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HomeMy WebLinkAbout10-0989Phelan 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 L, ,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 229144 CHASE HOME FINANCE, LLC 3415 VISION DRIVE COLUMBUS, OH 43219 V. Plaintiff BARBARA E. WILT 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 Defendant ,?, F?ILED-<DrcCE (?C THr_ PROMONOTARY 2010 FEB -5 PM 2: C4 PDIA -.'l?Ai A ATTORNEY FOR PLAINTIFF CIVIL DIVISION COURT OF COMMON PLEAS TERM NO. 10 - q$q a-tVit terM CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE, FORECLOSITRF O 4qa. Do P 0 AT'M ?„w go8943 Pa3??3 File #: 229144 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 229144 Plaintiff is CHASE HOME FINANCE, LLC 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known addresses) of:the"Defendant(s) are: BARBARA E. WILT 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/29/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR M&T MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1978, Page 1547. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 10/01/2009 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 #: 229144 6. The following amounts are due on the mortgage: Principal Balance $100,682.29 Interest $2,868.39 09/01/2009 through 02/04/2010 (Per Diem $18.27) Attorney's Fees $650.00 Cumulative Late Charges $173.00 12/29/2006 to 02/04/2010 Costs of Suit and Title Search $550-00 Subtotal $104,923.68 Escrow Credit $0.00 Deficit $850.50 Subtotal 850.50 TOTAL $105,774.18 7. Plaintiff is nat seeking a judgment of personal liability (or an in p .re_ nnam 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. 8. 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 #: 229144 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $105,774.18, together with interest from 02/04%2010 at the rate of $18.27 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: - L 1,A ? Lawrence T. Phel , Esq., Id. No. 32227 ? Francis S. Hallin , 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 Ceiter s, Esq., Id. No. 86657 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 File #: 229144 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Registered Surveyor, dated March 18, 1972, as follows: BEGINNING at a point on the southern line of Herman Avenue, which point is 186.1 feet measured eastwardly along the southern line of Herman Avenue from the; sout eastern corner of Second Street and Herman Avenue; thence along the southern line or Herman Avenue North 57 degrees East 17 feet to a comer of premises known as No. 126 Herman Avenue; thence along said premises and passing through the center of a partition wall South 33 degrees East 90 feet to a point in line of land of the Reading Railroad Company; thence along said land South 42 degrees 11 minutes West 17.58 feet to a comer of premises known as No. 134 Herman Avenue; thence along said premises North 33 degrees West 94.5 feet to the point and Place of BEGINNING. HAVING THEREON erected the western one half of a two-story frame double dwelling, known as No. 128 Herman Avenue, Lemoyne, Pennsylvania. BEING the same premises which Ralph M. Rhoads, a single man, and Shirley M. Rhoads, a single woman, by Deed dated June 2, 1972 and recorded June 15, 1972 in the O#fice of the Recorder of Deeds in and for Cumberland County in Deed Book R, Volume 24, Page 80, granted and conveyed unto Frank P. Belicic and Diane J. Belicic, his wife, the Grantors herein. The said Frank P. Belicic died January 27, 1977, thereby vesting title solely in the name of his wife, Diane J. Belicic. PREMISES BEING: 128 HERMAN AVE PARCEL#: 12-21-0265-426 File #: 229144 , r The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Couit an&6r.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. WQ. DATE: Attorney for Plainti File #: 229144 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor T FILED i?, it- ,? C' 1' 1;^f,if?1?AL11 2010 FEB 16 PH 2: 14 L?' ? I r ff?1T-.. L ,r''- A' 1 f Chase Home Finance LLC vs. Barbara E. Wilt Case Number 2010-989 SHERIFF'S RETURN OF SERVICE 02/08/2010 04:05 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on February 8, 2010 at 1605 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Barbara E. Wilt, by making known unto herself personally, at 128 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 February 09, 2010 SO ANSWERS, y NY R ANDERSON, SHERIFF By Deputy eriff Tel FLED - Fi r tDF ?1!E PATH`'?^!TA?Y 2010 KAR -9 AM 10: Iii4 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 Nly ATTORNEY FOR PLAINTIFF CHASE HOME FINANCE, LLC Plaintiff VS. : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 10-989 CIVIL TERM BARBARA E. WILT CUMBERLAND COUNTY Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 229144 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: (/ "w?-- ? La rence 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 Date: 3-2-10 PHS #: 229144 VERIFICATION Whitney K. Cook hereby states that he/she is of CHASE HOME FINANCE LLC, servicing agent for Plaintiff, CHASE HOME FINANCE LLC, 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. "" J(:?? DATE. Company: CHASE HOME FINANCE LLC File #: 229144 Wilt Phelan Hallman & 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 Plaintiff VS. BARBARA E. WILT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : NO. 10-989 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 #: 229144 BARBARA E. WILT 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: l/ v -A?-? ? L wrence 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 ? 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 Date: 3-2-10 PHS #: 229144 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 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 CHASE HOME FINANCE, LLC VS. BARBARA E. WILT P-F THE PR0TNo1&%±C3TARY AlpMROM Ila f f : 07 CUMBE` i :, , 7Y PENNS)1%1rW : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-989 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 BARBARA E. WILT, 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: SIN 0?pd-A, ?/J rkOf.,-) d/f k"O' J3Woa t4p-1Lt A,4-'I'd As set forth in Complaint $105,774.18 Interest - 02/05/2010 to 03/16/2010 $730.80 TOTAL $106,504.98 I hereby certify that (1) the Defendant's last known address is 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935, and (2) that notice has been given in accordance with Rule 237.1, copy attached. /A La e ce T. Phelan Esquire F ci S. al in , Esquire aniel eg, 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 hrisovalante P. Fliakos, Esquire "Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS # 229144 PROTHONOTARY 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 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE, LLC VS. BARBARA E. WILT : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-989 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 BARBARA E. WILT is over 18 years of age and resides at 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. LJ La w5f n LH, lan, sq:, Id. No. 32227 ? Fr cis an, sq., Id. No. 62695 ? D el ,Esq., Id. No. 62205 ? Michelford, 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 ff hrisovalante P. Fliakos, Esq., Id. No. 94620 o shua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised CHASE HOME FINANCE, LLC VS. BARBARA E. WILT : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-989 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: ? 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 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * 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 BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY" CHASE HOME FINANCE, LLC v Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-989 CIVIL TERM BARBARA E. WILT Defendant(s) TO: BARBARA E. WILT 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 DATE OF NOTICE: March 3, 2010 CUMBERLAND COUNTY 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 WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED 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. PHS # 229144 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 , (717) 249-3166 By: Lawren T Phelan, Esq., d. No. 32227 Franc. S. Ilinan, Es d. No. 62695 Daniel G. Sc ie q., 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 risovalante P. Fliakos, Esq., Id. No. 94620 lhua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 229144 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE HOME FINANCE, LLC Plaintiff : COURT OF COMMON PLEAS . CIVIL DIVISION V. BARBARA E. WILT Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 03/17/2010 to Date of Sale ($17.51 per diem) : NO. 10-989 CIVIL TERM COUNTY 3 081.76 TOTAL A[forney for Plaintiff Phelan Hallinan & Schmie , 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, Es ., Id. No. 69849 ? Judith T. Romano, Esq., I . 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., I . 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., d. No. 90134 ? Chrisovalante P. Fliakos, sq., Id. No. 94620 ? Joshua I. Goldman, Esq., . No. 205047 r7lCourtenay R. Dunn, Esq., d. No. 206779 Andrew C. Bramblett, Es ., Id. No. 208375 Note: Please attach description of property. PHS # 229144 4y T•" v ? M Qom. ,? tit tci O b ci CT zin vt r br Ai v d d ao U a? U W xW a C o n U W E A W 7 ?U %n eel 0 H H w v J 3 ? d O ` rn?r?r.c?r?po MM Gv?iON N?p00 ? r- cn r- cn, n r- O p? r- c J-m 5,.: 4), A 4 Val 401. ?ppCJ4ppppp da LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Registered Surveyor, dated March 18, 1972, as follows: BEGINNING at a point on the southern line of Herman Avenue, which point is 186.1 feet measured eastwardly along the southern line of Herman Avenue from the southeastern corner o Second Street and Herman Avenue; thence along the southern line of Herman Avenue North 17 degrees East 17 feet to a corner of premises known as No. 126 Herman Avenue; thence along said premises and pass' g through the center of a partition wall South 33 degrees East 90 feet to a point in line of land of the Reading - ilroad Company; thence along said land south 42 degrees 11 minutes West 17.58 feet to a corner of preises known as No. 134 Herman Avenue; thence along said premises North 33 degrees West 94.5 feet to a point and place of BEGINNING. HAVING THEREON ERECTED the western one-half of a two story frame double d' 128 Herman Avenue, Lemoyne, Pa. TITLE TO SAID PREMISES IS VESTED IN Barbara E. Wilt, a single person, by Belicic, widow, dated 12/29/2006, recorded 01/04/2007 in Book 278, Page 1264. PREMISES BEING: 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935 PARCEL NO. 12-21-0265-42612000577 known as No. from Diane J. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE, LLC Plaintiff V. BARBARA E. WILT Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS ,APY OF PRO 2010 HAS? 214 y r? ?1 i r 1•° : CIVIL DIVISION : NO. 10-989 CIVIL TERM CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the 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 authorities. By: COUNTY in the above captioned ing to unsworn falsification to Attaffey for Plaintiff Phelan Hallinan & Schmi g, LLP ? Lawrence T. Phelan, Es q., Id. No. 32227 ? Francis S. Hallinan, Esq, Id. No. 62695 ? Daniel G. Schmieg, Esq, Id. No. 62205 ? Michele M. Bradford, E q., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Es q., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., d. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., I . 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, E $q., Id. No. 208375 CHASEelOME FINANCE, LLC COURT OF COMMON PLEAS Igintiff FILED-OF-ra ' ?r OF ?NEE FT ; t??-p??y CIVIIL DIVISION V. 29 10 MAR 2 i4 fir, 10: 07 NO. 0-989 CIVIL TERM BARBARA E. WILT Defendant(s) ;Y CU1 BERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE, LLC, Plaintiff in the above action, by the undersigned attome , sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property to ated at 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935. 1 2 3 4 5. Name and address of Owner(s) or reputed Owner(s): Name BARBARA E. WILT Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be r ascertained, please so indicate) 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 Address (if address cannot be r ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien Name Address (if address cannot be reasonably ascertained, please indic None. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please 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 None. 6. Name and address of every other person who has any record interest in the property and sale. Name Address (if address cannot be reasonably ascertained, please ind the real property to be sold: interest may be affected by the None. Narare 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: ,came Address (if address cannot be reasonably ascertained, please indic#te) TENANT/OCCUPANT Domestic Relations of Cumberland County 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 13 North Hanover Street Carlisle, PA 17013 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 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6`h Floor, Strawberry Sq., Dept Harrisburg, PA 17128 13TH Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the knowledge or information and belief. I understand that false statements herein are of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. March 19, 2010 of my personal e subject to the penalties By: _ A ey for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 2695 ? Daniel G. Schmieg, Esq., Id. No. 2205 ? Michele M. Bradford, Esq., Id. N .69849 ? Judith T. Romano, Esq., Id. No. 5 745 ? Sheetal R. Shah-Jani, Esq., Id. No 81760 ? Jenine R. Davey, Esq., Id. No. 87 77 ? Lauren R. Tabas, Esq., Id. No. 93 37 ? Vivek Srivastava, Esq., Id. No. 20 331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61 91 ? Andrew L. Spivack, Esq., Id. No. 4439 ? Jaime McGuinness, Esq., Id. No. 0134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 5047 Courtenay R. Dunn, Esq., Id. No. 06779 ? Andrew C. Bramblett, Esq., Id. N . 208375 CHASE HOME FINANCE, LLC THE AILED-OFrTrT OF FD""T :? ? ITARY Plaintiff ZOi0 MAR 24 Pill 10: v 7 BARBARA E. WILT VS. Cu r, C' TO: BARBARA E. WILT 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 COURT OF COMMON PLEAS : CIVILIDIVISION NO. 10 989 CIVIL TERM 1.1Y ?: CUM RLAND COUNTY Defendant(s) : "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT rDA INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVDI CHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COL ECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935 is scheduled to be sold at the Sheriff's Sale on 09/08/2010 at 10:00 AM in the Cumberland County C urthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $106,504.98 obtained by CHASE HOME FINANCE, LLC (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: i215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to s ike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone a 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 c have of stopping the sale. (See notice on page two on how to obtain an attorney.) 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 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 to the value of your property. the more chance you will You may find out the inadequate compared 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 ?wrier 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 toe ict you. 6. You may be entitled to a share of the money which was paid for your house. A roposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not lat r than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made availa le 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 wro g) 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 after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF Y LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE O] 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 if you act immediately DO NOT HAVE A CE LISTED BELOW SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-989 CIVIL TERM CHASE HOME FINANCE, LLC vs. BARBARA E. WILT owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumbe land County, Pennsylvania, being (Municipality) 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935 Parcel No. 12-21-0265426 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $106,504.98 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of Lemoyne, Ciu Pennsylvania, bounded and described in accordance with a survey and plan thereof Registered Surveyor, dated March 18, 1972, as follows: BEGINNING at a point on the southern line of Herman Avenue, which point is 186.1 eastwardly along the southern line of Herman Avenue from the southeastern corner o Herman Avenue; thence along the southern line of Herman Avenue North 17 degrees of premises known as No. 126 Herman Avenue; thence along said premises and passi a partition wall South 33 degrees East 90 feet to a point in line of land of the Reading thence along said land south 42 degrees 11 minutes West 17.58 feet to a corner of pre 134 Herman Avenue; thence along said premises North 33 degrees West 94.5 feet to BEGINNING. HAVING THEREON ERECTED the western one-half of a two story frame double d 128 Herman Avenue, Lemoyne, Pa. TITLE TO SAID PREMISES IS VESTED IN Barbara E. Wilt, a single person, by Belicic, widow, dated 12/29/2006, recorded 01/04/2007 in Book 278, Page 1264. PREMISES BEING: 128 HERMAN AVENUE, LEMOYNE, PA 17043-1935 PARCEL NO. 12-21-0265-42612000577 and County, by Gerrit J. Betz, feet measured 'Second Street and East 17 feet to a corner ag through the center of Railroad Company; nises known as No. he point and place of known as No. Deed from Diane J. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NOIO-989 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE, LLC PI intiff (s) From BARBARA E. WILT (1) You are directed to levy upon the property of the defendant (s)and to sell SEE 1 EGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon ?n the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gami paying any debt to or for the account of the defendant (s) and from delivering any (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is fol of anyone other than a named garnishee, you are directed to notify him/her that he garnishee and is enjoined as above stated. Amount Due$106,504.98 L.L. $.50 Interest from 3/17/10 TO DATE OF SALE ($17.51 PER DIEM) - $3,081.76 Atty's Comm % Due Prothy $2.00 Atty Paid $174.90 Other Costs Plaintiff Paid Date: MARCH 24, 2010 (Seal) By: Deputy REQUESTING PARTY: Name COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP, 1617 JFK BOULEVARD PENN CENTER PLAZA, PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 is enjoined from of the defendant in the possession has been added as a 1400, ONE AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY CHASE HOME FINANCE, LLC PHS # 229144 DEFENDANT BARBARA E. WILT SERVE BARBARA E. WILT AT: 128 HERMAN AVENUE LEMOYNE, PA 17043-1935 SERVED Served and made known to -BAASW '?U i L? Defendant on the SQ ? 7day of Ql L 20 LO d 3:47 , o'clock P. M., at 1 rA ? al z M Ni;, P,4 , in the manner described below: it ca Defendant personally served. ?Adult family member with whom Defendant(s) reside(s). Relationship is N - N- `? - Adult in charge of Defendant's residence who refused to give name or relationship. ' - Manager/Clerk of place of lodging in which Defendant(s) reside(s)._ "a - Agent or person in charge of Defendant's office or usual place of business. W an officer of said Defendant's company. O Other: _ Description: Age 2D S Height 5'35* Weight I ri o Race W Sex _M_ Other 1, ?R6-1*44't-0 Nl D L L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _36+- day of Riff 2014 Not Onq 20_, at - Vacant Bad Address No Answer _ Service Refused Other: Sworn to and subscribed before me this day By: Notary: SERVICE TEAM/ iin COURT NO.: 10-989 CIVIL TERM TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 09/08/2010 -t rxi i3 -c KIMBERLY C'1RTY NOTr?RY M!lLiC STATE OF ti`$H' 3ERSFY COMMIssioN, rV IRES MARCH 7, 2013 NOTSERVED o'clock _. M., Defendant NOT FOUND because: Moved _ Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF 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 Sheelal 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. Joins, 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 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FELEL~--~~`~i - ,. tv°tiStt~r pf ~urnbrr~~0 ~; ~_ ,. 201 J%D~d -4 A~ $~ 26 J;;~` -?` QFfiGE £"dF'•~~ ; rtiRIFF ,a i~.~~{ ~ ; 1~I~ a Chase Home Finance LLC vs. Barbara E. Wilt Case Number 2010-989 SHERIFF'S RETURN OF SERVICE 06/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Schmieg on 5/25/10 SHERIFF COST: $94.78 SO ANSWERS, June 01, 2010 RON R ANDERSON, SHERIFF . ~ i~ ~, ,. ~~3 ~?y (c GounfySuite Sheriff. Teteosnfi Inc.