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Home My WebLink About01-1702FEDERMAN AND PHELAN, I_,LP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. I2248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 s) s6 -7o0o ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA. 17055 TERM CUMBERLAND COUNTY Defendant(s) CIVIl, ACTION ~ I,AW COMPI,AINT IN MORTGAGE FORECI,OSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND (:)UT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan#:1922026608 Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA. 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/12/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County. m Mortgage Book No. 1405, Page 208. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 232. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 10/1/00 through 3/1/01 (Per Diem $11.35) Attorney's Fees Cumulative Late Charges 9/12/97 to 3/l/0l Cost of Suit and Title Search Subtotal $57,121.52 1,725.20 2,856.00 116.56 55000 $62,369.28 Escrow Credit 133.36 Deficit 0 00 Subtotal ($ ! ~3.36) TOTAL $62,235.92 The attorney's fees set fi)rth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event ora third party purchaser at Sheriff's Sale. lfthe Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amotmt exceeds $50,000.00, WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $62,235.92, together with interest from 3/1/01 at the rate of$11.35 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PREMISES ON: 4162 KITTATINNY DRIVE VERIFICATION FRANK FEDE~MAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiffis outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiffas soon as it is received by counsel. The undersized understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01702 P COMMONWEALTH OF PENNSYLV~NIA COUNTY OF CUMBERLAND CHASE M32~7-L~TTAN MORTGAGE CORP VS SANDERSON JOHN M Thomas Kline ,Sheriff or Deputy Sheriff, who being search and he made a diligent DEFENDANT Ro duly sworn according to law, says, that inquiry for the within named defendant, SANDERSON JOHN M unable to locate Him COMPLAINT - MORT FORE in his bailiwick. He therefore returns but was the the within named DEFENDANT , NOT FOUND , as to , SANDERSON JOHN M PAPER EXPIRED BEFORE SERVICE WAS MADE Sheriff's Costs: Docketing 18.00 Service 9.92 Affidavit .O0 Surcharge 10.00 .00 37.92 So an~we~: . Sheriff of Cumberland County- FEDERMAN & PHELAN 04/24/2001 Sworn and subscribed to before me this ~ff;~ day of 200/ FEDERMANAND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 One Penn Center Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPOP~ATION : COURT OF COMMON PLEAS PLAINTIFF : vs. : CUMBERLAND COUNTY : : No. 01-1702-CIVIL JOHN M. SANDERSON : : DEFENDANT : PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. Date: May 16, 2001 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff VERIFICATION ~1~ L. [l[ffi~U[[I,88. hereby states thai he/she is ~g[~[~l~ of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: FEDERMANAND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff CHASE MANHATTAN CORPORATION Plaintiff vs. JOHN M. SANDERSON Defendants MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County N0.01-1702 PP~AECIPE TO REINSTATE CIVIL ACTION/MORTgAGE FORECLQSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in with reference to the above captioned matter. Mortgage Foreclosure Date: June 6, 2001 Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2001-01702 P COMMONWEALTH OF PENNSYLVA_NIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT SANDERSON JOHN M but was unable to locate Him deputized the sheriff of DAUPHIN , Sheriff or Deputy Sheriff who being says, that he made a diligent search and , to wit: in his bailiwick. County, serve the within COMPLAINT - MORT FORE He therefore Pennsylvania, to On June 20th , 2001 , attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 25.50 .00 62.50 06/20/2001 FEDERMAN & PHELAN Sworn and subscribed to before me this ~Q~ day of~ A.D. Prothonotary this office was in receipt of the So answer: R. Thomas Kline Sheriff of Cumberland County Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania : CHASE MANHATTEN MORTGAGE CORP vs County of Dauphin : SANDERSON JOHN M Sheriff's Return No. 1624-T - -2001 OTHER COUNTY NO. 01-1702 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for SANDERSON JOHN M the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Daughin, and therefore return same NOT FOUND, June 15, 200i DEFENDANT IS NO LONGER EMPLOYED BY BELL ATLANTIC PER SECURITY GUARD. Sworn and subscribed to before me this 15TH day of JUNE, 2001 PROTHONOTARY Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $25.50 PD 06/14/2001 RCPT NO 150992 In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mort§age Corp. VS. John M. Sanderson SERVE: John M. Sanderson No. 2001 1702 civil 1N-OW, June 12, 2001 hereby deputize the Sheriff of Dauphin , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA within upon at by handing to a and made known to Affidavit of Service ,20 ,at o'clock copy of the original So answers, M. served the the contents thereof. SWorn and subscribed before me this __ day of ,20__ Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 ~.215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 TERM ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Plaintiff JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG. PA. 17055 Defendant{s) CIVIl, ACTION - I,AW COMPI,AINT IN MORTGAGE FORgqCI,OSURE NOTICE CUMBERLAND COUNTY **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenW (20) days after this Complaint and Notice are served. by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case ma3' proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose moaey or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hereby certify the within to be a true and correct copy of the original filed of record ~'EDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE. PA 17013 (717) 249-3166 TRUE COPY FROM RECORD FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 56'I-7000 COURT OF COMMON PLEAS CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 TERM Plaintiff v. NO. CUMBERLAND COUNTY JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA. 17055 Defendant(s) CIVIl, ACTION - I,AW COMPI,AINT IN MORTGAGE FORECI,O,qURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO lie AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A kAWYER OR CANN(_)T AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAl. HELP We hereby certify the within to be atrue and correct copy of the original flied of record FEDERMAN AND PHELAH CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #; I92202660g Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 432~9 The name(s) and last known address(es) of the Defendant(s) are: JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA. 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/12/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERV/CES INC. x~hich mortgage is recorded m the Oftice of the Recorder of CUMBERLAND Cotmt3. in 5,)ol2gage Book No. 1405, Page 208. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572. Page 232. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forth~vith. The following amounts are due on the mortgage: Principal Balance interest 10/1/00 through 3/1/01 (Per Diem $11.35) Attorney's Fees Cumulative Late Charges 9/12/97 to 3/I/01 Cost of Suit and Title Search Subtotal $57,121.52 1,725.20 2,856.00 116.56 550 00 $62,369.28 Escrow Credit 133.36 Deficit 0 00 Subtotal ~ TOTAL $62,235.92 The attorney's fees set forth above are in conformit5' with the Mortgage documents and Penusylvania Lax~, and will be collected in tile event ora third part3,' purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to tile Sale, reasonable attorne.,,'s fees will be charged. This act/on does ilO! come ulldel' .-Nc[ 6 of 1974 because l]le origitlal morlg3gc 3i~lotm! exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $62,235.92, together with interest from 3/1/01 at the rate of$11.35 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /$/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PKEMISES ON: 4162 KITTATINNY DRIVE VERIFICATION FtL4.NK FEDERMAN. ESQUIRE hereby states that he is attorney for Plaintiffin this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge. information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiffas soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsx~orn falsification to authorities. FEDERMANAND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff CHASE MANHATTAN CORPORATION Plaintiff vs. JOHN M. SANDERSON Defendants MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County :No.01-1702 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAgE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in with reference to the above captioned matter. Mortgage Foreclosure Date: July 13, 2001 Attorney for Plaintiff SHERIFF' S RETURN - CASE NO: 2001-01702 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M REGULAR DAVID MCKINNEY , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE SANDERSON JOHN M DEFENDANT , at 0017:51 HOURS, at 4162 KITTATINNY DRIVE MECHANICSBURG, PA 17055 JOHN SANDERSON a true and attested copy of COMPLAINT REINSTATED WITH NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 13th day of August , 2001 by handing to - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 26.00 Affidavit .00 Surcharge 10.00 .00 54.00 Sworn and Subscribed to before me this /7 ~ day of 0 ~, ~,,;,.½ ,.,)c'~ f A.D. ~tothonotary So Answers: R. Thomas Kline 08/14/2001 FEDERMAN & PHELAN FEDERMAN AND PHELAN, LL P By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Court of Common Pleas CUMBERLAND County No. 01-1702-CIVIL VS. JOHN Mo SANDERSON Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. Date Frank Federman Attorney for Plaintiff