HomeMy WebLinkAbout12-4733F LED-OFFICc
0- PRDTNDNDTAf
2012 JUL 30 AM 9:37
C` MBEERLAND COUNTY
PENNSYLVANIA
PHELAN HALLINAN & SCHMIEG, LLP
Joseph P. Schalk, Esq., Id. No.91656
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, S/B/M TO CHASE HOME
FINANCE, LLC, S/B/M TO CHASE MANHATTAN
MORTGAGE CORPORATION
1 111 POLARIS PARKWAY
COLUMBUS, OH 43240
Plaintiff
ATTORNEY FOR
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
ivc
NO. l 2- LI 3-3
V.
WILLIAM E. BARRICK, JR
116 SALEM CHURCH ROAD
MECHANICSBURG, PA 17050-2834
CUMBERLAND COUNTY
Defendant
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 250384
? 1 l3o.sy?
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notic(
are served by entering a written appearance personally or by attorney and filing in writing witl
the Court your defenses or objections to the claims set forth against you. You are warned that
you fail to do so, the case may proceed without you, and a judgment may be entered against yc
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 LAWYEF
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File #: 250384
1. Plaintiff is
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,
S/B/M TO CHASE HOME FINANCE, LLC,
S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION
1111 POLARIS PARKWAY
COLUMBUS, OH 43240
2. The name and last known address of the Defendant are:
WILLIAM E. BARRICK, JR
116 SALEM CHURCH ROAD
MECHANICSBURG, PA 17050-2834
who is the mortgagor and real owner of the property hereinafter described.
3. On 03/12/2003 WILLIAM E. BARRICK, JR and ARLENE F. BARRICK made,
executed and delivered a mortgage upon the premises hereinafter described to CHASE
MANHATTAN MORTGAGE CORPORATION which mortgage is recorded in the
Office of the Recorder of Deeds of CUMBERLAND County, in Book 1801, Page 4069,
The mortgage and assignment(s), if any, are matters of public record and are incorporat(
herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the
Plaintiff from its obligations to attach documents to pleadings if those documents are of
public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon
mortgage due 06/01/2010 and each month thereafter are due and unpaid, and by the to
of said mortgage, upon failure of Mortgagor to make such payments after a date speci
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 250384
6.
The following amounts are due on the mortgage as of 04/30/2012:
Principal Balance $65,735.78
Interest $7,559.52
05/01/2010 through 04/30/2012
Late Charges $0.00
Property Inspections $126.00
Property Preservation $3,263.00
Escrow Deficit $9,694.29
TOTAL $86,378.59
7.
8
9.
10
Plaintiff is not seeking a judgment of personal liability (or an in nersonam judgment)
against the Defendant in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant has received a
discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage
Foreclosure is in no way an attempt to reestablish such personal liability discharged in
bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursua
to Pennsylvania Law.
Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default
required by the mortgage document, as applicable, have been sent to the Defendant on
date set forth thereon.
ARLENE F. BARRICK was a co-record owner of the mortgaged premises as a tenant
the entirety. By virtue of ARLENE F. BARRICK's death on or about 05/17/2008, her
ownership interest was automatically vested in the surviving tenant by the entirety.
Plaintiff hereby releases ARLENE F. BARRICK, from liability for the debt secured by
the mortgage.
File #: 250384
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant in the surd
of $86,378.59, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN & SCHMIEG, LLP
By: - P'14'J'11 -")
ose h chalk, squire
A rney for Plaintiff
File #: 250384
LEGAL DESCRIPTION
ALL THAT CERTAIN of of ground situate on the east side of the Salem Church Road in the Townstt"-p C*
Hampden. County of Cumberland and State of Pewsylvania, bounded and described as follows, to
BEGINNING at a point in the renter line of the public mad known aas Smarr Church Road, said point bsl located
lk-# eQ? and flve-tWNhs (53.5) feet measured northwardly along said center Ilne from the northerly line land of
the United Steftes Government and tiering also fourteen hundred siXtw and ninety4lve one-twr dttwa (4'16.95)
feet measured northwardly along said center ins from the norttwriy one of land now or of Rupp;
north two (2) de nsa$ "-four (54) minutes out aia said ranger tine of one hwxlred (I fed a
?
point; thence south =five (65 d twenty-four (24) rnrnltres out alpn line of lands now or of
Steward E. Myers, five hundred 500 Ibet to a point on the wastody line of a 5t}) foot rl?t-cef ce
south two hundred (2) -four (54) minutes west along sa=1abv t of way, one hundred {100 to a
point; thenoe north s? 05) degrees iw?enty-four (24) minutes the nortfierl?r lire of ana= fll`ty
MWIN XG70 "y, hundred (500) feet to a point in the center rive of the Salem Church Road, the F law of
The above described lands are sold and conveyed subject to the fdlowing reservations and restrictions ich
shall run with the iwnci and be binding upon the parties, their hems and assigns:
1. No dwelling shall be erected upon the hit hereby conveyed which shall coast less than $?4,000.00 ?er and
above the cost of excavation and foundation.
2. No second hand materials shall be used In the construction of any budding to be erected on said which
shall be exposed to the weather, and no asbestos slate surfacing or composition of any dwelling except fb, roof
covering.
3, No building of any kind shall be erected on the lot hereby conveyed within sixty feet from the canto r line of
the Salem Church Road, nor within sixty feet from the center line of the said flay hoot right-of-way, lying to I he east
of the property above deso bod.
4. No chWmn house or hog. pen or other bubding except the dwelling and private garage not to exceed
Wo-retr capacity, shag be erected within 150 few from the a mW Ilm of #6 aid public road and said fifty ficat
right-d vay lying to the set of the property harein conveyetf.
5. No merchandising or selling of manufacturing of any con Tiodity shall be coNucted upon said lot.
6. No building shall be erected within ten feet of any adjoining property fine.
Parcel #10-20-1838-012
PROPERTY ADDRESS: 116 SALEM CHURCH ROAD, MECHANICSBURG, PA 1
2834
PARCEL # 10-20-1838-012, CONTROL # 10005743
File #: 250384
Pennsylvania Verification
Brian Davenport , hereby states that he/she is Vice President of
JPMorgan Chase Bank, N.A. the Plaintiff
in this matter, and is authorized to make this Verification. The statements of fact
contained in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of my information, and belief. I understand that this statement
is ma subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
f l ' is i to authorities.
Vice Pr sident
Date: O W10/12
JPMoraan Chase Bank, N.A
Borrower: WILLIAM E BARRICK JR
Property Address: 116 SALEM CHURCH RD, MECHANICSBURG, PA 17050
County: CUMBERLAND
Last Four of Loan Number: 9048
T
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, SB/M TO CHASE HOME
FINANCE, LLC, S/B/M TO CHASE
MANHATTAN MORTGAGE CORPORATION
Plaintiff(s)
vs.
WILLIAM E. BARRICK, JR
FORM 1
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYbVAT.
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NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your len
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Serv
at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal
representative at no charge to you. Once you have been appointed a legal representative, you must promptly me
with that legal representative within twenty (20) days of the appointment date. During that meeting, you must pr
the legal representative with all requested financial information so that a loan resolution proposal can be preparf
your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, t
legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed
the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a concili
conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligib
for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment
legal representative. However, you must provide your lawyer with all requested financial information so that a lo,,
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the
format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court,
which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in
attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forwarc
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date
JosephV. Schalk, Esquire
Attorney for Plaintiff
CD C7
p C'7
--t s?
A
on
File #: 250384
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to
determine possible options while working with your counseling agency. Please provide the following
information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender:
Type of Loan:
State: Zip:
Yes El No El Listing date: Price: $
Realtor Phone:
Yes ? No ?
State: Zip:
Home:_ Office:
Cell: Other:
How long?
Home:
Cell:
Office:
Other:
State: Zip:
How long?
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $_ Included Taxes & Insurance:
Date of Last Payment:
File #: 250384
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles boats motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1 • Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1 • monthly amount:
2• monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage E
E
Food
2° Mort a e Utilities
Car Pa ment s Condo/Nei h. Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Money
Da /Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
File #: 250384
If yes, please provide the following information:
Counseling Agency:
Phone (Office): Fax:
Email:
Counselor:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve y
delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact:
Phone:
I/We, , authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are
no obligation to use the counseling services provided by the above named
Borrower Signature
Co-Borrower Signature
Date
Date
File #: 250384
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
6. Listing agreement (if property is currently on the market)
File #: 250384
PHELAN HALLINAN, LLP ' L'`- # " '* � �`� Yttbrney for Plaintiff j
Jonathan Lobb, Esq., Id. No.312174 2,0 13 APR _ I A 9: 4 7
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza CIT'IBULANG COUNT`'
Philadelphia, PA 19103 PENNSYLVANIA
215-563-7000
JPMORGAN CHASE BANK, : CUMBERLAND COUNTY
NATIONAL ASSOCIATION,SB/M TO
CHASE HOME FINANCE, LLC, SB/M COURT OF COMMON PLEAS
TO CHASE MANHATTAN
MORTGAGE CORPORATION CIVIL DIVISION
VS. No. 12-4733-CIVIL
WILLIAM E. BARRICK,JR
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against WILLIAM E. BARRICK,
JR, Defendant for failure to file an Answer to Plaintiff's Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as
follows:
As set forth in Complaint $86,378.59
TOTAL $86,378.59
I hereby certify that(1)the Defendant's last known address is 116 SALEM CHURCH
ROAD, MECHANICSBURG, PA 17050-2834, and(2)that notice has been given in accordance
with Rule Pa.R.C.P 237.1.
Date 3413 ,,42v/&
J than�Lob�b, Esq., Id. No.312174
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
r
DATE: CJ
PROTHONOTARY
aVA
^� 250�3�8 Q
y�1\�..�'! l
PHELAN HALLINAN, LLP Attorney for Plaintiff
Jonathan Lobb, Esq., Id. No.312174
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
JPMORGAN CHASE BANK, CUMBERLAND COUNTY
NATIONAL ASSOCIATION, S/B/M TO
CHASE HOME FINANCE,LLC, S/B/M COURT OF COMMON PLEAS
TO CHASE MANHATTAN
MORTGAGE CORPORATION CIVIL DIVISION
VS. No. 12-4733-CIVIL
WILLIAM E. BARRICK,JR
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts,to wit:
(a) that the defendant is not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of
Congress of 1940, as amended.
(b) that defendant WILLIAM E. BARRICK,A is over 18 years of age and
resides at 116 SALEM CHURCH ROAD, MECHANICSBURG, PA 17050-2834.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date 3A8_/_/3
J, athan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
250384
Department of Defense Manpower Data Center Results as of:Mar-28-2013 05:58:03
SCRA 3.0
Fuimft to Scrikemembe s Civil Relief Act
Last Name: BARRICK
First Name: WILLIAM
Middle Name: E
Active Duty Status As Of: Mar-28-2013
Qn Active Dt+ty CIrr4e thdy Status Data
, aty tit Day ;; ;Aroma �,aata°° statue
ty
NA NA
t ka NA
This response reite, ^�ts'active duty status based 0n the a(cM4e£51t1y<.Status Date
Iu1tl4ve' tttf+ Ni37 DaysAaMve Duty status 1
Ac#"Do $19tt 1 Via'` P 1twot '1=ta1^Bta6s Status
NA r A too NA
This response reflects individual left acti ve itCftYs ',iis` itk367 days preceding the Ar.ItvsJJuty Status Date
e �tb kt k da Y ret'a UR:utstaity Dull
tktf6e Imo# tYs 5f�us
NA ;� NA
r
7tds response reflects whether 1 and has received '"to-port for active duty
' '
Upon searching the data banks of the Department of Defense Manpower Dad ti 4aseI on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Mary M,Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
(Rule of Civil Procedure No. 236) -Revised
JPMORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY
ASSOCIATION, S/B/M TO CHASE HOME :
FINANCE,LLC, S/B/M TO CHASE COURT OF COMMON PLEAS
MANHATTAN MORTGAGE
CORPORATION CIVIL DIVISION
VS. No. 12-4733-CIVIL
WILLIAM E. BARRICK,JR
Notice is iven that a Judgment in the above captioned matter has been entered
against you on 7 N7.
By:
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id.No.312174
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT DEBT AND
ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PRE P70 USL Y RECEIVED A DISCHARGE IN BANKR Up TCy
, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT
ONL Y ENFOR CEMENT OF A LIEN A GA INS T PR OPER TY
250384
JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS
ASSOCIATION,S/B/M TO CHASE HOME CIVIL DIVISION
FINANCE,LLC,SIB/M TO CHASE MANHATTAN
MORTGAGE CORPORATION NO. 12-4733-CIVIL
Plaintiff
V. CUMBERLAND COUNTY
WILLIAM E.BARRICK,JR
Defendant(s)
TO: WILLIAM E.BARRICk,JR
116 SALEM CHURCH ROAD
MECHANICSBURG,PA 17050-2834
DATE OF NOTICE:
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
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 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 INFORMATIONABOUT AGENCIES'THAT'MAY-OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary. CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
I Courthouse Square CUMBERLAND COUNTY.COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
(717)249-3166
By: r2L 2&
j J �fi:n Lobb,Esq.,Id.No,312174
Olney'an
for Plaintiff
rn I y
elan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PHS#250384
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO COURT OF COMMON PLEAS
CHASE HOME FINANCE,LLC,SB/M TO CHASE MANHATTAN
MORTGAGE CORPORATION CIVIL DIVISION
Plaintiff
NO.: 12-4733-CIVIL
V.
WILLIAM E.BARRICK,JR CUMBERLAND COUNTY
Defendant(s)
To the Prothonotary:
Issue writ of execution in the above matter:
C= C=
Amount Due $86,378.59
r"Co r-nF
Interest from 04/02/2013 to Date of Sale $2,070.12 W
($13.27 per diem)
C
TOTAL $88,448.71 _=C C)
z �
-,C
Phelan Hallinan,LLP
Melissa J.Cantwell,Esq.,Id.No.308912
Attorney for Plaintiff
Note: Please attach description of property.
PHS#250384
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M TO CHASE HOME FINANCE,LLC,
S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION
Plaintiff
V.
WILLIAM E.BARRICK,JR
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
x '
Filed:
Address where papers may be served:
L--'n Hallinan,LLP WILLIAM E.BARRICK,JR
116 SALEM CHURCH ROAD
Melissa J.Cantwell,Esq.,Id.No.308912 MECHANICSBURG,PA 17050-2834
Attorney for Plaintiff
ti
LEGAL DESCRIPTION
ALL THAT CERTAIN plot of ground situate on the east side of the Salem Church Road in the
Township of Hampden,County of Cumberland and State of Pennsylvania,bounded and described
as follows,to wit:
BEGINNING at a point in the center line of the public road known as Salem Church Road, said
point being located fifty-three and five-tenths (53.5)feet measured northwardly along said center
line from the northerly line of land of the United States Government and being also fourteen
hundred sixteen and ninety-five one-hundredths(1416.95)feet measured northwardly along said
center line from the northerly line of land now or formerly of Jacob S. Rupp;thence north two(2)
degrees fifty-four(54)minutes east along said center line of one hundred(100)feet to a point;
thence south sixty-five(65)degrees twenty-four(24)minutes east along line of lands now or
formerly of Steward E.Myers, five hundred(500)feet to a point on the westerly line of a fifty(50)
foot right-of-way; thence south two hundred(2)degrees fifty-four(54) minutes west along said
right of way, one hundred(100) feet to a point;thence north sixty-five(65) degrees twenty-four(24)
minutes west along the northerly line of another fifty(50)foot right-of-way, five hundred(500)feet
to a point in the center line of the Salem Church Road,the place of BEGINNING.
The above described lands are sold and conveyed subject to the following reservations and
restrictions which shall run with the land and be binding upon the parties,their heirs and assigns:
1. No dwelling shall be erected upon the lot hereby conveyed which shall cost less than$4,000.00
over and above the cost of excavation and foundation.
2. No second hand materials shall be used in the construction of any building to be erected on said
lot which shall be exposed to the weather, and no asbestos slate surfacing or composition weather
sheeting of any kind shall be used in the construction of any dwelling except for roof covering.
3. No building of any kind shall be erected on the lot hereby conveyed within sixty feet from the
center line of the Salem Church Road, nor within sixty feet from the center line of the said fifty foot
right-of-way, lying to the east of the property above described.
4.No chicken house or hog pen or other building except the dwelling and private garage not to
exceed two-car capacity, shall be erected within 150 feet from the center line of the said public road
and said fifty foot right-of-way lying to the east of the property herein conveyed.
5. No merchandising or selling or manufacturing of any commodity shall be conducted upon said
lot.
6. No building shall be erected within ten feet of any adjoining property line.
TITLE TO SAID PREMISES IS VESTED IN William E. Barrick, Jr. her son and Arlene F.
Barrick, her daughter-in-law, as tenants by the entireties, by Deed from Marian E. Barrick,
unremarried widow, dated 12/31/1999, recorded 01/11/2000 in Book 214, Page 776.
By virtue of the death of ARLENE F. BARRICK on 0511712008, WILLIAM E.BARRICK,JR.
became the sole owner of the premises as surviving tenant by the entireties.
PREMISES BEING: 116 SALEM CHURCH ROAD,MECHANICSBURG,PA 17050-2834
PARCEL NO. 10-20-1838-012,CONTROL#10005743
1
PHELAN HALLINAN, LLP FILED-OFFICE Attorneys for Plaintiff
Melissa J. Cantwell, Esq., Id. No.308912 OF THE PROTHONOTARY
1617 JFK Boulevard, Suite 1400 -
One Penn Center Plaza 2013 APR 16 AM 10: 14
Philadelphia, PA 19103 CUMBERLAND COUNTY
215-563-7000 PENNSYLVANIA
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M COURT OF COMMON PLEAS
TO CHASE HOME FINANCE,LLC, S/B/M TO CHASE
MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION
Plaintiff
NO.: 12-4733-CIVIL
WILLIAM E.BARRICK,JR CUMBERLAND COUNTY
Defendant(s)
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91 because:
( ) the mortgage is an FHA Mortgage
the premises is non-owner occupied
( ) the premises is vacant
( ) Act 91 procedures have been fulfilled
(X) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197,41 Pa.B. 3943
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
Phelan Hallinan,LL
Melissa J.Cantwell,Esq.,Id.No.308912
Attorney for Plaintiff
' JPMORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS
ASSOCIATION,SB/M TO CHASE HOME FINANCE,
LLC, SB/M TO CHASE MANHATTAN MORTGAGE CIVIL DIVISION
CORPORATION
Plaintiff NO.: 12-4733-CIVIL
V.
CUMBERLAND COUNTY
WILLIAM E. BARRICK,JR
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO CHASE HOME FINANCE,LLC,SB/M TO
CHASE MANHATTAN MORTGAGE CORPORATION,Plaintiff in the above action,by the undersigned attorney,sets forth as of the
date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 116 SALEM
CHURCH ROAD,MECHANICSBURG,PA 17050-2834.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably ascertained,
please so indicate)
WILLIAM E.BARRICK,JR 116 SALEM CHURCH ROAD
MECHANICSBURG,PA 17050-2834
C
2. Name and address of Defendant(s)in the judgment: r Co
Name Address(if address cannot be reasonably =M �O ' -17
M ascertained,please so indicate) D O4=
WILLIAM E.BARRICK,JR 116 SALEM CHURCH ROAD Da O
MECHANICSBURG,PA 17050-2834 �Cp
Iy- p • o r
-C
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
WELLS FARGO BANK,N.A. 3476 STATEVIEW BOULEVARD
FORT MILL,SC 29715
WELLS FARGO BANK,N.A.C/O LINTON, 1720 MINERAL SPRINGS ROAD
DISTASIO&EDWARDS,P.C.ATTN: PO BOX 461
ANTHONY R.DISTASIO,ESQUIRE READING,PA 19602-2231
JAMES C.COSTOPOULOS 10 COURTHOUSE AVENUE
SUITE 103
CARLISLE,PA 1.7013
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
WACHOVIA BANK,NATIONAL 301 SOUTH COLLEGE STREET,VA 0343
ASSOCIATION CHARLOTTE,NC 28288-0343
PHS #250384
' WACHOVIA BANK,NATIONAL P.O.BOX 50010
ASSOCIATION ROANOKE,VA 24022
WACHOVIA BANK,NATIONAL P.O.BOX 50010
ASSOCIATION C/O RETAIL CREDIT ROANOKE,VA 24022
SERVICING ATTN:LISA KLEINGINNA
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 116 SALEM CHURCH ROAD
MECHANICSBURG,PA 17050-2834
COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ.
BUREAU OF INDIVIDUAL TAXES DEPT 280601
INHERITANCE TAX DIVISION HARRISBURG,PA 17128
DEPARTMENT OF PUBLIC WELFARE,TPL P.O.BOX 8486
CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING
PROGRAM HARRISBURG,PA 17105
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or 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.
Date: APR 15 2013 By
P e an Hallinan,LLP
Melissa J. Cantwell,Esq.,Id.No.308912
Attorney for Plaintiff
PHS #250384
s
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, COURT OF COMMON PLEAS
S/B/M TO CHASE HOME FINANCE,LLC,S/B/M TO CHASE
MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION
Plaintiff NO.: 12-4733-CIVIL
VS.
CUMBERLAND COUNTY
WILLIAM E. BARRICK,JR
Defendant (s)
-V:t
Cn. r-
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ;;a
rn oc
TO: WILLIAM E. BARRICK,JR <° m C:)-n
116 SALEM CHURCH ROAD z c o ca
MECHANICSBURG, PA 17050-2834 vZ
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house(real estate) at 116 SALEM CHURCH ROAD,MECHANICSBURG,PA 17050-2834 is
scheduled to be sold at the Sheriff's Sale on 09/04/2013 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$86,378.59 obtained by
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M TO CHASE HOME FINANCE,LLC,
S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION(the mortgagee)against you. In the
event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule
31.29:3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid.for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
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 LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
(800) 990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN plot of ground situate on the east side of the Salem Church Road in the
Township of Hampden, County of Cumberland and State of Pennsylvania,bounded and described
as follows,to wit:
BEGINNING at a point in the center line of the public road known as Salem Church Road, said
point being located fifty-three and five-tenths (53.5)feet measured northwardly along said center
line from the northerly line of land of the United States Government and being also fourteen
hundred sixteen and ninety-five one-hundredths(1416.95) feet measured northwardly along said
center line from the northerly line of land now or formerly of Jacob S. Rupp;thence north two(2)
degrees fifty-four(54)minutes east along said center line of one hundred(100) feet to a point;
thence south sixty-five(65) degrees twenty-four(24) minutes east along line of lands now or
formerly of Steward E. Myers, five hundred(500)feet to a point on the westerly line of a fifty(50)
foot right-of-way; thence south two hundred(2)degrees fifty-four(54) minutes west along said
right of way, one hundred(100)feet to a point; thence north sixty-five(65) degrees twenty-four(24)
minutes west along the northerly line of another fifty(50) foot right-of-way, five hundred(560)feet
to a point in the center line of the Salem Church Road,the place of BEGINNING.
The above described lands are sold and conveyed subject to the following reservations and
restrictions which shall run with the land and be binding upon the parties, their heirs and assigns:
1. No dwelling shall be erected upon the lot hereby conveyed which shall cost less than$4,000.00
over and above the cost of excavation and foundation.
2. No second hand materials shall be used in the construction of any building to be erected on said
lot which shall be exposed to the weather, and no asbestos slate surfacing or composition weather
sheeting of any kind shall be used in the construction of any dwelling except for roof covering.
3. No building of any kind shall be erected on the lot hereby conveyed within sixty feet from the
center line of the Salem Church Road, nor within sixty feet from the center line of the said fifty foot
right-of-way, lying to the east of the property above described.
4. No chicken house or hog pen or other building except the dwelling and private garage not to
exceed two-car capacity, shall be erected within 150 feet from the center line of the said public road
and said fifty foot right-of-way lying to the east of the property herein conveyed.
5. No merchandising or selling or manufacturing of any commodity shall be conducted upon said
lot.
6. No building shall be erected within ten feet of any adjoining property line.
TITLE TO SAID PREMISES IS VESTED IN William E. Barrick, Jr. her son and Arlene F.
Barrick, her daughter-in-law, as tenants by the entireties, by Deed from Marian E. Barrick,
unremarried widow, dated 12/31/1999, recorded 01/11/2000 in Book 214, Page 776.
By virtue of the death of ARLENE F. BARRICK on 0511712008, WILLIAM E.BARRICK,JR.
became the sole owner of the premises as surviving tenant by the entireties.
PREMISES BEING: 116 SALEM CHURCH ROAD,MECHANICSBURG,PA 17050-2834
PARCEL NO. 10-20-1838-012, CONTROL#10005743
SHORT DESCRIPTION
By virtue of a Writ of Execution No. 12-4733-CIVIL
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M TO CHASE HOME
FINANCE,LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION
V.
WILLIAM E. BARRICK,JR
owner(s) of property situate in the TOWNSHIP OF HAMPDEN, CUMBERLAND County,
Pennsylvania, being
116 SALEM CHURCH ROAD,MECHANICSBURG, PA 17050-2834
Parcel No. 10-20-1838-012
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $86,378.59
Attorneys for Plaintiff
Phelan Hallinan, LLP
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-4733 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION,SB/M TO CHASE HOME FINANCE,LLC,S/B/M TO CHASE MANHATTAN
MORTGAGE CORPORATION Plaintiff(s)
From WILLIAM E.BARRICK,JR.
(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 gamishee(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: $86,378.59 L.L.: .50
Interest FROM 4/2/2013 TO DATE OF SALE($13.27 PER DIEM)-$2,070.12
Atty's Comm: Due Prothy: $2.25
Atty Paid: $211.75 Other Costs:
Plaintiff Paid:
Date: 4/16/13
David D.�Buell,Prothonotary
(Seal), �By: "X,Q Q�hG t'• /l�E�',
Deputy
REQUESTING PARTY:
Name: MELISSA J. CANTWELL,ESQUIRE
Address: PHELAN HALLINAN,LLP
1617 JFK BOULEVARD,SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA,PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No.308912
Y
AFFIDAVIT OF SERVICE(FNMA)
PLAINTIFF CUMBERLAND COUNTY
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SKIM
TO CHASE HORSE FINANCE,LLC,SBIM TO CHASE PHS##250384
MANHATTAN MORTGAGE CORPORATION
DEFENDANT SERVICE TEAM/lxh
WILLIAM E.BARRICK,JR COURT NO.:12-4733-CIVIL
SERVE WILLIAM E.BARRICK,JR AT: TYPE OF ACTION � �
614 MONROE ST XX Notice of Sheriff's Sale.
JACKSONVILLE,TX 75766.4342 SALE DATE: September 4,2013
es SERVED �£-=T
erved and ma knawn to WILLIAM E.BARRICK JR,Defe dant on the day of .20 ''7
U ,o'clockV.M.,at CO I T MCAD�p , 14C#56F �j in the manner described below: � `.
Defendant personally served.
Adult family member with whom Defendants)reside(s).
Relationship is• _
Adult in charge of Defendant's residence who refused to give name or relationship.
_y Manager/Clerk of place of lodging in which Defendant(s)reside(s).
Agent or person in charge of Defendant's office or usual place of business.
_ an officer of said Defendant's company.
Other: y�
Description: Ages Height Weight Race 0 Sex,l!_Other
I, l� I(�tiA ,a competent adult:being duly sworn according to law,depose and state that I personally
handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned
case on the date and at the address indicated above.
Sworn to and subs ibed II1lA�ANN11�f
before me this�� day NOTARX PUK0 STATE OF TEX49
of y y5 __ ,2/013 "t a MV COMM.EXP 04-0613
Notary:
&A'ktha 0t,)14��_a NOT SERVED
On the day o f 20�,at o'clock_.M.,I, ,a competent adult hereby
state thatDefendantNU rT�U Ubecause:
Vacant —Does Not Exist Moved _Does Not Reside(Not Vacant)
No Answer on_ at at_Service Refused
Other.
Sworn to and subscribed
before me this day
of 2U_. By:
Notary: ATTORNEY FOR PLAINTIFF
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
(215)563-7000
r"ca c
PHELAN HALLINAN,LLP Attorney for Plaintiff can
Adam H.Davis,Esq.,Id.No.203034 p
1617 JFK Boulevard,Suite 1400 p
r D i
C O � -r,
3>C7 a =
One Penn Center Plaza =C) C:)
Philadelphia,PA 1'9103
Adam.Davis @PhelanHallinan.com —� o
215-563-7000
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
JPMORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY
ASSOCIATION,SB/M TO CHASE HOME
FINANCE,LLC,SB/M TO CHASE MANHATTAN COURT OF COMMON PLEAS
MORTGAGE CORPORATION
Plaintiff, CIVIL DIVISION
V. No.: 12-4733-CIVIL
WILLIAM E.BARRICK,JR
Defendant(s)
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa.R.C.P. 3129.2(c) on each of
the persons or parties named,at that address,set forth on the Affidavit and as amended if
applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A".
Adam H.Davis,Esq.,Id.No.203034
/ Attorney for Plaintiff
Date:
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PH#744218
tl'Niijrx:and Phelan I-Irdlinan,LLF
00
Address It 17 JFK Dovkvurd,Suitt 1400
Of Sender no One Penn Center Plaza
Pbjjgdo1 phj3.pt1 19103
A4PKJSCS-91910412013 SALE C3
Line Artide Number Name of Addressee.Strftit,ont!Post OMcc Address Pasta-M 0
'FENA NTAKICU PANT
$OAS
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ARpICR17RC PA 1712A tS NOrS
DEPARTMENTOF PUBLIC IVEUAM.TPL.CMSVALTY UNIT.MAM 9RCONFAY MOMAM
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00** 8VACROVIA BANK,NATION"ALASSOCIATION
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CHARLOT"M NC
6 *.*A %VAr.RO%IA RANV NATIONAL AR14)MATION*
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P.O.MX-1;0010 Su AS
ROA?iOXF—YA 24021
8 WELIS FART O SANK N.A. $OA
BT LFVARO
9 •A** WEUSFARGURANK Mk CIOLINKIN,DISTASIO&TVIVARD.S.P.r—ATF%:AVrrIO.XYR.DISTAStO.f3OUJRF
1714 MINERAL SPRINGS ROAD
M JIMIX 461
t1PAnVN4".PA 116,01-11M
Io DOMESTIC RELATIONS OF $0.0
CUMSERIANDCOMIV
l3rMR4nl J%ANDVXR
.('40IJ4MR,PA 17013
COMMONWFALT)l OF MVW,VANJA $0.45
DEPAIMIVNI'OrWWARE
A.O. PA 17.1;1
12 11111MRNIAL.03'rNUESFAVICE AIMSORY $OAS
IM LIBERTY AVVNUF ROOST;43
13 $0.0
US AFTORNFV FOR nVEMIDDLEDIMICT OF PA
FVOCRALRUJIDINC
221 WALNUT Zzo
PA
RE:WILLIAM E.SARRICK.JRICUN4BERI,,VND) PHS4,25038411021 page I of I writ $5.85
Tearn
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lbr ms.In.—Jr—ftj psiabk 41at)06 fw r IhKd os,&star"h 490 llmwvw,Sm Ow w U.11,0vol
Form 3877 Facsimile
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ';'t J-()�= j;'"
Sheriff
V+%,P at Lic1 ��td+
Jody S Smith
Chief Deputy 63 NOV 22 AM 8: 1,.J
Richard W Stewart �° m' "" a(jjQRL�t1u+ Gi� 1 ? Y
Solicitor OFFICE OF THE SHERIFF P E N N S Y LVH M A
JP Morgan Chase Bank, NA
vs. Case Number
William E Barrick, Jr 2012-4733
SHERIFF'S RETURN OF SERVICE
06/25/2013 05:11 PM -Deputy Noah Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 116 Salem Church Road, Hampden Township,
Mechanicsburg, PA 17050, Cumberland County.
07/16/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: William E. Barrick, Jr., but was unable to locate the
Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the
above titled action, as"Not Found" at 116 Salem Church Road, Mechanicsburg, PA 17055, property is
vacant, mail is still delivered there per post office.
09/04/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at
10:00 a.m. He sold the same for the sum of$1.00 to Attorney Joseph Schalk on behalf of Federal
National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $824.38 SO ANSWERS,
November 20, 2013 RON R ANDERSON, SHERIFF
�-
. 6?� /� per•
(c)CountySuite Sheriff,Teleosoft,Inc.
Y a
On April 23, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA,
Known and numbered as, 116 Salem Church Road,
Mechanicsburg, Exhibit "A" filed with this writ
and by this reference incorporated herein.
Date: April 23, 2013
By:
Real Estate Coordinator
1 :g ' Li
LXII 30 CUMBERLAND LAW JOURNAL 07/26/13
2012-4733 Civil Term
JP MORGAN CHASE BANK,NA
vs.
WILLIAM E. BARRICK,JR.
Atty.:Joseph Schalk
By virtue of a Writ of Execution
No. 12-4733-CIVIL, JPMORGAN
CHASE BANK, NATIONAL ASSO-
CIATION, s/b/m TO CHASE HOME
FINANCE, LLC s/b/m TO CHASE
MANHATTAN MORTGAGE CORPO-
RATION v. WILLIAM E. BARRICK,
JR owner(s) of property situate in
the TOWNSHIP OF HAMPDEN,CUM-
BERLAND County, Pennsylvania,
being 116 SALEM CHURCH ROAD,
MECHANICSBURG,PA 17050-2834.
Parcel No. 10-20-1838-012.
Improvements thereon:RESIDEN-
TIAL DWELLING.
Judgment Amount: $86,378.59.
25
r
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:
July 26, August 2 and August 9, 2013
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.
L sa Marie Coyne, Elflitor
SWORN TO AND SUBSCRIBED before me this
9 dav of Auszust, 2013
ZIA
,
J
Notary
F OTARIAL SEAL
ORAH A COLLINS
Notary Public
UGH,CUMBERLAND COUNTY
sion Expires Apr 28,2014
The Patriot-News Co.
1-900 Patriot Drive i4e r
"Mechanicsb'urg, PA 17050
Inquiries - 717-255-8213 NOW you know
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
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
Michael J. Morrow, being duly sworn according to law, deposes and says:
That he is the Controller 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 1900 Patriot Drive, 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 he 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 he 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:
2012.4733 Civil Term - 07/28/13
JP MORGAN CHASE BANK,NA 08/04/13
VS.
WILLIAM E BARRICK,JR 08/11/13
Atty Joseph Schalk
By virtue of a Writ of Execution No.
124733-CIVIL • . • • • • • • treme . . . . . . . . . . . . . .
JP MORGAN CHASE BANK,NATIONAL
ASSOCIATION, S/B/M TO CHASE
HOME FINANCE, LLC, S/B/M To Sworn o an subscrib bs day of A ugust, 2013 A.D.
CHASE MANHATTAN MORTGAGE
CORPORATION
V.
WILLIAM E.BARRICK,JR -
owner(s) of property situate in the O PU IIC
TOWNSHIP OF HAMPDEN,
CUMBERLAND County, Pennsylvania,
being
116 SALEM CHURCH ROAD, COMMONWEALTH OF PENNSYLVANIA
MECHANICSBURG,PA 17050-2834 Notarial Seal
Parcel Nosstreet address Hofl Lynn Warfel Notary Public
(Acreage or street address) Y Y � rY
Improvements thereon: RESIDENTIAL Washington Twp.,Dauphin County
DWELLING My Commission Expires Dec.12,2016
Judgment Amount:$86,37859 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Federal National Mortgage Association is the grantee the same having been
sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution
issued on the 16th day of April, A.D., 2013, out of the Court of Common Pleas of said County as of
Civil Term, 2012 Number 4733, at the suit of JP Morgan Chase Bank,N.A. against William E. Barrick
Jr. is duly recorded as Instrument Number 201337483.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this „,7z day of
, A.D. C2 el) 13_
<�J��� Recorder of Deeds
Recorder of Deeds,Cumberland County,Carfsle,PA
My Commission Expires the First Monday of Jan.2014