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HomeMy WebLinkAbout10-5416 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, nn.. Plaintiff, NO.: Ib - 541(o l..4vil Vs. TYPE OF PLEADING: ALEKSEY G. ROVNYANSKY, Administrator of the Estate of CIVIL ACTION-COMPLAINT GERMAN A. ROVNYANSKY, IN MORTGAGE FORECLOSURE Defendant. FILED ON BEHALF OF TO DEFENDANT Chase Home Finance LLC, s/b/m/t You are hereby notified to plead to the ENCLOSED Chase Manhattan Mortgage Corpoi COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF COUNSEL OF RECORD FOR TB - ATTORNEY FOR PLAINTIFF PARTY: Kristine M. Anthou, Esquire I HEREBY CERTIFY THAT THE ADDRESS Pa. I.D. #77991 OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 Brian M. Kile, Esquire Pa. I.D. #89240 AND THE DEFENDANT IS: GRENEN & BIRSIC, P.C. 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 One Gateway Center LL Ninth Floor ATTORNEY FOR PLAINTIFF Pittsburgh, PA 15222 (412) 281-7650 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS: 38 Johns Drive East Pennsboro Two. (CITY, BORO, TOWNSHIP) A NEY FOR PLAINTIFF 4ga.00 ?I i I rya Qp 0 -1 i ATI,y 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set fi following pages, you must take action within twenty (20) days after this complaint and served, by entering a written appearance personally or by attorney and filing in writin court your defenses or objections to the claims set forth against you. You are warned fail to do so the case may proceed without you and a judgment may be entered against court without further notice for any money claimed in the complaint or for any othe relief requested by the plaintiff. You may lose money or property or other rights irr you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF th in the otice are with the at if you >u by the claim or ortant to 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. 11 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 , I [ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. 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 1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, OH 43219 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, is an individual whose last known address is 41 Grandview St., Apt ? 806, Santa Cruz, CA 95060. 3. On or about September 29, 2008, German A. Rovnyansky executed Note in favor of Howard Hanna Mortgage Services ("Howard Hanna') in the original pri of $130,100.00. 4. On or about September 29, 2008, as security for payment of the German A. Rovnyansky made, executed and delivered to Mortgage Electronic Systems, Inc. ("MERS), as Nominee for Howard Hanna, a Mortgage in the original amount Note, amount of $130,100.00 on the premises hereinafter described, said Mortgage being recotded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008 at Number 200833295. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a hereof. 5. "MERS" as Nominee for Howard Hanna assigned all of its right, title and interest in and to aforesaid Mortgage to Plaintiff pursuant to a certain Assignment of Mortgaged recorded in the Office of the Recorder of Deeds of Cumberland County on June 16, 2010 at Number 201015816. A true and correct copy of said Assignment of Mortgage is marked Exhibit "B" attached hereto and made a part hereof. 6. Plaintiff believes and therefore avers that German A. Rovnvanskvl died on February 16, 2010. A true and correct copy of the Social Security Administration Deadh Master File is marked as Exhibit "C", attached hereto and made part hereof. 7. Defendant, Aleksey G. Rovnyansky, is the Administrator of the Estate of German A. Rovnyansky, pursuant to an order entered at Cumberland County Docket No. 21-10-172. 8. The Estate of German A. Rovnyansky ("the Estate") is the record and r$al owner of the aforesaid mortgaged premises. 9. The Estate is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. a Estate is due for the February 1, 2010 payment. 10. Plaintiff was not required to send Defendant written notice pursuant to 3$ P.S. '1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 Act 91 of 1981) prior to the commencement of this action for the reason that the mortgaged premises is not principal residence of the Defendants [35 P. S. 'l 680.401 (a) (1)]. 11. Plaintiff was not required to send Defendant written notice of Plaintiffs to foreclose said Mortgage pursuant to 41 P.S. '403 (Act 6 of 1974) prior to the of this action for the reasons that the Defendant is not a "residential mortgage debtor" 0 defined in 41 P.S.'101. 12. The amount due and owing Plaintiff by the Estate is as follows: Principal $ 128,134.00 Interest to 6/2/10 $ 3,924.12 Late Charges to 6/2/10 $ 166.08 Escrow Deficiency to 6/2/10 $ 0.00 Corporate Advances $ 217.70 Attorney's fees $ 1,300.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $ 136,241.90 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the ount due of $136,241.90 with interest thereon at the rate of $21.50 per diem from June 3, 010, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. BY: v 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 INFORM ATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" a?aq ! cg-? Recordation Requested by: Howard Hanna Mortgage Services 119 Gamma Dr Pittsburgh, PA 15236 When Recorded Mail to: Howard Hanna Mortgage Services 119 Gamma Dr Pittsburgh, PA 15238 Send Tax Notices to: 38 JOHNS DRIVE ENOLA, PA 17025 PARCEL TAX 10M. 0945-1268.410 lom Above This Lim For Rewrdin8 Data] - " State of Pennsylvania LOAW 200852099 MIN 10002914200852099.0 MORTGAGE THIS MORTGAGE ("Security Insirument") Is given on September 29th, GERMAN A ROVNYANSKY, AN UNMARRIED PERSON whose address is 319 WEST SHADY LANE UNIT P, ENOLA, PA 17125 %I-- i illi ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. (" j, (solely as nominee for Lender, as heraalter defined, and Lenders successors and assigns), MBRS is organlz and existing under the lays of Delaware, and has an address and telephone number of 3300 S.W. 34th Avenue, Suite 101, Ocala, FL 34474 or P.O. BOX 2026, Flint, MI 48501.2026, tel. (888) 6794BRS. Howard Hanna Mortgage Services, a Pennsylvania Corporation which Is organized and existing under the laws of THE COMMONWEALTH OF PENNSYLVANIA , and wh0se address is 119 Gamma Dr, Pittsburgh, PA 15288 ONE HUNDRED THIRTY THOUSAND ONE HUNDRED AND NO1100 ewer owes Lender the principal shun of Dollars (U.S. $ 180. This debt is evidenced by Borrowers note dated the same date as this: Security y Inst Inst 100-00 rument ("Note"), which provides for mopthly payments, with the fail debt, If not paid earlier, due and payable on October 1 2038 This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all mw*i ls, extensions and modifications of the Note; ) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Sfflxrity Instrument, and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. InrN r P841* YLVANIA -Single Famay - FHA SECLFM INSTRUMEdT -1108 Page v or a GCC - mi 5904 PIA ) XI •r For this purpose, Borrower does busby mortgage, grant and convey to MERS (iolely as nominee for Len and Lender's successors and assigns) and to the successors and assigns of MFRS, the following described prop" located in CUAMERI AND County, Pennsylvania: SEE ATTACHED LEGAL DESCRIPTION which has the address of 38 JOHNS DRIVE, ENOLA Pennsylvania 17025 ("Property Address"); C41. VAP COO! TOGETHER WITH all the improvements now or hereafter erected on the property, and a appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions covered by this Sectrily Instrument. All of the foregoing is referred to in this Security Instru "Property." Borrower understands and agrees that MERS holds only legal title to We Interests Borrower in this Security Instrument, but, if necessary to comply with law or custom, MERS (ns Lender and Lender's successors and assigns) has the right to exec ise any or all of those inteests, I t not limited to, the right to foreclose and sell the Property; and to take any action required of Lend but not limited to releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seburd of the estate hereby conveyed right to mortgage, grant and convey We Property and that the Propety Is unencumbered, except for e of record. Borrower warners and will defend generally the title to te Property against all claims a en suloct to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform cov nls with limited variWoas by jurisdiction to constitute a uniform security Instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and We as follows: 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 Payments of Taxes, Insurance and Other Charges. Borrower shell Include In each mo nthly payment, together with the principal and Interest as set forth in the Note and any two charges, a sum of (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents the Property, and (c) premiums for insurance required under paragraph 4.1n any year In whkb the Lender moat a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary', or in any In which such premium would have been required if Lender still held the Secudly Instrument, each monAddy t shall also Include either: (i) a sum for the annual mortgage insurance premium to be paid by Lander the Secretary, or (ii) a monthly charge instead of a mortgage Insurance premium V this Security Instrument is by the Secretary. in a reasonable amount to be determined by the Secretary. Except for the monthly charge the Secretory, dim items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds". Lender may, at any time, collect and hold amounts far Escrow Items In an agpegrte amount not to the maxitmurn amount that may be required fbr Borrower's escrow account under the Real Estate SeW Procedures Ad of 1974, 12 U.S.C. section 2801 et seq. and implementing regulations, 24 CFR Part S , as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by R85P for unanticipated disbursements or disbursements before the Borrower's payments are available in the acco may not be based on amounts due for the mortgage Insurance premium. GW - m1590 2W1(osici) erg. a or a Inaak. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be bold by A, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds d by Leader at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Bo=we and require Borrower to make up the shortage as permitted by RESPA. The Escrow Punds are pledged as additional security for all sums secured by this Security Instrume it. If Borrower readers to Lender the fall payment of all such sums, Borrower's account shall be credited wi the balance remaining for all installment items (a), (b) and (c) and any mortgage insurance premium installmen that Leader has not become obligated to pay to the Secretary, and Leader shall promptly refhad any exoceur to Borrower. Immediately prior to a foreclosure sale of the Properly or its acquisition by Lender, Borro'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 I and 2 shall be applied by Le r as follows: $WL to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly c_b?iu? by the Secretary instead of the monthly mortgage Insurance premium; i & Md. to any taxes, special assessments, leasehold payments or gronad rents, and fire, flood and other hazard insurance premiums, as required; 3,, to interest due under the Note; fligCOL to amortization of the principal of the Note; and alt , to late charges due under the Note. 4. Fire, Plood and Other Hazard Insurance. Borrower shall insure all improvements on the Pro , whether now In existence or subsequently erected, against any hazards, casualties, and contingencies, had ding fare, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the that Lender requires, Borrower shall also insure all improvements on the Property, whether now in exisle ce or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be ,ad with companies approved by Lender. The Insurance policies and any renewals shall be held by Leader 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 if not made promptly by Borrower. Each insurance company concerned Is hereby authorized and directed to payment for each lass dirodly to Lender, instead of to Borrower and to Leader jointly. All or any part tha insurance proceeds may be applied by Lender, at it, option, either (a) to the reduction of the indebtedness er the Note and this Security Instrument, first to any delinquent amounts applied In the order in paragraph , and then to prepayment of principal, or (b) to the restoration or repair of the damaged Properly. Any appllcatf of the proceeds to the principal shall act extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any cess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this ty 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. Ovaupenay, Preservation, Maintenance and Protection of the Property; Borrower's van Appifoadon; Laaseholds. Borrower shall occupy. establish, and use the Properly as Borrower's pri dpaf residence within sixty days after the execution of this Security Instrument (or within sixty days of a later si le or transfer of the Property) and shall continue to occupy the Properly as Borrower's principal residence for at least one year after the date of occupancy, unless Leader determines this requirement will cause undue hardshl) for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall i at* Lender of any extenuating circumstances, Borrower shall not commit waste or destroy, damage or substantially GCC • 1 ago-8PA (oeM) Paps 3 W 8 inklair T Y change the Property or allow the Properly to deteriorate. reasonable wear and tear excepted. Lender may the Property If the Properly is vacant or abandoned or the loan is in dellanlt. Leader may take reasonable to probed and preserve such vacant or abandoned Properly. Borrower shall also be is debult if Borrower, the loan application process, gave materially false or inaccurate infotmabbn or statements to Larder (or to provide Lender with any material information) in connection with the loan evinced by the Note, .but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence, this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the least. If acquires he title to the Property, the leasehold and fee title shall not be merged unless Lender agrees the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consetm connection with any condemnation or other taping of any part of the Property, or for conveyance condemnation, are hereby assigned and shall be paid to Leader to the extent of the foil amount of We that remains uWW under the Note and this Security Instrument. Leader shall apply such proreduction of the Indebtedness under the Note and this Security Instrument, first to any delinquent amoin the order provided in paragraph 3, and then to prepayment of principal. Airy application of the prprincipal shall not extend or postpone the due date of the monthly payments, which are referred to In or change the amount of such payments. Any excess proceeds over an amount required to pay all indebtedness under the Note and Was Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protoatioa of Leader's Rights in the Property. Borrower shall all governmental or municipal charges, fines and impositions that are not included in paragraph 2. shall pay these obligations on time directly to the entity which Is owed the payment. If failure to pay would affect Lender's interest in the Property. upon Lender's request Borrower shall promptly furnish to Leader Is evidencing these payments. If Borrower Bills to make these payments or the payments required by paragraph 2, or fans to pufta any other covenants and agreements contained In this Security instrument. or theirs is a legal proceeding thal may significantly affect Lender's rights in the Property (suds as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Leader may do and pay whatever Is necessary to probed the value of the Property and Lender's rights In the Properly, including payment of (am, hazard insuruce and other item mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional dirt of Borrower a? d be secured by this Security Instrument. These amounts shall bear Interest from the date of disbursement at thel Note rate, and at the option of Lender shall be immediately due and payable. Borrows shall promptly discharge any lien which has priority over this Security Instrument Borrower: (a) agrees In writing to the payment of the obligation secured by the lien in a manner to Leader; (b) contests In good faith the Hen by, or defends against enforcement of the lien in, legal p which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the hol r of the lien an agreement satisfactory to the Leader subordinating the Hen to this Security Instrument. If der .W to a lien which may attain priority over this ty determines that any part of the Property is sub Instrument. Leader may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may called fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Dedtenlt. Lender may, except as limited by regulations issaW by the Secretary in the cue of payment defaults, require immediate payment in Poll of all sums secured by this Security Insti mat if: p) Borrower defaults by falling to pay In full any monthly payment required by this S ty Instrument prior to or on the due date of the next monthly payment, or (IQ Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained In this Security Instrument. K- GOC - I50"PA MM) POP 4 of a Widu (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including section 1(d) of the Garn-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701)-3(d)) and with prior approval of the Secretary, require immediate payment In full of all sums secured by this Security Ins eat if (i) All or part of the Property, or a beneficial Interest In a trust owning all or part of the Properly, is sold or otherwise transferred (other than by devise or descent), and (U) The Property Is not occupied by the purchaser or grantee as his or bar principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approin accordance with the requirements of the Secretary. (e) No Waiver. If circumstances occur that would permit Lender to require immediate payment in fill} but Lender does not require such payments, Lender does not waive Its rights with respect to subsequent ova s. (d) Regulations of HUD Secretary. In many circumstances regulations Issued by the Secretary will 't Lender's rights, In the case of payment defaults, to require immediate payment in fill and foreclose 1 not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regale ions of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if tins Security Instrument and the Note are not Ideteed to be eligible for insurance under the National Housing Act within 30 DAY from the Lender may, at its option require immediate payment in full of all sums secured by this Security A written statement of any authorized agent of the Secretary dated subsequent to 30 DAY e date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusif such Ineligibility. Notwithstanding the foregoing, this option maay not be exercised by Lendeunavailability of insurance is solely die to Lender's failure to remit a mortgage insurance premSecretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in fall because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right a es even after foreclosure proceedings are Instituted. To reinstate the Security Instrument, Borrower shall In a lump sum all amounts required to bring Borrower's account current including, to the extent they are ous of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Seirrity Instrument and the obligations that It secures shall remain in effect as if Lender had not required imam to payment in full. However, Lender Is not required to permit reinstatement If: (1) Lender has reinstatement after the commencement of foreclosure proceedings within two years immediately prece i the commencement of a current foreclosure proceeding, (10 reinstatement will preclude foreclosure on at grounds in the future, or (111) reinstatement will adversely affect the priority of the lien created by this ty Instrument. 11. Borrower Not Released; Forbearance By Leader 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 su in interest. Lender "I not be required to commence proceedings against any successor in interest or reh se to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrume at by reason of any demand made by the original Borrower orBorrower's successors in interest. Any forbearan by Leader in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Sucoamors and AsWsos Bound; Joint and Several Liabl[ity; Co-Signers. The cove jAny agreements of this Security Instrument shall hind and benefit the successors and assigns of Lender and Bo subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be Joint and ral Borrower who co-signs this Security h>strument but does not execute the Note: (a) is co-signing this ty Instrument only to mortgage, grant and convey that Borrower's interest in fire Property under the terms OCC - 1590-5PA (08100) Papa 5 ore ankWst Security Instrument; (b) is not personally obligated to pay the sums secured by this Security lostrumeM; (c) Was; that Lender and any other Borrower may agree to extend, modify, forbear or make any s ations with regard to &a terms of this Security Instrument or the Note without that Borrower's consent. 13. Notions. Any notice to Borrower provided for In this Security Instrument shall be given by ddM d% it or by maiNng It by first class mail unless applicable law requires use of another method. The notice sl all be directed to the Property Address or any other address Borrower designates by notice to Lender. Any ice to Lender shall be gives by first class mail to Lender's address stated herein or any address Lender d by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been to Borrowed or Lender when given as provided in this paragraph. 14. Governing Law; Sevaability. This Security InOmment shall be governed by Federal law and a law of the jurisdiction in which (be Property Is located. In the event flat any provision or clause of this S ly Instrument or the Note conflicts with applicable taw, such conflict shall not affect other provisions this Security Instrument or the Note which can be given effect without the conflicting provision. To this d the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be giver one conformed copy of the Note and of this Se curity Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, stem je, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else do, anything affecting the Properly that Is in violation of any Environmental Law. The preceding two sentence s shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances at are generally recognized to be ap?ate to normal residential uses and to mnatntenance of the ? i Borrower shaft prompt yy glue Lender written notice of any Investigation, claim, de d, lawsuit or other action by any governmental or regulatory agency or private party hmlvlng the Properly and any Haza rdous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or Is noti by any governmental or regulatory authority. that any removal or other remedtation of any Hazardous S ce affecting the Property Is necessary. Borrower shall promptly take all necessary remedial actions in acco ce with Environmental Law. As used In this paragraph 16, "Hazardous Substances" are those substances defined as toxic or haza rdous substances by Environmental Law and the following substances: gasoline, kerosene, An flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbash is or formaldehyde. and radioactive materials. As used in this paragraph 16, "Environmental Law" mesna federa l laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental prof n. NON-UNIFORM COVENANTS. Borrower and Lender farther covenant and We as follows: 17. Assignment of Rota. Borrower unconditionally assigns and transfers to Lender all the ran and revenues of the Property. Borrower authorizes Lender or Lender's agents to tolled the rents and and bereby directs each tenant of the Property to pay the rents to lender or Lender's agents. However, or to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security ant, Borrower shall collect and naive all rents and revenues of the Property as trustee for the benefit of Len and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for addi nal security only. If Lender gives notice of breach to Bonower: (a) all rents received by Borrower shall be held by 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 shalt all rents due and unpaid to Lander or Leader'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 would prevent Lender from exercising its rights under this paragraph 17. GCC -169 0$PA (96100) Pape s of a maim, i I Lender shall not be required to enter upon, take control of or maintain the Property before or aft l oving notice of bread to Borrower. However, Leader or a judldally appointed receiver mrq? do so at any time the m is a breach. Any application of rents shall not cars or waive my deihalt or invalidate any other r[09 rm* dy of 4 Lender. This assignment of rents of the Properly shall terminate when the debt secured by the Securlly -butri nneut is paid In fall. 18. Foreclosure Procedure. If Lender requires immediate payment in fail under paragraph 9, may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect ail wq mss In pursuing the nm W&m provided in this paragraph 18, including, but not IiMted to, reasonable a 'fees and costs of title evidence to the exlert permitted by applicable law. If the Leader's interest in this Security Instrument is held by the Secretary and the Secretary ufres Immediate payment In fill under paragraph 9, the Secretary may invoke the nor judicial power of sale provii led in the Single Family Moetgtnge Foreclosure Act of 1994 ("Act's 42 U.S.C. 3751 at seq.) by regae a osare commissioner designated under the Act to commence foreclosure and to sell the Property as provided In Act. Nothing In the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and ttsfy this Security Instrumest without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, valves and releases any error or in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or !iris laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and hum otead exemption. 21. Rebwtatement Period. Borrower's time to reinstate provided In paragraph 18 shall extend too hour prior to the commencement of bidding at a sherlWs sale or other sale pursuant to this Security Instrument. 22. Purdum Money Mortgage. If amy of the debt secured by this Security Instrument Is lent to Bor rower to acquire tike 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 judyn ot is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time u the Note. 24. Riders to this Security Instrument. If one or more riders an executed by Borrower and rec aded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a of this Security Instrument. [Check applicable box(es)] Condominium Rider Growing Equity Rider Growing Graduated Payment Rider Unit Development Other(s) [spacif'] LEML aCC-1590.7PA (oeroo) Pago 7 or 13 BY SIGNING BELOW, Borrower accepts and agrees to the terms contained In this Security in any rider(s) executed by Borrower and recorded with it. 7 wi This is a contract under seal and my be enforced under 42 Pa. C.S. Section GERMAN A ROVNYANSKY and (sue -(Seal) -Borrower (SO) CERTIFICATE OF RESIDENCE I hereby certify, that die precise address of the mortgagee, d Hanna Mortg 0 Services herein is follows: ' /J 119 Gamma Dr, Pittsburgh, PA 16238 W f j fJ •Altwaap Ageat for Mwgnu INDIVIDUAL ACKNOWLEDGMENT STATE OF PEVNSYLANIA 1 A ) ??- ) ss COUNTY OF ) On this, the 29th day of September „ 2008 , before me the undersigned Notary Public, personally appeared GERMAN A ROMNYANSKY, AN UNMARRIED PERSON known to me or satshoorily proven) to be the person whose name(s) is/are subscribed to the within and acknowledged that lhe/shatthey executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my *lei& GCC - 1690.8PA (08107) Page a of a NOTARIAL SEAL UNDA L. Md*TH, Notary Publc Camp HM WM Chrttberlathd C X12 My Gomtidti ift ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southernmost corner of Lot No. 267 on the hereinafter described Final Subdivision Ian; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds Bast, a distance o 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivision Plan; then along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119. 4 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; enoe along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds Wesk a distance of 27.70 feet to a point; thence continuing along the same, by a urve to the right, having a radius of 125.00 feet, an aro length of 44.88 feet, to a point at the southwest comer of t No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated lime 5, 2sod July in Plan 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, pt=iv; Book 83, Page 113. BEING improved with a townhouse dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots am. such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utili purposes. Electric service will be supplied only from the underground distribution system in accordance with en current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, easements, set-back lines and condi ons as now appear of record including, but not limited to Declaration of Covenants and Restrictions app ' le to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, PITW"al dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easernen? across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING THE SAME PREMISES which Laurel Hills Development Corp., a Pennsylvania corpomti by deed dated December 23, 2005 and recorded December 27, 2005 in the Office of the Recorder of Dee in and for Cumberland County in Deed Book 272, Page 2507, granted and conveyed unto Dana L. Carley, ' gle person, Grantor herein. 4 Barristers Land A CO. 3310 mww Camp HUI PA 1 811 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200833295 Recorded On 10/1/x008 At 3:38:31 PM * Total Pages -10 * Instrument Type - MORTGAGE Invoice Number - 30046 User M - KW * Mortgagor - ROVNYANSKY, GERMAN A * Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC * Customer - BARRISTERS LAND ABSTRACT CO * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $10.00 JUSTICE DO NOT DETACH RECORDING FEES - $21.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $10.00 FEES of this legal document. APP@RDABLE ROUSING $11.50 COUNTY ARCHIVES PEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $58.50 I Certify this to be recorded in Cumberland County PA 10- .N/° RECORDER( "-Information denotcd by an asterisk may change during the verification process and may not be reflected on this 11111111111111 EXHIBIT "B" CHF Loan No.: 1 77 1 1 20700 Prepared By: Grenen & Birsic, P.C. One Gateway Center, 90 Floor Pittsburgh, PA 15222 Return To: Grenen & Birsic, P.C. One Gateway Center, 90' Floor Pittsburgh, PA 15222 Parcel #: 09-15-1288-410 ASSIGNMENT OF MORTGAGE From German A. Rovnyansky, Mortgagor To Mortgage Electronic Registration Systems, Inc., as Nominee for Howard Hanna Mortgage Services, Mortgage Dated: September 29, 2008 Mortgage Recorded: October 1, 2008 Instrument Number 200833295 in the Recorder's Office of Cumberland Mortgagee County, Pennsylvania. Amount: $130,100.00 For value received and intending to be legally bound hereby, Mortgage Electronic Regist] Systems, Inc. (Assignor) does hereby this 141,• day of St z , 2010, grant, sell, transfer, set over and deliver unto Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation (Assignee), its successors and assigns, all right, title and interest of Assignor in and ti above-referenced Mortgage together with all of Assignor's rights, remedies, incidents and appurtc as stated in the Mortgage and all of the right, title and interest of Assignor in the premises describ Mortgage; and Assignor specifically assigns by this Assignment the debt instrument intended to b secured by the Mortgage Assignor, its successors and assigns, is making this Assignment of Mortgage without any recourse, representation or warranties. In Witness Whereof, Assignor has caused this Assignment to be executed by its hand and with authority therefore, the day and year first above written. ATTEST: q 1 11 1 - L 61 Mortgage Electronic Registration S, Kristine M. Antliou Certifying Officer h?llllll assign, the in the Inc. Property Address: 38 Johns Drive, Enola, PA 17025 East Pennsboro Township k STATE OF PENNSYLVANIA ) ) ss: COUNTY OF ALLEGHENY ) On this, the day of T , , 2010, before me, the undersigned officer, personally appeared Kristine M. Anthou, who acknowledged herself to be the Certifying Officer f Mortgage Electronic Registration Systems, Inc., and that she, being authorized to do so, execute the foregoing Assignment of Mortgage for the purposes therein contained by signing the name of th corporation by herself as Certifying Officer. It Witness Whereof, I hereunto set my hand and official seal. COIAMpMAIFAI.TH OF PENN YLVANIA NouAM ?M - _ P&VM A. TOwn•MW Notary PubNC aly of 201 + Notary Public ?-? • Certificate of Residence I, Kari L. Skovira, do certify that the Assignee's precise address is 3415 Vision Drive, Ohio 43219. Commonwealth of Pennsylvania ) ss: County of Cumberland ) Recorded on this day of A.D. 2010, in the Recorder's Office of the said County, at Mortgage Book Volume Page WITNESS: Give under my hand and the seal of the said office the day and year aforesaid. Recorder By: 1 k ? ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201015816 Recorded On 6/16/2010 At 12:21:38 PM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 67430 User ID - MSW * Mortgagor - ROVNYANSKY, GERMAN A * Mortgagee - CHASE ROME FINANCE LLC * Customer - GRENEN & BIRSIC * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 * Total Pages - 3 Certification Page DO NOT DETA This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA /4 RECORDER( * - Information denoted by an asterisk may change during) the verification process and may not be reflected on th' page. EXHIBIT "C" . Public Records, - Search Results View: Results List I Full ? 1 - 1 of 1 Find FOCUSTM Terms Search: Public Records > Social Security Death Master Search a > Search Results Terms: ssn(164-72-6036) ( Edit Search I New Search ) Page 1 of 1 L s Select for Delivery or View Checked 0 Full Name DOD SSN Death Issuing Authors No. Certificate View Source SSN Search Documents 1. ROVNYANSKY, 02/16/2010 164-72-XXXX Social Security GERMAN Link ID: Administration (DOB: 08/1961) 002208140759 Search: Public Records > Social Security Death Master Search 13 > Search Re Its Terms: ssn(164-72-6036) ( Edit Search New Search ) Date/Time: Friday, July 02, 2010 12:02 PM Your DPPA Permissible Use: Litigation Your GLBA Permissible Use. Leaal Compliance About LexisNexis I Terms & Conditions I Contact Us $rLexisNmiss Copvriahta 2010 LexisNexis, a division of Reed Elsevier Inc. All rights Riag.Framework.Web v1.0.3808.18448 I'ail https://r3.lexis.com/lexisprma/Results.aspx?setld=ccOlbac5-f9d7-49da-8a54-385ddc8l66db 7/2/2010 VERIFICATION U&dW Born , 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 unworn falsification to authorities, that the facts set forth in the foregoing Complaint are true and correct to his/her know information and belief. Chase Home Finance ] Chase Manhattan Mortgage s/b/m/t mm" BOm , Assistant Secretary M 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 The last known address of Defendant is: 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 GRENEN &BIRSIC, P.C. Attorneys for Plaintiff NO.: 10-5416-Civil Term 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: Kristine M. Anthou, Esquire Pa. LD. #77991 ~~ a ~ ri.s -~~ :~ ~ ~ ~ ~. ~ ~ ' °~~, .s. ::, ~.:.~ 1.3 t r=-, -T~ GRENEN &BIRSIC, P.C. _~ ~, ~' ~~° One Gateway Center v=~~=' ~ ~ -; Ninth Floor '`~ v~= -- Pittsburgh, PA 15222 ~ ' `J' ~,._ __.; (412) 281-7650 ~~~. oc~~t ~L. R~~ CK~ /3v~~7 ~~t c.~ rn~ ~~~ 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil Term PRAECIPE FOR DEFAULT 3UDGMENT TO: PROTHONOTARY SLR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, in the amount of $140,472.37, which is itemized as follows: Principal $ 128,134.00 Interest to 9/30/10 $ 5,886.18 Late Charges to 9/30/10 $ 166.08 Escrow Deficiency to 9/30/10 $ 1,988.61 Corporate Advances $ 497.50 Attorney's fees $ 1,300.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $ 140,472.37 with interest on the principal sum at the rate of $21.50 per diem from October 1, 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. BY: Kristine . Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OFNON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant was not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copy. ~~.~ ~~ Sworn to and subscribed before me this day of , 2010. Notary ublic COMMONWEALTH OF PENNSYLVANIA NotaAal Seal Elizabeth M. Gagnon, Notary Publk City Of Pitt~urgh, Allegheny County My Commission Expires ]an. 6, 2012 Member. Pennsvivanla Association of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DNISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 10-5416-Civil Term vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. TO: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview Street, Apt. 806 Santa Cruz, CA 95060 DATE OF NOTICE: September 22, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE 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 NOTICE TO A 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 GRENEN & BIRSIC, P.C. ' c 'iLta! c•~-~~~ By: Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID 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.: 10-5416-Civil Term vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NOTICE OF ORDER, DECREE_OR JUDGMENT TO: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 ( )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: $140,472.37 with interest on the principal sum at the rate of $21.50 per diem from October 1, 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 CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 10-5416-Civil Term vs. TYPE OF PLEADING: ALEKSEY G. ROVNYANSKY, Administrator of the Estate of Proof of Service GERMAN A. ROVNYANSKY, Defendant. 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 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 ~_, } r~ :~::•~ -y ~» _rg t~ r ~ _.. ~ i..~ CY~i M1~7 i y _ .~ T ! ~ '°°T~ ~ ~~~ m~ !/_~ ' .....~. ~>.y ~,..~ + ~ i "~ F-;~n _~~t c~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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil Term PROOF OF SERVICE Kristine M. Anthou, Esquire, 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 Plaintiff s Complaint in this matter on Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky: 1. On August 23, 2010, Plaintiff mailed a copy of the Complaint in Mortgage Foreclosure to Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, at 41 Grandview St., Apt. 806, Santa Cruz, CA 95060, by certified mail, return receipt requested. 2. On or about September 2, 2010, the signed certified mail receipt was returned to Plaintiff, indicating that Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, was served with the Complaint in Mortgage Foreclosure. A true and correct copy of the signed receipt is marked Exhibit "A", 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: ~~. Kristine . Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS~DAY OF 2010. Notary Public M NWEALTH OF PENNSYLVANIA Natartal Seal Elizabeth M. Gagnon, Notary Public City of plgsburgh, Allegheny County My Comm~slon Expires ]an. 6, 2012 Member, Pennsvivania AssodaUon of Notaries EXHIBIT "A" ~--- ~--~ -- E' ~ Hiara 1; ~. and 3._AierioampM~s~ t ite~» 4 !t Rest~ia~ted Deik+wy Is deelieci. ^ Prim your r~rrs er~d address on the reverse so that we cmr return the cad to you. ^ Attaoh thbs ~ to the bade d the m~. . or on the trorrt K specs permits: 1. ardcrsAddre.eidtoc ~ ~e.~,g~1 G , ~~ ny a~ sk ~c~:in ~ -~~~ ~~` y B. by (Rirdad Narns) !~. Dses ot` Delkeryr ~dMrsyredtl~sdNlitr~rtt+an 1?' CfYbs tt vE?lii enter dWwry addreeabsl0~r. RECD SEP 0 ~ ~~ ~~~ ~~oA ~ ~`~+tt 2• Artla.Mtnb.. 70Q9 282Q 0002 5288 045 (liantlirFAvara sarrk+s 1...., ~..~.~ PS Forrrr 38 1. Fel~xuar~ 2t»t" DonNSlb Ratum ' " 4 CERTIFICATION OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Proof of Service was mailed by U.S. First Class Mail, postage pre-paid, on the day of 2010, to the following: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5416 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From ALESKEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A ROVYNANSKY (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 $140,472.37 L.L.$.50 Interest FROM 10/1/10 -- $8,373.44 Atty's Comm % Due Prothy $2.00 Atty Paid $132.50 Other Costs Plaintiff Paid Date: 2/24/11 David D. Buel , Prothonotary (Seal) By: REQUESTING PARTY: Name: BRIAN M. KILE, ESQUIRE Address: ONE, GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. $140,472.37 $ 8,373.44 $148,845.81 PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary SIR: n C7 -u rn ` --A C' Please issue a Writ of Execution, directed to the Sheriff of Cumberland County, against the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, as follows: Amount Due Interest from 10/ 1 / 10 TOTAL ?13a• Sc 066- ( I PGl A?.kr 3 2337 SCG `I GRENEN & BIRSIC, P.C. CIVIL DIVISION NO.: 10-5416-Civil By: ? - ?-- L Attorneys for Plaintiff 14W Z')?,, da-? L L 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, NO.: 10-5416-Civil vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southernmost comer of Lot No. 267 on the hereinafter described Final Subdivision Plan; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds East, a distance of 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivision Plan; thence along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119.74 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; thence along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds West, a distance of 27.70 feet to a point; thence continuing along the same, by a curve to the right, having a radius of 125.00 feet, an arc length of 44.88 feet, to a point at the southwest corner of Lot No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001, last revised July 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 83, Page 113. BEING improved with a townhouse dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots and such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utility purposes. Electric service will be supplied only from the underground distribution system in accordance with then current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, easements, set-back lines and conditions as now appear of record including, but not limited to Declaration of Covenants and Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easement across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING the same premises which Dana L. Carley, single person, by Deed dated September 26, 2008 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008, at Instrument Number 200833294, granted and conveyed unto German A. Rovnyansky. German A. Rovnyansky died on February 16, 2010, Aleksey G. Rovnyansky, the Administrator of the Estate of German A. Rovnyansky, became the owner by operation of law. GRENEN & BIRSIC, P.C. By. Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 09-15-1288-410 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. CIVIL DIVISION NO.: 10-5416-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 Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky located at 38 Johns Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 1. The name and address of the owner or reputed owner: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 2. The name and address of the Defendant in the judgment: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 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 [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, 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 may be affected by the sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant(s) 38 Johns Drive Enola, PA 1702 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. Brian M. Kile, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ?- DAY OF 2011. Notary Pu lic ??ry pF PENNSYLVANIA COMMONW? otarial Seal Elizabeth K Gagnon' Notary Public h Allegheny County City of Pittsburg , 2012 My commission Expires . tion of Notaries Member of n- la nia Associ 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) S w r `.r) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Brian M. Kile, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owner of the property located at 38 Johns Drive, Enola, PA 17025 is Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, who resides at 41 Grandview St., Apt. 806, Santa Cruz, CA 95060, to the best of her information, knowledge and belief. 7 SWORN TO AND SUBSCRIBED BEFORE ME THIS ?'b-70 DAY OF 2011. Notary blic COMMONWEALTH 0 PENNSYLVANIA Notarial seal public Elizabeth M. Cagnon, Notary City of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2012 Mern?r p'"` ""* n'? Association of Notaries 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.: 10-5416-Civil ..a :: ? + vs. 74 - ?, ALEKSEY G. ROVNYANSKY, `'• == Administrator of the Estate of CD GERMAN A. ROVNYANSKY, Defendant. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974,41 P.S.101, ET. SEQ. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Brian M. Kile, attorney for the Plaintiff, who being duly sworn according to law deposes and says that Plaintiff was not required to send Defendant written notice pursuant to 35 P. S. §1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 Act 91 of 1983) prior to the commencement of this action for the reason that the mortgaged premises is not the principal residence of the Defendants [35 P.S. § 1680.401(a) (1)]. Additionally, Plaintiff was not required to send Defendant written notice of Plaintiffs intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reasons that the Defendant is not a "residential mortgage debtor" as defined in 41 P. S. §101. SWORN TO AND SUBSCRIBED BEFORE THIS _ DAY OF "AJJAXk? 2011. oh??' ?2(19o" Notary Publi COMMONWEALTH OF PENNSYLVANIA Notarial Seal Public Elizabeth M. Cagnon, Notary City of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2012 Member a?nns?lvania 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, NO.: 10-5416-Civil CIVIL DIVISION VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 -mac : c ' T'a 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 June 1, 2011, at 10:00 A.M., the following described real estate, of which Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 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. Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, Defendant, at Execution Number 10-5416-Civil in the amount of $148,845.81. 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. B C y Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 .01 4 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil LONG FORM DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southernmost corner of Lot No. 267 on the hereinafter described Final Subdivision Plan; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds East, a distance of 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivision Plan; thence along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119.74 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; thence along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds West, a distance of 27.70 feet to a point; thence continuing along the same, by a curve to the right, having a radius of 125.00 feet, an arc length of 44.88 feet, to a point at the southwest corner of Lot No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001, last revised July 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 83, Page 113. BEING improved with a townhouse dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots and such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utility purposes. Electric service will be supplied only from the underground distribution system in accordance with then current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, easements, set-back lines and conditions as now appear of record including, but not limited to Declaration of Covenants and Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easement across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING the same premises which Dana L. Carley, single person, by Deed dated September 26, 2008 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008, at Instrument Number 200833294, granted and conveyed unto German A. Rovnyansky. German A. Rovnyansky died on February 16, 2010, Aleksey G. Rovnyansky, the Administrator of the Estate of German A. Rovnyansky, became the owner by operation of law. GRENEN & BIRSIC, P.C. By. , s iV Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 09-15-1288-410 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Home Finance LLC vs. Aleksey G Rovnyansky 011, ?n 2: 9 ['*UNBEPLA,vim l'~ =`f PENNSYL4A14,11 Case Number 2010-5416 SHERIFF'S RETURN OF SERVICE 03/17/2011 03:02 PM - Deputy Michelle Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 38 Johns Drive, Enola, PA 17025, Cumberland County. 04/12/2011 Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice and Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Aleksey G. Rovnyansky at 41 Granidview Street, Apt 806, Santa Cruz, CA 95060. The mailing was returned Unclaimed" and returned to the Cumberland County Sheriff's Office on 4/12111 05/26/2011 As directed by Brian M. Kile, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/7/2011 08/03/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,181.65 August 03, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF DD pd 67. 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-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 Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky located at 38 Johns Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 1. The name and address of the owner or reputed owner: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 2. The name and address of the Defendant in the judgment: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 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 [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, 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 may be affected by the sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 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. NO.: 10-5416-Civil ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 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 June 1, 2011, at 10:00 A.M., the following described real estate, of which Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 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. Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, Defendant, at Execution Number 10-5416-Civil in the amount of $148,845.81. 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. r By: J, 111 Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 s 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.: 10-5416-Civil vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southernmost corner of Lot No. 267 on the hereinafter described Final Subdivision Plan; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds East, a distance of 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivision Plan; thence along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119.74 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; thence along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds West, a distance of 27.70 feet to a point; thence continuing along the same, by a curve to the right, having a radius of 125.00 feet, an arc length of 44.88 feet, to a point at the southwest corner of Lot No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001, last revised July 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 83, Page 113. BEING improved with a townhouse dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots and such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utility purposes. Electric service will be supplied only from the underground distribution system in accordance with then current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, easements, set-back lines and conditions as now appear of record including, but not limited to Declaration of Covenants and r Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easement across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING the same premises which Dana L. Carley, single person, by Deed dated September 26, 2008 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008, at Instrument Number 200833294, granted and conveyed unto German A. Rovnyansky. German A. Rovnyansky died on February 16, 2010, Aleksey G. Rovnyansky, the Administrator of the Estate of German A. Rovnyansky, became the owner by operation of law. GRENEN & BIRSIC, P.C. By: ;? t L' Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 09-15-1288-410 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5416 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 ALESKEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A ROVYNANSKY (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 $140,472.37 L.L.$.50 Interest FROM 10/1/10 -- $8,373.44 Atty's Comm % Due Prothy $2.00 Atty Paid $132.50 Other Costs Plaintiff Paid Date: 2/24/11 avid D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: BRIAN M. KILE, ESQUIRE Address: ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. TRUE COPY FROM RECORD In Testimony whereof I here unto set my hand and the Seal of said Court at Carlisle, Pa. This day of 20 l Prothonotary c I On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 38 Johns Drive, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-5416 Civil Chase Home Finance LLC vs. Aleksey G Rovnyansky, Administrator of the Estate of German A. Rovnyansky Atty.: Brian M. Kile ALL THAT CERTAIN piece or parcel of land situate in the Town- ship of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and de- scribed as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southern- most corner of Lot No. 267 on the hereinafter described Final Subdivi- sion Plan; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds East, a distance of 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivi- sion Plan; thence along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119.74 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; thence along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds West, a dis- tance of 27.70 feet to a point; thence continuing along the same, by a curve to the right, having a radius of 125.00 feet, an arc length of 44.88 feet, to a point at the southwest cor- ner of Lot No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivi- sion Plan of Laurel Hills North, Phase 5, dated June 5, 2001, last revised July 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 83, Page 113. 71 BEING improved with a town- house dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots and such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utility purposes. Electric service will be supplied only from the underground distribution system in accordance with then current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVER- THELESS, to restrictions, easements, set-back lines and conditions as now appear of record including, but not limited to Declaration of Covenants and Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscella- neous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easement across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING the same premises which Dana L. Carley, single person, by Deed dated September 26, 2008 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008, at Instrument Number 200833294, granted and conveyed unto German A. Rovnyan- sky. German A. Rovnyansky died on February 16, 2010, Aleksey G. Rovnyansky, the Administrator of the Estate of German A. Rovnyansky, be- came the owner by operation of law. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 22, April 29, and May 6, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, Lito=r SWORN TO AND SUBSCRIBED before me this da of May, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patti* ot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 ?_ 05/06/11 1 Ux .?'j?' Sworn to,ali subscribed bef e t 2 d of May, 2011 A. D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrle 1, l0sner, Notary Public Lower Paxton Twp., Dauphin County My Commisslon 6cplres Nov. 26, 2011 Member, Pennsylvania Association of Notaries ALL THA'T' `Cf:R" pi-e or parcel of land situate in the Tmndlip of "Fast Pento m, CM M of Cw bwaw and Commoeweah of Pemtayhmma, boop*d iadtid tiaras £oums to wit BE? at it l oir the northem (erroneously stMd as southern ih prior deed) line of lohhs Drive, at the som*xrtlt** com ofSLot 10.267 on the mTojwtafber'&sdibed Final lion pLw, U*pee *ng the ea" Irate of said Lot No. 267, Nortb 24 dcg nss 14 nn antes 10 seams Fast, a &move bf132"M'ket to apb&l n the n?e*ft hW 4L'tyt NO,269.on the ltart? d Pk* %W *m pi"; ftooe_Mk ag *c *Opm liar of said Lot No. 2w, 'to 25 mineUrs 00 sp6t?tds 6'r, a ti :tO f1Q.'R'fw to a,Il t of the *Iosdm (errccw* statdd as scattft m in Ott dmd? i*4- way f of Jo4m Dnvc; tlierit a > ( ttaw es in prior l w Y. bnc of Jol m f)rivT Sguth 81 degrees 3S io 00 k,cmds.Neat, a distance of ?7,-V feet to a poid2 t*n';ey?? B skrag the a ratdais'c1R 1w a.Oant t4j41fe . -14 127f3et, +di a4.?, bo f a P** 2614-11n Plan, the point ;-id . BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, , . 2001, rewrded m the W f tha kicwter o?Pp?e I13, B1 (3,; M. 0 at s; `3!t Jr>l D&c. SUBJECT' to an Easement for utility tnsta}Tmm and maintenance which its rea+eivedo??la?psa??rcasements; F1 ? r+cr?.,, K ;W OG underground S from & dish-battna,>a syskM in accPfdaPcc with the" PY'QrLCW U4 , UNJO NEVERMLOS, to restrictions, easetti, set4aek lines and conditions . as troy appear of rdcard ring, but not I #o Decia of Qvmpa? and Rcj,tricrrona to Fiaml Subdivision Plan For I auNm1h, Phase 5, East PcWbgro &ransbp, Cumberland County, y dart ScVtember 14, 2001, and r, mwOd m *t (tae of ft Racutder 681, 601. ANN) S1j C1 to Part )f a l 4M (-Ls) foot wide dmiO gee casaaont aeausa ibe "stato partidsi Of the 7TIPFg as "M 00 the aGove?tienGed l?"mal ? ?t)tie premisp ljana L. so& person, by Deed dated 26, 2008 apt recorded m the Office cj the T +?r of Deeds of cnmbexl"O"Xi +Oty oa Qctmber 1, 208, at IMW*0 l t;w W6833294, PUWd and cotiveye4luDW German ,k G,mw A %wWwvjpy diod on Vehruary 16, 2MO G. Ruvmyaw*y, the A, *MW At by IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. CIVIL DIVISION NO.: 10-5416-Civil C n cD CD r . -7 . PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary SIR: Please issue a Writ of Execution, directed to the Sheriff of Cumberland County, against the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, as follows: Amount Due Interest from 10/1/10 TOTAL $140,472.37 $ 22.481.13 $162,953.50 GRENEN & BIRSIC, P.C. a s ,18 I. 1o S L"Y?OT C6 u u ?L. () ULi « U ,. BY" Attorneys for Plaintiff tea. as +? ?'j2?d73?3`/ ?? 1S?ued n? 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.: 10-5416-Civil vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. LONG FORM DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive, at the southernmost corner of Lot No. 267 on the hereinafter described Final Subdivision Plan; thence along the eastern line of said Lot No. 267, North 24 degrees 14 minutes 10 seconds East, a distance of 132.75 feet to a point on the western line of Lot No. 269 on the hereinafter described Final Subdivision Plan; thence along the western line of said Lot No. 269, South 08 degrees 25 minutes 00 seconds East, a distance of 119.74 feet to a point on the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive; thence along the northern (erroneously stated as southern in prior deed) right-of-way line of Johns Drive South 81 degrees 35 minutes 00 seconds West, a distance of 27.70 feet to a point; thence continuing along the same, by a curve to the right, having a radius of 125.00 feet, an arc length of 44.88 feet, to a point at the southwest corner of Lot No. 267 on the hereinafter Final Subdivision Plan, the point and place of BEGINNING. BEING Lot No. 268, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001, last revised July 12, 2001, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 83, Page 113. BEING improved with a townhouse dwelling known as 38 Johns Drive. SUBJECT to an Easement for utility installation and maintenance which is reserved on all lots and such other easements, as may be shown in recorded documents, granted to Public Utility Companies for utility purposes. Electric service will be supplied only from the underground distribution system in accordance with then current PP&L Company Tariff provisions. UNDER AND SUBJECT, NEVERTHELESS, to restrictions, easements, set-back lines and conditions as now appear of record including, but not limited to Declaration of Covenants and Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Miscellaneous Book 681, Page 601. FURTHER UNDER AND SUBJECT to part of a twenty-five (25) foot wide drainage easement across the western portion of the premises as shown on the above-referenced Final Subdivision Plan. BEING the same premises which Dana L. Carley, single person, by Deed dated September 26, 2008 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 1, 2008, at Instrument Number 200833294, granted and conveyed unto German A. Rovnyansky. German A. Rovnyansky died on February 16, 2010, Aleksey G. Rovnyansky, the Administrator of the Estate of German A. Rovnyansky, became the owner by operation of law. GRENEN & BIRSIC, P.C. By Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 09-15-1288-410 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, V3. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) f. rTj ?r 0-t 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 Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky located at 38 Johns Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 1. The name and address of the owner or reputed owner: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 2. The name and address of the Defendant in the judgment: Aleksey G. Rovnyansky, Administrator 41 Grandview St., Apt. 806 of the Estate of German A. Rovnyansky Santa Cruz, CA 95060 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 [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, 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 may be affected by the sale: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes Inheritance Tax Division Dept. 280601 Harrisburg, PA 17128-0601 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant(s) 38 Johns Drive Enola, PA 1702 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. 14904 relating to unsworn falsification to authorities. Y ) Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED /q? BEFORE ME THIS. DAY 0F-A 2012. C--_._MMON An OF PENNSYLVANIA Notarial Seal 1`1aryP;O t"; fans, Notary Public City n' v"<:jurQr) Allegheny County m L y Commissic;, Expiates March 16, 2015 MEMBER, PENNSYL' ANU. ASSOCYATION 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 i -.a 71 - f-131 - -? cn A LL, 2, ?3 c7 _....i r1l 1 VS. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 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 5, 2012, at 10:00 A.M., the following described real estate, of which Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky is the owner or reputed owner: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. 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. Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, Defendant, at Execution Number 10-5416-Civil in the amount of $162,953.50. 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. By: Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 10-5416 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 ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY (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: $140,472.37 Interest FROM 10/1/10 - $22,481.13 Atty's Comm: % Atty Paid: $1,342.65 Plaintiff Paid: Date: 4/16/12 (Seal) L. L.: Due Prothy: $2.25 Other Costs: e , Prothonota By: Deputy REQUES'T'ING PARTY: Name: KRISTINE M. ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, P.C. 1 GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA..., c ~ -°i CHASE HOME FINANCE LLC, s/b/m/t -~3 CIVIL DIVISION r~~ ''~ cn `' =~~~`-~ Chase Manhattan Mortgage Corporation, ~ ~ ~'~-:° ~ ~ ~e r; ~,'1 Plaintiff, NO.: 10-5416-Civil E"~ ~ .. ~~' ~ ~r~ ~ vs. ~~ ~ ~' TYPE OF PLEADING --~~ -~" -~` ALEKSEY G ROVNYANSKY -~`~ ^' '':- Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. MOTION FOR SERVICE OF NOTICE OF SHERIFF SALE PURSUANT TO SPECIAL ORDER OF COURT 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 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.: 10-5416-Civil Term vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. MOTION FOR SERVICE OF NOTICE OF SHERIFF SALE PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by and through its attorneys, GRENEN & BIRSIC, P.C., and files the within Motion for Service of Notice of Sheriff s Sale Pursuant to Special Order of Court under Pennsylvania Rule of Civil Procedure 430 as follows: On or about August 19, 2010, Plaintiff filed a Complaint in Mortgage Foreclosure against the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, at the above-captioned number and term. 2. On or about August 23, 2012, Plaintiff mailed the Defendant a copy of the Civil Action -Complaint in Mortgage Foreclosure filed by Plaintiff at the above-captioned number via certified mail, restricted delivery, return receipt requested to her last known address being 41 Grandview Street, Apt. 806, Santa Cruz, California 95060. 3. On or about August 30, 2012, the signed certified mail receipt was returned to Plaintiff, indicating that Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, was served with the Complaint in Mortgage Foreclosure. A true and correct copy of the signed receipt is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about October 14, 2010, Plaintiff entered Default Judgment against Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky in this action in the amount of $140,472.37 and for foreclosure and sale of the mortgaged premises. 5. On or about April 16, 2012, Plaintiff filed with the Prothonotary a Praecipe for Writ of Execution on the judgment in this action. 6. In accordance with Pa. Rule of Civil Procedure 3129, Plaintiff mailed the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky a true and correct copy of Plaintiffs Notice of Sheriff Sale on April 19, 2012 and July 24, 2012, by certified mail, return receipt requested at her last known address being 41 Grandview Street, Apt. 806, Santa Cruz, California 95060. 7. The certified mailings regarding the Defendant have been returned to Plaintiff indicating that the mail is unclaimed. True and correct copies of the returned certified mail envelopes are marked Exhibit "B", attached hereto and made a part hereof. 8. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, and the reasons why service of the Notice of Sheriff s Sale cannot be made, is marked Exhibit "C", attached hereto and made a part hereof. 9. Pursuant to Cumberland County Local Rule 208.3(a)(2), no Judge has ruled upon any other issue in this case or any related matter. 3. Pursuant to Cumberland County Local Rule 208.3(a)(9), the Defendant is pro se and no attorney has entered an appearance of record on behalf of the Defendant. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Sheriff of Cumberland County to serve Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky by mailing a true and correct copy of the Notice of Sheriff s Sale by first-class mail, postage pre-paid to 41 Grandview Street, Apt. 806, Santa Cruz, California 95060 and by posting of the handbill in accordance with Pa. R.C.P. 3129.2(b). Service of the Notice of Sheriffs Sale shall be deemed complete and valid upon mailing by the Plaintiff and posting by the Sheriff. GRENEN & BIRSIC, P.C. r~ Kristine M. Atithou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412)281-7650 ^ ~ ~ f r "~ rK~ .~. 00ltl~l~l~: liefTt 4 It ~ (s C~ll~+~d.- ^ PrItM yC{N flBlie ~ taflthe tdlflfM ~O thaE Nfe-tit fr118it th card t0 y011: • Attadt tfiis t•rd to tl1• of tt~ mailpbcs or on the front H ayes p~srrMts. 1. Article Addrseeed to P~~~.'t~~~G•~CxJ~ anal C~ w~.~,~. ~vr~yar~k-v{ ~1l ~nt~.ar~3~ie~.- S~•, ~~~ Wiz--, ~ °t SOtpt~ B. by { Pr/nhat -Yemsl C. DaEs of De~rary 1~'I4.t"S~`t ~Y^~^~5~~ D. is deYwnr eddrses cyllY~wk Anm I~am i9 D Yes M YE3, enter deNrwy address tnlow: REG'D SEP o 2 ''Q'~~.. I~ 2• ^'"~`"""~ 7009 2820 0002 5288 045 (Iians~rAoirrnrM~r P8 Form 3811. February! oon,eWc Ream ReoefPt ~~ _ Y ~r ~, ~~ ;~ ~~~ ~~ 3a {' ~~ ~~ C~ ~ a "~ r ~ r~ ~ '~ c ~' ~ ..~', ,,~ ~ _. Q r-1 aS .. . ~ M `~' ~ u <°. r ~ ..D .~,,r,= ~ ~ `, ~ ~ .-a ~ ~ ~ O C C ut "~ o, > p > m ...~. p ' ~ ++ N "1'' ~~ ~ ~ +-' C`- C ` ~. .-a ~ ~ ~ ~ C ~'~~' t~ r. t~ ..y j ~i i~ {.~~ !~ n \ l.tl ~` ``~j itt "~ ~` + ~ _O i ~ ~ ~~ } 1. ~ ~ ° J vN w ~ t J~.J i r1. y N C ' ~. \ v Z `r~ p ~ C3. U m N ~ 3 d C N 0~ ~- - \\ °~ ~ W cS U ~ '~ ~ J ! ~ V .o m3a X60 ~~a ~ ~ ~ aciC~~ ~~ ~~~ J `~ ~ c~ C ~ Cy i4 A ,-F ~ '~" ~ I 4' ~ w v 1 q- 7A ~ jA~ r w! w 1~ ,, ~ AQ a 0 wr~a m -- ~Q3 A z a n ~ ,, ,-r ~ ~. owo ~ `,.• ~ !il a t- J F- m -- ~- zaw ~ ~ aa.~ o -- ~, >, ° ~ ~- `~ awm wM z cv - ~- L" a r ^ a~J u r .~ . ;~ ' ~ ~ ." ~ ~ ~ w ~" ~ - Q ~ Q ° '~ z ~ ~ .. ._ a ~ ~ z m > ~ (/~ ~° ~ ~ U a i ~N '~ n "d N ~~ w ~ U ~ ~ ~ ~ v ~.. ~ Q O ~ Cn ~l j ;.~ i N O N C'h O Q 0 w >_ W ~..~ W 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil Term AFFIDAVIT PURSUANT TO PA. R.C.P. 430 COUNTY OF ALLEGHENY ) SS COMMONWEALTH OF PENNSYLVANIA ) Before me, a notary public, in and for the foregoing county and commonwealth, personally appeared Kristine M. Anthou, Esquire, of GRENEN & BIRSIC, P.C. attorneys for Plaintiff and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, named in the above-captioned matter: (a) On July 20, 2012, Plaintiff mailed to the United States Postmaster at Enola, PA 17025 a request to be furnished with a forwarding address of the Defendant. (b) On July 31, 2012, Plaintiff received a response from the United States Postmaster indicating that the Defendant is not known at the address. A true and correct copy of that response is marked as Attachment "A", attached hereto and made a part hereof. (c) On July 20, 2012, Plaintiff mailed to the United States Postmaster at Santa Cruz, CA 95060 a request to be furnished with a forwarding address of the Defendant. (d) As of September 4, 2012, Plaintiff has not received a response from the United States Postmaster indicating the whereabouts of the Defendant. (e) Examinations were made of the Enola Area Telephone Directory; said examination did not produce a listing for the Defendant. A true and correct copy of the search is marked as Attachment "B", attached hereto and made a part hereof. (f) Examinations were made of the Santa Cruz Area Telephone Directory; said examination did not produce a listing for the Defendant. A true and correct copy of the search is marked as Attachment "C", attached hereto and made a part hereof. (g) Examinations were made of the Cumberland County Voter Registration Records; said examination failed to yield any useful information regarding the whereabouts of the Defendant. (h) Examinations were made of the Santa Cruz County Voter Registration Records; said examination failed to yield any useful information regarding the whereabouts of the Defendant. (i) A computer records search of a nationwide database indicates that the Defendant resides at 41 Grandview Street, Apt. 806, Santa Cruz, California 95060. A true and correct copy of the search is marked as Attachment "D", attached hereto and made a part hereof. Finally, affiant deposes and says that after the foregoing investigation, the Plaintiff believes and avers that the Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, resides at 41 Grandview Street, Apt. 806, Santa Cruz, California 95060. GRENEN & BIRSIC, P.C. ,~ ~ «. BY: r ~ ~~ Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Sworn to~anh subscribed before me this _ ~~~`J day of ~~~j,~,m 2012. i _ _T~ Notary Public COMMpNyyEglTFf ©F P Notarial seaEN~ ~~~ CKY of p ' Townsend, Notary Public M tisourgigf Alieghen Y Commission Expdres June County MEMBER, PENNSYLVgN1A A , 2015 ~~T1~N OF NOTq~~ Postmaster N:nola, PA 17025 Date July 20, 2012 Request for Change of Address or Boaholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) for the following: Name: Aleksey G. Rovnyanslry, Administrator of the Estate of German A. Rovnyansky Address: 38 Johns Drive NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manua1352.44a and b. Capacity of requester (e.g., process server, attorney, party representing himself): Paralegal 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro .se must cite statute): 3. The names of all known parties to the litigation: Chase Home Finance LLC, et al. vs. Rovnyansky 4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County 5. The docket or other identifying number if one has been issued: 10-5416-Civil 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. ~, .. , 1~ Signature Jennifer D. Johnson, Paralegal Printed Name Grenen & Birsic, P.C., One Gateway Center, Ninth Floor, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY No change of address order on file. Not known at address given. Moved, left no forwarding address No such address POSTMARK NEW ADDRESS OR BOXHOLDER'S NAME and STREET ADDRESS Free People Search ~ WhitePages WhitePages • People . Business . Reverse Phone • Reverse Address Log In» ~ Help» 1, Aleksey 2, * Rovnyansky 3, ',17025 4, Submit Query Sorry, we could not find a match. Try our sponsors for more information about Aleksey Rovnyansky. Connect with WhitePages: Like <' 31 k! Follow (a,whitepar;es • About Us • Advertise • Careers • B1o~ . Pnvacy • Help . Feedback • Site Man Page 1 of 1 People Search. ~ Business Search ~ Reverse Phone ~ Reverse Address ~ Area Codes ~ Area Code Mans ~ ZIP Codes ~ International ~ More... © 2012 WhitePages Inc. - Privacv Policy and Terms of Use http://www.whitepages.com/search/FindPerson?site_id=15277&firstname begins with=l&... 9/4/2012 Free People Search ~ WhitePages WhitePages . People . Business . Reverse Phone . Reverse Address Lo,~In»~ Heln» 1, Aleksey 2, * Rovnyansky 3, '.95060 4, Submif Que Sorry, we could not find a match. Try our sponsors for more information about Aleksey Rovnyansky. Connect with WhitePages: Like 31 k E~,~ . About Us . Advertise . Careers . Bloc . Pnvacy . Help . Feedback . Site Man Page 1 of 1 PeoQle Search ~ Business Search ~ Reverse Phone ~ Reverse Address ~ Area Codes ~ Area Code Mans ~ ZIP Codes ~ International ~ More... © 2012 WhitePages Inc. -Privacy Policy and Terms of Use http://www.whitepages.com/search/FindPerson?site id=15277&firstname begins_with=l&... 9/4/2012 Page 1 Search: Public Records :Comprehensive Person Report Terms: first-name(Aleksey) last-name(Rovnyansky) state(CA) radius(30) No. Full Name Address/Phone SSN ROVNYANSKY, ALEKSEY G ROVNYANSKY,ALEKSEY (DOB: 1988) (Age: 24) 41 GRANDVIEW ST APT 806 SANTA CRUZ, CA 95060-3096 SANTA CRUZ COUNTY (07!2009-Current) 717-329-0839 /Phone 8 ZIP code conflict 7555 GEARY BLVD APT 104 SAN FRANCISCO, CA 941 21-1 553 SAN FRANCISCO COUNTY (07/2009-05!2010) 164-72-XXXX (PA:1990-1992) LexID(sm):161825667804 Search: Public Records :Comprehensive Person Report Terms: first-name(Aleksey) last-name(Rovnyansky) state(CA) radius(30) Date/Time: Tuesday, September 04, 2012 9:52 AM PermlSSlble USe: DPPA - Litigation GLBA - Legal Compliance Copyright ©2012 LexisNexis, a division of Reed Elsevier Inc. All Rights Reserved. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. AND NOW, to wit, this CIVIL DIVISION NO.: 10-5416-Civil Term ORDER OF COURT day of 2006, upon consideration of the within Motion for Service of the Notice of Sheriff s Sale Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Plaintiff is permitted to serve Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, by first class mail, postage pre-paid at 41 Grandview Street, Apt. 806, Santa Cruz, California 95060 and by posting of the handbill in accordance with Pa. R.C.P. 3129.2(b). Service on the Defendant shall be deemed complete and valid upon mailing and posting in accordance with this order. BY THE COURT: J. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of the Notice of Sheriff s Sale Pursuant to Special Order of Court and Order of Court was mailed to the following on this _~ day of , ~r„w-~~~ , 2012, by first class, U.S. Mail, postage pre-paid: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky 41 Grandview Street, Apt. 806 Santa Cruz, CA 95060 GRENEN & BIRSIC, P.C. Kristine M. A'nthou, Esquire Attorneys 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 CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. ALF.KSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A ROVNYANSKY. CIVIL DIVISION e-> ~ ~..., ~=, ; NO.: 10-5416-CIVIL -:7~ ~, rte, ~ ~-~-' -.~ ~ .ti. ~~ f t__ te` ~ TYPE OF PLEADING r ~_~;', ~~ Pa. R.C.P. RULE 3129.2(c)(2) 'L~' _~ ~~ `', PURSUANT TO RULE 3129 1' ~ ~ , = ~ . LIENHOLDER AFFIDAVIT OF -'~ `"' " ~ - . SERVICE Defendant FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/h; mit Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR. THIS PARTY: 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: 11/7/12 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, SBLM/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff. CNIL DNISION NO.: 10-5416-CIVIL vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Brian M. Kile, Attorney for Plaintiff, Chase Home Finance LLC, s/bim/t Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and rnakes 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 April ]', 9, 2012, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129, ] 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 23, 2012, 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. 1 verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. 1 BY: ~ ~:~ ---~-' Brian M. Kile, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS -~ ~--~ DAY OFIS~' c`i :~-~ , 2012. .. ~ __. „_ ~ Notary Publi ~ ~~ ~~~ ,loanne M. hl~tlnefi . 'v~,, ~ u "A.; ,i;: MCityofPltt~burnh aiF,,r;,,.,., ; t;c~-,*N y Con,mhfit~'i ~ ~r~ P.:r, '~ PaambEr. Pennsyv~ni~~lc„r~.~:>., , , 'i3y EXHIBIT "A" IN "i'ElE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY', Pi;tiNSYLVAN[A CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff; vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 C0;~IMONWEALTH 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 tiled the following information concerning the real property of Aleksey G. Rovnyansky, ,Administrator of the Estate of German A. Rovnyansk.y located at 38 Johns Drive, Enola, PA 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09- l 5-1288-410. I . The name and address of the owner or reputed owner: ~~Icksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky ?. "I"he Warne and address of the Defendant in the judgment: :'1lcksey G. Rovnyansky, Administrator of the Estate of German A. ;Rovnyansky ~ 1 Grandview St.., ,1pt. 806 Santa Cruz, CA 95060 41 Grandview St., Apt. 806 Santa Cruz, CA 95060 3. The name and last known address ofevery judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation ~. T'he 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 S. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. "I'he name and address ofevery other person who has any record interest in the property and whose interest may be affected by the sale: Department of Revenue [nheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Bureau of Individual Taxes [nheritance Tax Division Dept. 280601 1 [arrisburg, PA 1 "7128-0601 7. "the name and address of every other person whom the plaintiff has knowlcd,~e who has any interest in the property which may be affected by the sale: Tenant(s) 38 Johns Drive Enola, PA 1702 [ verity 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~~A~~Nff,,D SUBSCRIBE /D~~ BE1?ORE ME THIS ~ DAY OF7V X012. ti NoI'aryiPublic ~; 5, ~' ~t~ry Public ~ ~r~l ~ ,agt , ~JIe9h?ny ~eunty !_ iy G;,m,rrr .. i .nr cs ugrch 15, X415 .fA77,;,y t,;r Mt~T~R1E5 ~_LLj ___ ~ ~; :; ~.; I ~uI __._y v ii C c LL ' --? a O ~O: ~U ~~ 0 ~ ~ N ~ ~ C ~~ ____.~ y 'J y v ~o ~'r I ~' S ___ _~ ___1 I d d d C O .. C r------~ ._____. '_ Il f 4/ Q V a =~? Q m E '° a ~ °' --~- N ~ ~ ~ --4 I - _._~t..___- = Y N ~ ~ D O Ip ~ ..y v .y. V ~ ~ ', I X b ~ Q N ~ ~ LL ~ ~ `'~ C~QO m ~ ~ . y V d' ~ ~ I Q ~ v o ° ~ O m ~ --~-- } a ~ -_t.~ U _ .___ __ - ~_- C _ m p ~ v ~ m i y m o J O~ U U Q n a> ~ m { N ~ I l o ~ ~ = ~ ' ~ N j ~ ~ 7 _ ~ ~ ~ ~ -, nl ~~~~ O ^^^^ ~: N cD ~ °~ _ o sl I O , O O ~ c0 ~ O v ° ~ ~' ~ Imo'' ' C N ~ O N O ? ' O p .N N > o M '~ ~ i v_ ~ (0 ~ O ~ ~ ~ ~ ~-- N` ~ (II +.a _~r C ~ ~ O ~" ' U _ ONd v.- lf7 r ~ r > ~-- U7 O ~ ~ Ofd l-(Ad OOCOa ..~., --`-~ •~~ m a~ 0 a~ x N ~ a U U O W ~ ;} O N 7 7 0 .~ O ~ O~ C f0 N O to X ~ Q.' O O 7 C Op 7 (n C Q, (l ~ D o ~ ~ U it1U ~ c~ 00(12 ~ co pat = : co ~Cn2 _ d (n N I-W W ~2 -C O N Cp= C MW 1 ~ -}-~_____. L ~ O c ~ ` O I ~ '. IV O C O j ~ U mN ~ n. a~ > ~ ~ Q. .~ ~ > ~ ro c U U ~ z Q C . ~.. ,~. ~ c~ i ~, Q ~ -O ' II 1 0 ~ td O O _ a I I o ~ Q. I q n m =9 L..,, ~ ~ C N C O C w 1 I _ i ~~~ L ll ~ (II d C O ~ ~ O i~ Q C~~ ~~ ~0 ~ Q O O C~ m` C U n ~ Q~ ~ I~ ~, a U 0 ~ ~ (~ ~ ~ F'- ' i L ~ •1•~+ ~~Oa_ , _ I~.; ~ m v I ri , co r~ ! ~ c a~ a ~_ O 0] O Y C i, .-, 4.7 ~0 3 j~ a ~ H °c' ~ S ~ U ~ m a 0 Eo '~ ~ c Iz ~a 6) U ~N ~ i O N ~{ ~ ` _' ' ` J a m y E , ~ _ 1'z > lm ~\ ~ V ~ ~'~ ~ ~ ! ~, u.. W m o ~ ~ t` ~ v°'i M ~t ~ >. Ya ~ ~ ti ~ ~ ~ N - _ Q. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, S/13/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, CIVIL DIVISION NO.: 10-5416-CIVIL V S. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A RO VNYANSKY, Defendant. TYPE OF PLEADING SUPPLEMENTAL AFFIDAVIT' PURSUANT TO RULE 3129.1 FILED ON BEHALF OF PLAPVTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Brian M. Kile, Esquire Pa. LD. #8924Q GRENEN & BIRSIC, P,C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412)281-7650 SALE DATE: 11 /7/ 12 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, S/:B/M/T CHASE MANHATTAN MORTGA~;~E CORPORATION, Plaintiff, CNIL DIVISION NO.: 10-5416-CIVIL vs. AL.EKSEY G. ROVNYANSKY, Administrator of the Estate of GERN[AN A. RUVNYANSKY, Defendant 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. L 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 Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky located at 38 Johns Drive, Enola, PA 1 i025, and is more fully described as follows ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVN~'ANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15- 1288-410. 1. The name and address of every judgment creditor whose judgment is a record lien. on the real property to be sold: Township of East Pennsboro, 98 South Enola Drive, Enola, PA 17025 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief: 1 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: ~ ~, '°--~ ~ ~ __ ____ _ Brian M. Kile, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Fluor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME ~- /~ r THIS -.-Z~' DAY OF C~~~ ~~-r~-'~ _4~~ ! , 2012. -,, - _, Notary Public COMMONWE,q~TH OF F'E9~tvS`=t,~ANi~, Notaria-- ~ S-~._..,._..,_~ Joanne M. Wehnev, Notary .,ubr;c City ofPit~roh Alleyhc;r~ s.ourity MY Commli~ res Jana ~ y, ~~~ 3 M~:mber, Panntylvanla Ag _ ~ U. S. POSTAL SERVICE CERTIF(CI~TE'O!&'MAILING-~ MAY BE USED FOR DOMESTIC AND INTERNI471DI~AitM4l~ DOES NOT PROVIDE FOR INSURANCE•POSTMASTER • ,' i:'' !" ''~ ' Received From: ~' ~. S ~:' Grenen & Birsic P.C. One Gateway Center, 9~ Floor Pittsburgh. F'A 15222 One piece of ordinary mail addressed to: Township of East Pennsboro 98 South Enola Drive Enola. PA 17025 75-9774 (NOS) JDJ .;~, Alfa ieo here in stamps "w meter postage ahd post rnarlf: Inquire of Postrhaster for t;urrerit lee. , PS Form 3817, January 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, SBL~VI/T CHASE MANHATTAN MORTGAGE CORPORATION, t'lai ntiff, vs. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, CIVIL DIVISION r,p ~_ :7 NO.: 2010-5416-CIVIL ' ~~ ~ r`Ti ~_ (17 ~ rV °' ,vJ rv TYPE OF PLEADING `~~ "`' c t., ~ ~ ,~ :z= ~~ _._ Pa. R.C.P. RULE 3129.2(c) ~''-`,~_ ~~ :::?° ~' AFFIDAVIT OF SERVICE; ~ -~~i ='~ DEFENDANT/OWNER - -:: ;Defendant. FILED ON BEHALF OF PLACI~I'TIFF: Chase Home Finance LLC, s/b/m!t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR. THIS PARTY: Kristine M. Anthou, Esquire Pa. L 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: ll/7/l2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE: HOME FINANCE LLC, SBLM/T CNIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. NO.: 10-5416-CIVIL ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, 'Defendant. Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS Erian M. Kile, Esquire, Attorney for Plaintiff, Chase Home Finance LLC, sibi'm/t Chase Manhattan Mortgage Corporation, being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter an Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky as follows: Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky is the rnvner of the real property and has not entered an appearance of record. ~. On September 11, 2012, this Court entered an Order authorizing Plaintiff to serve Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, by causing the Sheriff of Cumberland County to post the real property at38 Jolms Drive, Enola, PA 17025, by certified mail, return receipt requested, and by first class mail, postage prepaid, addressed to 41 Grandview Street, Apt. 806, Santa Cruz, CA 95060 and by publication. A true and correct copy of the Order is marked as Exhibit "A" attached hereto and made a part hereof. 3. Pursuant to the Order and Pa R.C.P. 3129.2 (C) on September 18, 2012, the undersi~,med counsel served Defendant, Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky, with a true and correct copy of Plaintiffs notice of the sale of real property by certified mail, return. receipt requested, and regular U.S. mail postage prepaid, addressed to 41 Grandview Street, Apt. 806, Santa Cruz, CA 95060. A true and correct copy of the L".S. Postal Service form 3800, Article Number 7012 1640 0001 4748 61 1 l , and the Certificate of Mailing, evidencing service by certified mail and first class mail on the Defendant, are marked Exhibit "B", attached hereto and made a part hereof. 4. On September 18, 2012 and September 28, 2012, Notice of Sheriff's Sale of Real Property was published in the The Sentinel and the Cumberland Law Journal, respectively. Copies of the Proofs of Service are marked Exhibit "C", attached hereto and made a part hereof. 5. On September 20, 2012, Sheriff s Office of Cumberland County posted the property located at 38 Johns Drive, Enola, PA 17025. 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. Brian M. Kile, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME ., ~_. THIS ~~ L~` SAY OF ~ ~~-~-~~ / 2012. __ Notary PuUlic t~~~~~ Joanne M Notanat Say - _ i CitY of Pt ' ~ahn~r, Nc~t7 y, xt iii, ^ P""~mbErC, ~nn~on Ex ~~~h,/~~ ~ cf:, ^•~ o ;s ,y~~s~:~~:; EXHIBIT "A" CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff v. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant NO. 2012-5416 IN RE: MOTION FOR SERVICE OF NOTICE OF SHERIFF SALE PURSUANT TO SPECIAL ORDER OF COURT ORDER OF COURT AND NOW, this 11th day of September 2012, upon consideration of Plaintiff's Motion for Service of Notice of Sheriff Sale Pursuant to Special Order of Court, it is ordered and directed that servilce of the Notice of Sheriff's Sale in this case upon the Defendant, Aleksey G. Rovnyansky, may be made in the following manner: (1) by First Class and Certified Maii, return receipt requested, no signature required at the last known address, 41 Grandview Street, Apartment 806, Santa Cruz, California 95060, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 38 Johns Drive, Enola, Pennsylvania 17025; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civi{ Procedure and Cumberland ~~ ~ ~~~ ~~. IN THE NINTH JUDICIAL DISTRICT COURT OF COMMON PLEAS County Rules of Procedure. directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendants at the aforesaid Grandview Street address, with service to be deemed complete upon mailing. BY THE COURT, _.__~ ~,,---, Thomas A. Placey, C.P.J. Distribution: Kristine M. Anthou, Esq. Grenen & Birsic, P.C. One Gateway Center, Ninth Floor Pittsburgh, PA 15222 Attorney for Plaintiff i7 _.,~ i 7~ C~*'~ ~w~ :~~ -~ ~~ c-~ ~=. c~ Aleksey G. Rovnyansky, Adminitrator of the Estate of German A. Rovnyansky 41 Grandview Street, Apartment: 806 Santa Cruz, California 95060 Defendant, pro se ~_~ _~ t~ N ~~ -~.; ,_,-- ~i v ~ i ~ _-~ ;.:; - _ -,-~ ' ~ T~ -_ -, _~,.. w s; ~n EXHIBIT "B" ., ra s ..~ ~ POSS3rJe $ 4. ~ Conrfied Fee ~~ Pesvnark ~ Retum Receipt Fee ~ > -- ~ Here ~ (Entlorsement Required) ~ ~ ,~~~~ L7 lestdded Delivery Fee (Endorsement Required} I~ ~j `' ' S B -a fc,tEil P~~stage & Fees _ ~_ q~iu kun r`- LcrP09oxNo. ~fl~.-~~i.~[.l~V~ll~!_J~----~~-~ll~-------- i cry, s~'fa.,~tP±9 - / ..,, ~~ /~Jl (iCr`~f „F'1 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAE MAft:, QOffS NOT PROVIDE FOR INSURANCE-POSTMASTER Recerved From: Grenen & Birsic P.C. _One Gateway Center 9~ Floor Pittsburgh, PA 15222 One piece of ordinary rail addressed to: ~t~K`x'•~<.1~,~ii-l(_.~t~v,SK~~ 1~,lY~IVII`>kYrtit.~~ ~'~~ t1'1r ~ ~ fLl FC "~-~~C's'!7~ 'til /~ . (~~1`~ }'1~V"1`,K-t~ __.~~L1~~ t ~~flt"Z. {'i~~ ~j~~~~ Affix fee here in stamps or meter postage and.. post marks, Inquire of Postmasterforcurrent (ea:° PS Form 3817, January 2001 EXHIBIT "C" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland ackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13t~, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of TH'E SENTINEL on the following day(s): S~~tember 18, 2012 COPY OF NOTICE OF PUBLICATION to lc~ ssuBi~Q~r,terEe~ s CUMBERLAND PBNN>;YLYAN44 CHASE HOME FINANGE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporatlon NO.: 10-5418 ChrN Plaintiff, vs ALEKSEY G.ROVNYANSKY, Adminiatretor of the Eatate of GERMAN A. ROVNYANSKY Defendant Nodce H Sherii~s Sets of Raat Estate on November 7, 20t2 at 10:00 A.M. in the Cumt»rlald Ciwnty Courthouse, One Courthouse Squats, Carlisle, PA 17013. ,. ALL THE RIGH'i, TITLE, INTEREST AND CLAtM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF:GERMAN A..' ROVNYANSKY OF, IN AND TO THE FOLLOWING DESCRIBED' PROPERTY.. ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATEQ IN THE TOWNSHIP OF EAST PENNSBORO, CUMBERlJ1NDiCClUNTYF PENNSYLVANIA, HAVING ERECTED T#EREON A DWELLING BEING KNOWN AND MUMBERHD AS 38'JOHNt3 DR1YE, ENOLA, PA t70Z8. INSTRUMENT NUMBER 200833294. PARCEL #0&:15-1288.4t0. Chase Home Finance, LLC, et ah vs. Aleksey G. Rovnyansky, Adminbtrator of the Estate of German A. Rovrryansky, at Execution No. 10.54E8-CNiI in the amountot $182,953.50: Schedule of DisVibution will be filed by the Sheriff on fFte data specified by the Sherfff no later then thirty (30) days from sale date. DisMbutbns will be made in accordance with the schedule unless exceptione are filed within ten (10) days of the filing of the Schedule. Kristine M. Anfhou, Esquire Grenen 8 Birsic, P.C. One Gateway Center, 9th Floor Pittsburgh, PA 15222 412-281-7850 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are. true. t1 i ~1 Sworn to and subscribed before me this ~fi~~ ~ ~.~~r~hzv~Z Notary Public. My commission expires: BAi1~1:`31 ,~~'ViJ IicCKEdDGR;J "~"Mary Put,lic CA.RfJSLF BOR~QL' ,ii, CUP,+~;~nL,,;`~U ~, T,r, ~..~Y I'~'~~mi, r~ ~ "' ..a ~ . CUMBERLAND LAW JOURNAL NOTICE filed within ten (10) days of the filing -- of the Schedule. In the Court of Common Pleas of KRISTINE M. ANTHOU, ESQUIRE Cumberland County, Pennsylvania GRENEN & BIRSIC, P.C. Civil Di~~sion One Gateway Center -- 9th Fl. NO.: 10-5416-Civil Pittsburgh, PA 15222 (412) 281-7650 CHASE HOME FINANCE LLC Sept. 28 s/b/m/t Chase Manhattan Mortgage Corporation Plaintiff vs. ALEKSEY G. ROVNYANSKY, Administrator o1'the Estate of GERMAN A. ROVNYANSKY, Defendant Notice of Sheriff's Sale of Real Estate on November 7, 2012 at 10:00 A. M. in the Cumberland County Courthouse, One Courthouse Squaze, Carlisle, PA 17013. ALL THE RIGHT, TITLE, INTER- EST AND CLAIM OF ALEKSEY G. ROVNYANSKY, AL)MINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY, OF, IN AND TO THE FOLLOWING DESCRIBED PROP- ERTY: ALL THE FOLLOWING DE- SCRIBED REAL ESTATE SITUATED IN THE TOWNSHIP OF EAST PENNS- BORO, CUMBERLAND COUNTY, PENNSYLVANIA, HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 .JOHNS DRIVE, ENOLA, PA 17025, INSTRUMENT NUMBER 200833294. PARCEL #09-15-1288-410. Chase Home Finance LLC, et al. vs. Aleksey G. Rovnyansky, Administrator of the Estate of Ger- man A. Rovnyansky, at Execution No. 10-5416-Civil in the amount of $162, 953.50. Schedule of Distribution will be filed by the Sheriff on the date speci- fied by the Sheriff no later than thirty (30) days from sale date. Distribu- tionswill be made in accordance with the schedule unless exceptions aze IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYI:VANIA - ,~ , ,~::-~ CHASE HOME FINANCE LLC, SB/1~~/T ~~.' tTt CIVIL DIVISION ~ f'") -~-+ ~ y' ~` r"1 -:~ ~ CHASE MANHATTAN MORTGAGE ;~- ~; ~ ~ a , ~.3 CORPORATION, .. --c _ :~ ~-- .~_ ~ --;~~ NO.: 10-5416-CIVIL ~ ~'~ ~:~'' :;;--~ Plaintiff, ~ ~. `~ __ ~- ° .; c~.~ ~~~ vs TYPE OF PLEADING ~ ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. SUPPLEMENTAL AFFIDAV I"I' PURSUANT TO RULE 3129.1 FILED ON BEI-IALF OF PLAINTIFF: Chase Home Finance LLC, s/b/mit Chase Manhattan. Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY Brian M. Kile, Esquire Pa. LD. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 11/7/12 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. ALEKSEY G. ROVNYANSKY, Administrator of the Estate of GERMAN A. ROVNYANSKY, Defendant. NO.: 10-5416-CIVIL SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Chase Home Finance L,LC, 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 infornation 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 Aleksey G. Rovnyansky, Administrator of the Estate of German A. Rovnyansky located at 38 Johns Drive, Enola, PA 17025, and is more fully described as follows ALL-THE RIGHT, TITLE, INTEREST AND CLAIM OF ALEKSEY G. ROVNYANSKY, ADMINISTRATOR OF THE ESTATE OF GERMAN A. ROVNYANSKY OF, IN AND TO THE FOLLOWING :DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN "I'HE TOWNSHIP OF EAST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 38 JOHNS DRIVE, ENOLA, PA 17025. INSTRUMENT NUMBER 200833294. PARCEL #09-15- 1288-~ 10. 1. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Township of East Pennsboro, 98 South Enola Drive, Enola, PA 17025 I verify that the statements made in the Supplemental Affidavit are true a.nd correct to the best of n-y 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.G.. BY: ! `~ } L -------------- - Brian M. Kile, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BF,FORE ME -__ ~ _ THIS ,.~ ~E` DAY OF L k <~f~%(, s~~ %' 2012. ,. /,~. . __ . ,,~_ ~- j..y -e `~' t'' _____-- _. Notary Public CO~VIMONWEALTH OF pEBM~i~~~~~~~,4lVt.. hlotarial Sell " - `'"-~- Joanne M. Wehngr, tUota CityofPfttpburph Alleyt;~:;~~:o~t~;Pv eny Comml~ ~ fires di~t,z 3 9 277 3 M~mibEr, Penn--- ~ -~.^~,--------._~.. U,S. POSTAL SERVICE CERT~FIC~T~El6'MAILING= MAY BE USED FOR DOMESTIC AND INTERNAT10l~t.MA~; t)OES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Grenen & Birsic, P.C. One Gateway Center, 9~ Floor, Pittsburgh, PA 15222 One piece of ordinary mail addressed to: Township of East Pennsboro 98 South Enola Drive Enola, PA 17025 75-9774 (NOS) JDJ Affa fee herein stamps or meter postage and postmart~ Inquire of Postma9t~ for current fee, PS Form 3817, January 2001