The URL can be used to link to this page

Home My WebLink About05-1212 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T, PHELAN, ESQ., Id. No, 32227 FRANCIS S, HALLINAN, ESQ., Id. No, 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, S/B/M TO CHASE MORTGAGE COMPANY, F/K/A CHEMICAL MORTGAGE COMPANY 3415 VISION DRNE COLUMBUS,OH 43219 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO.OS' -1;l./~ G O~ b:vz-VV Plaintiff CUMBERLAND COUNTY v. VONNIE J. ECKENRODE 812 RITNER HIGHWAY SHIPPENSBURG, PA 17257 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 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 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 INFORMA nON ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 113137 File#: 113137 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. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. I. Plaintiff is CHASE HOME FINANCE LLC, SfBfM TO CHASE MANHATTAN MORTGAGE CORPORATION, SfB/M TO CHASE MORTGAGE COMPANY, F/K/A CHEMICAL MORTGAGE COMPANY 3415 VISION DRIVE COLUMBUS,OH 43219 2. The name(s) and last known addressees) of the Defendant(s) are: VONNIE J. ECKENRODE 812 RITNER HIGHWAY SHIPPENSBURG, P A 17257 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/13/2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to 1ST CENTRAL MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book: 1647, Page: 503, By Assignment of Mortgage recorded 12/4/01 the mortgage was Assigned To PLAINTIFF which Assignment is recorded in Assignment Of Mortgage Book No, 682, Page 4103. 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 said mortgage due 11/01/2004 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith, File#: 113137 6, The following amounts are due on the mortgage: Principal Balance Interest 10/0112004 through 03/07/2005 (Per Diem $15,85) Attorney's Fees Cumulative Late Charges 10113/2000 to 03/07/2005 Cost of Suit and Title Search Subtotal $74,665.10 2,504.30 1,225,00 502.92 $ 550.00 $ 79,447.32 Escrow Credit Deficit Subtotal TOTAL 0.00 1,177.35 $ 1.1 77,35 $ 80,624,67 7. 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, 8, Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) haslhave failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or haslhave been denied assistance by the Pennsylvania Housing Finance Agency, 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000, WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 80,624,67, together with interest from 03/07/2005 at the rate of$15.85 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, PHELAN HALLINAN & SCHMIEG, LLP , . ~~I- /~_ By: ~lFrancis S, Hallinan LAWRENCE T, PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 113137 . I'LL that c:erta1n l.ot:. at ground with the buildings and 1lIlprovementB tbereem erected situated in tbe Tovnsb1p of Sbippensburg. County of CUmberland and State of Pennsylvania. bounded a~d described a6 follows. to~tt: BEGINNING at tbe turnplke road leading frOll Carlisle to Sblpp""sburg; tbence by lands nOW or fot1l2dy of Samuel Sm1tb. Soutb forty-aix and five tentbs (46.5) de.grees B a 8 t:, (inc:orrec:tly shown a8 Southweet Q:n prior deed.). tWAnty,..four and six tenths (24.6) percbes to a poat; thence by land. formerly of Rev. WID. G. Craig, now or formerly Kacbel B. Bollar, Soutb foorty-aeven (47),degrees:Wett. six and five teaths <~...s) per.che. to a post; thence by lands fOnlerly of Elias 'TbuaN. now or formerly of Ralph Kl11ian, Nortb forty-six and five tentbs (46.5) degrees West. twenty-five (25) perches to tbe turnpike road aforesald; thence along tbe same. North forty-eiaht and five tenths (48,,5) degrees East, six and. five t.entha (6.S) percl>es t.. tbe place of BEGINNING. CONTAINING one (I) acre, stdct .......ure. BEING tbe ....... \IT_iae. coaveyd by I!elvln D. Scherlch by hi. ded dstad April 29. 1985, and recorded in Cumberland COU1\ty Deed Book "G", VoL 31. Pa.e 252, unto Ranclall A. Gilbert and Sharon E. Gilbert, husband and wife, tbe Grautors lIerein. . PREMISES BEING: 812 RITNER HIGHWAY. VERIFICATION HEATHER R. BOGAN hereby states that he/she is ASSISTANT SECRETARY of CHASE HOME FINANCE LLC SUCCbSSOl<. BY IvlhRGER wlTH CHASE lviAI~dATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best ofhislher 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, Wf1t/l;A /2I6oqi/U HEATIIERR. BOGAN ASSISTANT SECRETARY DATE: ~, '.3-05 D -bq. ~ ~ ~ ~ II( - C> ~ ::::: - ...:2 -J \/) .::& ?- -.:) 0 S- o (; r-.' "-,,';1 2:;11 <j~ o -n ~-!l ~ t~nf- -a\!~ l^ \ ,"''1' v.J 00 (:,)IC> ~':':' -:r\ --'.,_,n ?1 ~~~~ ~~ ':.:'.\ t:"? "1';" ~":; N :..:.;. O~I - ,.,,',,- :;:.... ,;:<J SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-01212 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE HOME FINANCING LLC VS ECKENRODE VONNIE J R. Thomas Kline ,Sheriff or Deputy Sheriff, who eing duly sworn according to law, says, that he made a diligent sea hand inquiry for the within named DEFENDANT ECKENRODE VONNIE J b twas unable to locate Her in his bailiwick. He therefore returns t e COMPLAINT - MORT FORE , NOT FOUND, s to the within named DEFENDANT , ECKENRODE VONNIE J 812 RITNER HIGHWAY SHIPPENSBURG, PA 17257 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE WE WERE UNABLE TO SERVE DEFENDANT. SERVICE STOPPED PER FAX. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.06 5.00 10.00 .00 47.0 / R. Thomas Kline eriff of Cumberland County PHELAN HALLINAN SCHMIEG 04/06/2005 this and subscribed to before me !1a I~ { day of ~ A.D. Sworn ~~' Phelan Hallinan & Schmieg, L.L.P. By: Daniel G. Schmieg, Esquire No. 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff COURT OF COMMON PLEAS Chase Home Finance LLC, sib/m to Chase Manhattan Mortgage Corporation, sib/m to Chase Mortgage Company, fi'kla Chemical Mortgage Company CNIL DNISION vs. Cumberland COUNTY Vonnie J. Eckenrode NO. 05-1212 Civil Term MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, L.L.P., moves this Honorabl Court for an Order directing service of the Complaint upon the above-captioned Defendant, V 0 ie J. Eckenrode, by first class mail and certified mail to the last known address and mortgaged pr mises, 812 Ritner Highway, Shippensburg, P A 17257, and in support thereof avers the following: 1. Attempts to serve Defendant, Vonnie J. Eckenrode, with the Complaint ha unsuccessful. The Sheriff of Cumberland County attempted to serve the Defendant at the mo premises, 812 Ritner Highway, Shippensburg, PA 17257. As indicated by the Sheriffs Re of Service attached hereto as Exhibit "A", there was no answer after numerous attempts. 2. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to loc te the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries ma e and the results is attached hereto as Exhibit "B". 3. Plaintiff has reviewed its internal records and has not been contacted by the Defendant as of April 21, 2005 to bring loan current. 4. Plaintiff submits that it has made a good faith effort to locate the defend ts, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail and certified ail. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. /' BY:~ Daniel G. Schmieg, Esquire Attorney for Plaintiff Date: April 21 , 2005 Phelan Hallinan & Schmieg, L.L.P. By: Daniel G. Schmieg, Esquire No. 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff Chase Home Finance LLC, s/b/m to Chase Manhattan Mortgage Corporation, sib/m to Chase Mortgage Company, flkla Chemical Mortgage Company COURTOFCOMMONPLE S CNIL DNISION Cumberland COUNTY NO. 05-1212 Civil Term vs. Vonnie J. Eckenrode MEMORANDUM OF LAW Pa. RC.P. 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may m ve the Court for a special order directing the method of service. The motion s all be accompanied by an affidavit stating the nature and extent of the investi ation, which has been made to determine the whereabouts of the defendant d the reasons why service cannot be made. evidence of concealment. Gonzales YS. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last lena Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is i sufficient requires a good faith effort to discover the correct address." Adootion of Walker, 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries purs Freedom of InfotTlUltion Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) exa local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, attached hereto and as Exhibit "A", the'Sheriffhas been unable to serve the Complaint. A good faith effort to . cover the whereabouts of the Defendant has been made as evidenced by the attached Affid vit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Order pursuant to Pa.R.C.P. 430 directing service ofthe Complaint by first class mail and certified ail. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. BY:~ Daniel . Schmieg, Esquire Attorney for Plaintiff Date: April 21, 2005 --------- , \ \ SHERIFF'S RETURN - NOT FOUND C~SE NO: 2005-01212 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHASE HOME FINANCING LLC . VS ECKENRODE VONNIE J R. Thomas Kline ,Sheriff or Deputy Sheriff, who duly sworn according to law, says, that he made a diligent sea hand inquiry for the within named DEFENDANT ECKENRODE VONNIE J b twas unable to locate Her in his bailiwick. He therefore returns t e COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , ECKENRODE VONNIE J 812 RITNER HIGHWAY SHIPPENSBURG, PA 17257 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE WE WERE UNABLE TO SERVE DEFENDANT. SERVICE STOPPED PER FAX. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.06 5.00 10.00 .00 47.0 R. Thomas Kline eriff of Cumberland County PHELAN HALLINAN SCHMIEG 04/06/2005 Sworn and subscribed to before me this day of A.D. Prothonotary FORECLOSURE REVIEW SERVICES, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION FHLMC SKIP TRACE File Number: 113137 Attorney Firm: Phelan, Hallinan & Schmieg, LLP Subject: Vonnie Eckemode Current Address: 812 Ritner Highway, Shippensburg, PA 17257 Property Address: 812 Ritner Highway, Shippensburg, P A 17257 Mailing Address: 812 Ritner Highway, Shippensburg, PA 17257 I, Brendan Booth, being duly sworn according to law, do hereby depose and state follows, I have conducted an investigation into the whereabouts of the above-note individual(s) and have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Vonnie Eckemode -176-34-9315 B. EMPLOYMENT SEARCH Vonnie Eckenrode - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Vonnie Eckemode reside(s) at: 812 Ritn r Highway, Shippensburg, PA 17257. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office contacted directory assistance, which indicated that Vonnie Eckenr de reside(s) at: 812 Ritner Highway, Shippensburg, PA 17257. On 2/25/05 our office made a telephone call to the subject's phone number, (717) 532-5335, an received the following information: no answer. III. INQUIRY OF NEIGHBORS On 2/25/05 our office attempted to contact Irvin Keefer, at 808 Ritner Highwa , Shippensburg, P A 17257: spoke with an unidentified male who could not confirm or deny that the subject reside(s) at 812 Ritner Highway, Shippensbur , PA 17257. Using our White Pages data base our office was unable to locate any additiona neighbors within ten houses of 812 Ritner Highway, Shippensburg, PA 17257. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 2/28/05 we reviewed the National Address database and found the following information: Vonnie Eckenrode- 812 Ritner Highway, Shippensbu g, PA 17257. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. V. DRIVERS LICENSE INFORMATION A. MOTOR VEHICLE & DMV OFFICE Per the P A Department of Motor Vehicles, we were unable to obtain address information on Vonnie Eckenrode. VI. OTHER INQUIRIES A. DEATH RECORDS As of 2/28/05 Vital Records and all public databases have no death record 0 file for Vonnie Eckenrode. B. COUNTY VOTER REGISTRATION The county voter registration was unable to confirm a registration for Vonnie Eckenrode residing at: last registered address. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Vonnie Eckenrode - 2/1944 · All accessible public databases have been checked and cross-referenced f r the above named individual(s). · Please be advised all database information indicates the subject resides a the current address. I certify that the foregoing statements made by me are true. I am aware that' any of the foregoing states made by me are willfully false, I am subject to punishmen . I herby verify that the statements made herein are true and correct to the best f my knowledge, information and belief and that this affidavit of investigation is mad subject to the penalties of 18 Pa C.S. See. 4904 relating to unsworn falsification to authorities. ~". AFFIANT - Brendan Booth Foreclosure Review Services, Inc. L..:-iL__..___ , ~":~.~:~~-~l ,,';,un:y J ",".'" . ,.,.j ~ , ','~~c;\." Ilu I L , , L008 ~r- ? tJv' ,.,." Sworn to and subscribed before me this 28th day of February 2005. The above information is obtained from available public records and we are only liable for the cost of the affidavit. VERIFICATION Daniel G. Schmieg, Esquire, hereby states that he is the Attorney for the Plainti fin this action, that he is authorized to make this Affidavit, and that the statements made i the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COUR are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements made are subject to the penalti s of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. ~ By: Daniel G. Schmieg, Esquire Attorney for Plaintiff Date: April 21, 2005 () S'~ < ~fL'; c/) -< r.: '< 't'>- ".;~' <~~1 "';C) ;Pc ~: ~, -< , )--, '" = t..'":~ <J> > ~J :;;u N 0"< ",. ::;;;: '-!? o 4,0 o ""1 ..... :r:" f11-- r- -ry r"n -'30 QL ,tl\,! ~7?~ (jf'n 5~ :u -< Phelan Hallinan & Schmieg, L.L.P. By: Daniel G. Schmieg, Esquire No. 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff Chase Home Finance LLC, siblm to Chase Manhattan Mortgage Corporation, sib/m to Chase Mortgage Company, fi'kla Chemical Mortgage Company COURT OF COMMON PLEAS CIVIL DNISION Vs. Cumberland COUNTY Vonnie J. Eckenrode NO. 05-1212 Civil Term CERTIFICATION OF SERVICE I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the foregoing Motion for Service Pursuant to Special Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to the individual as indicated below by first class mail, postage prepaid, on the date listed below. Vonnie J. Eckenrode 812 Ritner Highway Shippensburg, P A 17257 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. ~ B' Danle .. chmieg, EsqUire Attorney for Plaintiff Date: April 21, 2005 o ,; :.,'" -rYre srr.f --;"'i ~): ~. ,- j:;- . ~~~ ""? -:::I =<: "" = = c.n ".. -u ::0 N CT> ",. :::K '-f? c:> \.0 o -0'1 -l :r: -r; fn~ -rJ11' -tJO (=<,s ---1 .~~. "\~ -~~ '~~L~:~ :~ ~- -.., :< , I '. PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T, PHELAN, ESQ., ID, NO. 32227 FRANCIS S. HALLINAN, ESQ., !D. NO. 62695 DANIEL G. SCHMIEG, ESQ., !D. NO. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (2 I 5) 563-7000 CHASE HOME FINANCE LLC, S/BIM TO CHASE MANHATTAN MORTGAGE CORPORATION, S/B/M TO CHASE MORTGAGE COMPANY, FIKIA CHEMICAL MORTGAGE COMPANY Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION CUMBERLAND COUNTY ; I IVONNIE J. ECKENRODE ! vs. No. 05-1212 CIVIL TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE rO THE PROTHONOTARY: i I I 1 1 iaptioned matter. 1 1 1 'I i i 1 I ! I i qate: April 21. 2005 /jL. Svc Dept. Fil~~ 113 137 I Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above PHELAN HALLINAN & SCHMIEG, LLP By: 1'.<-0---:5 iI~ FRANCIS S. HALLINAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff .1 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., !D. NO. 32227 FRANCIS S. HALLINAN, ESQ., !D. NO. 62695 DANIEL G. SCHMIEG, ESQ., !D. NO. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, SIBIM TO CHASE MANHATTAN MORTGAGE CORPORATION, SIB/M TO CHASE MORTGAGE COMPANY, F/K1A CHEMICAL MORTGAGE COMPANY Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION CUMBERLAND COUNTY "'~) , , vs. ; VONNIE J. ECKENRODE No. 05-1212 CNIL TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE o THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above raptioned matter. I I I PHELAN HALLINAN & SCHMIEG, LLP By: )~ 5. tf,lL- -, FRANCIS S. HALLINAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff qate: April 21, 2005 /jL. Svc Dept. Ft# 113137 I I I I \ ~ ~ -:::0 \"-) CJ' o ~ '5~, '"i:J\,:; (l~"-'; l ~:;./ .?-"', ~. (jJ 'c- --':'{B ~v ~~ ~:~.~ :r--c; '-7' ~..A .. -. o -n .--\ ::C-n rn-- -(J \1:" ~-"J c,.. 'J:., .1-. "':;,C) ~~~~ ::::-. 'v ~r1 .-,,~ ~ -P. c:> ..J - CHASE HOME FINANCE LLC, : s/b/m to CHASE MANHA TT AN : MORTGAGE CORPORATION, s/b/m to CHASE MORTGAGE COMPANY, f/k/a CHEMICAL MORTGAGE COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW VONNIE J. ECKENRODE, Defendant NO. 05-1212 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of May, 2005, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is ordered that said motion is granted. IT IS FURTHER ordered that Plaintiff may obtain service of the Complaint and all future pleadings on the above-captioned Defendant, Vonnie J. Eckenrode, by: 1. First-class mail to Vonnie J. Eckenrode at the last known address and the rnortgaged premises located at 812 Ritner Highway, Shippensburg, P A 17257; 2. Certified mail to Vonnie J. Eckenrode at the last known address and the mortgaged premises located at 812 Ritner Highway, Shippensburg, P A 17257; and 3. By publication once in the Cumberland Law Journal and a newspaper of general circulation in Cumberland County, and by posting the property. BY THE COURT, 11~\ln, !\.Ll'1tI' -'-<""!'\~ 1;[:",) L~.? " 1 s 'v l"~~' Z- I \!ll ('n07 r. j,' " ,;uUl.! f\t;\jL )><'~;:LOUd 3i-il :/0 3~:;~~~x}-n:nH - Daniel G. Schrnieg, Esq. Phelan, Hallinan & Schmieg, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff :rc PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, S/B/M TO CHASE MORTGAGE COMPANY, FIKJ A CHEMICAL MORTGAGE COMPANY Plaintiff vs. VONNIE J. ECKENRODE Defendants ATTORNEY FOR PLAINTITF COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND County No. 05-1212 CNIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: Mav 16.2005\ /eep, Svc Dept. File# 113137 PHELAN HALLINAN & SCHMIEG, LLP By: ,rl1rJ:_'UI/~/ d. tluJf/~rc-r'j F NCIS S. HALLINAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff _0_1 !",,'\ PHELAN HALLINAN & SCHMIEG LLP . By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (71 S) SIi'\-7000 CHASE HOME FINANCE LLC, SIB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, SIB/M TO CHASE MORTGAGE COMPANY, FIKIA CHEMICAL MORTGAGE COMPANY Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CNIL DNISION vs. : CUMBERLAND COUNTY VONNIE J. ECKENRODE : NO. 05-1212 CNIL TERM Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT BY MAn. PTTRSTT A NT TO COTTRT OROF,R I hereby certify that a true and correct copy ofthe Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following person, VONNIE J. ECKENRODE at 812 RITNER HIGHWAY, SHIPPENSBURG, P A 17257, on M A V 10, 200!'i, in accordance with the Order of Court dated MAY 2, 2005. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.s. 94904 relaling to unsworn falsification to authorities. Date: May lli 700S i~M J, ifr,11;'~ FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff 1....':':' --" SHERIFF'S RETURN - REGULAR CASE NO: 2005-01212 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCING LLC VS ECKENRODE VONNIE J SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon EfKENRODE VONNIE J the DEFENDANT , at 1705:00 HOURS, on the 20th day of May , 2005 at 812 RITNER HIGHWAY SHIPPENSBURG, PA 17257 by handing to POSTED PROPERTY AT 812 RITNER HIGHWAY, SHIPPENSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge So Answers: 18.00 14.80 6.00 10.00 .00 48.80 .r~4<'.f~..R R. Thomas Kline Sworn and Subscribed to before OS/23/2005 PHELAN HALLINAN SCHMIEG / Ii) rJ t ~./ '-\.7(,,<. '-'... ~./> ~eputy She rf By: me this J~~ day of !'h, JOO!'/ A.D. Ltk~~o~~t~~l;iJih: ~ 5PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 "no:. Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Chase Home Finance ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Vonnie J. Eckenrode Defendant No. 05-1212 CIVIL TERM PRAECIPE TO THE PROTHONOTARY: Please mark the above referenced case Discontinued and Ended without prejudice. X Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: 7/14/06 ~/1/~~ Francis S. Hallinan, Esquire Attorney for Plaintiff 113137 ..~ '""' '"._c, ",", _.l (.'