wells,Esq.,Id.No,309519 Melissa J,Cantwell,Esq.,Id.No.308912 Mario J.Hanyon,Esq.,Id.No.203993 Andrew J.Marley,Esq.,Id.No.312314 John M.Kolesnik,Esq.,Id.No.308877 Process Server Check List If Service Is Made: Spouses Names if Applicable Wife : Husband: Divorced: Yes ( } No t 7 No Service Made / 1 . vacant : Yes ( V ) No ( ) 2 . Is there a name on the mailbox? Is it the defendants? X16 3 . Neighbor Contact : Yes ( ) No ( v } Left Side: Right Side : 4 . For Sale Sign: Yes ( V ) No ( ) Realtor Name : �3 .......�( (- .. ..C O . .��d'..(6 61� Company Name : C_.T _ CATI IV Phone Number: 5 . Car in Drive Way Yes ( ) No ( V/) Plate Number: AFFIDAVIT OF SERVICE(FNMA) 1 PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M C13ASR HOME MUNCE,LLC,94M TO CHASE MANHATTAN PHS#204960 MORTGAGE CORPORATION DEMINDANT SBRVICLUAMb b WnJJAM K.COLEMAN COURT NO.:W3103 CIVIL TERM SERVE WILLIAM IL COLEMAN AT: TYPE OF ACTION 407 AIJSON AVE XX Notice of SheriWs Sale MECHANICSBURG,PA 17055-6657 SALE DATE: March 6,2013 SERVED Served and made known to WH IJAM K.COLEMAN,Defendant on the_.._day of ,20_,at o'clock_.M.,at in the manner described below: _Defendant personally served. _Adult family member with whom Defendants)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clark of place of lodging in which Defendants)reside(s). _Agent or person in charge of Defendant's office or usual place of busines& an officer of said Defendant's company. .—Other: Description: Age Height Weight Race Sex Other I, r.a competent adult,hereby verify that I personally handed a true and cared copy of the KQ§a of Shariffa Sala in the manner as set forth herein,issued in the captioned catsse an the date and at the address incficated above. I understand that this statement is made subject to the penalties of l8 Pa.C.S.Sac.4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE: NOT.SERVF� On the .t 1 day of MCAM 2.0 t at 6 dclock�.M.,I,��i7�R'tA a competent adult hereby state tha Dfendant NUT'FUUND b cause: _Vacant 0�at t Zxist _Moved X Does Not Reside(Not Vacant) J CAmT VNt4\10k / No Answer on �5- ft, _Service Refused Other. I �" sudanmt s made subj ect to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn fat BY _ PRINTED NAME: AEWA=FOR LAINTIFF Lawrence T.Phelan,Esq.,k1.No.32227 Francis S.Hall"inan,Esq.,Id.No.62695 Daniel G.Schmieg,F-N.,Id,No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovelante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Allison F.Wells,Esq.,Id.No.309519 Melissa J.Cantwell,Esq.,Id.No.308912 Mario J.Hanyon,Esq.,Id.No.203993 Andrew J.Marley,Esq.,Id.No.312314 John M.Kolesnik,Eaq.,Id.No.308877 Process Server Check List If Service Is Made: Spouses Names if Applicable Wife: Husband: �- Divorced: Yes ( } No t ) --------------------- ---- - - - - - -- ------- ----------------- No She 1 . Vacant : Yes ( ) No { 2 . Is there a name on the mailbox? Is it the defendants? 3 . Neighbor Contact : Yes ( ) No (: Left Side: Right Side : 4 . For Sale Sign: Yea ( ) No ( ) Realtor Name: Company Name: Phone Number: 5 . Car in Drive Way Yes ( ) No Plate Number: � � EXHIBI'T "B " AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 204960 Attorney Firm: Phelan,Hallinan&Schmie&LLP Subject: William K.Coleman Current Address: 407 Alison Avenue,Mechanicsburg,PA 17055 Property Address: 12 West Lisburn Road,Bowmansdale,PA 17055 Mailing Address: 407 Alison Avenue,Mechanicsburg, PA 17055 I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct William K.Coleman-xxx-xx-1164 B. EMPLOYMENT SEARCH William K.Coleman-A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that William K.Coleman reside(s)at:407 Alison Avenue,Mechanicsburg,PA 17055. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases,which had no listing for William K.Coleman. B. On 01-30-13 our office made a telephone call to a possible phone number of the subject(s) (717)645-8518 and received the following information: spoke with William K. Coleman who confirmed that he reside(s)at:407 Alison Avenue,Mechanicsburg, PA 17055. III. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 01-30-1.3 we reviewed the National Address database and found the following information:William K.Coleman-407 Alison Avenue 238,Mechanicsburg,PA 17055. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors,the following is a possible mailing address:no addresses on file. IV. OTHER INQUIRIES A. DEATH RECORDS As of 01-30-13 Vital Records and all public databases have no death record on file for William K. Coleman. s V. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH William K.Coleman-1979 B. A.K.A. William Kenneth Coleman *Our accessible databases have been checked and cross-referenced for the above named individual(s). *Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge,information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S.Sec.4904 relating to unsworn falsification to authorities. .l The above information is obtained from available public records and we are only liable for the cost of the affidavit. EXHIBIT "C " o U.S.POSTAGE}k>PITNEY BOWES > =; a c" a ` r"i F Z a-. 0001 3811 ZIP 19103 02 1 Y9 91 1 AP13 ,E O can w CCD o . m .0 ^ Eta n � � o � cn i aro Or > O CD y cn o 0 z w (Z A 0 C � � 0 eY a y H Y �sn•O� � Z;; 8 � x rA da.sg5 :it �sd ,od__•o' N = 8mo A o� 9.� UO$ o O ems+ Q O� N M N y f e Q � �O 9 , u m n ELM n �p d a X 0. Ir 999EFo9E � ►+ vq' �. 0V4 T a'Hg o 00 C ° to wig Rau'a H e� E �? iT a O N ' O 01 O • V Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail lily.hainey&helanhallinan.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania and New Jersey March 5, 2013 WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 RE: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION v. WILLIAM K. COLEMAN Premises Address: 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840 CUMBERLAND County,No. 09-3103 CIVIL TERM Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by March 12, 2013. Should you have any further questions or concerns,please do not hesitate to contact me. Oth rwise,'please be guided accordingly. Ve y yours, LI ,Legal Assis f Ph an Hallinan,LLP 204960 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA IN THE CO , JPMORGAN CHASE BANK, NATIONAL ;. ASSOCIATION, S/B/M TO CHASE HOME CIVIL 60VISION FINANCE, LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION NO. 09-3103 CIVIL TERM Plaintiff C �. V. Mw ; 7:m % ► Ct3 j :Z;:o :XJ -um WILLIAM K. COLEMAN cnr— N Defendant 'T�y<.,,,<'' =x ORDER c 4C n� t- � -- AND NOW, this 2 day of 0.t G^ 2013, after consideration of Plaintiff's Motion for Service of Notice cf Sale Pursuant to Special Order'of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is permitted on Defendant WILLIAM K. COLEMAN by: V/ REGULAR MAIL TO WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 Service by mail is complete upon the date of mailing CERTIFIED MAIL TO WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 Service by mail is complete upon the date of mailing POSTING 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). BY THE COURT: J. PHS #204960 /CC PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 WILLIAM K. COLEMAN 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 4p j '=i! E f)--OFFICE OF �T ii- PRO I O dOTA c`; PHELAN HALLINAN, LLP Attorney for Plaintiff 19 1x � `5 AM 10: 18 1617 JFK Boulevard, Suite 1400 CUB IBE€?LAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M CHASE HOME CUMBERLAND COUNTY FINANCE, LLC, S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO. 09-3103 CIVIL TERM VS. WILLIAM K. COLEMAN Defendant AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail,return receipt requested,to WILLIAM K. COLEMAN on APRIL 1,2013 in accordance with the Order of Court dated MARCH 22,2013. The property was posted on APRIL 7, 2013. Publication was advertised in THE CUMBERLAND LAW JOURNAL on APRIL 12, 2013 &in THE SENTINEL on APRIL 4, 2013. d The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. Phelan Hallinan, LLP DATE: I# By: Jt/ Jonath n Lobb, Esq., Id. No.312174 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M TO CHASE HOME CIVIL bVVISION FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION NO. 09-3103 CIVIL TERM Plaintiff C C V. rn Co T Zrn ::Y& WILLIAM K. COLEMAN N `7' ° Defendant a° s-*+ ORDER �� D G N rn AND NOW,this day of 0.t 4^ , 2013, afteft o consideration of Plaintiff s Motion for Service of Notice cf Sale Pursuant to Special Order of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P.430(a),service of the Notice of Sale is permitted on Defendant WILLIAM K. COLEMAN by: REGULAR MAIL TO WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD,BOWMANSDALE, PA 17055-5840 Service A •#� by mail is complete upon the date of mailing ✓ CERTIFIED MAIL TO WILLIAM K. COLEMAN at 12 WEST LISBURN ROAD, BOWMANSDALE,PA 17055-5840 Service by mail is complete upon the date of mailing POSTING 12 WEST LISBURN ROAD, BOWMANSDALE,PA 17055-5840 PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). BY THE COURT: %�' J. PHS#204960 /CC PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 WILLIAM K. COLEMAN 12 WEST LISBURN ROAD, BOWMANSDALE, PA 17055-5840 co o Name and PHELAN HALLINAN&SCHMIEG o Address One Penn Center at Suburban,Suite 1400 �^ p of Sender Philadelphia,PA 19103 1 p a w 1 � � C9 � rn Line Article Name of Addressee,Street,and Post Office Address Postage `� M Number t ILLIAM K.COLEMAN c 12 WEST LISBURN ROAD OWMANSDALE,PA 17055-5840 2 3 **** a. 4 5 APR� i"..:.��'a 7 * ** g ** * 9 **** 10 **** 11 **** 12 :. WILLIAM K.COLEMAN PHS#204960 Total Number of Total Number of Pieces Postmaster,Per(Name of Receiving Pieces Listed by Sender Received at Post Office Employee) LXH- *NOTICE OF SALE: CERTIFICATE OF MAILING* CODE: 102,0 ' 7178 2417 6099 0130 6335 LXH/204960 1020 WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 --fold here(regular) --fold here(6x9) --fold here(regular) USPS.com® - Track & Confirm Page 1 of 1 English Customer Service USPS Mobile Register l Sign In Azu'sp.a.coff Seardl USPS.com or Track Packages Quick Tools Ship a Package Send Mail Manage Your Mail Shop Business Solutions Track & Confirm GET EMAIL UPDATES PRINT DETAILS YOUR LABEL NUMBER SERVICE STATUS OF YOUR ITEM DATE 6 TIME LOCATION FEATURES 71 78241 7 60 9 90 1 3DS335 First-Class MaiI0 Delivered April 22,2013,9:00 am PHILADELPHIA,PA 19103 Expected Delivery By: April 3,2013 Certified Mall° Return Receipt Electronic .Available for Pickup !April 19,2013,11:28 am PHILADELPHIA,PA 19103 Depart USPS Sort April 15,2013 LANCASTER,PA 17604 Facility Processed through April 14,2013,3:38 pm LANCASTER,PA 17604 , USPS Sort Facility Depart USPS Sort April 14,2013 LANCASTER,PA 17604 Facility Moved,Left no Address April 4,2013.11:13 am MECHANICSBURG,PA 17055 Available for Pickup April 3,2013,11:39 am MECHANICSBURG.PA 17055 Arrive]at Unit April 3,2013,8:23 am MECHANICSBURG,PA 17055 Depart USPS Sort April 3,2013,2:26 am HARRISBURG,PA 17107 Facility Depart USPS Sort April 2,2013,10:16 pm HARRISBURG,PA 17107 Facility _Processed through April 2,2013,11:41 am HARRISBURG,PA 17107 USPS Sort Facility Depart USPS Sort April 2,2013 PHILADELPHIA,PA 19116 Facility Processed at USPS April 2,2013,12:17 am PHILADELPHIA,PA 19116 1 Origin Sort Facility Dispatched to Sort April 1,2013,6:06 pm PHILADELPHIA,PA 19102 Facility Acceptance April 1,2013,3:49 pm .PHILADELPHIA,PA 19102 Electronic Shipping Info April 1,2013 Received Check on Another Item What's your label(or receipt)number? Find LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Privacy Policy Government Services, About USPS Home, Business Customer Gateway, Terms of Use> Buy Stamps&Shop, Newsroom, Postal Inspectors, FOIA, Print a Label wlth Postage, Mail Service Updates, Inspector General, No FEAR Act EEO Data, Customer Service) Forms&PUbllCations, Postal Explore;s Delivering Solutions to the Last Mile) Careers, Site Index, Copyright1d2013 USPS.All Rights Reserved. https://tools.usps.com/go/TrackConfirmAction.action?tLabels=71782417609901306335 5/13/2013 AFFIDAVITT ORVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M CHASE HOME FINANCE,LLC,SB/M TO CHASE MANHATTAN PHS#204960 MORTGAGE CORPORATION DEFENDANT SERVICE TEAM/snl WILLIAM K.COLEMAN COURT NO.:09-3103 CIVIL TERM SERVE WILLIAM K.COLEMAN AT: TYPE OF ACTION 12 WEST LISBURN ROAD XX Notice of Sheriff's Sale BOWMANSDALE,PA 17055-5840 SALE DATE:06/05/2013 ****PLEASE POST THE PROPERTY*** **PLEASE POST PROPERTY IN ACCORDANCE WITH THE COURT ORDER** SERVED erved and made known to WILLIAM K. COLEMAN,Defendant on the Z day of ,�'S o'clock P.M.,at 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840,in the manner described below: Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. XX Other: POSTED THE PROPERTY Description: Age Height Weight Race Sex Other I, S a competent adult,hereby verify that I personally posted the property with a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement ' in e subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. y F DATE: NAME: iii+ l PRINTED NA E: a`l !r1'1 Ql rri j�O G(/J TITLE: 5" NOT SERVED On the day f 20 ,at o'clock_.M.,I, a competent adult hereby state that e endyant iT07FOUND—because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallman,Esq.,Id.No.62695 Daniel G.Schmieg,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Allison F.Zuckerman,Esq.,Id.No.309519 Melissa J.Cantwell,Esq.,Id.No.308912 Mario J.Hanyon,Esq.,Id.No.203993 John M.Kolesnik,Esq.,Id.No.308877 ' y PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 12, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 12 day of April, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 t; CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County,Pennsylvania NO. 09-3103 CIVIL TERM JPMORGAN CHASE BANK, NATIONAL ASSOCIATION s/b/m CHASE HOME FINANCE,LLC s/b/m TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO:WILLIAM K. COLEMAN Being Premises: 12 WEST LIS- BURN ROAD, BOWMANSDALE, PA 17055-5840. Being in TOWNSHIP OF UPPER ALLEN, County of CUMBERLAND, Commonwealth of Pennsylvania,42- 30-2114-005. Improvements consist of residen- tial property. Sold as the property of WILLIAM K. COLEMAN. Your house (real estate) at 12 WEST LISBURN ROAD,BOWMANS- DALE, PA 17055-5840 is scheduled to be sold at the Sheriff's Sale on June 5, 2013 at 10:00 A.M., at the CUMBERLAND County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the Court Judg- ment of $65,687.04 obtained by, JPMORGAN CHASE BANK,NATION- AL ASSOCIATION s/b/m CHASE HOME FINANCE, LLC s/b/m TO. CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee), against the above premises. PHELAN HALLINAN,LLP Attorneys for Plaintiff Apr. 12 9 2p►��(�O PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Ron Thayer,Sales Manager,of The Sentinel, of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): ARril 4,2013 COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE Affiant further deposes that he/she is not IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA interested in the subject matter of the 9 NO.09-3103 CIVIL TERM i JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,5/B/M CHASE ! aforesaid notice or advertisement, and that N HOME FINANCE,LLC,S/B/M TO CHASE MANHATTAN MORTGAGE all allegations in the foregoing statement as CORPORATION Vs. WILLIAM K.COLEMAN to time,place and character of publication ' NOTICE TO: WILLIAM K.COLEMAN are true. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Being Premises:12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840 Being in TOWNSHIP OF UPPER ALLEN,County of CUMBERLAND, Commonwealth of Pennsylvania,42-30-2114-005 Improvements consist of residential property. Sold as the property of WILLIAM K.COLEMAN Your house(real estate)at 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840 is scheduled to be sold at the Sheriffs Sale on 06/05/2013 at I Sworn t and subs bed bef re me this 10:00 AM,at the CUMBERLAND County Courthouse,f Courthouse Squate,Carlisle,PA 17013,to enforce the Court Judgment of$65,687.04 obtained by,'JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, U I Jl S/B/M CHASE HOME FINANCE,LLC,S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION(the mortgagee),against the above Premises. PHE HALLINAN,LLP Attorney for Plaintiff Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ;� -U( 'ICI:' ." t r €� '� � Sheriff �_;� C, L , O( t of t;F OI J 0'� IItP��C,�f�i�t� � �U .�!i l!G�1.1 �t1 try`[ Jody S Smith 2013 SEP _6. PH 2: Chief Deputy Richard W Stewart WW CUMBERLAND �°y p. q� Solicitor OFFICE OF`rREVERIFF CUNT f r PENNSYLVANIA Chase Home Finance LLC Case Number vs. 2009-3103 William K. Coleman SHERIFF'S RETURN OF SERVICE 01/02/2013 06:37 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 12 West Lisburn Road, Bowmansdale, PA 17055, -Cumberland County. 02/04/2013 As directed by Francis Hallinan, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013 02/06/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: William K. Coleman, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found"at 407 Alison Avenue, Mechanicsburg, PA 17055, this address is that of defendants parents who are currently in Florida, per neighbor of defendants parents at address stated, defendant is believed to be living in New York, did not leave a forwarding with the post office. 06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$15,000.00 to Attorney Joseph Schalk, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,550.31 SO ANSWERS, August 02, 2013 RbNqrY R ANDERSON, SHERIFF Yf.00 P� a a4 9 91/4/A/ (c)CountySulte Sheriff,Teleosoft,Inc. JPMORGAN CIS++ASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SB/M TO CHASE HOME FINANCE, LLC, SB/M'TO CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION . Plaintiff NO.: 09-3103 CIVIL TERM V. CUMBERLAND COUNTY WILLIAM K. COLEMAN . Defendant(s) PHS #204960 -- _ JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO CHASE HOME FINANCE,LLC,SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located.at 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) WILLIAM K.COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE,PA 17055-5840 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is.a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) HEATHER PLANK VAN TASSELL 117 E MAIN ST APT 2 MECHANICSBURG,PA 17055-3817 HEATHER PLANK VAN TASSELL 2225 MILLENNIUM WAY C/O TIMOTHY ALLEN SHOLLENBERGER, ENOLA,PA 17025 ESQUIRE JPMORGAN CHASE BANK,NA 1111 POLARIS PARKWAY COLUMBUS,OH 43240 .rPMORd-_ ] CHASE AlYKNA 8333 RIDGEPOINT DR IRVING,TX 75063 JPMORGAN CHASE BANK,NA 436 SEVENTH AVE C/O PATRICIA L.BLAIS,ESQUIRE STE 1400 PITTSBURGH,PA 15219 JPMORGAN CHASE BANK,NA 160 N SPRAGUE AVE C/O PATRICIA L.BLAIS,ESQUIRE PITTSBURGH,PA 15202 JPMORGAN CHASE BANK,NA 436 SEVENTH AVE C/O PATRICK THOMAS WOODMAN, STE 1400 ESQUIRE PITTSBURGH,PA 15219 r GENERAL MOTORS ACCEPTANCE 570 CROOKS ROAD CORPORATION TROY,MI 48007 GENERAL MOTORS ACCEPTANCE 5000 LOUISE DRIVE CORPORATION PO BOX 40 C/O MEMBERS FIRST FCU,GARNISHEE MECHANICSBURG,PA 17055 GENERAL MOTORS ACCEPTANCE 436 7TH AVE CORPORATION 1400 KOPPERS BUILDING C/O WILLIAM THOMAS MOLCZAN, PITTSBURGH,PA 15219 ESQUIRE CUMBERLAND COUNTY ADULT 1 COURTHOUSE SQUARE PROBATION CARLISLE,PA 17013 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) JPMORGAN CHASE BANK,NA 1111 POLARIS PARKWAY COLUMBUS,OH 43240 JPMORGAN CHASE BANK,NA PO BOX 11606 C/O RETAIL LOAN SERVICING KY2-1606 LEXINGTON,KY 40576 JPMORGAN CHASE BANK,NA 1820 E SKY HARBOR CIRCLE C/O VALERIE JARAMILLO,PROCESSOR SOUTH PHOENIX,AZ 85034 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG,PA 17055-5604 UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE C/O ROBERT O LIVINGSTON,ACTING MECHANICSBURG,PA 17055 TOWNSHIP MANAGER 6. Name and address of every other person who has any record interest in the property and whose iiiterest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 12 WEST LISBURN ROAD BOWMANSDALE,PA 17055-5840 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 r r INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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. Date: 1 I a By. 1A114" Phelan Hallinan&Schmieg,LLP Meredith Wooters,Esq.,Id.No.307207 Attorney for Plaintiff J r JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, COURT OF COMMON PLEAS SB/M TO CHASE HOME FINANCE, LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO.: 09-3103 CIVIL TERM VS. CUMBERLAND COUNTY WILLIAM K. COLEMAN Defendant(s) NOTICE OF SHERIFFS SALE OF REAL PROPERTY TO: WILLIAM K. COLEMAN 12 WEST LISBURN ROAD BOWMANSDALE, PA 17055-5840 "THIS FIRM IS.ADEBT.COLLECTOR TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840 is scheduled to be sold at the Sheriff's Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$65,687.04 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO CHASE HOME FINANCE,LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION(the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. r� 1. If the Sheriff's Sale'is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong)are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Village of Bowmansdale,Township of Upper Allen, County of Cumberland,and Commonwealth of Pennsylvania,being more particularly bounded and described as follows,to wit: BEGINNING at a corner on Lot#6 and West Main Street;thence by said lot,North eighteen(18)degrees West,a distance of one hundred fifty(150)feet to Summit Alley;thence by said Alley, South seventy-two (72)degrees West,a distance of forty(40)feet to Lot#8;thence by said Lot, South eighteen(18)degrees East,a distance of one hundred fifty(15 0)feet to Main Street;thence by said Street,North seventy-two(72) degrees East,a distance of forty(40)feet to the place of BEGINNING. BEING Lot#7 in the general plan of the Village of Bowmansdale,of which the above distance in feet is understood to be more or less,having thereon erected a two and one-half story frame dwelling being known and municipally numbered as 12 West Lisburn Road,Bowmansdale,PA 17008. UNDER AND SUBJECT,NEVERTHELESS,to an Easement Agreement recorded in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Miscellaneous Book 690,at page 1713, and easements and restrictions of record. TITLE TO SAID PREMISES VESTED IN William K. Coleman, single man, by Deed from Bonnie S. Davis, single person,dated 04/16/2003, recorded 04/23/2003 in Book 256,Page 3392. PREMISES BEING: 12 WEST LISBURN ROAD,BOWMANSDALE,PA 17055-5840 PARCEL NO.42-30-2114-005 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-3103 CIVIL TERM JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M TO CHASE HOME FINANCE,LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN owner(s) of property situate in the TOWNSHIP OF UPPER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 12 WEST LISBURN ROAD, BOWMANSDALE,PA 17055-5840 Parcel No. 42-30-2114-005 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $65,687.04 Phelan Hallinan&Schmieg,LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 09-3103 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SIB/M TO CHASE HOME FINANCE,LLC,S/BIM TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff(s) From WILLIAM K.COLEMAN (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: $65,687.04 L.L.: Interest FROM 7/2/2009 TO DATE OF SALE($10.80 PER DIEM)-$14,515.20 Atty's Comm: Due Prothy:$2.25 Atty Paid: $1,545.00 Other Costs: Plaintiff Paid: Date: 11/26/12 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name:MEREDITH WOOTERS,ESQUIRE Address:PHELAN HALLINAN&SCHMIEG,LLP 1617 JFK BLVD. ONE PENN CENTER PLAZA TRUE COPY FROM RECORD PHILADELPHIA,PA 19103 in Tezitiniony whereof,I here unto let MY hand and In'e seal of said-Court at Carlisle,Pa. Attorney for:PLAINTIFF This dey of 20 Prothonotary Telephone: 215-563-7000 Supreme Court ID No.307207 On November 30, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 12 West Lisburn Road, Bowmansdale, more filly described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2012 By: Real Estate Coordinator 8� :0IV 8ZAONZ101 JJI1 IHS 3H i .:10 .13I-jJ CUMBERLAND LAW JOURNAL Writ No. 2009-3103 Civil Chase Home Finance LLC vs. William K. Coleman, Atty.: Francis Hallinan By virtue of a Writ of Execu- tion NO. 09-3103 CIVIL TERM JP- MORGAN CHASE BANK,NATIONAL ASSOCIATION, s/b/m TO CHASE HOME FINANCE, LLC, s/b/m TO CHASE MANHATTAN MORTGAGE CORPORATION vs. WILLIAM K. COLEMAN owner(s) of property situate in the TOWNSHIP OF UP- PER ALLEN, Cumberland County, Pennsylvania, being 12 WEST LIS- BURN ROAD, BOWMANSDALE, PA 17055-5840. Parcel No.42-30-2114-005. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $65,687- .04. 35 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 8 da y of Februga, 2013 v� Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy Suit.e $00 . r Pat alp twXews. Mechanitiburg;PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. P_UBLICATION OPY This ad ran on the date(s)shown below: / 2009-3103 lvi 01122113 Chase Home Finan LLC vs 01/29/13 William K.Coleman AttY. Francis Hafllnan 02/06/13 BY virtue of a wit of Execution No.og.; . . . . . . . . . . . . . 3103 CIVIL TERM At>.le� . . . . . . . . . . . JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,S/B/M To f - CHASE HOME FINANCE LLC,S/B/M Sworn to and subscribed before me 14 day of,February, 2013 A.D. TO CHASE MANHATTAN FINANCE,LLC, CORPORATION VS. WILLIAM K COLEMAN wAcw -4) owner(s) of property situate in the u lic TOWNSHIP OF UPPER ALLEN Cumberland County,Pennsylvania,being (Municipality) 12 WEST LISBURN ROAD, BOWMANSDALE,PA 17055-5840 COMMON PENNSYLVANIA Parcel No.42-30-2114-005 I Notarlal Seal (Acreage or street address) Holly Lynn Warfel,Notary Public Improvements thereon: RESIDENTIAL Washington Twp.,Dauphin County DWELLING i My Commission Expires Dec.12,2016 JUDGMENT AMOUNT. $65,687.04 MEMBEFL,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal Nation].Mortgage Association is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 26th day of November,A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 3103, at the suit of JP Morgan Chase Bank,N A against William K. Coleman is duly recorded as Instrument Number 201329749. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of C A.D -9 -4 le- �� R�ecorder Recorder Deeds