HomeMy WebLinkAbout10-2043
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
CIVIL DIVISION
NO.: 10 - S10 43
TYPE OF PLEADING
o'-vi ( Tem
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
TO DEFENDANTS
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
?_. ,c.? A
ATTORNEY FOR PLAINTI
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANTS IS:
23 Adams Street
EEnnola, PA 17025
ATTORNEY FOP, PLAI F
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
23 Adams Street
East Pennsboro Township
(CITY, BORO, TOWNSHIP,WARD)
ATTvOMEY FOR PLAINT
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
?stine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
P
I
D
#89240
a.
.
.
GRENEN & BIRSIC, P.C. q... a
n
One Gateway Center i7-3
Ninth Floor s {
Pittsburgh, PA 15222
(412) 281-7650
ft-oo PD A-M4
CO IA5q a
e aag3aCo
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO..
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.:
VS.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its
attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage
Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio
43219 and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendants, Robert C. Cassel and Tanya K. Cassel, are individuals whose last
known address is 23 Adams Street, Enola, PA 17025.
3. On or about November 24, 2004, Defendants executed a Note in favor of Plaintiff
in the original principal amount of $56,769.00. A true and correct copy of said Note is marked
Exhibit "A," attached hereto and made a part hereof.
4. On or about November 24, 2004, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $56,769.00 on the premises hereinafter described, said Mortgage being recorded in the Office
of the Recorder of Deeds of Cumberland County on February 18, 2005 in Mortgage Book
Volume 1897, Page 3095. A true and correct copy of said Mortgage containing a description of
the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part
hereof.
5. Defendants are the record and real owners of the aforesaid mortgaged premises.
6. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the October 1, 2009 payment.
7. On or about December 2, 2009, Defendants were mailed combined Act 91 and
Act 6 Notices, via certified mail, return receipt requested, and by first class mail, in compliance
with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974,
41 P. S. §101, et seq.
8. The amount due and owing Plaintiff by Defendants is as follows:
Principal $53,030.31
Interest to 2/26/10 $ 1,590.90
Late Charges to 2/26/10 $ 58.48
Escrow Deficiency to 2/26/10 $ 0.00
Corporate Advances $ 21.51
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $58,501.20
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $58,501.20 with interest thereon at the rate of $8.72 per diem from February 26, 2010, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
- 1410 I NAt NOTE
17908076
1179080766
23 ADAMS ST, ENOLA, PA 17025
FHA Csrc No.
4417598403703
November 24, 2004 Date
I. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns, "Lender" means
CHASE MANHATTAN MORTGAGE CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
Fifty-Six Thousand, Seven Hundred Sixty-Nine and 00/100
Dollars (U.S. $ 56,769.00 ), plus interest, to the order of Lender. Interest will be charged on
unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of
Six
percent ( 6.000 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as
this Note and called the "Security Instrument." That Security instrument protects the Lender from losses which might result if
Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
January 1, 2005 . Any principal and interest remaining on the first day of
December, 2034 will be due on that date, which is called the maturity date.
(B) Place
Payment shall be made at P.O. BOX 78824
PHOENIX, A2 85062
or at such other place as tender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 340.36
Three Hundred Forty and 36/100
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal,
interest and other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment A4justmeuts
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge
shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a pan of this Note.
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay die debt evidenced by this Note, in whole or in pan, without charge or penalty, on the first
day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a
partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing
to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(c) of this
Note by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of
4%
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the
Secretary in the case of payment defaults, require immediate payment in full of the principal balance retraining due and all accrued
interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many
circumstances regulations issued by the Secretary will limit Lender's right to require immediate payment in full in the case of payment
defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means
the Secretary of Housing and Urban Development or his or her designee.
FHA MULTISTATL/MiED RATE NOTE At l.• tt
G7302(11M) Pate 1 or2 (Repbees 1/%)
0 0
(C) Payrt'i`n't of Costs and Expenses
If Lender has requited immediate payment in frill, as described above, Lender may require Borrower to pay costs and expenses
including reasonable and customary attorney's fees for enforcing this Note to the extent not prohibited by applicable law. Such
fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentmem and notice of dishonor.
"Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require
Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by
delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has
given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in
Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser
of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its tights under this Note against
each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the
amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
ROBERT C CASSEL TANYA CASSEL
PHA MULTISTATE FIXED RATE NOTE
C-7302 (11196) Pqe 2 or 2 (Repbm U96)
Exhibit "A"
ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATED IN EAST PENNSBORO TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS
FOLLOWS:
BEGINNING AT A POINT ON THE NORTHWEST SIDE OF ADAMS STREET AS LAID OUT ON PLAN OF
LOTS OF THE SAID JOHN 0. ADDAMS AND JOSEPH PYNE, THE SAME BEING RECORDED AT
CARLISLE, PENNSYLVANIA, THENCE WESTWARDLY 25 FEET TO THE LINE OF LOT NO. 152;
THENCE NORTHWARDLY 150 FEET TO MONROE STREET; THENCE EASTWARDLYA DISTANCE OF
25 FEET TO LINE DIVIDING LOTS NOS. 150 AND 151; THENCE ALONG SAID LINE THROUGH THE
CENTER OF PARTITION WALL OF A DOUBLE HOUSE BUILT THEREON 150 FEET TO THE PLACE OF
BEGINNING.
BEING LOT NO. 151 OF AFORESAID PLAN BOOK 1, PAGE 17 AND HAVING THEREON ERECTED THE
WESTERN ONE HALF OF A DOUBLE TWO AND ONE-HALF (2 112) STORY FRAME DWELLING HOUSE.
PARCEL # 09-15-1291-293
EXHIBIT "B"
5 _7Y3
ROBERT P. ZIttER
RECORDER OF DEEDS
CUMBERLAND COUNT`!-PA
2005 FEB 18 RM 1124
State of Pennsylvania MORTGAGE
Record and Return to:
CHASE MANHATTAN MORTGAGE CORPORATION
4915 INDEPENDENCE PKWY, FOUNTAIN SQ II
TAMPA, FL 33634-7541
ATTENTION: POST CLOSING
THIS MORTGAGE ("Security Instrument") is given on
The Mortgagor is
ROBERT C CASSEL,
TANYA K CASSEL, HUSBAND & WIFE
whose addre s is
23 ADAM ST, ENOLA, PA 17025
Instrument is even to
CHASE MANHATTAN MORTGAGE CORPORATION
,("Borrower'). This Security
which is organized and existing under the laws of the State of New Jersey ,
and whose address is 194 WOOD AVENUE-SOUTH
ISELIN NJ 08830 ,("Lender"). Borrower owes Lender the
principal sum of
Fifty-Six Thousand, Seven Hundred Sixty-Nine and 00/100
Dollars (U.S. $ 56,769-00 ). This debt is evidenced by Borrower's Note dated the same
date as this Security Instrument ("Note"), which provides for monthly payments, with the frill debt, if not paid
earlier, due and payable on December 1, 2034
This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest,
and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest,
advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of
Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does
hereby mortgage, grant and convey to Lender, the following described property located in
CUMBERLAND County, Pennsylvania:
PENNSYLVANIA FHA MORTGAGE
C-3701 (1/02) (Replaces 6100) PAGE I OF 8
?, e, e eke
FHA Case No.
4417598403703
908076
1 9080766
November 24, 1004
BK 1897PG3095
See Attached Legal Description
which has the address of
23 ADAMS ST, ENOLA, PA 17025
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property."
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances
of record. Borrower warrants and will defend generally the title to the Property against all claims and demands,
subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with
limited variations by jurisdiction to constitute a uniform security instrument covering real property.
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS:
1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and
interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Tares, Insurance, and Other Charges. Borrower shall include in each monthly
payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes
and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the
Property, and (c) premiums for insurance required under Paragraph 4. In any year in which the Lender must pay
a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year
in which such premium would have been acquired if Lender still held the Security Instrument, each monthly
payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the
Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by
the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the
Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds".
Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed
PENNSYLVANIA FHA MORTGAGE
C-3701 (1102) (Replaces 6100) PAGE 2 OF 8
9KI897PG3096
the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement
Procedures Act of 1974, 12 U.S.C. § 2601 V cq. and implementing regulations, 24 CPR Part 3500, as they may
be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated
disbursements or disbursements before the Borrower's payments are available in the account may not be based on
amounts due for the mortgage insurance premium.
If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA,
Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by
Lender at any time arc not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and
require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds arc pledged as additional security for all sums secured by this Security Instrument. If
Borrower tenders to Leader the full payment of all such sums, Borrower's account shall be credited with the balance
remaining for all installment items (a), (b) and (c) and any mortgage insurance premium installment that Lender has
not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower.
Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be
credited with any balance remaining for all installments for items (a), (b) and (c).
3. Application of Payments. All payments under Paragraphs 1 and 2 shall be applied by Lender as
follows:
First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge
by the Secretary instead of the monthly mortgage insurance premium;
Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other
hazard insurance premiums, as required;
T
Kird, to interest due under the Note;
Po", to amortization of the principal of the Note; and
Pifth, to late charges due under the Note.
4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property,
whether now in existence or subsequently erected, against any hazards, casualties and contingencies, including fire,
for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that
Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or
subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried
with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall
include loss payable clauses in favor of, and in a form acceptable to, Lender.
In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of
loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to
make payment for such loss directly to Lander, instead of to Borrower and to Lender jointly. All or any part of
the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under
the Note and this Security Instrument, first to any delinquent amounts applied in the order in Paragraph 3, and then
to prepayment of principal, or (b) to the restoration or repair of the damaged property. Any application of the
proceeds to dic principal shall not extend or postpone the due date of the monthly payments which arc referred to
in Paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required
to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally
entitled thereto.
In the event of foreclosure of this Security Instrument or other transfer of title to the Property that
extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass
to the purchaser.
5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within sixty days afar the execution of this Security instrument (or within sixty days of a later sale or
PENNSYLVANIA FHA MORTGAGE
C-3701 (1/02) (Replaces 6/00) PAGE 3 OF 8
P.6. e? Jke,
8K1897PG3097
4
transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least
one year after the date of occupancy, unless Lender determines that requirement wil1 cause undue hardship for
Borrower, or unless extenuating circumstances exist which are beyond Boffower's control. Borrower shall notify
Lenders of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially
change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect
the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action
to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during
the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to
provide Lender with any material information) in connection with the loan evidenced by the Note, including, but
not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this
Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires
fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in
writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any c;ondcmnation or other taking of any part of the Property, or for conveyance in place of
condemnation, arc hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness
that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction
of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order
provided in Paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall
not extend or postpone the due date of the monthly payments, which arc referred to in Paragraph 2, or change the
amount of such payments. Any excess proceeds over an amount required to pay 211 outstanding indebtedness under
the Note and this Security Instrument shall be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shdli pay all
governmental or municipal charges, fines and impositions that are not included in Paragraph 2. Borrower shall pay
these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect
Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts
evidencing these payments.
If Borrower fails to make these payments or the payments required by Paragraph 2, or fails to perform any
other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may
significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to
enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property
and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in
Paragraph 2.
Any amounts disbursed by Lender under this Paragraph shall become an additional debt of Borrower and
be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note
rate, and at the option of the Lender, shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which
in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien
an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that
any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may
give BOffower a notice identifying the lien. Boffowcr shall satisfy the lien or take one or more of the actions set
forth above within 10 days of the giving of notice.
8. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceleration of Debt.
(a) Default. Lender may, except as limited by regulations issued by the Secretary in the case of
PENNSYLVANIA FHA MORTGAGE
c-3701 (1/02) (Replaces 6/oo) PAGE 4 OF R
A. e. C. Jlk(?
BKI897PG3098
4
payment defaults, require immediate payment in full of all sums secured by this Security
Instrument if:
(i) Borrower defaults by failing to pay in full any monthly payment required by this
Security Instrument prior to or on the due date of the next monthly payment, or
(ii) Borrower defaults by failing, for a period of thirty days, to perform any other
obligations contained in this Security Instrument.
(b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including
section 341(4) of the Cram-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d))
and with the prior approval of the Secretary, require immediate payment in full of all sums
secured by'this Security instrument if-
(i) i All or part of the Property, or a beneficial interest in a trust owning all or part of the
Property, is sold or otherwise transferred (other than by devise or descent), and
(ii) The property is not occupied by the purchaser or grantee as his or her principal
residence, or the purchaser or grantee does , occupy the Property, but his or her credit
has not been approved in accordance with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate payment
in full, but Lender does not require such payments, Lender does not waive its rights with respect
to subsequent events.
(d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary
will limit Lender's rights in the case of payment defaults to require immediate payment in full and
foreclose if 'not paid. This Security Instrument does not authorize acceleration or foreclosure if
not permitted by regulations of the Secretary.
(e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under the National Housing Act within 60 days from the
date hereof, Lender may, at its option require immediate payment in full of all sums secured by
this Security Instrument. A written statement of any authorized agent of the Secretary dated
subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the
Note, shall be deemed conclusive prof of such ineligibility. Notwithstanding the foregoing, this
option may 'not be exercised by Lender when the unavailability of insurance is solely due to
Lender's failure to remit a mortgage insurance premium to the Secretary.
10. Reinstatement.' Borrower has a right to be reinstated if Lender has required immediate payment in
full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right
applies even after foreclosure proceedings arc instituted. To reinstate the Security Instrument, Borrower shall tender
in a lump sum all amour required to bring Borrower's account current including, to the extent they are obligations
of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorney's fees and
expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security
Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment
in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the
commencement of foreclosure proceedings within two years immediately preceding the commencement of a current
foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or reinstatement will adversely affect the priority of the lien created by this Security Instrument. (iii)
11. Borrower not Released; Forbearance by Lender not a Waiver. Extension of the time of payment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor
in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor
in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to
extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason
of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender
PENNSYLVANIA FHA MORTGAGE
C-3701 (1/02) (Replaces 6100) PAGE 5 OF 8
A, C. if, JAL
oKI897PG3099
in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,
subject to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any
Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security
Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this
Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c)
agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with
regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering
it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be
directed to the Property Address or any other address Borrower designates by notice to lender. Any notice to
Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by
notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to
Borrower or Lender when given as provided in this Paragraph.
14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the
law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security
Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security
Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of
this Security Instrument and the Note are declared to be severable.
15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or
release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do,
anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall
not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are
generally recognized to be appropriate to normal residential uses and to maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other
action by any governmental or regulatory agency or private party involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by
any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances
affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with
Environmental Law.
As used in this paragraph 16, "Hazardous Substances" arc those substances defined as toxic or hazardous
substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde,
and radioactive materials. As.used the paragraph 16, "Environmental Law" means federal laws and laws of the
jurisdiction where the Property is located that relate to health, safety or environmental protection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and
revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and
hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to
Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument,
Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and
Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security
only.
PENNSYLVANIA FHA MORTGAGE
G3701 (1102) (Replaces 6100) PAGE 6 OF 8
f. e, C. JM
BK { 897PG3100
If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower
as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall
be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all
rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act that
would prevent Lender from exercising its rights under this Paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property before or after giving
notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is
a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of
Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument
is paid in full.
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9,
Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all
expenses Incurred In pursuing the remedies provided In this paragraph 18, including, but not limited to,
attorneys' fees and costs of title evidence to the extent permitted by applicable law.
If the Lender's interest in this Security Instrument Is held by the Secretary and the Secretary requires
immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale
provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act'l (12 U.S.C. 3751 et sea.) by
requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the
Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights
otherwise available to a bender under this Paragraph 18 or applicable law.
19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy
this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs.
20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future
laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead
exemption.
21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one
hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note.
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded
together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were
a part of this Security Instrument.
The following riders are attached: T Certify this to be recorded
NO RIDERS ATTACHED In Cumberland County PA
PENNSYLVANIA FHA MORTGAGE
C-3701 (l/02) (Replace 6/00) PAGE 7 OF & ?. eReco1 feeds
sKf897PC3101
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument
and in any rider(s) executed by Borrower and recorded with it.
The Borrower certifies that a true copy of the mortgage has been received-
ROBERT C CASSEL TANYA K dhSSEL
COMMONWEALTH OF PENNSYLVANIA
ss:
COUNTY OF CUMBERLAND
On this 24th day of November, 2004
before me, the ?u+^A pJ?iG ??w
subscriber, a Notary public in and for th mmonwea of Pennsylvania, residing in (fC._j {' CAM ber c.,f
came the above-named subsc ' s)
ROBERT C CASSEL,
TANYA K CASSEL, JBAND & WIFE
;-14? /?- 0"-"4
owledged the within indenture of Mortgage to be their act and deed, and desired the same to be recorded
WITNESS my hand and seal, the day and year aforesaid.
?NPh+bIAt
O?paryTv4x?? mvftcw?
y?i
PENNSYLVANIA PHA MORTGAGE
C-3701 (1102) (Rcylaco 6100) PAGE 8 OF 8
11 'fo
M 'ssion expire
ti
BX 1897PG3 I OZ
Exhibit "A"
ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATED IN EAST PENNSBORO TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS
FOLLOWS:
BEGINNING AT A POINT ON THE NORTHWEST SIDE OF ADAMS STREET AS LAID OUT ON PLAN OF
LOTS OF THE SAID JOHN 0. ADDAMS AND JOSEPH PYNE, THE SAME BEING RECORDED AT
CARLISLE, PENNSYLVANIA, THENCE WESTWARDLY 25 FEET TO THE LINE OF LOT NO. 152;
THENCE NORTHWARDLY 150 FEET TO MONROE STREET; THENCE EASTWARDLY A DISTANCE OF
25 FEET TO LINE DIVIDING LOTS NOS. 150 AND 151; THENCE ALONG SAID LINE THROUGH THE
CENTER OF PARTITION WALL OF A DOUBLE HOUSE BUILT THEREON 150 FEET TO THE PLACE OF
BEGINNING.
BEING LOT NO. 151 OF AFORESAID PLAN BOOK 1, PAGE 17 AND HAVING THEREON ERECTED THE
WESTERN ONE HALF OF A DOUBLE TWO AND ONE-HALF (2 1/2) STORY FRAME DWELLING HOUSE.
PARCEL # 09-15-1291-293
BKI897PG3103
. $, . .
VERIFICATION
Beth Cottrell , Assistant Secretary, and duly authorized representative
of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation deposes and says,
subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her
knowledge, information and belief.
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
&tj ?;?
Beth ottrelt Assistant Secretary
3' ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNS~V~IIA_;.%
-r~ ~
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION ..~ ~ ~ `~
=--,
Chase Manhattan Mortgage Corporation, ~ ~_, --
Plaintiff, NO.: 2010-2043-Civil =' '
.~ N 'i;_~
CO
VS.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
I hereby certify that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
the last known address of
Defendants is:
23 Adams Street
Enola, PA 17025
GRENEN &BIRSIC, P.C.
i~- "/~,l-
Attorneys for Plaintiff
TYPE OF PLEADING
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
J~`istine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN &BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
~ I~• oo P ~ A~
~~r Ia ~ oa7
~# ayaa..53
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
CIVIL DIVISION
NO.: 2010-2043-Civil
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Robert C. Cassel and Tanya K. Cassel, in the amount of $58,479.53, which
is itemized as follows:
Principal $52,879.52
Interest to 5/13/10 $ 1,694.38
Late Charges to 5/13/10 $ 58.48
Escrow Deficiency to 5/13/10 $ 0.00
Corporate Advances $ 86.01
Unapplied Funds ($ 38.86)
Attorneys' Fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $58,479.53
with interest on the principal sum at the rate of $8.69 per diem (as may change from time to time
in accordance with the terms of the Note) from May 13, 2010, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
~~
B T" l ~ ~c_ c. i ~ ~ ~~ t % c.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants were not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copies.
Sworn to and subscribed before me
this day of 2010.
~ o
Nol'~ry Public
COMMONVeIEAL~'H OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiano, No~ry Public
City OFD E~~ ~ 2
Member, Pennsylvania Association of Notarle5
IN'1'IfE COURT OF COMMON PLEAS Ul~ CUMBERLAND COl1N'!'l' Pl?NNS1'LVANIA
CI IASE I-{OME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Curporation,
CIVIL D[V[SION
Plaintiff,
vs.
ROI3I:R"r C. CASSEL and
'I'ANYA K. CASSEL,
Defendants.
TO: Robert C. Cassel
23 Adams Street
Enola, I'A 17025
NO.: 2010-2043
DATE OF NOTICE: April 28, 2010
IMPORTANT1 NOTICE
YOU ARC IN DEFAULT' BECAUSE YOU fIAVE TAILED TO l;N'1'I:R A WR['1'TIN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING W['rI-I THE
COURT YOUR DEFENSES OR OBJEC'T'IONS TO THE CLAIMS SE"r 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 R[GHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
I-LAVE A LAWYER, GO TO Olt TELEPHONE THE OFFICI? SET FORTH BELOW. THIS
OFFICI CAN PROVIDE YOiI WITI-I INFORMATION A[30UT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, "THIS OI~F[Cf; N1AY [3E ABLE
'I'O PROVIDE YOU WITH INFORMATION ABOU"r AGENCIES "I'IIA'I' MAY OFFI?R
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-31b6 or'Coll Free (800) 990-1108
FIRST CLASS MN[_, I'O5TAGE PREPAID
GRENI;N & I3IRSIC, P.C.
c~r__._ .
By: ~-" ~"
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, I'A 15222
(412) 281-7650
~ r.
IN "i'tIE COURT OF COMA-10N PLEAS OI~ CUMBERLAND CO[1N'1'Y PI;NNSY[.VANIA
CHASE ItOMI: f~1NANCE l,l,C, s/h/m/t
Chase Manhattan Morlbal;c Cc~rlu~rcttirn~,
CIVIL DIVISION
1'lainti i'f,
vs.
1tOI3ER"I C. CASSEL and
'I'ANYA K. CASSEL,
Defendants.
'1'O: Tanya K. Cassel
23 Adams Street
Enola, PA 17025
NO.: 20 I U-2043
DATE OP N01'ICE: April 28, 2010
IMPORTANT NOTICE
YOU ARI? IN I)EI~AUL'f BECAUSE YOU HAVI: PALLID TO I;N'I'I:R A WRI"I"I'EN
APPI?ARANCT; I'ERSONA[,LY OR BY ATTORNEY AND PILE [N WRITING WITI-f TI-{E
LOUR'!' YOUR DEFENSES OR OBJECTIONS TO TIII; C[_AIMS SI:'I' FORTii AGAINST
YOU. UNL[;SS YOU ACT VI'I'I I[N "l'I;N DAYS PROM "I'HE DATI: Ol~ THIS NO ['ICE, A
JUDGMIiN"l' MAY Bl: 1:NTIRED AGAWS"I' YOU WITHOUT A }II?AR1NG AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE TI-[IS NOTICE TO A LAWYER AT ONCE. II~ YOU DO NOT
[-PAVE A hAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITI-[ INFORMATION ABOUT HIRING A LAWYER.
[F YOU CANNOT AFFORD TO I-IIRE A LAWYER, "CHIS OFF(CI; MAY' f3E ABLE
'1'O PROVIDE YOU WITH INFORMATION AI30U"C AG[sNCIE5 'I'IIA'1' MAY OFFER
L~GAI, SERVICES 'I'O T;L[GIBLE PERSONS AT A REDUCED FLE OR NO FEE.
Cumberland County 13ar Association
32 5. Kcdford Street
Carlisle, 1'A 17013
(717) 249-3166 or'Coll Frcc (800) 990-~1O8
GRENEN $c I3IRSIC, P.C.
FIRST CLASS MAIL, POSTAGE PREPAID
B ~~-
Y•
Attorneys for Plaintiff
One Gateway Cent<;r, vinth l~lc~or
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Robert C. Cassel
23 Adams Street
Enola, PA 17025
( )Plaintiff
(XX) Defendant
( )Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on /
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $58,479.53
with interest on the principal sum at the rate of $8.69 per diem (as may change from time to time
in accordance with the terms of the Note) from May 13, 2010, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
/~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CNIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 2010-2043-Civil
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Tanya K. Cassel
23 Adams Street
Enola, PA 17025
( )Plaintiff
(XX) Defendant
( )Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on r
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $58,479.53
with interest on the principal sum at the rate of $8.69 per diem (as may change from time to time
in accordance with the terms of the Note) from May 13, 2010, and additional late charges,
additional reasonable and actually incurred attorneys' fees, plus costs (including increases in
escrow deficiency) and for foreclosure and sale of the mortgaged premises.
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL, DIVISION
C1
PRAECIPE FOR WRIT OF EXECUTION ~ ° _~
Caption:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
vs.
Robert C. Cassel and Tanya K. Cassel
TO THE PROTHONOTARY OF SAID COURT:
( )Confessed Judgment ~-'-'-
ra ~
-:-
' (X) Other (Default Judgme~~~ : ' `,
--
::. -~
_
File No. 2010-2043-Civil '~` ~
' - `~-
' Amount Due $58,479.53 '~'~ r-, ':`~
=
. ..{ <
~
Interest $ 1,103.90 (5/14/10 to sale)
' Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,
or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding
filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for
debt, interest and costs, upon the following described property of the defendant(s)
23 Adams Street Enola PA 17025
(Please see attached legal description)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue Writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
^ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date '~ ~ ~
s
~d~. oo Pb A-rr--
57. so CBF
9a . oo
,~. oo ,.
a • 50 ''
$ Iqo. oo - P° ATE
~ a. oo Acs C~ ~ . so °L
C~~r t a-lo 50o R,'~d~ ~5
Signature: ~~~- ~ `~-C ~~-~- L~ ~~-
Print Name: Kristine M. Anthou
Address: One Gateway Center, 9``' Floor
Pittsburgh, PA 15222
Attorney for: Plaintiff
Telephone: (412) 281-7650
Supreme Court ID No.: 77991
(over)
+~ u)nt~l
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or piece of land situated in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the northwest side of Adams Street as laid out on Plan of Lots of the
said John Q. Addams and Joseph Pyne, the same being recorded at Carlisle, Pennsylvania, thence
westwardly 25 feet to the line of Lot No. 152; thence northwardly 150 feet to Monroe Street; thence
eastwardly a distance of 25 feet to line dividing Lots Nos. 150 and 151; thence along said line
through the center of partition wall of a double house built thereon 150 feet to the place of
BEGINNING.
BEING Lot No. 151 of aforesaid Plan Book 1, Page 17 and having thereon erected the western one
half of a double two and one-half (2 1 /2) story frame dwelling house.
PARCEL #09-15-1291-293
BEING the same premises which Robert C. Cassel, Administrator of the Estate of Casey E. Cassel,
by Deed dated May 30, 2002 and recorded in the Office of the Recorder of Deeds of Cumberland
County on July 10, 2002, at Deed Book Volume 252, Page 3119, granted and conveyed unto
Robert C. Cassel and Tanya K. Cassel.
GRENEN & BIRSIC, P.C.
..
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Parcel #09-15-1291-293
i 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
C>
- ca --9
_
rr,,' .~~; ~~
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. .
~ ~
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in
the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property of Robert C. Cassel and Tanya K. Cassel
located at 23 Adams Street, Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
1. The name and address of the owners or reputed owners:
Robert C. Cassel
23 Adams Street
Enola, PA 17025
Tanya K. Cassel
23 Adams Street
Enola, PA 17025
2. The name and address of the Defendants in the judgment:
Robert C. Cassel
Tanya K. Cassel
23 Adams Street
Enola, PA 17025
23 Adams Street
Enola, PA 17025
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
Commonwealth of Pennsylvania
LVNV Funding LLC
[PLAINTIFF]
Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128
c/o David J. Apothaker, Esquire
Apothaker and Associates
520 Fellowship Road, C306
Mount Laurel, NJ 08054
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
Manhattan Mortgage Corporation
5. The name and address of every other person who has any record lien on the property:
Cumberland Domestic Relations
PA Department of Revenue
Commonwealth of Pennsylvania
P.O. Box 320
Carlisle, PA 17013
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
6. The name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
NONE
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which maybe affected by the sale:
NONE
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
~r
'~ _
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS --~~ DAY OF 2010.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiano, Notary Public
City Of Pittsfxrgh, ABegi>eny County
My Comrnfasion E.~irras Jan. 6, 2012
Mambar, Pennaylvartia Assoclatlon of Notarlss
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
AFFIDAVIT OF LAST KNOWN ADDRESS
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
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Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that the owners of the property located at 23 Adams
Street, Enola, PA 17025 are Defendants, Robert C. Cassel and Tanya K. Cassel, who reside at 23
Adams Street, Enola, PA 17025, to the best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS _ ~5~ DA OF 2010.
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Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Elizabeth M. Paiano, Notary Public
City Of Pitlsbuglt, Apegheny County
My Corrrmissbrt F~Ires Jan. 8, 2012
Member, Pennsylvania Association of Notaries
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
CIVIL DIVISION ~..,
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N0.:2010-2043-Civil `~- `~~
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Defendants.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEO.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on December 2, 2009, Defendants were mailed
combined Act 91 and Act 6 Notices, via certified mail, return receipt requested, and by first class
mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983
and Act 6 of 1974, 41 P.S. '101, et seq.
SWORN TO AND SUBSCRIBED BEFORE
ME HIS ~5'"1 D OF 2010.
Notary Public
COMMONWEALTH Os- Pi=NNSYLVANIA
Notarial Seal
EI'izabeth M. Paiano, Notary Public
City Ot Pittsbirgh, ANeghenY ~~Y
My Conxr~ssion Fires Jan. 6, 2012
Member, Pennsylvania Association of Notaries
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
CIVIL DIVISION
NO.: 2010-2043-Civil
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Robert C. Cassel
23 Adams Street
Enola, PA 17025
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TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
on September 8, 2010, at 10:00 A.M., the following described real estate, of which Robert C.
Cassel and Tanya K. Cassel are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation,
Plaintiff,
vs.
Robert C. Cassel and Tanya K. Cassel,
Defendants,
at Execution Number 2010-2043-Civil in the amount of $59,583.43.
A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30)
days from the sale date.
Distribution will be made in accordance with the Schedule of Distribution unless
exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when
the Schedule of Distribution is filed by the Office of the Sheriff.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or piece of land situated in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the northwest side of Adams Street as laid out on Plan of Lots of the
said John Q. Addams and Joseph Pyne, the same being recorded at Carlisle, Pennsylvania, thence
westwardly 25 feet to the line of Lot No. 152; thence northwardly 150 feet to Monroe Street; thence
eastwardly a distance of 25 feet to line dividing Lots Nos. 150 and 151; thence along said line
through the center of partition wall of a double house built thereon 150 feet to the place of
BEGINNING.
BEING Lot No. 151 of aforesaid Plan Book 1, Page 17 and having thereon erected the western one
half of a double two and one-half (2 1/2) story frame dwelling house.
PARCEL #09-15-1291-293
BEING the same premises which Robert C. Cassel, Administrator of the Estate of Casey E. Cassel,
by Deed dated May 30, 2002 and recorded in the Office of the Recorder of Deeds of Cumberland
County on July 10, 2002, at Deed Book Volume 252, Page 3119, granted and conveyed unto
Robert C. Cassel and Tanya K. Cassel.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
Parcel #09-15-1291-293
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
NO.: 2010-2043-Civil
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Tanya K. Cassel
23 Adams Street
Enola, PA 17025
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TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
on September 8, 2010, at 10:00 A.M., the following described real estate, of which Robert C.
Cassel and Tanya K. Cassel are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation,
Plaintiff,
vs.
Robert C. Cassel and Tanya K. Cassel,
Defendants,
at Execution Number 2010-2043-Civil in the amount of $59,583.43.
A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30)
days from the sale date.
Distribution will be made in accordance with the Schedule of Distribution unless
exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when
the Schedule of Distribution is filed by the Office of the Sheriff.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
NO.: 2010-2043-Civil
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or piece of land situated in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the northwest side of Adams Street as laid out on Plan of Lots of the
said John Q. Addams and Joseph Pyne, the same being recorded at Carlisle, Pennsylvania, thence
westwardly 25 feet to the line of Lot No. 152; thence northwardly 150 feet to Monroe Street; thence
eastwardly a distance of 25 feet to line dividing Lots Nos. 150 and 151; thence along said line
through the center of partition wall of a double house built thereon 150 feet to the place of
BEGINNING.
BEING Lot No. 151 of aforesaid Plan Book 1, Page 17 and having thereon erected the western one
half of a double two and one-half (2 1/2) story frame dwelling house.
PARCEL #09-15-1291-293
BEING the same premises which Robert C. Cassel, Administrator of the Estate of Casey E. Cassel,
by Deed dated May 30, 2002 and recorded in the Office of the Recorder of Deeds of Cumberland
County on July 10, 2002, at Deed Book Volume 252, Page 3119, granted and conveyed unto
Robert C. Cassel and Tanya K. Cassel.
GRENEN & BIRSIC, P.C.
By:'
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
Parcel #09-15-1291-293
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or piece of land situated in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the northwest side of Adams Street as laid out on Plan of Lots of the
said John Q. Addams and Joseph Pyne, the same being recorded at Carlisle, Pennsylvania, thence
westwardly 25 feet to the line of Lot No. 152; thence northwardly 150 feet to Monroe Street; thence
eastwardly a distance of 25 feet to line dividing Lots Nos. 150 and 151; thence along said line
through the center of partition wall of a double house built thereon 150 feet to the place of
BEGINNING.
BEING Lot No. 151 of aforesaid Plan Book 1, Page 17 and having thereon erected the western one
half of a double two and one-half (2 1/2) story frame dwelling house.
PARCEL #09-15-1291-293
BEING the same premises which Robert C. Cassel, Administrator of the Estate of Casey E. Cassel,
by Deed dated May 30, 2002 and recorded in the Office of the Recorder of Deeds of Cumberland
County on July 10, 2002, at Deed Book Volume 252, Page 3119, granted and conveyed unto
Robert C. Cassel and Tanya K. Cassel.
GRENEN & BIRSIC, P.C.
By- ~
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
Parcel #09-15-1291-293
~;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
NO.: 2010-2043-Civil
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Tanya K. Cassel
23 Adams Street
Enola, PA 17025
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in the
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
on September 8, 2010, at 10:00 A.M., the following described real estate, of which Robert C.
Cassel and Tanya K. Cassel are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation,
Plaintiff,
vs.
Robert C. Cassel and Tanya K. Cassel,
Defendants,
at Execution Number 2010-2043-Civil in the amount of $59,583.43.
A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30)
days from the sale date.
Distribution will be made in accordance with the Schedule of Distribution unless
exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when
the Schedule of Distribution is filed by the Office of the Sheriff.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
r'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
NO.: 2010-2043-Civil
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot or piece of land situated in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point on the northwest side of Adams Street as laid out on Plan of Lots of the
said John Q. Addams and Joseph Pyne, the same being recorded at Carlisle, Pennsylvania, thence
westwardly 25 feet to the line of Lot No. 152; thence northwardly 150 feet to Monroe Street; thence
eastwardly a distance of 25 feet to line dividing Lots Nos. 150 and 151; thence along said line
through the center of partition wall of a double house built thereon 150 feet to the place of
BEGINNING.
BEING Lot No. 151 of aforesaid Plan Book 1, Page 17 and having thereon erected the western one
half of a double two and one-half (2 1/2) story frame dwelling house.
PARCEL #09-15-1291-293
BEING the same premises which Robert C. Cassel, Administrator of the Estate of Casey E. Cassel,
by Deed dated May 30, 2002 and recorded in the Office of the Recorder of Deeds of Cumberland
County on July 10, 2002, at Deed Book Volume 252, Page 3119, granted and conveyed unto
Robert C. Cassel and Tanya K. Cassel.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
Parcel #09-15-1291-293
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-2043 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, s/b/m/t CHASE
MANHATTAN MORTGAGE CORPORATION, Plaintiff (s)
From ROBERT C. CASSEL and TANYA K. CASSEL
(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 $58,479.53 L.L.$.50
Interest from 5/14/10 to Date of Sale -- $1.,103.90
Atty's Comm % Due Prothy $2.00
Atty Paid $190.00 Other Costs
Plaintiff Paid
Date: 5/28/10
avid D. Buell, Protho otary
(Seal)
By:
REQUESTING PARTY:
Name: KRISTINE M. ANTHOU, ESQUIRE
Address: GRENEN & BIRSIC, PC
ONE GATEWAY CENTER, 9TH FLR
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Deputy
Telephone: 412-281-7650
Supreme Court ID No. 77991
D ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
CNIL DIVISION n ~ ;
~- -- ;,
._ TA~ .~
NO.: 2010-2043-Civil `'~'~ ~ i
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-:~ : ~
TYPE OF PLEADING - - ~ ' ` ` '
{_. . • =~
SUPPLEMENTAL AFFIDAVIT ~' ~ -
PURSUANT TO RULE 3129.1
Defendants.
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SALE DATE: September 8, 2010
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in
the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1.
The information identified below is in addition to the information previously identified in the
Affidavit Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed, the information set forth
below was of record concerning the real property of Robert C. Cassel and Tanya K. Cassel
located at 23 Adams Street, Enola, PA 17025, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
w
The name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
U.S. Treasury Department
1000 Liberty Ave.
Pittsburgh, PA 15222
I verify that the statements made in the Supplemental Affidavit are true and correct to the
best of my personal knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities.
GRENEN & BIRSIC, P.C.
Krist~ M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS ~ DAY OF , 2010.
C ~'~~ ~ ~ ~e`~a , ~ Q
Notary Public
COMMONWEALTH OF_PENNSYLVANIA
Notarial 3~1
Prtnsxa A. Townsantl. Notary Publ~
City Ot Pittsburgh, Atlepneny County
tNy Commission Expires June 2, 2011
Marrmbar, PsnnayNania Association of Notaries
~. ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
VS'.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
SALE DATE: September 8, 2010
N0.:2010-2043-Civil r, h"y
TYPE OF PLEADING ~ " , ~ _ °-
.~~,
Pa. R.C.P. RULE 3129.2(c)(2) ' ' ~
PURSUANT TO RULE 3129.1- ~` ~
LIENHOLDER AFFIDAVIT OF- ;.
~ -- .~
SERVICE .
~~
W
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
Pa. R.C.P. RULE 3129.2(c)(2)
LIENHOLDER AFFIDAVIT OF SERVICE
I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the
following Affidavit regarding service of the notice of the sale of real property on all persons
named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1, as well as all
persons named in Plaintiff's Supplemental Affidavit pursuant to Rule 3129.1 as follows:
1. By letters dated June 14, 2010, undersigned counsel served all persons (other than
the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1
with a notice of the sale of real property by ordinary mail at the respective addresses set forth in
the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule
3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit
"A", attached hereto, and made a part hereof.
2. By letters dated July 2, 2010, undersigned counsel served the persons named in
Plaintiffs Supplemental Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real
property by ordinary mail at the respective address set forth in the Supplemental Affidavit
Pursuant to Rule 3129.1. A true and correct copy of said Supplemental Affidavit Pursuant to
Rule 3129.1 and Certificate of Mailing are marked Exhibit "B", attached hereto, and made a part
hereof.
I verify that the facts contained in this Affidavit are true and correct based upon my
personal knowledge, information, and belief.
GRENEN & BIRSIC, P.C.
BY: ~ ~--~C..-L- ~,t, oL.
Krist a M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412)281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
THIS ~~ DAY OF 2010.
~A p 1` ,~j, ~2~Y~n~.n~
Notary Public
t;OMMONWEALTH OF PENNSYLVANIA
Notarial Seal
?atneia A 7ownasnd, Notary Public
City of Ptttaburph, AlNpher~y County
My Commission Expires June 2, 2011
Member, pennaylvaNa Association of Notaries
EXHIBIT "A"
• f
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
AFFIDAVIT PURSUANT TO RULE 3129 1
COMMONWEALTH OF PENNSYLVANIA )
)SS:
COUNTY OF ALLEGHENY )
Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in
the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property of Robert C. Cassel and Tanya K. Cassel
located at 23 Adams Street, Enola, PA 17025 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
____ _--___-- --ALI,-THE-F'OLI,-OWING-I3ES~RTBED-REAL~STATE-SITUATEDIN:EAST __ ___
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
1. The name and address of the owners or reputed owners:
Robert C. Cassel 23 Adams Street
Enola, PA 17025
• s
Tanya K. Cassel 23 Adams Street
Enola, PA 17025
2. The name and address of the Defendants in the judgment:
Robert C. Cassel
Tanya K. Cassel
23 Adams Street
Enola, PA 17025
23 Adams Street
Enola, PA 17025
3. The name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
Commonwealth of Pennsylvania
LVNV Funding LLC
[PLAINTIFF]
Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128
c/o David J. Apothaker, Esquire
Apothaker and Associates
520 Fellowship Road, C306
Mount Laurel, NJ 08054
4. The name and address of the last record holder of every mortgage of record:
Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF]
Manhattan Mortgage Corporation
5. The name and address of every other person who has any record lien on the property:
Cumberland Domestic Relations
PA Department of Revenue
Commonwealth of Pennsylvania
P.O. Box 320
_ _ _ __
Carlisle, PA 17013
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
• •
6. The name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
NONE
7. The name and address of every other person whom the plaintiff has knowledge who has any
interest in the property which maybe affected by the sale:
NONE
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED BEFORE
ME THIS __~~,_ DAY OF ~ 2010.
Notary Public
COMMONWEALTH OF PENNSYWANIA
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EXHIBIT ~~B"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Chase Home Finance LLC, s/b/m!t Chase Manhattan Mortgage Corporation, Plaintiff in
the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1.
The information identified below is in addition to the information previously identified in the
Affidavit Pursuant to Rule 3129.1.
As of the date that the Praecipe for Writ of Execution was filed, the information set forth
below was of record concerning the real property of Robert C. Cassel and Tanya K. Cassel
located at 23 Adams Street, Enola, PA 17025, and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ROBERT C. CASSEL AND
TANYA K. CASSEL OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN EAST
PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 23 ADAMS
STREET, ENOLA, PA 17025. DBV 252, PAGE 3119. PARCEL #09-15-1291-293.
1. The name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
U.S. Treasury Department
1000 Liberty Ave.
Pittsburgh, PA 15222
I verify that the statements made in the Supplemental Affidavit are true and correct to the
best of my personal knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities.
GRENEN & BIRSIC, P.C.
BY: ~ tz c: ~~ (~., ~ 2 ~L..
Kris M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
SWORN TO AND SUBSCRIBED BEFORE ME
/TH'~IS _~~ DAY OF' ~~ 2010.
Notary Public ~~
COMMONWEALTH OF PENNSYLVANIA
Notarial SsN
PatHt~e A. TownNntl. Notary PubNo
City W PittaDUrgh, Ailaphany Caunly
tVty Commisebn Expiros Juns 2, 2011
Momber, P~nruylvanta Association of Notaries
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U.S. POSTAL SERVICE CERTIFICATE QF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Grenen & Birsic. P.C.
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One piece of ordinary mad addressed to:
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PS Form 3817, January 2001
SHERIFF'S OFFICE OF CUMBERLAND
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor `' `=t= 3? s€F
COUNTY
FILED-CFFIC?
G o ' -'I '-?'0 e HONOTARY
LU?0 SEP 21 P l ?a 06
C {MP- .! ^,t N TY
w} j 4
c.? wa §_ct ti,r^, ?IA
et
Chase Home Finance LLC
vs.
Robert C. Cassel (et al.)
SHERIFF'S RETURN OF SERVICE
Case Number
2010-2043
06/2212010 08:28 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 22,
2010 at 2028 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description,
in the above entitled action, upon the property of Robert C. & Tanya K. Cassell, located at, 23 Adams
Street, Enola, Cumberland County, Pennsylvania according to law.
06/22/2010 08:28 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 22,
2010 at 2028 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the
above entitled action, upon the within named defendant, to wit: Robert C. Cassell, by making known unto,
Robert C. Cassell, personally, at, 23 Adams Street, Enola, Cumberland County, Pennsylvania its contents
and at the same time handing to him personally the said true and correct copy of the same.
06/22/2010 08:28 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 22,
2010 at 2028 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the
above entitled action, upon the within named defendant, to wit: Tanya K. Cassell, by making known unto,
Robert C. Cassell, husband of defendant, at, 23 Adams Street, Enola, Cumberland County, Pennsylvania
its contents and at the same time handing to him personally the said true and correct copy of the same.
09/02/2010 As directed by Kristine M Anthou, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/6/2010
09/2012010 As directed by Kristine M Anthou, Attorney for the Plaintiff, Sheriffs Sale Cancelled
SHERIFF COST: $725.16
September 20, 2010
SO ANSWERS,
RbNNYY R ANDERSON, SHERIFF
a.60 P). C0' .
s "pd.
OTT
ci coun;ySuite Sher ft. "f2ia;1^ ft. Inc.
C
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
Plaintiff,
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
ISSUE NUMBER:
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NO.: 2010-2043-Civil _,~~ ~~%
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PRAECIPE TO WITHDRAW µ-" `' - -
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JUDGMENT =' ?
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CODE-
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
~'8.0o Pp A~'ry
~~ [3o4~g
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 2010-2043-Civil
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
PRAECIPE TO WITHDRAW JUDGMENT
TO: PROTHONOTARY
SIR:
Kindly withdraw the judgment entered on or about May 17, 2010 in the above-captioned
matter and mark the docket accordingly.
GRENEN & BIRSIC, P.C.
t,J-----~ ~~
BY:
Brian M. Kile, Esquire
Attorney for Plaintiff
Sworn to and subscribed before me
this a~day of , 2010.
Notary ublic
CpMMONWEALTH OF pENNSYWANIA
Notarlal5eal
Elizabeth M. Cagnon, Notary PUblk
City of Pittsburgh, Allegherry County
My Commission Expires Jan. 6, 2012
Member, PennsvNz~n~a Association of Notaries
1..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
CNIL DNISION
ISSUE NUMBER:
VS.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
NO.: 2010-2043-Civil
TYPE OF PLEADING:
PRAECIPE TO SETTLE AND
DISCONTINUE WITHOUT
PREJUDICE
CODE-
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FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance LLC, s/b/m/t Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
.~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION
Chase Manhattan Mortgage Corporation,
Plaintiff,
NO.: 2010-2043-Civil
vs.
ROBERT C. CASSEL and
TANYA K. CASSEL,
Defendants.
PRAECIPE TO SETTLE AND DISCONTINUE
WITHOUT PREJUDICE
TO: PROTHONOTARY
SIR:
Kindly settle and discontinue without prejudice the above-captioned matter and mark the
docket accordingly.
Sworn to and subscribed before me
thisday of ~C 71(.lA ~ , 2010.
Notary P lic
COMMONWEALTH OF PENNSYLVANIA
Notarlel Seal
Elizabeth M. Cagnon, Notary Public
City of Pittsburgh, Allegheny County
Commission Expires ]an. 6, 2012
M"'""a°" °nr'^~~vAnla 4s~Uatlon of Notaries
GRENEN & BIRSIC, P.C.
BY.
Brian M. Kile, Esquire
Attorneys for Plaintiff