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Home My WebLink About02-0867FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff JOHN M. SANDERSON 4162 K1TTATINNY DRIVE MECHANICSBURG, PA 17055 Defendant(s) TERM ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.O -Ye7 CUMBERLAND COUNTY CIVTI, ACTION - I,AW **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 1922026608 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: JOHN M. SANDERSON 4162 KITTATINNY DRIVE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/12/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EASTERN MORTGAGE SERVICES, INC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1405, Page 208. By Assignment of Mortgage recorded 3/27/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 572, Page 232. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT= PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. The following amounts are due on the mortgage: Principal Balance Interest 9/1/01 through 2/1/02 (Per Diem $10.39) Attorney's Fees Cumulative Late Charges 9/12/97 to 2/1/02 Cost of Suit and Title Search Subtotal $52,323.16 1,600.96 1,250.00 116.47 550 On $55,840.59 Escrow Credit 0.00 Deficit o 00 Subtotal ~ 0_00 TOTAL $55,840.59 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $55,840.59, together with interest fxom 2/I/02 at the rate of $10.39 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL T~h~T CEI~TALN lot or tract o[ land with the improve.~ants erecte~ ~.hereon, situate ~n ~en To, ship, ~erland Co~ty, pen~sylv~a, as ~et forth on ~he F~n~l Su~ivis[on Plan for Mou~ltain View Village, P~se IV, al~o known as ~ndham Place, ~ated .]u~le 1, 1989 ~nd rscor~e4 May 7, 1990 ~n the OrE,ce oE the ~ec~rder of De~s in and for ~erland County, Pennsylvania in Plan Book 60, Pa~e 87, more particularly l-~unded and described as B~i~Ih~ at a point on ~he northern rl.~h=-~iwaY line of .K;~t~st:inny Drive (64' wide private), a~ tile divlu~g 1%~e o~ ~ ~;2 and ~63~ fjord ~int also be~ totaled 441,28 Eeet west o~ TJt~DC~ by th~ nor=her~ r~hu-of-way l~ne of Kittati~y Dr~ve Nor~l~ 82 degrees 02 minu~es 02 sec~ds West 20.00 ~ee~ to a ~int; Thence by line o~ Lo2 ~4 arid ~as~n~ through 2he center 100.00 ~'~t ~o a poi~lt~ 'l~ance ~ line o~ lan~ now or fo~ri~ oE J.~. ~ohh, Sout[l 82 de~re~s 0~ ~nuhes 02 secon~ ~ast 20.00 Eee2 to a poir.~ ~ence by L~.ne o~ Lot ~62 and pa~s~g through the We~t 100.00 ~ee= r.o ~ point o~1 the northe~ r~ght-of-w~y llne of ~t=ati~y D~[ve, the place of B~I~ING. ~AIN~ 2,000 s~are feet. BEI~ ~ ~63 on Fi~l S~ivis~on Pi~ o~ Mo~2a~n View Village Phase IV ~ecorded in Pl~ Book 60, Page 8~B. P~SES ON: 4162 KI~ATI~ D~ VERIFICATION RYAN L. REITMAJER hereby states that she is ASSISTANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. RYAN L REITM~ER, SR ,,,~SSISTN~ SECRET/~RY CT_ FEDERMAN AND PHELAN BY: FRANKFEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. JOHN M. SANDERSON Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No. 02-867 CIVIL pRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in with reference to the above captioned matter. Mortgage Foreclosure Date: February 28, 2002 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CZC, SVC DEPT FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 V'hiladelphia, PA 19103-1814 CHASE MANHATTAN CORPORATION Plaintiff JOHN M. SANDERSON MORTGAGE Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County :No.02-867-CIVIL PRAECiPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in with reference to the above captioned matter. Mortgage Foreclosure Date: ADril 3, 2002 ~K FEDERMAN, ESQUIRE Attorney for Plaintiff Dyh, SVC DEPT SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-00867 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT SANDERSON JOHN M unable to locate Him COMPLAINT - MORT FORE but was in his bailiwick. He therefore returns the , NOT FOUND , as to the within named DEFENDANT , SANDERSON JOHN M SERVICE WAS ATTEMPTED AT 4162 KITTATINNY DRIVE 23 TIMES BY OUR DEPUTIES. Sheriff's Costs: Docketing 18.00 Service 53.82 Not Found 5.00 Surcharge 10.00 .00 86.82 R~ Thomas Kline ~J Sheriff of Cumberland County FEDERMAN & PHELAN 04/11/2002 Sworn and subscribed to before me this 7¢ ~ day of ~j.'~ ~ A.D. Pro~hbnotary ~ ' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-00867 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SANDERSON JOHN M but was unable to locate Him deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On April llth , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 26.75 .00 51.75 04/11/2002 FEDERMAN & PHELAN Sheriff of Cumberland County Sworn and subscribed to before me this 7~ day ~ 2~ A.D. / t Prothonot~ryt Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of PennsyNania : CHASE MANHATTAN MORTAGE CORP vs County of Dauph~ : SANDERSON JOHN M Sheriff's Return No. 0641-T - -2002 OTHER COUNTY NO. 02-867 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for SANDERSON JOHN M the DEFENDANT named in the within COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, March 25, 2002 DEFENDANT HAS NOT LIVED IN DAUPHIN COUNTY FOR OVER A YEAR. MOVED TO CUMBERLAND COUNTY Sworn and subscribed to before me this 25TH day of MARCH, 2002 PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $26.75 PD 03/18/2002 RCPT NO 161575 In The Court of Common Pleas of Cumberland County, Pennsylvania Chase Manhattan Mortage Corporation VS. John M. Sanderson SERVE: same No. 02 867 civil NOW, March 1!, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriffof Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within Affidavit of Service , 20__, at o'clock M. served the upon at by handing to a and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20__ Sheriff of COSTS SERVICE MII,EAGE AFFIDAVIT County, PA FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. I.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (7.1 s) 56~.7000 CHASE MANHATTAN MORTGAGE CORPORATION VS. JOHN M. SANDERSON ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DMSION CUMBERLAND COUNTY NO. 02-867 THIS FIRM IS A DEBT COLLECTOR ATrEMi~NG TO COLLECT A DEBT. ANY INFORMATION oB'rAINED WILL BE USED FOR THAT PURiK3OE. IF YOU HAVE pREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATrEMI~ TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. MOTION FOR SERVICE PURSUANT TO ~PECIAI, ORnF~R OF COIIRT Plaintiff, by its counsel, Michele M. Bradford, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 4162 KITTATINY DRIVE, MECHANICSBURG, PA 17055 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with the Complaint have been unsuccessful, as indicated by the Sheriffs Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". BYH, Svc Dept. H:/Main Forms/motions/coun ~y.comp 3. Internal records reviewed by Plaintiff and has not been contacted by defendant as of ~t~fil2.?t,_21X~ to bring loan current. 4. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WItEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Michele M. Bradford, Esquire BYH, Svc Dept. H:/Main Forms/motions/county.comp FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. I.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 CHASE MANHATTAN MORTGAGE CORPORATION VS. JOHN M. SANDERSON ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-867 ~IF, MORANI~ITM OF I,AW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable role, the plaintiff my move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriffs return of'qqot Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealmem. G~Tal~ ye Pnlie: 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of Inteoded adoption mailed to last known addxess requires a good faith effort to discover the correct address." A,t,,?ic~ c,f W~lkor: 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postel authorities theloding inquiries pursuant to the Freedom of Information Act, 39 C.F.IL part 265, (2) inquiries of relatives neighbors, friends and en~loyers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriffs Return of Service, attached hereto and marked as Exhibit "A", the Sheriffhas been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WItEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail. Respectfully submitted: Michele M. Bradford, Esquire H:/Main Forms/motions/county.comp SHERIFF'S CASE NO: 2002-00867 P COMMONWEALTH OF PENNSYLVAiqIA COUNTY OF CUMBERLAND RETURN - NOT FOUND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named defendant, DEFENDANT SkNDERSON JOHN M ,Sheriff or Deputy Sheriff, who being search and but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named DEFENI]~kNT , SANDERSON JOHN M SERVICE WAS ATTEMPTED AT 4162 KITTATINNY DRIVE 23 TIMES BY OUR DEPUTIES. Sheriff's Costs: Docketing 18.00 Service 53.82 Not Found 5.00 Surcharge 10.00 .00 86.82 So answers~- /- ~ R{ Thomas Kline Sheriff of Cu~berland County FEDERN3LN & PHELAN 04/11/2002 Sworn and subscribed to before me this day of A.D. Prothonotary NIBITA SHERIFF'S RETURN - CASE NO: 2002-00867 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SANDERSON JOHN M OUT OF COUNTY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SANDERSON JOHN M but was unable to locate Him in his bailiwick. deputized the sheriff of DAUPHIN County, serve the within COMPLAINT - MORT FORE He therefore Pennsylvania, to On April llth , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 26.75 .00 51.75 04/11/2002 FEDERMAN & PHELAN So answers~- 3>~ .~ ~' R zT~masJKline ~ ~/ Sheriff of Cumberland County Sworn and subscribed to before me this day of A.D. 'Prothonotary Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : CHASE MANHATTAN MORTAGE CORP : SANDERSON JOH~M Sheriff's Return NO. 0641-T - -2002 OTHER COUNTY NO. 02-867 I, Jack Iaotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for SANDERSON JOHN M the DEFENDANT named in the within COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NO? FOWND, March 25, 2002 DEFENDANT HA~ NOT LIVED IN DAUPHIN COUNTY FOR OVER A YEAR. MOVED TO CUMBERLAND COUNTY · Sworn and subscribed to before me this 25TH day of MARCH, 2002 PROT~ONOTARY EXHIBIT A SO Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $26.75 PD 03/18/2002 RCPT NO 161575 EKL DATA, INC AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Subject: Property Address Federman & Phelan John M. Sanderson 4162 Kittatinny Drive Mechanicsburg, PA 17055 Last Known Address: 4162 Kittatinny Drive Mechanicsburg, PA 17055 Current Address: 646 S. 2nd Street Steelton, PA 17113 Last Known Number: 717 939-7090 George H. Lewis, III, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of researcher for EKL DATA, 1NC. 2. On February 15, 2002, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: Credit Information A. Social Security Number 1. John M. Sanderson: 184-48-9422 B. Employment Search: Could not locate any employment information for the above named subject at this time. Inquiry of Creditors: The creditors indicated that John M. Sanderson resides at 646 S. 2nd Street, Steelton, PA 17113. II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has John M. Sanderson listed with an address of 646 S. 2nd Street, Steelton, PA 17113. The phone number is 717 939-7090. Called number and verified that the above named subject does reside at 646 S. 2nd Street. III. Inquiry of Neighbors N/A IV. Inquiry of Post Office A. National Address Update: As of February 15, 2002 the National Change of Address has no fomvardlng record for John M. Sanderson listed at 646 S. 2nd Street, Steelton, PA 17113. Inquiry of DMV The Pennsylvania Department of Motor Vehicles has John M. Sanderson listed at 646 S. 2nd Street, Steelton, PA 17113. · - EKL DATA, INC AFFIDAVIT OF GOOD FAITH INVESTIGATION VI. Other Inquiries A. Death Records: As of February 15, 2002 the Social Security Death Index has no death record on ~e for John M. Sanderson under his social security number. B. Public Licenses None Found C. County Voter Registration: The county does not have John M. Sanderson listed as a registered voter with an address of 646 S. 2nd Street, Steelton, PA 17113. D.O.B.: John M. Sanderson: 06/14/1972 E. Miscellaneous Information None (~o~g~ H Lewis III Subscribed and sworn before me on February 15, 2002. EKL DATA, INC. O 66 Brookline Boulevard ® Havertown, PA 19083 Tel.: 1-888-829-5768 ® Fax: 610-446-2779 O email: eld-data®home.corn Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date: April Michele M. Bradford, Esquire H:/Main Forms/motion s/coun ~y.comp FEDERMAN AND PI-!ELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (~ ~) CHASE MANHATTAN CORPORATION MORTGAGE Plaintiff VS. JOHN M. SANDERSON Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County :No.02-867 PRAECIPE TO REINSTATE CIVIL ACTION/MORTC=A~E FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the with reference to the above Civil Action in captioned matter. Mortgage Foreclosure Date: April 24, 2002 byh,SVC DEPT FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. I.D. g69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 CHASE MANHATTAN MORTGAGE CORPORATION Vs. JOHN M. SANDERSON ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-867 ~!ERTIi~ICATION 01~ gERVIC. E I, Michele M. Bradford, Esquire, herby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. JOHN M. SANDERSON at: 4162 KITTATINY DRIVE MECHANICSBURG, PA 17055 646 SOUTH 2ND STREET STEELTON, PA 17113 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date:April_23,_2[~ Michele M. Bradford, Esq~re Attorney for Plaintiff BYH, Svc Dept. H:/Main Forms/motions/county.comp FEDERMAN AND PI/ELAN BY: Michele M. Bradford, Esq. Atty. I.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (~ ~) ATTORNEYFORPLAINT~F CHASE MANHATTAN MORTGAGE CORPORATION VS. JOHN M. SANDERSON COURT OF COMMON PLEAS : CIVIL DIVISION CUMBERLAND COUNTY NO. 02-867 ORDER AND NOW, this [_Ak" day of______~, 2002, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s) JOHN M. SANDERSON , by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 4162 KITTATINY DRIVE, MECHANICSBURG, PA1705$. (~Q ~ bO'~'~C~ ~'~ ~l~ ~ ~ervlce of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY~ J. BYH,Svc Dept. H:/Main Forms/motions/county.comp FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE , Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. JOHN M. SANDERSON Defendant(s) Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DMSION : CUMBERLAND COUNTY : NO. 02-867-CIVIL AFFIDAVIT OF SERVICE OF COMPLAINT RV MAll. PI~RRIIANT TO C~OI~RT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to JOHN M. SANDERSON at 4162 KITTATINNY DRIVE, MECHANICSBURG, PA 17055 on ~, in accordance with the Order of Court dated May 1, 2002. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date: May_8~?2~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN AND pHELAN By: FRANK FEDERMAN, ESQUIRE Attorney I.D. No. 12248 suite 1400 - ONE penn center AT sUBURBAN sTATION philadelphia, PA 19102 (215) 563-7000 cHASE MANHATTAN MORTGAGE coRpORATION vs. Attorney for Plaintiff : CoURT OF coMMON pLEAS : CIVIL DIVISION : cuMBERLAND coUNTY : No. 02_867-CIVIL JoHN M. sANDERSON I hereby certify that service of the civil Action Complaint in Mortgage Foreclosure was made in accordance with the attached Court order dated MAY 1, 2002 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b) in in ~ on MAY 15, 2002 ,_ axxd ~IMBERLAND LAW JOURNAL on ~' Proofs of the said publications are attached heretO. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to DATE: June 10, 2002 PROOF OF pUBLICATION State of Pennsylvania, county of cumberland. · . . of THE SENTINEl-, · , Classified Advertising Manager ..... es and says that THE sENTI.NE,L',.a_~ee~=ralP;~h°,! say o , sworn, ..... w.. of the CoumY u.~ --- _ .... u~h of Carhsle, ~uu.,= - said Count, and that the printed notice general circulation in the =u[~ ~ in the regular editions and 1881, since which date THE SENTINEL has been regularly issued in or publication affached hereto is exactly the same ~s was printed and published issues of THE SENTINEL on the following dates, wz Copy of Notice of Publication · . ..... de~,oses that he is not interested in Affiant furtne[ t~ the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. May 15, 2002 15th Sworn to and subscribed before_m~e~this ~ -- day of ~ ~ -' ;,uu~. Notary Public My commission expires: NOTARIACSEA~--'~ SHtRt. EY O DURNtN, Notary Pubtic PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthai, 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 MAY 24, 2002 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 SWORN TO AND SUBSCRIBED before me this 24 day of MAY, 2002 i NOTARIAL ~ CUMBERI2MND IAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action--Law No. 02-867-Civ/1 CHASE MANHATTAN MORTGAGE cORPORATION, PLAIN~IIFF VS. JOHN M. SANDERSON, DEFENDANT NOTICE TO JOHN M. SANDERSON: You are hereby notified that on FEBRUARY 20, 2002, Plaintiff, CHASE MANHATTAN MORTGAGE CORPORATION. filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUM- BERLAND County, Pennsylvania, docketed to No. 02-867-CIVIL. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 4162 KITTATIN- NY DRIVE, MECHANICSBURG, PA 17055, whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a dudgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the court. You are warned that if you fall to do so, the case may proceed without you and Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money, the property or 6ther rights important to you. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth be- low to find out where you czm get legal help. CUMERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE FEDE~ & PHELAN, L.L.P. Attorneys for plaintiff One Penn Center Suite 1400 philadelphia, PA 19103 {2151 563 7000 May 24 3 FEI~ERMAN AND PHELAN, LLP By: Frank Federman, Esquire I.D. No. 12248 Lawrence T. Phelan, Esquire I.D. No. 32227 Francis S. Hallinan, Esquire I.D. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Court of Common Pleas CUMBERLAND County No. 02-867 CIVIL VSo JOHN M. SANDERSON Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT~ WITHOUT PRETUDICE f AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this case discontinued and ended, upon payment of your costs only. Date Frank Federman, Esquire Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Attorneys for Plaintiff