HomeMy WebLinkAbout04-3476IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CiVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
TO DEFENDANTS
You are hereby notified to plead
to the ENCLOSED COMPLAINT WITHIN
TWENTY (20) DAYS FROM SERVICE HEREOF
Y FOR P/~INTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 43219
AND THE DEFENDANTS IS:
152 Kline Road
Shippensburg, PA 17257 A~]
TYPE OF PLEADING:
CIViL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTI]?F:
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
9 West
Pittsburgh, PA 15222
(412) 281-7650
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF THE
REAL ESTATE AFFECTED BY THIS LIEN IS
152 Kline Road
Southampton, PA
(CITY, BORO(TOWNSH[~ (WARD)
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.:
VS.
GARY KELLEY aYk/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so the case may proceed without you and a judgment may be entered against you by the court without
further notice for any money claimed in the complaint or for any other claim or relief requested by
the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIViL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files
this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Manhattan Mortgage Corporation, which has its principal
place of business at 3415 Vision Drive, Columbus, Ohio 43219.
2. The Defendants, Gary Kelley, aJkJa Gary Kelley, Jr. and Sherry Kelley, are
individuals whose last known address is 152 Kline Road, Shippensburg, Pennsylvania 17257.
3. On or about August 2, 2001, Defendants executed a Note in favor of Plaintiff in
the original principal amount o f $93,840.00. A true and correct copy ofsaid Note is marked Exhibit
"A", attached hereto and made a part hereof.
4. On or about August 2, 2001, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $93,840.00 on the premises hereinafter described, said Mortgage being recorded in the Office of
the Recorder of Deeds of Cumberland County on August 7, 2001, at Mortgage Book Volume 1729,
Page 4857. A true and correct copy of said Mortgage containing a description of the premises
subject to said Mortgage is marked Exhibit "B", attached hereto and made a part hereof.
5. Defendants are the record and real owners of the aforesaid mortgaged premises.
6. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are
due for the March 1, 2004 payment.
7. On or about May 5, 2004, Defendants were mailed a combined Act 91 and Act 6
Notice, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983
and Act 6 of 1974, 41 P.S. §101, et seq.
8. The amount due and owing Plaintiff by Defendants is as follows:
Principal
Interest to 7/13/04
Corporate Advances
Unapplied funds
Attorney's fees
Title Search, Foreclosure and
Execution Costs
$89,785.63
$ 2,623.04
$ 16.00
$ 313.89 )
$ 1,250.00
$ 2,500.00
TOTAL $95,860.78
WHEREFORE, Plaintiff demands judgment m mortgage foreclosure for the amount due
of $95,860.78 with interest thereon at the rate of $15.95 per diem from July 13, 2004, 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.
BY:
GRENEN & BIRSIC, P.C.
Kristinb-M. Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WiLL BE
USED FOR THAT PURPOSE.
Exhibit "A"
1041548342
NOTE
AUGUST 02,2001 CARLISLE PENNSYLVANIA
(Scal)
wITHOUT RECOURSE
CHASE MANHATTAN
M TGA E R RATION
SANDRA L.
ViCE PRESIDENT
10~1548342
(Rev 1-98)
Rural Housing Loan
7 CFR Pan 1980
GARY KELLEY JR AND SHERRY KELt. EY
1400 E NEWFORT CENTER DR
DEERFIELD BEACH, FL 33442-7713
PENNSYLVANIA
LOAN ~'OTE '('; UARA/~'TEE CUMBERLAND
D~t¢:~O 8 -30 -2001
(Transfere~l
Exhibit "B"
ROBERT P. Z!EGLER
RECORDER OF DEEDS
-p
MORTGAGE
"1041548342'
BK 1729PG~B57
B~, 17297g~858
TRANSFER OF RIGHTS 1N TH~ PROPERTY
[Cltyl [Ztp C~I
BKI729PG48GO
B~I729PG~861
'- B~ITZ9PG~862
~1729~h863
B~I729P~b86~
B~I729?G~865
BI~I729?Gt;856
BI( 17 2 9 P~,h 8 6"/
BKI729PG~868
8~(.I 729PG~869
~KI729P~870
(Seal)
(Seal)
WITNESSES:
B~I729P~h871
Gary Kelley Jr., and Sherry Kelley, husband and ~ife
~KI729?~h87Z
I Certify this to be recorded
In Cumberland County PA
EXHIBrY A - LEGAL DESCR1P ..?,Ifl~k~ ~-~ ~
52 KL1NE ROAD fi(4~{ -- "~ --
Recorder of Deeds
Cumberland County, Pennsylvania, more fully botmdcd and described as
follows:
BEGINNING at a point on the North side nfl.e?islafive Rr~t~le X.ro 2l 0O(; ,~nd
Nearons lot, North 39 degrees 27 minutes East 200 feet to other lands now or
formerly nEC. Roy Funk; tlne!',ce by ofiTcr la~d> nc,,v er firm, fly cf C. k'~;,
and other lands now or formerly of tl~e said C. Roy Funk; thence by Lot No. 25,
degrees 33 minutes East 10634 feet 1o a poinL tke Place of BEGINNING.
BEING Lot No. 24 in a plan of Lots for C. Roy Funk, surveyed by D.P.
Ra ff,.'nsper?r Registered ~tlrvcyor, al;itt'c! },~.~ ~,' ?, 155 :~;d rill., ~cord~ ~ ii; t~c
Off]ce of'the Reco;dcr of Deeds in and lbr CumberLand County, in l:;an hook
14, Page 32.
BEING the same prcmiscs which Samuel S. Small 1II aod Nancy A. Small, his
wife, formerly Nancy A. Peck by Deed dated and recorder in the Office of the
Recorder of Deeds in and fi~r Cumberland County, Pennsylvania, in Record
Book 32-S Page 924 granted and conveyed unto Jeffrey P. Denis and Cynthia
L. Denis, his wife. 4 ~',
AND BEING the same premises which Jeffrey P. Denis and Cynthia L. Denis,
husband and wife, by their deed dated and recorded even date herewith in the
Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania,
granted and conveyed unto Gary Kelley, Jr., and Sherry Kelley, husband and
wife, Mortgagors herein.
VERIFICATION
Summer M. Winegardner, Assistant Secretary, and duly authorized representative of
Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom
falsification to authorities that the facts set forth in the foregoing Complaint are true and correct to
his information and belief.
Summer M. Winegardner, A~ssistant Secretary
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-03476 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE MANHATTAN MORTGAGE CORP
VS
KELLEY GARY ET AL
CPL. MICHAEL BARRICK
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT PORE
KELLEY GARY AKA GARY KELLEY JR
DEFENDANT at 1721:00 HOURS,
at 152 KLINE ROAD
pHIPPENSBURG, PA 17257
SHERRY KELLEY, WIFE
a true
Sheriff or Deputy Sheriff of
who being duly sworn according to
was served upon
and attested copy of COMPLAINT -
on the 20th day of July
the
by handing to
MORT FORE
together with
law,
, 2004
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18 00
14 06
00
10 00
00
42 06
Sworn and Subscribed to before
me this ~ ~ day of
~Ooq A.D.
! t;rothonotary t '
So Answers:
R. Thomas Kline
SHERIFF'S RETURN -
CASE NO: 2004-03476 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CU]~BERLAND
CHASE MANHATTAN MORTGAGE CORP
VS
KELLEY GARY ET AL
REGULAR
CPL. MICHAEL BARRICK
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
KELLEY SHERRY
DEFENDANT at 1721:00 HOURS,
at 152 KLINE ROAD
SHIPPENSBURG, PA 17257
SHERRY KELLEY
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
on the 20th day of July
by handing to
the
, 2004
- MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this ~ ~ day of
~l~O~,` A.D.
! ~rothonot ary"
So Answers:
R. Thomas Kline
07/21/2004
GRENEN & BIRSIC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CWIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
NO.: 04-3476
ISSUE NUMBER:
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
1 hereby certify that the
address of Plaintiffis:
3415 Vision Drive
Colmnbus, OH 43219
the last known address of
Defendants is:
152 Kline Road
Shippensburg, PA 17257
FILED ON BEHALF OF PLAINT~F:
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
9 West
Pittsburgh, PA 15222
(412) 281-7650
GRENEN & BIRSIC, P.C.
Attoq'neys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
CIVIL DIVISION
NO.: 04-3476
VS.
GARY KELLEY aAc/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Gary Kelley, a/k/a Gary Kelley, Jr. and Sherry Kelley, in the amount of
$97,281.00, which is itemized as follows:
Principal
Interest to 8/23/04
Late Charges to 8/23/04
Escrow Deficiency to 8/23/04
Corporate Advances
Unapplied Funds
Attorneys' fees
Title Search, Foreclosure and
Execution Costs
$89,785.63
$ 3,268.83
$ 23.73
$ 707.70
$ 59.00
($ 313.89)
$ 1,250.00
$ 2,500.00
TOTAL $97,281.00
with interest on the principal sum at the rate of $15.95 per diem from August 23, 2004, 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 M. Anthou, Esquire
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
)
) SS:
)
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants are not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notices &Intent to take Default Judgment
were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
Sworn to and subscribed before me
this2.~~ day of /'~]~-( ¢(-'L-I/
Not~ Publi~ ~'
2004.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
)
)
GARY KELLEY a/k/a GARY KELLEY, JR. )
and SHERRY KELLEY, )
)
Defendants. )
) CIVIL DIVISION
)
) NO.: 04-3476
)
TO:
Gary Kelley a/k/a Gary Kelley, Jr.
152 Kline Road
Shippensburg, PA 17257
DATE OF NOTICE: August 10~ 2004
/MPORTANT 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 JIYDGMENT 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
PROVDE 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
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
By:
GRENEN & BIRSIC, P.C.
Atto~rieys for P{aintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
GARY KELLEY ama GARY KELLEY, JR.
and SHERRY KELLEY,
Defendants.
TO:
Sherry Kelley
152 Kline Road
Shippensburg, PA 17257
CUMBERLAND COUNTY, PENNSYLVANIA
CIV1L DWISION
NO.: 04-3476
DATE OF NOTICE: August 10, 2004
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WlLI'ILI'EN
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.
1F 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
2 Liberty Avenue
Carlisle, PA 17013
Phone (800)990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
By:
GRENEN & BIRSIC, P.C.
Attor~ys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAEClPE FOR WRIT OF EXECUTION
Caption:
Chase Manhattan Mortgage Corporation
( ) Confessed Judgment
(7~) Other (Default Judgment)
Fi~e No. 04-3476
vs.
: Amount Due $97,281.00
Gary Kelley a/k/a Gary Kelley, Jr.
and Sherry Kelley
Interest $ 1,793.23 (from 8/23/04
to sale)
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
issue writ of execution in the above matter to the Sheriff of CUMBERLAND
for debt, interest and costs, upon the following described property of the defendant(s)
152 Kline Road, Shippensburg~ PA 17257
County~
( see attached legal description )
PRAECIPE FOR ATTACHMENT EXECUTION
--Issue-writ of sffachment to the Sheriff of County, for debt, interest and
3sts, as above, directing attachment against the above-named garnishee(s) for the following property (if real
~tate, supply six copies of the description; supply four copies of lengthy personalty list)
all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Signature:
Print Name:
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
Kristine M. Anthou, Es~.
One Gateway Center, 9th Fl.
Pittsburgh. PA 15222
Plaintiff
(412) 281-7650
77991
(over)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
Plaintiff, NO.: 04~3476
GARY KELLEY a/Ida GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot of ground situate in Southampton Township, Cumberland County, Pennsylvania,
more fully bounded and described as follows:
BEGINNING at a set point on the North side of Legislative Route No. 21006 and corner of Lot No. 23,
now or formerly of priscilla K. Neurone; thence along said Neurone lot, North 39 degrees 27 minutes
East 200.00 feet to lands now or formerly of C. Roy Funk; thence by lands now or formerly of C. Roy
Funk North 50 degrees 33 minutes West 128.77 feet to a corner of Lot No. 25 and other lands now or
formerly of C. Roy Funk; thence by Lot No. 25 South 33 degrees 03 minutes West 201.25 feet to a point
at the Northerly edge of Legislative Route 21006; thence along Legislative Route 21006 South 50
degrees 33 minutes East 106.34 feet to a point of the BEGINNING.
BEING Lot 24 in a Plan of Lots for C. Roy Funk, surveyed by D. P. Raffensperger, Registered Surveyor
dated May 7, 1963 and duly recorded in the Office of the Recorder of Deeds in and for Cumberland
County in Plan Book 14 at page 32.
Having thereon erected a dwelling house known and numbered as 152 Kline Road, Shippensburg,
Pennsylvania 17257 which was formerly R.D. #2, Box 222-A, Shippensburg, PA 17257.
BEING the same premises which Jeffrey P. Denis and Cynthia L. Denis, by Deed dated August 2, 200l and
recorded in the Office of the Recorder of Deeds of Cumberland County on August 7, 2001, at Deed Book
Volume 247, Page 4053, granted and conveyed unto Gary Kelley and Sherry Kelley.
GRENEN & BIRSIC, P.C.
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. 39-32-2285-005
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 04-3476 Civil
COI. YNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE
CORPORATION, Plaintiff (s)
From GARY KELLEY A/K/A GARY KELLEY, JR., AND SHERRY KELLEY
(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 $97,281.00 L.L. $.50
Interest FROM 8/23/04 TO SALE - $1,793.23
Atty's Corem % Due Prothy $1.00
Atty Paid $140.06 Other Costs
Plaintiff Paid
Date: AUGUST 31, 2004
(Seal)
REQUESTING PARTY:
Name KRISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, 9TM FL.
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-7650
Supreme Court 1D No. 77991
CURTIS R. LONG
Vrothono
D~u~
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DWISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 04-3476
Plaintiff,
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
AFFIDAVIT OF LAST KNOWN ADDRESS
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 Kxistine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that the owners of the property located at 152
Kline Road, Skippensburg, Pennsylvania 17257 are Defendants, Gary Kelley, a/k/a Gary Kelley,
Jr. and Sherry Kelley who reside at 152 Kline Road, Shippensburg, Pennsylvania 17257, to the
best of her information, knowledge and belief.
SWORN TO AND SUBSCRIBED BEFORE
ME THIS ~'~ DAY OF ~.~ ~{" d ~-
Notary Public
,2004.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CW1L DWISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 04-3476
Plaintiff,
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEO.
AND ACT 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for the said County mad
Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being
duly sworn according to law deposes and says that on May 5, 2004, Defendants were mailed a
combined Act 91 and Act 6 Notice, in compliance with the Homeowner's Emergency Mortgage
Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq.
SWORN TO AND SUBSCRIBED BEFORE
. Notary Public ' c;
,2004.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
NO.: 04-3476
Plaintiff,
VS.
GARY KELLEY a/Fda GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
AFFIDAVIT PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
Chase Manhattan Mortgage Corporation, Plaintiffin the above action, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following information was of record concerning
the real property of Gary Kelley and Sherry Kelley located at 152 Kline Road, Shippensburg,
Pennsylvania 17257 and is more fully described as follows:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF GARY KELLEY AND
SHERRY KELLEY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 152 KL1NE
ROAD, SHIPPENSBURG, PA 17257. DBV 247, PAGE 4053, AND PARCEL #39-32-2285-005.
1. The name and address of the owner(s) or reputed owner(s):
Gary Kelley, a/k/a Gary Kelley, Jr. 152 Kline Road
Shippensburg, PA 17257
Sherry Kelley 152 Kline Road
Shippensburg, PA 17257
2. The name and address of the defendants in the judgment:
Gary Kelley, a/k/a Gary Kelley, Jr.
Sherry Kelley
152 Kline Road
Shippensburg, PA 17257
152 Kline Road
Shippensburg, PA 17257
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 Manhattan Mortgage Corporation
[PLAINTIFF]
4. The name and address of the last record holder of every mortgage of record:
Chase Manhattan Mortgage Corporation
County of Cumberland
[PLAINTIFF]
c/o Redevelopment Authority
of the County of Cumberland
114 North Hanover Street
Carlisle, PA 17013
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
Bureau of Individual Taxes
Inheritance Tax Division
Dept. 28O6O1
Harrisburg, PA 17128-0601
Commonwealth of Pennsylvania
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:
NONE
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:
NONE
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
GRENEN & BIRSIC, P,C.
Kristine M. Alathou, Esquire
Attorney for Plaintiff
SWORN to and subscribed before
me this~ dayof f~,~(~(-~'~]'/ , 2004.
Notary Public
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff,
GARY KELLEY aJk/a GARY KELLEY,
JR. and SHERRY KELLEY,
TO:
CIVIL DIVISION
NO.: 04-3476
Defendants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
Gary Kelley a/k/a Gary Kelley, Jr.
152 Kline Road
Shippensburg, PA 17257
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 December 8, 2004, at 10:00 A.M., the following described real estate, of which Gary Kelley and
Sherry Kelley are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF GARY KELLEY AND SHERRY
KELLEY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 152 ICL[NE
ROAD, SHIPPENSBURG, PA 17257. DBV 247, PAGE 4053, AND PARCEL #39-32-2285-005.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
Gary Kelley, a/leda Gary Kelley, Jr. and Sherry Kelley,
Defendants.
at Execution Number 04-3476 in the amount of $99,074.23.
Claims against the property must be filed with the Sheriffbefore the above sale date.
Claims to proceeds must be made with the Office of the Sheriffbefore distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
This paper is a notice of the date and time of the sale of your property. It has been issued
because there is a judgment against you. It may cause your property to be held or taken to pay the
judgment. You may have legal rights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 OUT WHERE YOU CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
800-990-9108
You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection,
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you mayhave the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiff has a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sher/ffhas not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other
legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
Kristhae M. An]hou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
Plaintiff, NO.: 04-3476
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot of ground situate in Southampton Township, Cumberland County, Pennsylvania,
more fully bounded and described as follows:
BEGINNING at a set point on the North side of Legislative Route No. 21006 and comer of Lot No. 23,
now or formerly of Priscilla K. Nearone; thence along said Nearone lot, North 39 degrees 27 minutes
East 200.00 feet to lands now or formerly of C. Roy Funk; thence by lands now or formerly of C. Roy
Funk North 50 degrees 33 minutes West 128.77 feet to a comer of Lot No. 25 and other lands now or
formerly of C. Roy Funk; thence by Lot No. 25 South 33 degrees 03 minutes West 201.25 feet to a point
at the Northerly edge of Legislative Route 21006; thence along Legislative Route 21006 South 50
degrees 33 minutes East 106.34 feet to a point of the BEGINNING.
BEING Lot 24 in a Plan of Lots for C. Roy Funk, surveyed by D. P. Raffensperger, Registered Surveyor
dated May 7, 1963 and duly recorded in the Office of the Recorder of Deeds in and for Cumberland
County in Plan Book 14 at page 32.
Having thereon erected a dwelling house known and numbered as 152 Kline Road, Shippensburg,
Pennsylvania 17257 which was formerly R.D. #2, Box 222-A, Shippensburg, PA 17257.
BEING the same premises which Jeffrey P. Denis and Cynthia L. Denis, by Deed dated August 2,2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on August 7, 2001, at Deed Book
Volume 247, Page 4053, granted and conveyed unto Gary Kelley and Sherry Kelley.
GRENEN & BIRSIC, P.C.
By'.
K_ristine l~/Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. 39-32-2285-005
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
NO.: 04-3476
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
De~ndants.
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO:
Sherry Kelley
152 Kline Road
Shippensburg, PA 17257
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 December 8, 2004, at 10:00 A.M., the following described real estate, of which Gary Kelley and
Sherry Kelley are the owners or reputed owners:
ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF GARY KELLEY AND SHERRY
KELLEY OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY:
ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE
SOUTHAMPTON TOWNSI-GP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING
ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 152 KLINE
ROAD, SHIPPENSBURG, PA 17257. DBV 247, PAGE 4053, AND PARCEL #39-32-2285-005.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of
Chase Manhattan Mortgage Corporation,
Plaintiff,
VS.
Gary Kelley, a/k/a Gary Kelley, Jr. and Sherry Kelley,
Defendants.
at Execution Number 04-3476 in the amount of $99,074.23.
Claims against the property must be filed with the Sheriff`before the above sale date.
Claims to proceeds must be made with the Office of the Sheriff`before distribution.
Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriff`no later than ten (10) days fi.om the date when Schedule of Distribution is filed in the
Office of the Sheriff.
This paper is a notice of the date and time of the sale of your property. It has been issued
because there is a judgment against you. It may cause your property to be held or taken to pay the
judgment. You may have legal fights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 OUT WHERE YOU CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE~ PA 17013
800-990-9108
You may have legal fights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection,
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the plaintiffhas a valid claim to foreclose the mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriffhas not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution of service or demonstrate any other
legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR, 1F THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT, YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELWERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELWER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
GRENEN & BIRSIC, P.C.
Kristine M. Anthou, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
Plaintiff, NO.: 04-3476
VS.
GARY KELLEY a/k/a GARY KELLEY,
JR. and SHERRY KELLEY,
Defendants.
LONG FORM DESCRIPTION
ALL THAT CERTAIN lot of ground situate in Southampton Township, Cumberland County, Pennsylvania,
more fully bounded and described as follows:
BEGINNING at a set point on the North side of Legislative Route No. 21006 and comer of Lot No. 23,
now or formerly of Priscilla K. Nearone; thence along said Nearone lot, North 39 degrees 27 minutes
East 200.00 feet to lands now or formerly of C. Roy Funk; thence by lands now or formerly of C. Roy
Funk North 50 degrees 33 minutes West 128.77 feet to a comer of Lot No. 25 and other lands now or
formerly of C. Roy Funk; thence by Lot No. 25 South 33 degrees 03 minutes West 201.25 feet to a point
at the Northerly edge of Legislative Route 21006; thence along Legislative Route 21006 South 50
degrees 33 minutes East 106.34 feet to a point of the BEGINNING.
BEING Lot 24 in a Plan of Lots for C. Roy Funk, surveyed by D. P. Raffensperger, Registered Surveyor
dated May 7, 1963 and duly recorded in the Office of the Recorder of Deeds in and for Cumberland
County in Plan Book 14 at page 32.
Having thereon erected a dwelling house known and numbered as 152 Kline Road, Shippensburg,
Pennsylvania 17257 which was formerly R.D. #2, Box 222-A, Shippensburg, PA 17257.
BEING the same premises which Jeffrey P. Denis and Cynthia L. Denis, by Deed dated August 2, 2001 and
recorded in the Office of the Recorder of Deeds of Cumberland County on August 7, 2001, at Deed Book
Volume 247, Page 4053, granted and conveyed unto Gary Kelley and Sherry Kelley.
GRENEN & BIRSIC, P.C.
Kristine M: Anthou, Esquire
Attorneys for Plaintiff
One Gateway Center, Nine West
Pittsburgh, PA 15222
(412) 281-7650
Parcel No. 39-32-2285-005
IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff, NO.: 04-3476
VS.
GARY KELLEY a/k/a
GARY KELLEY, JR. and
SHERRY KELLEY,
Defendants.
TYPE OF PLEADING:
PRAECIPE TO SATISFY, SETTLE AND
DISCONTINUE WITHOUT PREJUDICE
FILED ON BEHALF OF PLAINTIFF:
Chase Manhattan Mortgage Corporation
COUNSEL OF RE,CORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa.I.D.#77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Nine West
Pittsburgh, PA 152:22
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CWIL DIVISION
CHASE MANHATTAN MORTGAGE
CORPORATION,
VS.
Plaintiff, NO.: 04-3476
GARY KELLEY a~k/a
GARY KELLEY, JR. and
SHERRY KELLEY,
Defendants.
PRAECIPE TO SATISFY, SETTLE AND DISCONTINUE
WITHOUT PREJUDICE
TO: PROTHONOTARy
Kindly satisfy, settle and discontinue without prejudice the above-captioned matter and mark
the docket accordingly.
GRENEN & B[RSIC, P.C.
Attom~-y for Plaintiff
Sworn to and subscribed before me
this ~:lay of (~0',~ ~d~) ,2004.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
[ mY~ ~Jan. 6,~
Member, Pennsylvania Association ~ N~ades
WRIT OF EXECUTION andJor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 04-3476 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE
CORPORATION, Plaintiff (s)
From GARY KELLEY AJK/A GARY KELLEY, JR., AND SHERRY KELLEY
(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 othe~vise disposing thereof;
(3) ~f pr~perty ~f the defendant(s) n~t ~evied up~n an subject t~ attachment is f~und in the p~ssessi~n
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 $97,281.00
Interest FROM 8/23/04 TO SALE - $1,793.23
Atty's Corem %
Atty Paid $140.06
PlainfiffPaid
Date: AUGUST 31, 2004
(Seal)
REQUESTING PARTY:
Name KILISTINE M. ANTHOU, ESQUIRE
Address: ONE GATEWAY CENTER, 9TM FL.
PITTSBURGH, PA 15222
Attorney for: PLA/NTIFF
Telephone: 412-281-7650
Supreme Court ID No. 77991
L.L. $.50
Due Prothy $I.00
Other Costs
CURTIS R. LONG
Prothono~
Deputy
Real Estate Sale #43
On September 03, 2004 the Sherifflevied upon the
defendant's interest in the real property situated in
Southampton Township, Cumberland County, PA
Known and numbered as 152 Kline Road,
Shippensburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 03, 2004
Real Esta[e Deputy
Chase Manhattan Mortgage Corporation
VS
Gary Kelley a/k/a Gary Kelley, Jr. and
Sherry Kelley
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2004-3476 Civil Term
R. Thomas Kline, Sheriff; who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Kristine Anthou.
SherifFs Costs:
Docketing 30.00
Poundage 1958.70
Advertising 15.00
Law Library .50
Prothonotary 1.00
Levy 15.00
Mileage 14.80
Surcharge 30.00
Share of Bills 30.42
$ 2095.42
Sworn and subscribed to before me
This it. ~ dayof
2004, A.D.
Prothonotary
R. Thomas Kline, Sheriff
Real F~asI6te Deputy