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HomeMy WebLinkAbout10-0845 2110 FE3 -L ;,..11 ',.' L 1' .. _ 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 1. 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 228478 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 Plaintiff V. NORMA JEAN CHAPMAN 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ID , G f (2tv?C t X-r CUMBERLAND COUNTY ACTION -1,AW COMPT AINT IN MORTGAGE. FORE.C1.0S11RF. O S gQ;?.Qa?L eed 4o7zsy iZ=f' aa7i/8 File #: 228478 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 r ,. the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 228478 I . Plaintiff is RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. 10561 TELEGRAPH ROAD GLEN ALLEN, VA 23059 2. The name(s) and last known address(es) of the Defendant(s) are: NORMA JEAN CHAPMAN 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 05/31/2006 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. 1953, Page 3037. 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 03/01/2009 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 #: 228478 6 The following amounts are due on the mortgage: Principal Balance $127,932.37 Interest $9,139.02 02/01/2009 through 02/01/2010 (Per Diem $24.97) Attorney's Fees $650.00 Cumulative Late Charges $437.77 05/31 /2006 to 02/01/2010 Costs of Suit and Title Search $550+00 Subtotal $138,709.16 Escrow Credit $0.00 Deficit $5,610.39 Subtotal 5.610.39 TOTAL $144,319.55 7. 8. 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' 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. 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. File #: 228478 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $144,319.55, together with interest from 02/01/2010 at the rate of $24.97 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? 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 ? ourtenay R. Dunn, Esq., Id. No. 206779 IL?J Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 228478 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNCED AND DESCRIBED ACCORDING TO A SURVEY OF ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED April 24, 1967, AS FOLLOWS: BEGINNING AT A POINT ON THE Southwesterly LINE OF BRIDGE Street, (FIFTY (50) FEET WIDE) WHICH POINT IS LOCATED TWO HUNDRED TWENTY-ONE AND THIRTY-FOUR HUNDREDTHS (221.34) FEET Southeastwardly FROM 16TH Street AND WHICH POINT IS ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON THE HEREINAFTER MENTIONED Plan OF Lots; THENCE CONTINUING Southeastwardly ALONG SAID LINE OF BRIDGE Street FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 3 AND 4 OF SAID Plan; THENCE South FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES West ALONG SAID DIVIDING LIE ONE HUNDRED FIFTY (150) FEET TO A,STAKE ALONG SAID LIE OF THE SIXTEEN (16) FOOT ALLEY; THENCE North FORTY-FIVE (45) DEGREES West FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON SAID Plan; THENCE North FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES East ALONG THE LAST SAID DIVIDING LINE ONE HUNDRED FIFTY (150) FEET TO A POINT IN THE Southerly LINE OF BRIDGE Street, THE PLACE OF BEGINNING. BEING Lot No. 4, Section D, on the Plan of Hillside, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75. HAVING THEREON erected a two and one-half (2 1/2) story frame dwelling house known as No. 1544 Bridge Street. TAX ID# 26-23-0541-149 PREMISES: 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 File #: 228478 ? i 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. Attorney for Plaintiff DATE: // IO File #: 228478 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor FILED-DFFI ;E ''F ?l-.'c P^0, TH! dN10-j*y 2019 FEB 12 AH 11: 0 7 Cm pv N; RBS Citizens, N.A. vs. Norma Jean Chapman Case Number 2010-845 SHERIFF'S RETURN OF SERVICE 02/04/2010 06:00 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2010 at 1800 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Norma Jean Chapman, by making known unto Tanya Moppin, adult in charge at 1544 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 February 08, 2010 SO ANSWERS, NY R ANDERSON, SHERIFF Bw ('1r.(? 1 )f 7k/ Dep?ity -Sheri "Cl Gcw--tySulte Shenff. Tile.^„o`t. Irc of ~~r~r ?OIQ NAR -2 AID I i ~ I ~ CUM:7.~..~~4.~4, 'i:: 5.::U'~ ('c"N~ ~~t ~'t.V ~JI~ 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 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. Plaintiff vs. NORMA JEAN CHAPMAN Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-845 CIVIL TERM CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 228478 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan &Schmieg, LLP Attorney for Plaintiff BY• ~1~~ ^ 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 ^ ourtenay R. Dunn, Esq., Id. No. 206779 ~] Andrew C. Bramblett, Esq., Id. No. 208375 Date: 2-25-10 PHS #: 228478 VERIFICATION ~~ j _ hereby states that he/she is of CCO MORTGAGE, A DIVISION OF RBS CITIZENS BANK, N.A, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ~ 3~ O(~ I V Name: T~ ~ ~~ ~~ Title: ~ C.. Company: CCO MORTGAGE, A DIVISION OF RBS CITIZENS BANK, N.A File #: 228478 Chapman 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 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. Plaintiff vs. NORMA JEAN CHAPMAN Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-845 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: PHS #: 228478 NORMA JEAN CHAPMAN 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff Date: 2-25- ^ 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 ^ urtenay R. Dunn, Esq., Id. No. 206779 [v~CAndrew C. Bramblett, Esq., Id. No. 208375 PHS #: 228478 Office of the Prothonotary Cumberland County David D. Buell Prothonotary Joseph P. Schalk, Esq. 156 Locust Street Harrisburg, PA 17101 DATE: July 29, 2010 TO Attorney Schalk: THIS IS TO NOTIFY YOU THAT CASE NUMBER 10-845 RBS Citizens, N.A. F/K/A Citizens Bank, N.A. SB/M to CCO Mortgage Corp. VS. Norma Jean Chapman HAS BEEN LISTED FOR ARGUMENT ON Ausust 18, 2010 f nmharl.~n~l (~'nnn*v A ranmpnt f nurf Rules 102R(cl_ rhIONOTARY ~'"'"" ~~ BERLAND COUNTY COURTHOUSE ~ ~ ` ~~~' COURTHOUSE SQUARE. STE. 100 FILI~C~ ~ `<,-', _,, ,~ .ISLE PA 17013 ~ ~ ~ . 0 2 ~ A ~ ~.~ ,,1, 0004631598 AUG03 20' MAILED FROM 2'P000E 1 70' ~.,,~ ~.~ aol o r~,xr ~ ~~ r ~ ~ o!~ l a , g ~s W GUI _. _ _ ~ , ',~ ~~~ Joseph P. Schalk, Esq. 156 Locust Street Harrisburg, °~ ~~~M rifTXSE i?6' DE' ~ Ott ~9/05/'S•G RETURN TO SENDER NO SUCH NUMBER UNABLE TO FORWARD BC: 17013339Q99 *0219-02758-03-40 l~t~'1~~+~e~ I.,~III~,.III,~~~~~li~,ll~,~t`!-~~Il~i~l,~~l»11~1~~1~1-~~~~iil THE PROTHHNO T A?y 2010 MOV 23 AM I1: 38 CUMBERLAND COUNT y PENNSYLVANIA 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 RBS CITIZENS, N.A. F/KIA CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. VS. NORMA JEAN CHAPMAN Attorney for Plaintiff : CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-845 CIVIL TERM V.pa 01N, I D3 2 228478 1 \" PRAECIPE TO ASSESS DAMAGES PURSUANT TO COURT ORDER TO THE PROTHONOTARY: Kindly assess damages in favor of the Plaintiff and against NORMA JEAN CHAPMAN, Defendant(s) in accordance with the Court's Order dated August 23, 2010. As set forth in the Court's Order $1449319.55 Interest - 02/01/2010 to 08/23/2010 $5,093.88 TOTAL $149,413.43 rence 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? drew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS # 228478 PROTHONOT Y CC: NORMA JEAN CHAPMAN, PRO SE 411 ROSS AVE NEW CUMBERLAND, PA 17070-2619 228478 w A011 I IN THE COURT Or COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RBS Citizens, N.A. FWA Citizens Bank, N.A. Court of Common Pleas S/B/M to CCO Mortgage Corp. 10561 Telegraph Road Civil Division Glen Allen, VA 23059 Plaintiff No. 10-845 CIVIL TERIM vs. Norma Jean Chapman 1544 Bridge Street New Cumberland, PA 17070-1119 Defendant : Cumberland County ORDER AND NOW, this day of t?w" , 2010 upon considcrtztiori of Plaintiffs Motion for Swnmary Judgment and Brief in Support thereof, and upon consideration of the Response, if any, filed by Defendant, the Court determines that Plaintiff is entitled to Summary Judgment as a matter of law, and it is hereby: ORDERED and DECREED that an in rem judgment is entered in favor of Plaintiff and against Defendant, Norma Jean Chapman, for $144,319.55 plus interest from February 01, 2010 at the rate of $24.97 p er diem and other costs and charges collectible under the mortgarc, for foreclosure and sale: of the mortgaged property. BY THE COURT: J. PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SIB/M TO CCO MORTGAGE CORP. Plaintiff V. NORMA JEAN CHAPMAN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 08/24/2010 to Date of Sale ($24.56 per diem) TOTAL COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-845 CIVIL, TERM CUMBERLAND COUNTY $149,413.43 56,925.92 S156,339.35 Attorne for Plaintiff 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 ? Allison F. Wells, Esq., Id. No. 309519 Note: Please attach description of property. PHS # 228478 FiLED-OFFICE OF THE PROTHONOTARY 0 a 0 U 0 z w as Oa U ? ? d o z ? O w ? U W ? A" 1010 DEC 14 PH 1: 54 CUMBEFLPANID COUHTY PBMSYLVANIA ON o ? q v c, Ica 0 Z E z U? ?°', a W W 3 H ? U zz ?1 4w z 0 O? aID w C oN t4 a, CV 'Nb?~??cn M b Q oO C M N r z N a N O Q O O"? ?zZ0,NIjtC O pb C d zz 01 r ;.d A ; ^N o o^ ? 43 a fsl a H A > .?>, > o ' an WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-845 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. Plaintiff (s) From NORMA JEAN CHAPMAN (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 $149,413.43 L.L.$.50 Interest FROM 8/24/2010 TO DATE OF SALE ($24.56 PER DIEM) --- $6,925.92 Atty's Comm % Atty Paid $175.80 Plaintiff Paid Date: 12/14/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs I t( D &,to David . Buell, Pro not By: Deputy Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JFK BLVD., SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNCED AND DESCRIBED ACCORDING TO A SURVEY OF ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED April 24, 1967, AS FOLLOWS: BEGINNING AT A POINT ON THE Southwesterly LINE OF BRIDGE Street, (FIFTY (50) FEET WIDE) WHICH POINT IS LOCATED TWO HUNDRED TWENTY-ONE AND THIRTY-FOUR HUNDREDTHS (221.34) FEET Southeastwardly FROM 16TH Street AND WHICH POINT IS ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON THE HEREINAFTER MENTIONED Plan OF Lots; THENCE CONTINUING Southeastwardly ALONG SAID LINE OF BRIDGE Street FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 3 AND 4 OF SAID Plan; THENCE South FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES West ALONG SAID DIVIDING LIE ONE HUNDRED FIFTY (150) FEET TO A STAKE ALONG SAID LIE OF THE SIXTEEN (16) FOOT ALLEY; THENCE North FORTY-FIVE (45) DEGREES West FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON SAID Plan; THENCE North FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES East ALONG THE LAST SAID DIVIDING LINE ONE HUNDRED FIFTY (150) FEET TO A POINT IN THE Southerly LINE OF BRIDGE Street, THE PLACE OF BEGINNING BEING Lot No. 4, Section D, on the Plan of Hillside, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75. HAVING THEREON erected a two and one-half (2 ''/2) story frame dwelling house known as No. 1544 Bridge Street. UNDER AND SUBJECT to easements, restrictions, reservations, conditions and rights-of-way of record. TITLE TO SAID PREMISES IS VESTED IN Norma Jean Chapman, single person, by Deed from Karen B. Fincham, single person, dated 05/24/2003, recorded 05/28/2004 in Book 263, Page 1199. PREMISES BEING: 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 PARCEL NO. 26-23-0541-149 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 FILED-OFFICE One Penn Center Plaza OF THE PROTHONOTARY Philadelphia, PA 19103 215-563-7000 2010 DEC 14 P11 1: 54 RBS CITIZENS, N.A. F/K/A CITIZENS B)&I W" Y CCO MORTGAGE CORP. Plaintiff v. NORMA JEAN CHAPMAN Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 10-845 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. ?J Y. Attorney for Plaintiff 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 ? Allison F. Wells, Esq., Id. No. 309519 ROS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S?B/M TO CCO MORTGAGE CORP. FILED-OFFICE i Plaintiff OF THE PROTHONOTARY V. 2010 DFC, 14 PM 1: 54 NORMA JEAN CHAPMAN Defendant(s) CUI BER,LANID COUNTY PENINSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-845 CIVIL TERM CUMBERLAND COUNTY PHS # 228478 AFFIDAVIT PURSUANT TO RULE 3129.1 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP., 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 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119. Name and address of Owner(s) or reputed Owner(s): Name NORMA JEAN CHAPMAN 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 411 ROSS AVENUE NEW CUMBERLAND, PA 17070 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) New Cumberland Borough 1120 Market Street; P.O. Box 220 New Cumberland, PA 17070 New Cumberland Borough 127 South Market Street; P.O. Box 95 C/o: Andrew C. Sheely, Esquire Mechanicsburg, PA 17055 4. 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. 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: y Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Norma Jean Chapman, Pro Se 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 411 Ross Avenue New Cumberland, PA 17070 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 unworn falsification to authorities. December 2010 By: Attorney for Plaintiff 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 ? Allison F. Wells, Esq., Id. No. 309519 RBS CITIZENS, N.A. F/K/A FkTM1f?NK, N.A. SB/M TO : COURT OF COMMON PLEAS CCO MORTGAGE COIF-THE PROTHONOTARY : CIVIL DIVISION 2010 DEC 14 PM 1: 54 Plaintiff : 1,U''iOt DAND COUNTY : NO.: 10-845 CIVIL TERM ? ?'17 S Y LVA NIA NORMA JEAN CHAPMAN CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NORMA JEAN CHAPMAN NORMA JEAN CHAPMAN 1544 BRIDGE STREET 411 ROSS AVENUE NEW CUMBERLAND, PA 17070-1119 NEW CUMBERLAND, PA 17070 "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 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 is scheduled to be sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $149,413.43 obtained by RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. (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. b 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 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-845 CIVIL TERM RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. VS. NORMA JEAN CHAPMAN owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland County, Pennsylvania, being (Municipality) 1544 BRIDGE STREET. NEW CUMBERLAND. PA 17070-1119 Parcel No. 26-23-0541-149 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $149,413.43 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNCED AND DESCRIBED ACCORDING TO A SURVEY OF ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED April 24, 1967, AS FOLLOWS: BEGINNING AT A POINT ON THE Southwesterly LINE OF BRIDGE Street, (FIFTY (50) FEET WIDE) WHICH POINT IS LOCATED TWO HUNDRED TWENTY-ONE AND THIRTY-FOUR HUNDREDTHS (221.34) FEET Southeastwardly FROM 16TH Street AND WHICH POINT IS ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON THE HEREINAFTER MENTIONED Plan OF Lots; THENCE CONTINUING Southeastwardly ALONG SAID LINE OF BRIDGE Street FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 3 AND 4 OF SAID Plan; THENCE South FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES West ALONG SAID DIVIDING LIE ONE HUNDRED FIFTY (150) FEET TO A STAKE ALONG SAID LIE OF THE SIXTEEN (16) FOOT ALLEY; THENCE North FORTY-FIVE (45) DEGREES West FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON SAID Plan; THENCE North FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES East ALONG THE LAST SAID DIVIDING LINE ONE HUNDRED FIFTY (150) FEET TO A POINT IN THE Southerly LINE OF BRIDGE Street, THE PLACE OF BEGINNING BEING Lot No. 4, Section D, on the Plan of Hillside, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75. HAVING THEREON erected a two and one-half (2 %i) story frame dwelling house known as No. 1544 Bridge Street. UNDER AND SUBJECT to easements, restrictions, reservations, conditions and rights-of-way of record. TITLE TO SAID PREMISES IS VESTED IN Norma Jean Chapman, single person, by Deed from Karen B. Fincham, single person, dated 05/24/2003, recorded 05/28/2004 in Book 263, Page 1199. PREMISES BEING: 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 PARCEL NO. 26-23-0541-149 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-845 CIVIL TERM RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. vs. NORMA JEAN CHAPMAN owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland County, Pennsylvania, being (Municipality) 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 Parcel No. 26-23-0541-149 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $149,413.43 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. PHS # 228478 0 DEFENDANT NORMA JEAN CHAPMAN SERVICE TEAM/ kxc COURT NO.: 10-845 CIVIL, TERM SERVE NORMA JEAN CHAPMAN AT: TYPE OF ACTION t7 ,, 1544 BRIDGE STREET XX Notice of Sheriff's Sale 06/01/2011 E DATE C= ` = -~ : NEW CUMBERLAND, PA 17070-1119 SAL 0 ['NCO ,n , --v Z:m rn cc M -= SERVED Served and made known to NORMA JEAN CHAPMAN , Defendant on the _ day of ?/ !alt --tca QyE, IYEweuMfAPt P91n the manner described below: 11:4 S, o'clock ,4 M., at 411 QoSS < ^~t _ _I/ Defendant personally served. n ° Adult family member with whom Defendant(s) reside(s). Ca t? _ Relationship is .{ r > - 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. of _jpNL, 2016• Notary: By: NOT SERVED On the ay 20_, at o'clock _. M., Defendant NOT FOUND because: V _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at _ Other: Description: Age / 60" Height 16 Weight '.2 5-6 Race Vj Sex F Other I, ipJNM,,1 N10 Lt„ 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. 5' I y Ifs tT , I N VLS 77 6*1-7 6,-J 15CLA" Sworn to and subscribed 71la7tT c ND4sit W IDES C6 411 112265s- h E before me this -2-*U day PP. (U M 6%Qt q?14 P11 Service Refused Other: KIMBERLY CURTY Sworn to and subscribed IpRY PUBLIC before me this day : OF NEW JERSEY ofBy: MY COMON EXPIR RCH 7 2013 Notary: LAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallhum, 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 Shectal 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 Allison F. Wells, Esq.„ Id. No. 309519 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 191113-1814 (215) 563-7000 1 r C=) -"i -? M03 M 3s M r - `.? cnr o rn ;z3 - c:) o r :;>C-) C3-q Z e C N -?M 7 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RBS CITIZENS, N.A. F/K/A CITIZENS BANK, Court of Common Pleas N.A. S/B/M TO CCO MORTGAGE CORP. Plaintiff Civil Division V. CUMBERLAND County NORMA JEAN CHAPMAN No.: 10-845 CIVIL TERM Defendant RULE AND NOW, this day of ,0 2011, a Rule is entered upon the Defendant 01 to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading to Plaintiff s Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY OURT J7 228478 A 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 NORMA JEAN CHAPMAN NORMA JEAN CHAPMAN 1544 BRIDGE STREET 411 ROSS AVE NEW CUMBERLAND, PA 17070-1119 NEW CUMBERLAND, PA 17070-2619 Allison Y' WIS, &t PN4-5 ?ples 228478 228478 i' -CFFICL T` FROTHOHOTAT,'? 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 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. Plaintiff V. NORMA JEAN CHAPMAN Defendant 'Ii APR 20 1lli If: ', CUMBERLAND COU10 T d? PENNSYLVANIA ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-845 CIVIL TERM CERTIFICATION OF SERVICE 228478 I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of May 3, 2011 was sent to the following individual on the date indicated below. NORMA JEAN CHAPMAN NORMA JEAN CHAPMAN 1544 BRIDGE STREET 411 ROSS AVE NEW CUMBERLAND, PA 17070-1119 NEW CUMBERLAND, PA 17070-2619 Phelan Hallinan & Schmieg, LLP DATE: `1 I M I t t By: 'jLAl/ ? - ? Lawrence T. Phelad, 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 ? J dith 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 ATTORNEY FOR PLAINTIFF 228478 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. Plaintiff, v NORMA JEAN CHAPMAN Defendant(s) Q? CUMBERLAND COU COURT OF COMMO* EA9 F ?D CIVIL DIVISION C-) No.: 10-845 CIVIL TER3?4C c ; : t AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: oC) ?Z-n r1 T? r 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 address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certi ' 'Return Receipt stamped by the U.S. Postal Service is attached hereto E, `-'7 Date: 2 Z ? Lawrenc an , Esq., Id. No. 32227 ? Francis S allinan, Esq., Id. No. 62695 ? Daniel chmieg, Esq., Id. No. 62205 ? Mic 1 Bradford, Esq., Id. No. 69849 ? Jud 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. Jo ; Esq., Id. No. 86657 ? P 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 Attorney for Plaintiff IMPORTAN 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 # 228478 1 1 ao a? r U ? PA U x??4 a`.-°Oa t yy 61 N q Q = 8_ w 046L 3009d1Zwou:i0mim °.t ?O ?o OWZ g 01030 9SZLLWp o 10 o?aEO $ o? ?3 0 y av?i y a ??a ?? ? ' 20? 5 1 t" S i 1 C^ W [ N ? y V7 b r, ° o 04 ?. . 42 i Q? N ?e Lam U w s d Q CD d 6 ? 'O ?e ? ? ? ? p , v1 a a F a '" ?, a. a ' S R7G o o = e? , , bow o ? ° r ? dW? ?zeW q q Len ? = 4, u n w aN ? qN ao w e? ° °..Clr ? 0; O a. . % Pq 5 a .q?? S d VwW U ot? ?w d q dd .,,, dqw o s.d 9 x ?++a ° w agOul L a v ,? 9 q•., ? -- ova w ..? ..rn.,# _, ?.? q ?? w o i7 d C N O oh a a: a ? ' CD s? ex z ,? Z ???v uc ax ?10 Nt z?i ?t4 z . ` d 4 c o er * w y O? a~ N M h b t - o o a .?r' q e4 e n vt F IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RBS CITIZENS, N.A. F/K/A CITIZENS BANK, Court of Common Pleas N.A. S/B/M TO CCO MORTGAGE CORP. Plaintiff Civil Division vs. CUMBERLAND County NORMA JEAN CHAPMAN No.: 10-845 CIVIL TERM Defendant ORDER r I CD r AND NOW, this /1-'day of r? 2011, upon consideration of Pl tff s -+c:) Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the R nte& upon Defendants shall be and is hereby made absolute and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $127,932.37 Interest Through June 1, 2011 $21,272.80 Per Diem $24.97 Late Charges $1,057.97 Legal fees $1,300.00 Cost of Suit and Title $870.00 Property Inspections/ Property Preservation $815.00 Escrow Deficit $11,628.32 TOTAL $164,876.46 Plus interest from June 1, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. ?OJm ua.Z Goidman , Norma Jw-n Opmu BY T E COUIR : -J94- J. 228478 t ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 7:'! L u0- F ?f - Sheriff ????1' ,i C?ru+brrl,r0 1T? -' Jody S Smith Chief Deputy -Zr: ? !. Richard W Stewart Solicitor C YL'>ft RBS Citizens, N.A. Case Number vs. Norma Jean Chapman 2010-845 SHERIFF'S RETURN OF SERVICE 03/10/2011 08:54 PM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1544 Bridge Street, New Cumberland, PA 17070, Cumberland County. 06/01/2011 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, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Atty Daniel Schmieg, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $775.32 August 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 412 ,A':* 6? 4,,-) (,63 r , S CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. /M TO CCO MORTGAGE CORP. Plaintiff ' v. NORMA JEAN CHAPMAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-845 CIVIL TERM . CUMBERLAND COUNTY PHS # 228478 AFFIDAVIT PURSUANT TO RULE 3129.1 RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP., 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 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) NORMA JEAN CHAPMAN 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 411 ROSS AVENUE NEW CUMBERLAND, PA 17070 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) New Cumberland Borough 1120 Market Street; P.O. Box 220 New Cumberland, PA 17070 New Cumberland Borough C/o: Andrew C. Sheely, Esquire 127 South Market Street; P.O. Box 95 Mechanicsburg, PA 17055 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. 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 Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Norma Jean Chapman, Pro Se 1544 BRIDGE STREET NEW CUMBERLAND, PA 17070-1119 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 411 Ross Avenue New Cumberland, PA 17070 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 unworn falsification to authorities. )W-?Avo December 2010 By. Attorney for Plaintiff 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 ? Allison F. Wells, Esq., Id. No. 309519 Rl* CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO COURT OF COMMON PLEAS CCO MORTGAGE CORP. CIVIL DIVISION Plaintiff : NO.: 10-845 CIVIL TERM VS. NORMA JEAN CHAPMAN : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NORMA JEAN CHAPMAN NORMA JEAN CHAPMAN 1544 BRIDGE STREET 411 ROSS AVENUE NEW CUMBERLAND, PA 17070-1119 NEW CUMBERLAND, PA 17070 "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 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 is scheduled to be sold at the Sheriffs Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $149,413.43 obtained by RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. (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 Sheriffs 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 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-845 CIVIL TERM RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. VS. NORMA JEAN CHAPMAN owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland County, Pennsylvania, being (Municipality) 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 Parcel No. 26-23-0541-149 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $149,413.43 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, PENNSYLVANIA, MORE PARTICULARLY BOUNCED AND DESCRIBED ACCORDING TO A SURVEY OF ERNEST J. WALKER, PROFESSIONAL ENGINEER, DATED April 24, 1967, AS FOLLOWS: BEGINNING AT A POINT ON THE Southwesterly LINE OF BRIDGE Street, (FIFTY (50) FEET WIDE) WHICH POINT IS LOCATED TWO HUNDRED TWENTY-ONE AND THIRTY-FOUR HUNDREDTHS (221.34) FEET Southeastwardly FROM 16TH Street AND WHICH POINT IS ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON THE HEREINAFTER MENTIONED Plan OF Lots; THENCE CONTINUING Southeastwardly ALONG SAID LINE OF BRIDGE Street FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 3 AND 4 OF SAID Plan; THENCE South FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES West ALONG SAID DIVIDING LIE ONE HUNDRED FIFTY (150) FEET TO A STAKE ALONG SAID LIE OF THE SIXTEEN (16) FOOT ALLEY; THENCE North FORTY-FIVE (45) DEGREES West FIFTY (50) FEET TO A STAKE ON THE LINE DIVIDING Lots NOS. 4 AND 5 ON SAID Plan; THENCE North FORTY-FOUR (44) DEGREES THIRTY (30) MINUTES East ALONG THE LAST SAID DIVIDING LINE ONE HUNDRED FIFTY (150) FEET TO A POINT IN THE Southerly LINE OF BRIDGE Street, THE PLACE OF BEGINNING BEING Lot No. 4, Section D, on the Plan of Hillside, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 75. HAVING THEREON erected a two and one-half (2 ''/z) story frame dwelling house known as No. 1544 Bridge Street. UNDER AND SUBJECT to easements, restrictions, reservations, conditions and rights-of-way of record. TITLE TO SAID PREMISES IS VESTED IN Norma Jean Chapman, single person, by Deed from Karen B. Fincham, single person, dated 05/24/2003, recorded 05/28/2004 in Book 263, Page 1199. PREMISES BEING: 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119 PARCEL NO. 26-23-0541-149 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COTJ- NTY OF CUMBERLAND) NO 10-845 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RBS CITIZENS, N.A. F/K/A CITIZENS BANK, N.A. SB/M TO CCO MORTGAGE CORP. Plaintiff (s) From NORMA JEAN CHAPMAN (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 ------- --- payinganytleb?to?rf t-(s)-and-fram-delivering-any-Ixoperty-ekhe-de ndant- (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 $149,413.43 L.L.$.50 Interest FROM 8/24/2010 TO DATE OF SALE ($24.56 PER DIEM) --- $6,925.92 Atty's Comm % Due Prothy $2.00 Atty Paid $175.80 Other Costs Plaintiff Paid Date: 12/14/10 David . Buell, Pr otary (Seal) By. Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JFK BLVD., SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 TRUE DOPY F;3C7M RECORD In Testimony whereof, I here unto set my hand and the seal-of saia Court at Carlisle. Pa' -Lb This L `"gay cf, • proth. •?otary On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Known and numbered as, 1544 Bridge Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-845 Civil RBS Citizens, N.A. VS. Norma Jean Chapman Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 10-845 CIVIL TERM, RBS CITI- ZENS, N.A. F/K/A CITIZENS BANK, N.A. S/B/M TO CCO MORTGAGE CORP. vs. NORMA JEAN CHAPMAN, owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland County, Pennsylvania, being 1544 BRIDGE STREET, NEW CUMBERLAND, PA 17070-1119. Parcel No. 26-23-0541-149. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $144,319- .55. 12 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 22, April 29, and May 6, 2011 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'Aisa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this _ LdLofMagy, 2011 l?C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 A The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe Patr1*otwXtws Now you k110W 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 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. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 ? 04/29/11 Vs 05/06/11 Aar: Do" sdalfte ? ., ....... . yvlue of a Writ of Eaea lion NO. 10- ........ 8455CIMTERM RBS Cfi VZK N.A. F/KfA CPt'MS BANCNA. 4TOCCO Swor re a this 23 dray f May, 2011 A.D. MORTQAOE C? N?A J v CHAPMAN of propwy iu the Bt?RUtiGHOFNEWCUMBERLAM, Notary Public Cumberland county, Pe-ylvan* being 1 STREET, NEW t CL MBERLAND, PA 17090.1119 Patxd No. 26.3341541-144 , (Acreage or etwxtaddm* COMMONWEALTH OF PENNSYLVANIA h%vo mmanis dmm m: AESME Ti7AL Notarial seal DWEUJM Sherrie L Klsner, Note JUDQ99g ? 1144,3105 Lower Paxton TwR Notary P , Dauphin County County My Commission BOM NOV. 26, 2011 Member, PennsYN-dr4a /lssociatim of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Association is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 14 day of December, A.D., 202010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 845, at the suit of RBS Citizens N.A. F/K/A Citizens Bank, N.A. SB/M to CCO Mortgage CgM. against Norma Jean Chapman is duly recorded as Instrument Number 201121365. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a-) day of A.D.?- ' Recorder o?lDeeds ?ecarder of Cee?, t teie, AA ?AY Commission Wk u dw Fret ti w4N of Jon. =4