HomeMy WebLinkAbout05-2669
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA
CHASE HOME FINANCE, LLC, slblmlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
VS.
ANDREW E. REDMOND and
JENNIFERL. VVILL,anda
JENNIFER L. REDMOND,
Defendants.
TO DEFENDANT
You afe hereby notified to plead
to the ENCLOSED COMPLAINT WITHIN
TWENTY (20) DAYS FROM SERVICE HEREOF
/r} 'U! J' )"1 /L ;, '
'. / t\;'" ,j ^-L ,U'-/~.C"~
A TTO EY FOR PLAINTlFF
I HEREBY CERTIFY THAT TIfE ADDRESS
OF THE PLAINTIFF IS:
3415 Vision Drive
Columbus, OH 432 I 9
AND TIfE DEFENDANTS IS:
124 South Second Street
Wormleysburg, PA 17043
,jC.7-'-M,-./..0{ a.Lti.Jrl_)
A TTtJRNEY FOR PLAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT TIfE LOCATION OF THE
REAL ESTATE AFFECTED BY THIS LIEN IS
124 South Second Street. Borough ofWormlevsburg
(CITY, BORO, TOWNSHIP) (WARD)
of (J,{ \lU fC}'rL UL ( 1.1'",-
ATTOIwEY FOR PLAINTIFF
CNIL DNISION
NO.: ci5'.. ;2~t; l'
Cau-!
TYPE OF PLEADING
CNIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance, LLC, slblmlt Chase
ManhattaIl Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. J.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.:
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, a!k/a
JENNIFER 1. REDMOND,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
**********************
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CNIL DNISION
Plaintiff,
r;;;) ~
NO.: 05"' ,:{ (Pt 1
vs.
ANDREW E. REDMOND and
JENNIFERL. VVILL,anda
JENNIFER L. REDMOND,
Defendants.
CNIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
Chase Home Finance, LLC, slb/mlt Chase Manhattan Mortgage Corporation, by its
attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Chase Home Finance, LLC, slb/mlt Chase Manhattan Mortgage
Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio
43219 and is authorized to do business in the Commonwealth of Pennsylvania.
2. The Defendants, Andrew E. Redmond and Jennifer L. Will, anda Jennifer L.
Redmond, are individuals whose last known address is 124 South Second Street, Wormleysburg,
Pennsylvania 17043.
3. On or about April 24, 1998, Defendants executed a Note in favor of 1st
Preference Mortgage Corporation ("I st Preference") in the original principal amount of
$93,507.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and
made a part hereof.
4. On or about April 24, 1998, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to 1" Preference a Mortgage in the original principal
amount of$93,507.00 on the premises hereinafter described, said Mortgage being recorded in the
Office of the Recorder of Deeds of Cumberland County on April 29, 1998 in Mortgage Book
Volume 1449, Page 383. A true and correct copy of said Mortgage containing a description of
the premises subject to said Mortgage is marked Exhibit "B", attached hereto and made a part
hereof.
5. 1" Preference assigned the aforesaid Mortgage and Note to Plaintiff pursuant to
the terms of a certain Assignment of Mortgage, recorded in the office of the Recorder of Deeds
of Cumberland County on Apri129, 1998 at Mortgage Book Volume 575, Page 113.
6. Defendants are the record and real owners ofthe aforesaid mortgaged premises.
7. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the February I, 2005 payment.
8. Plaintiff was not required to send Defendants written notice pursuant to 35 P.S.
91680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983) prior
to the commencement of this action for the reason that the aforesaid Mortgage is insured by the
Federal Housing Administration under Title II ofthe National Housing Act (12 U.S.C.
9~ 1707-1715z-18).
9. Plaintiff was not required to send Defendants written notice of Plaintiffs intention
to foreclose said Mortgage pursuant to 41 P.S. ~403 (Act 6 of 1974) prior to the commencement
of this action for the reasons that said Mortgage is not a "residential mortgage" as defined in 41
P.S. ~101 and Defendants are not "residential mortgage debtors" as defined in 41 P.S. ~101.
10. The amount due and owing Plaintiff by Defendants is as follows:
Principal
Interest to 5/12/05
Late Charges to 5/12/05
Escrow Deficiency to 5/12/05
Corporate Advances
Attorneys' Fees
Title Search, Foreclosure and
Execution Costs
TOTAL
$86,302.90
$ 2,340.36
$ 163.13
$ 6.97
$ 25.00
$ 1,250.00
$ 2.500.00
$92,588.36
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount
due of$92,588.36 with interest thereon at the rate of$17.73 per diem from May 12,2005, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premIses.
GRENEN & BIRSIC, P.C.
/~!.<2UJ"-{h( /0 '_I j..( ;
BY: !.'''-L._^' 'j I"--"
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
~,
.s
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NOTE
S "77~~
FHA CASE NO.
441-5675577
April 24( 199B
lDoe
124 SOUTH 2ND STREET, 1I0RMLEYSBURCl., Pennsylvania 17043
[Property AGCDelll
I. PARTIJlS
"Borrower" tnCtu:lll each person signing at the cnd of tfus Note, and the person's SUCCCSSOJ'S and asugns. "LeDder"
means
1st preference Mortgage Corporation
and its successors and ass1g11S.
z. BORROWER'S PROMISE TO PAY; INTEREST
In nwmfor a loan rtccivedfroro L.ender.Borrowef pronu5t$ top.y the principal sum of
Ninety Three Thousand Five Hundred seven and nO/100ths DoUan
(U.s. S 93, 507 .00 ), plus mtele$l., to the ordc:rofLead<<. lZllerc:st will be charged on unpaid
principal, frOOl tbe date of disbursement of the loan proceeds by Lender I al the rare of
seven and one half
percent ( 7.500 %) per )'carunti! the full amount o(pnncipalhas bcenpaid.
3. PROMISE TO PAY SECURI!D
BonoWOJ"s promise to pay is secured by a mortgage, deed of trust. or similusccuritYlllsttUmCQ( tl1at is dated the same
date as tlus Note and called the "Security Instrument." The Security Inaaument protects (he Lender from losses which JIUBht
result IfBonowcr defaults under this Note.
4. MANNEROFPAYMENT
(A) Time
BOlI'Owcr shall make a payment of principti and mterest 10 Lender on the rust day of each month beglllniag on
June 1, 1998 . An,principal.ndinleresUemainingOl1therusldayo( May, 2028
will be due on that date, which is called the "Maturity Da~:
(8) PI...
Paymcnlshallbcma<lcat 9309 Belair Road
Baltimore, MD 21236
or al such other place as Lender may desllJDatc In writing by noticcto Borrower.
(C) AmoUDl
Each montblypaymcDt ofpincipal and Intcre&twill bcin the amount of U.s. $ 653.81 .
This alDount will be part of . laraer monthly payment required by the Security Ill$UumcIH, thai shall be applied to pnncipal,
interest and other itema in the order descnbed in the Security rnstromenr.
MUL11STATE FHA FIXED KA. TE NOTE
....
OAE.\Ti.ANO.
TaOrll"ClJI1-lOO-63lH3I3Chd,l-nn-1131
1TEt.ltolaZ.1(11Deffl
(POI' J '" J pag.1}
"
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.
.
.
(D) AUong. to this Note lor hymenl Adjuslmeo"
If an allonge: providing for payment adjustments is c:xecuted by Borrower together with this Note. the COVenants of Ihc
allonge &hall be: incmporated mlo and shall amend aDd suppJemt.1lt the covenants of this Note as if the allonge were a part of
this Note. (Chctt apphcabJe box.)
D Growing Equity Allonge 0 Graduated Payment Allonge
o Other [specify]
5. BORROWER'S IUGBT TO PJlEFA Y
Borrower has the nghrlo pay thedebl evidenudby this Note, in wboleor in part, without charge orpenalty,onlhe firs.
day of any month. Lender shall accept prepayment on other days provided that Bonower pays interest on the amount prepaid
(or lite remamderof the month to the extent required by lender and pc::mutted by regulations of me Secretary. IfBOlTOWCI'"
makes a par1iaJ prepayment, there wlIl be 110 changes in the due date or in the amount of lhc monthly payment U1IIesa: Leader
agrcea in writing to thOl5C changes.
6. BORROWER'S FAILURE TO FAY
(A) Late Cbal'lt for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument I as described in ParagraJil4(C)
of this Note. by the end of fifteen calendu days after 1hc payment is due, Lender may collect a late charge m the amown of
four percent ( 4.00 %) of the overdue amount ofcachpayment.
(8) Delaoll
If Borrower defaults by faibng to pay in full any monthly payment. then Lender may, except as limited by ",guJatJoDS of
the Secretary in the case of payment defaults, reqUire immediate payment in full of the principal belirlcc remainingduc and all
accrued blterest. Lender may choose not to exercise this optiorJ: without waiving its rights in the event of any sub&cquent
default. In many circumstances regulations issued by the Seaelarywill hmit Lender's rights to require immc:dul1e pa)'lDCll.t m
full in the case of peymcnt defaults. Th.i$ N()le doea not authorize acceleration when not permitted by HOD regulatiOllL AI
ulltd in this Note, -Secrclary" means the Secretary of Housing and Urban Development or his or her dcslgnee.
(C) Payme>>totCostsaDdEs:peIlSflS
If Lender has required immediate payment in full. 8$ dcscribed'above, Lender may require Borrower to pey COISt5 .Dd
eXpenses includ:1ng reasonable and customary anorneys' feesfor enforcing this Note to the c:xtenl not prohibiICd by applicable
law. Such fees and costs shall bear interest from the date ofdisbttr9cmeot at !he same tale as the principal oftbis Note.
7. WAIVERS
Borrower and any orher person who has obligations under this Note waive the righa of pIUCntmcnt and notice of
disholWr. "Pre.senlmeJlt" means the nght to ~qulJ'C Lender to demand payment of amounts due. "Notice of dishonor" means
the nBhJ 10 require Lender to give notice to ClIher persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method. &lIy rwtice thai mUSl be given to Borrower under this Note wl be
given by delivering it or by mailing rt by (ust class mail 10 Bonower at the property address above or at a different addreas if
Borrower has given Lender a notree of Bonnwcr's different address.
Any notice: thai must be given to Lender UIldct this Note will be given by first class mail to Lender at the addrcsa slated
III Paragraph 4(B) or at a different address if BorroWer is given a notice of that differeut address.
9. OBLIGATIONS OF PERSONS UNDER TIDS NOTE
If more than one person Signs this Note, each person [s fully and p::r.5ODa1Jy obJi8ated to keep all of the promises made
III tbis Note.lncludillg the promise to pay the full ID10UllI owed. ADy person who is a guarantor, surety or endorser of this
Note is also obligated to do these things. Any pt.n>On who takes over theat obligations, tncludtng the obUgauOll.s of a
guarantor, surety or endorser of thisNotc. is also obligated to keep all of the promiscs made III this Note. Lender may enforu
its rights under Ihi..Note against each penon individually or against .U signatoriestogc:ther. Anyone person lignina this NQ(c
may be required to pay all of the amounts owed under this Note.
ITEM M3aL2 \IIDIAI
...............
Ta~CIII 1.IOD-UMSt50""II.?IH131
IPogI12D/3paB'"
I,.
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. BY SIGNING BElOW, lJonower accepts and agrees to the terms and covenantscontaiDed in pages 1 through 3 of this
Nme. . ()J uJ . (Se~)
-Bonower
ANDREW E. REDMOND
~~~ ~mun~ -(Seti)
JE IFER . DMOND .!lGm>wu
(Se~)
.........,
(Se~)
._,
(S.~)
.BotroIII~r
(Se~)
.........
{Sign Original Onlyj
'l.T
J 1\
,
Pay to the Order or "
Without Recourse
eh~'~ III hllttlln Mortgage Corp
~~a~1 .ljIEVEt-ISON/ASH S CR5TARV
, PAY TO THE ORDER OF.
CHAoSI!' "'''''HArrA''' ^"C>Rn~'" col'lil"o~TION
WITHOUT RECOURSE
:JJIr,.~C~O:J"'E CORPORATION
WM.S~~RfS'DENT
lTE'" eGa.3lM01RJ
(PDltJtfl/NJ1es)
.R""'.....
TO_Ie.! 1~...3lI30~&lel..71\.1131
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NAME AFFIDAVIT
Date. April 24, 1998
This is to certify that ANDREW E. REDMOND
and 1\NIJREW EUGENE REDMOND. ANDREW REDMOND
person, ANDREW E. REDMOND
is one and the same
being the
correct name for the purpose of this transaction.
ANDREWtI!iio1t ~rtgagor
State of Pennsylvania
County of DAUPHIN
Subscribed and sworn to before me in my jurisdiction on this
24th day of April 1998.
My commission Expires:
Nota~7C7h;"
NalanlN Seal
Nancy J ~n. Nola!)' ~
wa"'ngllln T." , """""'" _nlY,
I My I;om/mlJSICln E~re' May 21.200
Membe1,Pe.nnsytvlnlaA$SOCllIlKlnOfNotI!1llS
e.
.
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NAME AFFIDAVIT
Date. April 24, 1998
This is to certify that JENNIFER L. REDMOND
and JENNIFER L. WILL. JENNIFER REDMOND
person, JENNIFER L. REDMOND
correct name for the purpose of this transaction.
is one and the same
being the
Rui.
State of pennsylvania
County of DAUPHIN
Subscribed and sworn to before me in my jurisdiction on this
24th day of April 1998.
My Commission Expires.
Not:::&9/r
Notanal seal
N_ J uoon. Nolary p-
WashIngton Twp , Dauphln CountY
My Comll'dllOn Expires Mey 21, 2001
Member, Pennsytvanll Assocratron of NOUries
/JtJ~IJ'~ .Jt
,-\0009
1:\~<10 ~<1
: ~:::f,j p :i:'~L!:R
I~ 31.)
t~ /50 7 !!:t/@
I;J H5'i Dtf 1"
: "0; uft' OF DU.OS
Mc,'ll:.t1D COliNn ~i".
'98 APtl29 AI'I10 07
Parcel Nun1ber: 47201858141
ISplU'e Abort Tbb Un' For Rfto,dlll' O,t_1
COUI1IUllIw('ullb ur J'rJ1l1syJvonla
MORTGAGE
I FHA C'K No.
441-5675577
THIS MORTGAGB (-Security lnslrumcnl-) is BIven on April 24, 1998
. The MOrlgalOt is
Mdrew E. Redrcnd and Jennifer Li Redrcnd
Husband and Wife
~
which is ar&Dnized and c~j5lilll under the: laws or 'lbe state Of Marylarrl , and w~ ~ ~
address is 9309 Belair Road, Baltinore, 101) 21236 '\.~
(-Lender"). borrower owe" Lender the principal $Urn or~
Ninety Three'lbJusand Five /IUIldred Seven and no/100the DolJ.,,(U.S.$93,507.00 ). ~
This debt is evidenced by Borrower's note daled the SDnte: date IS this Seturit)' Inslrun\enl (-Nolel. which provides ror
monthly payments, will1 the full debt. if not paid earlier. due.nd payable on May 01 2028 .
This Sceurlt)' Ins'rutllent secures (0 Lender: (8) rbe ~pa)'mcnJ or the debt evidenCed by I' Note. with Inlerest. and all renewals.
ulensions and l1lodilicnlions: (b) rhe payment of aU olher sums. with interest, advanced under paragraph 6 10 protect the
security of Ihis Security InstrUmenl: and (e) the pcrfonllance of Borrower's CtIvenants and agreemenls under this Security
Inslrul11cnt and the: Hole. Por Ibis purpose, Borrower docs hereby mortgage, Branl and convey to Lender the rollowin.
described proper1y )(,cnled in DaUIi'dn County. Pennsylvania:
("Borrower"). This StcurilY Instrutnent is given 10 1st Preference lobrtgaqe CorpJratioo
See SChedule A attached hereto and II'ade a part hereof.
which hDllhe address of 124 South 2nd street, W:mnleysburg
Pe:nnsylvllnilt 17043 IlJpCodtJ ("Property Address.);
FIlA J'enJU)h.n" Alurl'lIt. 519$
_ -2004RIPAj _Oil
_'''''~'C1f1''''~lOOln17U\
hilt''''. 1lIlt..... ".I I'I-lnI..._""c...."-
Bood449tAGt 383
ISllCd.Cltyl.
IIII~~ IIIII ~II~IIIIIIIIIIII
C ~()1(OBt2C8
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TOOETH ER WITH all the improve-menu now or hereaner erected on Ihe property. and afl cuscmcnCs. rights.
appurlcnanccs, rellls, royallit's, mineral. 011 and ps nghls and profits, water rights and slock and all fil{(ures now or ',creafter II
part of lhe properlY. All replaccn\Clts and additions shall pl50 be tOycrclJ by Ibis Security Inslrument. All or the foregoing is
referred 10 inlhis Sccurily Instrument as 'be "Prop~rty:'
BORROWER COVENANTS Ihol Borrower is law(ully seised of the estale hereby conveyed and has the rigblto mortPlc,
granl and tDnvcy the Property amll1lal the Property is unencumbered. eAcept for cncumbnmccs of record. Borrower worr'lnls
and will ddcnd generally the lille to Un: Propcny agaillsl all claim' and demands, subject to any encumbrances of record.
I. Payanrnt or Principal, Inlerest and laic Charge. Borrower shall PlY when due the principal of, and intertst on, the
debt evidenced by the NOIC' and lale challes due under the Nole: '
2. Monfhly !)aymcnl of Tu.cs, InSllnmcl: and OlllCf Charges. Borrower shall Include in each monlhly payment.
logether wilh lhc principal and inlcreSi\ as sd farth inlhe NOle and any lale cballes. a sum (or (a) faxes and .special assessmenU
levied or to be levied againSiI Ihe ProperlY, (b) Icasehold paYlnenls or ground ~nU on Ihe Property. and (e) prclniulPs for
illsunulCe required under pnrngrnph 4. In any year in whicb Che Lender /Rust pay a mortgage insurance premium 00 lhe:
Sec~tary of HOUlinS IInd Urban Development ("Secretary.), or in any year in which such premiull1 would have been required if
Lender slill held tbe: SecurilY Instrument, elK'h mOIl,ldy pa)'ment .mall also Include either: (i) a sum for Ibe annual mart gale
insurance prcllliulIIlo be paid by Lender 10 the Sec~lat)l. or (ii) a lIIonlhly Charge lnslcad of D mortgagc insurance premium if
Ihis Securily Instrument is heW by I~e ~crellly. in II reasonable amount la be determined by Ihe Stcrellry. EJ.ce:pt for chc
Illondlly dlargc by 'lu: Sec~lary. tJlCSC hems arc called -Escrow Ilclns- and Ihe sums paid 10 Lender are caUed -Escrow Funds..
Lender 11m)'. at an)' time. collect and hold alllounts for Estrow llel1\S in an aurelace a!nount not to exceed Ibe maximum
8mount thllt lUll)' be required for Borrower', escrow IIccuunt undcr Ihe Real Cslale Seltlement Procedures AC1 of 1914. 12
U.S.C. Scclhln 2601 et _fNI' lint! lnlplel1lellling regulations. 24 CFR Pun 3'00. as 11~ m8)' be alllCndtd from time to time
(-RESPA"), cxccpllhat 1111: cushion' or reserve pcnniued by RESPA (or ulWllicipblcd dUbuf1Cl1Ienls or disbursements beron:
the 8orrower', PIlYlllcllls lire DYUillIbit in the aCOOlml may nol be bJlKd on amounts due for Ihe 1110rlPCe Insurance premium.
If the amollnts held by Lender for Escrow Items eActed tbe IImounts pcnl1iUed to be: heid by RESPA. lender shall dent
with Ihe CAC'C1S funds 01 required by RESPA. If the alllounts of funds held by Lender al an)' lime IIrc not surtkienC Co pay dle
Escrow Jlcms when due. Lender 1111I)' nolif)' thc Borrower and rtquirc Borrowcr 10 make up the shortage or deficiency Jl$
pcnuiUcd b)' RESPA.
TIlt Escrow Funds are pledged as addlliollal securit)' for all sums secured by Ihb Securil)' hlSlrumenl. If Borrower lenden
10 Lender the full phYlUellt of all such sums. Barrower"s account sllIdJ be crediled with the balance !'tmaining for all instlllhncnl
Items (II), (b), .nd (c) and .ny mortgage insul1lrK.'C pl"ellliuh1 installment Ihal t.cnder has not btconlt obllBalc:tIlO pay 10 the
Secretlu)'. and Lender sf",lIlproUlplly refund lIlI)' CJlteS! funds 10 BorroWer, Immedialely prior to a fol'Cclosul'C sale of the:
Properly 01' its Ik.-quh:irion by Lender. Borrower's accoul\l shall be credited with any balance remaining fot al1 inSlaUllltnfS (or
items (aJ. (b), and (c). .
3. Apllllcatiun ur PaYlIltllls. All paymcnls under pllragraphs I .,,"2 shaU be applied by Lender as follows:
~~~t. to the mortgage insurllllL'C prchliullI Co be paid by Lender 10 the Secretary or lu the OIonlhl)' charge by tilt Secrelal)'
instead of Ihe mOlllhly nlOrtgllge insurance premium;
Secolld. to aoy Cues. special asSClWlltlllS, le4lSeholll paYl11enlli or ground renls, and fire. flood and other hlll.lrd insurance
prel11iums:-as required:
Third, 10 inlerest due under the Note:
FOlInh. to amortizallon of the principal of tilt Note:
!:!~. 10 lale charscs due under the NOle.
~
_-2004fUPAI
'..2".
BOOK 1449 'rlGE 384
.
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4. 'Fire. Flood alld Olber Hazaro Insurance. Borrower shall insure all improvcmems on (he Property, wlldhtr now in
CJlistcncc or subsequenll)' eltded. against any hazards. casualties, and c:onlingcncics. including lire. tor which Lender requires
insurance. This insuranct: shall be maintained in the amounts and ror Ihe periods thlr Lender requlrrs. BorrDw~r shall also
Insure aU hnprOytlllCldS on the Property, wllelber IIDW in cxistcua: or subsequently erected. apinslloss by noods to the exlell'
requited by the Secretary. All in,c;urancc shall be carried wllh companies approved by l.endCl. The insurance polities anti any
renewals shall be held by LCnder and shall include loss pnyllblc c1uuses ;/1 favor of, and in a form acceptable 10, lender.
In the event of loss. Borrower shall give lender immediale notice by mail. ~ndcr may make proof of loss if nol made
promptly by Borrower. Eaclllflsllrance company concerned \1 bereby authorized and direcled 10 make payment: for sudl loss
directly '0 lender, Instead of 10 Borrower and 10 lender jointly. All or any part of the insururce proceeds Alay be appUed by
Under. ar its option. eilJler (a) 10 tht reduction of the 'indebtedness under the NoIe and Ibb SccuriCy Instrllment, firsl to any
dclinqlKllt alUounls applied in the order In plraanph 3, and Ihen 10 prcpaymtnt of principal, Or (b) to the reslQlalion or repair
of Ihe danUlicd Property. AllY applicalion of the proceeds 10 Ihe principII sh.I, not extend Of postpone Ihe due dale of IlIe
ll10nlbJy payments which .re rderkd to in paragraph '2, or change Ihe 1lf1l0unt of such payments. AllY e"cclS insurance proceeds
over an OIlIOUI1I required to pay .11 outslanding indebtedness under Ihe Nme and Jlds Security Instrument shaU be paid 10 the
entity le&ally endUed lheldo,
III the event of foreclosure or Ihis Sccurity Instrument or other trander of lille 10 the Property Ihal extinguishes the
hl()ebtedness, all right. tide and inlerell of Borrower in and to insu~nce polieiq in force shall palS 10 tbe pUrcbber.
S. Occupancy. Preservation; Malmenance and Prolectlol1 or the ProperlY. Borrower's Loan AppJJcalJoJl;
LeasmoJds. Borrower shall occupy, establ1sh, and use Ihe Properly ll$ Sorrcnver's principal residence willdn Si;lIY days afier
the eucuJion of Ihis Security Instrument and shan colllinue to occupy the Propc:l1y as Borrower's principal residence for at least
one year after Ihe dale of occupancy, unless the Secretary dc:tenninc:s dlis requirelntnl will ause: undue hardship for Borrower,
or unless txtenuutil1& circUInSlanc:es exist which art beyond Borrower's control, Borrower shall nolify Lender of Iny
ulenualil1g circulIlslances, Borrower, shall tlOI commil waste or destroy, damage or IUbSlal1lially change Ihe Property or allow
Ihc Properly 10 deleriorale, reasonable wear and Iear t.lcepled. under may ins.pect the Property If the Property is vatlnl or
abandoned or lhe loan is in default ullder may lake reasonable aclion 10 prolect and prc:sc:rYe such vacant or abandoned
Property. Borrower shaJJ also be in defaull if Borrower. duringlhe loan applicalion process, gave malerlaUy f.lse or ;nat'C'uNlIe
infomlaUOII or sflllelJlenls 10 L.ender (or failed to pro....ide: Under with any malerial informallon) in connection wllh the loan
C'Ytdenced by Ihe NOIe. Indudina. but nol Unlhed to, representations concerning Borrower's occupancy of 1M Property as a
print;".1 residence. If Ihis Security InslNllltnl is on II leasehold, Borrower shaU comp!y wilh tbe proyislons of lhe lease. If
Borrower acquires fee title 10 Ihe Properly. the leasehold and fee tide shall not be mc:ried unle" Lender agrees 10 the merler in
writing.
6. Charges 10 Borrowcr and Prolectlon of Lender'! Rlghls In Ihe Property, Borrower shall pay allgovcmme1tlaf or
municipal charges, fines mid. impositions 1111I1 are nol includec.l in p;lragraph '2. Borrower shall pay Ihcsc obUgllions on lime
directly 10 lhe: cntity whidl is owed the payment. If failure 10 pay would adversely affcel Lender's inlerest in the Property, upon
Lender's request Borrower slUllJ promptly furnish 10 Lender receipts evidencing lhese: payments.
If Borrower fails 10 make these: payments or Ihe payments required by paragruph 2, or fails 10 perform any other coyenanls
and agreemenls conlained In this Security ll1strunltJU, or lhere:: is. legal proceed;ni riNd may S)Bnificanlly .ffecl Lender's rights
in the Property (sllch as a proceeding in bankrulJlcy, for condemnation or 10 enfon:e Jaws or regulations), Ihcn Lender may do
and pay whatevcr is nc:a:ssary 10 proled (he: value of the: Propclty and Lender's rights in lilt Property, includina paymenl of
la"es, hazanl insunlllce and olher ilelllS mentioned ill paragraph 2.
Any amounts disbursed by Ltndtr under Ihis paragraph shall becon1C an additional debt of Borrower and be: secured by
this Se~rily Inslrumen!. 11lese alllounts shall bear interesl from the: date or disbursement, II dle Nole rate, and at lhe oplion of
Lender. shall be immediately due and payable.
7_ Condemnallon. The proceeds of any award or claim for damages, dired or consequential, in connc:clion with any
condemnalion or other lakina of any part of the Properly, or for oonveyance in pl.ace of condc::mnllion, arc: hertby Il$siancd and
shall be paid 10 Lender to lhe: ellent or the full amount of the indebledlless lbal remains unpaid under the Hate and Ihis Security
Inslrull1CllI. Lender shall apply such prottcds (a tltc reduction of the indebtedflCls under the Note and this Security Instrumenl,
rirsl tu any dellnqucnt amounts appJ~d in Ibe order proyided in paragraph 3, altd Ihell 10 prepaymenl or principal, Any
applicafion of lhe: proceeds 10 Ih~ principal shall not exlend or postpone: the due dale of Ihe 1110mhly payments. which 1ft
_.2D04RfPA) '-.-3." 0 ..............~'- *""""'~
Bo0K1449PAGE 385 Jt((
.
.
referred to in paragraph 2, or change tbe amounJ of such paymenls. Any excess proce.a1s over an amounl required 10 P'ly aU
oUlstanding indebfednesJ under lhe Nole and Ihls Stturhy Instrument shall be paid to Ihe entity legally entitled (hemo.
8. Fla. Lender may collecl fees and charges authorized by lhe Secretary.
9. Grounds for Acceleration of Debt.
(a) DerauU. Lendet may. except as Iimlred by ~Iulalions issued by the Secrtlary in the case of payment dcr..Us,
require immediate paymentln lull of aU sums JtCurcd by Ibis Sec:urhy Instrument if:
(I) Borrower delauhs by ralJina10 pay in full any monthl)' payment required by Ihls Security Instrument prior to or
on the due dale of IIIC nul monthly payment; or '
(ii) Borrower derlulls by rallins. (or. period of thin)' dlys, 10 perform any OCher obligalions contained in Ibis
Stt:urily Insll'\llI1Cnl.
(b) Sale Wlthont Credll Approval. Lender shall. if pe.mllKed by applicable Jaw and with the prior approval of lhe
Secretary, require hl1lnediale paymenl in full of III sums secured by IhJs Security IJ15Irument if:
(i) All Dr plrt of tbe Froperty, or a benelicial ;nlercst in a trusl owninl all or part of the Property. is sold or
otherwise transfened (OfheT llian by devise or dacellt) by the Borrower. and
(il) The Property Js not occupied by Ille purchaser or granlee as his or her principal residence. or the
purchaser or grantee: does $0 oIXupy the Property bul his or her credit lias not been approved in accordance with the
requiremenls of the Secrel.ry.
(el No Wa.lver. U circumslances OCCur Ibal would permit Lender 10 require immedia(e paymelH in fuJl. bul Lendcr dOcS
001 require such paymcnls, Lender does not waivc Us righes with respec( to subsequenl evenls.
(d) Reguladons of HUD Secretary. In miRY circumstances reBulalions issued by Ihe Secreta')' willllmil Lender's
rlghts in Ihc case of plymenl derauhs to require Jnnnediale paymenl In full and foreclose if nol paid. This S<<urily
(nslrumenl does not aldhorizc lCt'elual1on or foreclosure If nol permiued by regulallons of the S<<rctary.
(e) MorIa_Ie Not Insured. Borrowcr agrees Ihal should Ihis Security lnstrumen! and tbe Notc secured (hereby not be
eligible for insurance under lhe: National Housina Acl wilhin 60 days from me dale JICfCO(, Lender may, al ils option
and nolwilbstBndins anYlbins in paragflph 9. require immc:diBte payrncm in (uU 01 aU sums secured b)' Ihis Securily
Instrument A wriUtn slalellW1l of any authorized aBent of ,he: SecR1lry daled subsequenllo 60 days (rom lhe dale
hereo(, declinina10 Insurelhis Security Inslrumc:nI.nd the: Note secured Ihereby. shall be deemed conclusive proof of
such indiaibllily. NotwilhSlandinalhe foregoing, Illi.. option may nol be exercised by Lender whut Ibe unavailabllily
o( insurance is solely duc fo Lendcr's failure 10 remll I mortgage insunmct premium to Ihe Scc:rC:llry.
JO. Relllslatemen'. Borrower has a nlhl 10 be. reinstated i( Lender has required inune.diale payment: in full because of
Borrower's f.!liluTC 10 pay an amount due under Ihe: NDle or Ihls Sc:c:urily Inslrumenl. This right applies even Irler' (oreclosure
proceedinxs are: Inslhuted. To reinstale: Ihe: Steurily Inslrument, BOllower shallle:ndtr in a lump sum all amounls required 10
bring Borrower's account curre:nl indudina, 10 Ihe: exlcn' they are obligations of .borrower undtr Ihis Security Inslrumcnl.
(oreclosure costs and reasonable and cuslom.ry aUorneys' roes and e.pcnSCI proper))' associated with Ihe for=losure
pr(Jl;et:ding. Upon reinstalement by BOlTO\lier, Ihis Security Instrument and tbe: obJiaaJlons Ihal it sccurc:l shill remain in effecl
as if Lender had not required immediate payment in (ull. Howc:vu, Lc:nde.r is not required 10 permil reinstalemenl if: (i, Lender
has acccpled reinslaleanent aRcr Ihe commenccment or foreclosure Proce.edinl5 wilhin IWO yeaB itnmedilldy pre.cedina1be
commencement of a current (oreclosure proccedjn,. (ii) reinstatemenl will preclude foreclosure on different arouncts in lhe
ruture. or (Hi) reinsratemc:nl wm advcrsely .rrecllbe prlorily of lhe lien created by this Security Instrumenl.
1 l. Borrower Nol Released; Forbearance By Lender Not B Waiver. Extension of (he lime or P'lymern or modlralion of
amorlwlion of Ihe: sums secured by Ihis Security Inslrumc:nlgrnnled by undcr to any successor in intetesJ of BorroWer shllll
not operale 10 release Ihe liability of lhe. original Borrowu or Borrower's successor in Jnlen.sl. Lender shall not be required 10
commencc proceedings aaainSl any successor in intcrest or refuse 10 extend lime f01 paymenl or otherwise: modify amortizalion
of the SUlllS secured by lhls Se.curiCy Instrument by reason of any dClUand made by Ihe oriBinal Bonowe:r or Borrower's
successors in inh:rcsl. Any forbearance by Lender in r:xercishl8 lily right or remedy shan not be a waiver of or preclude Ihe
exercise o( any rlghl or temedy.
G .2DD4RtPAJ
.
"'''ol.
~
8oad449,16f 386
.
.
12. Succtssors and Asslalls Bound; Jolt)) DIIlJ Seyeral L1abllltYi Co-Signers. The coyenants and agreements or this
Securily fnsfrumeul 5118)1 bind and btnelil Ibe successors and assigns of Lender and Borrower. subject to lhe provisions of
paraaraph 9.b. Borrower's CO\lc:nanls and agreements shall be joint and sc..,erat Any Borrower who co-signs chis Security
In,uumCnI bUI does not Cltccute the Note: (0.) is co-slgning Ihis Securily lnslroO\cnl only (0 nlOrtgage:. granl and cOllvey IhnJ
Borrower's lnttrest in Ihe .Property under the: terlns of Ihls Security Instrunlent; (b) is noe persollally obli881ed 10 pay the sums
secured by this Sc:curi'ty Inslrument; and (e) aSrees Ihat Lender and any other Borrower Ria)' agree 10 Qtend, modUy, forbear or
make: aDY accommodations with rtlard 10 Ibe: terms of chis Security Instrument or .be Note: wilhoullllll Borrower's consent.
13. Notices. Any notice 10 Borrower provided fOf in Ibis Securlt)' InslrorneRl shall be glvt:n b)' dellverinB il or b)' b18inn.
il b)' firsl class mail unless appJicable law requires use: Qr anolher melhod. The nOlice shall be directed 10 lhe Properly Address
or an)' alM:r .ddre$s 8(1rrowcr desilllDks b)' nolia: 10 lender. I An)' nolice 10 Lender shall be given b)' firsl clan mail Co
Lender's address Slated herein or an)' address Lender designales by nolicc 10 Borrower. Any notice pmvidcd ror in this Securit)'
InstrllnJenl .'ilwU be dccmcd 1(1 hllvc beellcivcnlo Barlower or under when given as provided ill this paragrlph.
14. GO\lenllng (.a"'j Severabillt)'. l1lis SeculilY Inslrul1lent sball be:: lovented by kdenlJ Jaw and Ibe law or lhe
jurisdiction in which Ihe Pmptrty Is located. In Ihe event lhal any provision or clause of 11m Securit)' InMrumc:nl or Ihe Note
connlcls wilh npplicable law. Iluch connicl shall nol a(fecl uther pnwi.iolJJ of Ibis Seturily Instrumcnt or Ihe Notc which can be
givcn err<<t without Ihc conniclinc provision. To tld~ end d~ plOvi..ions or this Securily ln5trumtl11l1nd Ihe Note are dcclared
10 be severablc. I
is. Borrower's Copy. Borrow~r .shall be liven one conrormed copy or this Securit)' Instrumenl.
16. AssIgnmenl or Rents. Borrower unconditionall)' Bssigns and transrers 10 lender all (he ren(s and rc:venues or the
Propert)'. Borrower authorizes lender or Lender's alents to collecl the rents and revenues and hereby dired.s each tenanl ar the:
Properl)' Iu ptly lilt tenls 10 Lender or LcJKIer's agellls. Huwc:ver. prior Co Lender's notice 10 Borrowcr or Borrower's breac:h or
an)' covenant or agrccmcl1t in the Sc'curllY InslNmel1t, Borrower sllall colJed and receive aU rents and revenues of Ihe ProperlY
alii trustee flU the benefit of Lender and Borrower. This RSllgnmeJlf or renls constilUles an absolute assignment and hot an
llSsiglllllCld for addilillnaf security only.
f( Lender gives notice of breach to Borrower: (a) all renls I'Cccived by Borrower shall be held b)' Borrower IS IrUSlcc (or
benefit of Lellder only, 10 be applied to the suna secured by the Securily lnslrument: (b) Lender shall be enliUed to collecr and
receivc aU of die: rents of the Property; and (c) each lenant or lhe Property shall pa)' all fell(S due and unpaid 10 Lender or
Under's agent on Lender's wrillen demand 10 the lenant.
Borrower has not execuled an)' prior assignmenl of (he: rents and bas no! and wiU nol perfonn any act Ihat would ~vent
Lender rrom exercising its rialus under Ihis paraarapll16.
,
Lender shall noC be reqllimtlo enler upon, take control or or maimain the Propc:rt)' berore or arler living nolice orhrcacfl
10 Borrower. However, bnde; or a judiciJllly Appointed receiver may do so at any time there: Is a breach. Any application of
rents shaH 1101 (:ure or walvt an)' default or invalidale any other rllhl or renledy or Lender. This assignmenc of renes of IIIe:
ProperlY sJUllllenninllte whelllhe debt secured by Ihe Stcurity InatrunlCnt is paid in run.
NON~UNIFORM COVENANTS. Borrower and Lender (unller covenant and agree as follows:
17. Foreclosure Procedure. If Lender Rquirts IlIlIucdJale parlllCllf In full under pAragraph 9, Lender ma)' foreclose
this SecurUy InstrumenC by judicial proceeding. Lender shan be entitled 10 collect all expenses incurred In pursuIng the
rell1edics provided en tld. pumgraph 11, Including, bul nul Iindlcd 10, attorneys' fees and costs of title evidence.
18. ReJeasc. Upon payolCnl or all sums seCured by Ihis SecurilY JnslrumCl1t, this Securily (nslrumen( and the estlle
conveyed shall lenninate alld become: void. Arter such occurrenCe, Lender shall discbarse and satisfy Ihis Security Jnslrumenl
wllJNlUI chArge 1(1 8(lfrnwt:r. Borrower shall pay any rcc:ordalion culls.
19. Walvetl. Borrower, 10 Ihe Ulenl pcmliued by applicnble law, waivC;t and releases any error or defecls in Procetdinls
10 enrl.lrct Ihis Securily JnlilfUmenl. and hercby waives Ute benelil of any present or rUlUre laws ptovldinB ror stQY or execution.
exlension of time. exempliol1 rrom aUachmem, levy and IDle. and homestead exemption.
<G>.: .2004RIPAI
.
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Ohlnl"".."lIIqocWr_
~f
BOOK1449'AGE 381
.
.
. 20'. Relnstataucnt Period. Borrower's time 10 reinstalc provided In paragraph .10 shall cllend to one: hour prior 10 the
commencement of hiddina: BI a shcrifrs sate or Olber sale pursuant to this Securily Instrument.
21. Purchase MOllC)' Mortgage. If any of the debt seturcd by this Security Instrument Is lent to Borrower 10 acquire IlIle
to the Property I Ihis Security Instrument shall be I purrbJIse money mortgage.
22. Interest Rate Arter Judgment. Borrower agrees thai the Inlcresl fate payable after a jUd&ffiCnI is entered on the Note
or in an action of mortgage foreclosure shall be lhe ra'c payable from lime to dint under Ibe Note.
23. Riders to this Security Instrument. If one or more riders are executed. by Borrower and recorded together with this
Security Instrument, Ihe covenanls of each such rider shan be incorporated inlo and $ball amend and supplement the covenanll
and acreerm:nls of Ibls Scc:urity Instrument as if the rider(s) were'a part of this Securily InslNment,
{aleck applicable box(es))
B Condominium Rider
Planned Unit Development Rider
B Graduated Payment Rider
Growing Equity Rider
o Olhe< (Specily)
'h/TU} ~~
(Seal)
.Bormwcr
BY SlONINO BELOW. Borrower accepts and agrees to the terms
executed by Borrower and r<<:orded with il.
Witnesses:
(Seal)
..0<.....
(S..I)
-lIorntwer
(Seal)
-80nowcr
Certificate or Residence
I, Jeru1ifer Ecker . do hereby certify Ihatthe c:orrcct eddress of
the withln.named Lender is 9309 Belair Road, BaltiJtm'er K) 21236
WitneSs my hand this 24th
d.y 01 April 199B
C'u/IJI;nJu.kc.1.euv
~Ecker
Aim of Lender
COMMONWEALTH OF PENNSYLVANIA,
DAUPHIN
County IS:
On this, the
personaJl)' appeared
24th day or April , 1998
Andrew E. Redmond and Jennifer L. Redmond
. before me. the undersllntd ofliter.
known to me: (or satisfactorily proven) to be lhe
person s whose name 8 are subscribed 10 (he within inslruntefd and adc:nowledgo:l .b., they
executed the same for Ihe purposes hcrcin contained.
IN WITNESS WHEREOP, I hereunto set my hand and offielal SClI.
My COlRmission Expires:
.....
.. .20D4RIPAI
.
__
NO"., J ....on. Nola.., publ~
WaahlOglonTwp, Dauptlln CountY Notary Public
~f1MIl"lOn Exp1f81 May 21,2001
. 10.......... ale of Off_,
Membef.f'eMsytvanlIAtSOClIllOnO u........
Bod449flG[ 388
.
.
AlL TIlAT CPR-TAIN lot or parcel of land situated in the Borough of Wormleysburg, County
of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and descnbed
as follows, to wit:
,
BEGINNING at a point on the western line of Second Street on the dividing line between Lots
Nos. 75 and 76 on the General Plan of Wormleysburg, said point being also 116 feet measured
Northwardly along the Western line of Second Street from the Northwest corner of Second Street
and Market Street; thence in a Westerly direction along said dividing line 96.9 feet to a point
on the lands now or fonnerly of N.C.R.R. Company, thence along said last mentioned lands
South 42 degrees 25 minutes East 25.04 feet to a point on the line of lands, now or fonnerly
of William Rishel; thence in an Easterly direction along said last mentioned lands 95.4 feet to
Second Street, thence in a northerly direction along the Western line of Second Street 25 feet
to the point or place of BEGINNING.
BEING A PORTION of Lot No. 76 on said General Plan of Wormleysburg and having thereon
erected a three story frame dwelling house known and numbered as 124 South Second Street.
Wonnleysbun!:. Pennsvlvania.
UNDER AND SUBJECT to easements, restrictions, right-of-ways, or other conditions of prior
record.
IT BEING the same premises which BARC Properties, a Pennsylvania Partnership, by its Deed
dated August 8, 1997, and recorded in the Recorder of Deeds Office of Cumberland County in
Deed Book 162, Page 800, granted and conveyed unto Andrew E. Redmond and Jennifer L.
Will, nfkJa Jennifer L. Redmond, the MORTGAGORS herein.
EXHIBIT "A"
Stale of pennsylvania}
County of Cumberland 86
ReCOrdad~ln the office for tha recording of Daecl8
~c~. and 1 .rland County
In B ...,._!
wit e my ha 01 offI tJi-..J.
Car . PA . ay '1 u..'6
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C' \NL\DBSC\REtlMOND A&R
BooK14.49'AG[ 389
VERIFICATION
Beth Morris ' Assistant Secretary, and duly authorized representative of Plaintiff,
deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn
falsification to authorities that the facts set forth in the foregoing Complaint are true and correct to
his information and belief.
/j
b~n . 7;/ }~~(( " .~
. , L'
Beth Morris ' Asslstant Secretary
"'- ~
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2005-02669 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
REDMOND ANDREW E ET AL
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:
REDMOND ANDREW E
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On June
9th , 2005 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin Co
Postage
18.00
9.00
10.00
36.00
.74
73.74
06/09/2005
GRENEN & BIRSIC
So answer~. ..... ..' ...~ ...._.. c.c~~
~. ~ <-:------
/~ ~.~~
R. Thomas Kline /
Sheriff of Cumberland County
Sworn and subscribed to before me
this
/S"f':: day of ~
<><-t'O:) A. D.
/
~.. () !-h"iPI.
Prothonotary
,,1ft!
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2005-02669 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE HOME FINANCE LLC
VS
REDMOND ANDREW E ET AL
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:
WILL JENNIFER L A/K/A JENNIFER L REDMOND
but: was unable t:o locate Her
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On June
9th , 2005 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
06/09/2005
GRENEN & BIRSIC
~., .c-.--- ..?
So ~nsw .... .. - .-
-." .' .-.?,"~/ -_/.
/-'/-k~~/.
~mas Kline
Sheriff of Cumberland County
Sworn and
subscribed to before
day of LI.1A..<---
I
me
this ISf':...
2IJv{ A.D.
C}-YL- Q Yh,PPP,. A~
prothonot:ary'
In The Court of Common Pleas of Cumberland County, Pennsylvania
Chase Manhattan Mortgage Corporation .
VS.
Andrew E. Redmond et al
SERVE: Jennifer L. will a/k/a Jennifer L. Redmond
No.
05-2669 civil
Now, May 24. 2005
, I, SHERlFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r~~,,?~
Sheriff of Cumberland County, P A
Affidavit of Service
Now,
,20_, at
0' clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
In The Court of Common Pleas of, Cumberland County, Pennsylvania
Chase Manhattan Mortgage CorporatJ.Ol1 .
VS.
Andrew E. Redmond et al
SERVE: Andrew E. Redmond
No. 05-2669 civil
Now, May 24.' 2005
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r~ -*'<~~
Sheriff of Cumberland County, P A
Affidavit of Service
Now,
,20 ,at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
methis_dayof ,20_
COSTS
SERVICE .
MILEAGE
AFFIDAVIT
$
$
@ffice uf t4~ ~4~~iff
William T. Tully
Solicitor
J. Daniel Basile
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
CHASE HOME FINANCE LLC S/B/M/T CHASE
vs
County of Dauphin
REDMOND ANDREW E
Sheriff's Return
No. 0963-T - -2005
OTHER COUNTY NO. 05-2669 CIVIL
AND NOW:June 2, 2005
at 9:40AM served the within
NOTICE & COMPLAINT IN MORT FORECLOSURE
upon
REDMOND ANDREW E
by personally handing
to JENNIFER L WIFE OF ANDREW
1 true attested copy(ies)
of the original NOTICE & COMPLAINT IN MORT FORECLOSURE and making known
to him/her the contents thereof at 2028 FLETCHER COVE
HUMMELSTOWN, PA 17036-0000
Sworn and subscribed to
jf~
before me this 3RD day of JUNE, 2005
~~
Sheriff of Dauphin County, Pa.
s.,Ak A ::s:.cl~tJ-.-
By
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. J, 2006
Deputy Sheriff
Sheriff's Costs:$36.00 PD OS/26/2005
RCPT NO 207309
SS
@ffice of t4~ ~4~~iff
William T. TuIly
Solicitor
J. Daniel Basile
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
CHASE HOME FINANCE LLC S/B/M/T CHASE
vs
County of Dauphin
REDMOND ANDREW E
Sheriff's Return
NO.0963-T - -2005
OTHER COUNTY NO. 05-2669 CIVIL
AND NOW:June 2, 2005
at 9:40AM served the within
NOTICE & COMPLAINT IN MORT FORECLOSURE
upon
REDMOND JENNIFER L A/K/A
WILL JENNIFER L.
to JENNIFER REDMOND DEFT
by personally handing
1 true attested copy(ies)
of the original NOTICE & COMPLAINT IN MORT FORECLOSURE and making known
to him/her the contents thereof at 2028 FLETCHER COVE
HUMMELSTOWN, PA 17036-0000
Sworn and subscribed to
So Answers,
:;t~
before me this 3RD day of JUNE, 2005
Sheriff of Dauphin County, Pa.
~~
~ A ~IJ--
By
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. I, 2006
Deputy Sheriff
Sheriff's Costs:$36.00 PD OS/26/2005
RCPT NO 207309
SS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slblm/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
CNIL DNISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ISSUE NUMBER:
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
TYPE OF PLEADING:
Defendants.
PRAECIPE FOR DEF AUL T JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance, LLC, slblm/t Chase
Manhattan Mortgage Corporation
I hereby certifY that the
address of Plaintiff is:
3415 Vision Drive
Columbus, OH 43219
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. LD. #77991
the last known address of
Defendants is:
2028 Fletcher Cove
Hummelstown, PAl 7036
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
GRENEN & BIRSIC, P.C.
/{:;tJLZ'-/li' (}LUL~
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, s/b/m/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
Defendants,
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Andrew E. Redmond and Jennifer L. Will, aIkIa Jennifer L. Redmond, in the
amount of$93,700.l2, which is itemized as follows:
Principal
Interest to 7/5/05
Late Charges to 7/5/05
Escrow Deficiency to 7/5/05
Corporate Advances
Attorneys' Fees
Title Search, Foreclosure and
Execution Costs
TOTAL
$86,302.90
$ 3,314.77
$ 228.59
$ 29.14
$ 74.72
$ 1,250.00
$ 2.500.00
$93,700.12
with interest on the principal sum at the rate of$l 7.73 per diem from July 5,2005, and additional
late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including
increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises.
GRENEN & BIRSIC, P.C.
BY:
.~
. tJ(. L. .
~M. An Oil, Esquire
Attorney for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants were not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment
were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
L-~t2[ c 1-.( YJt c.k e,L t/--v----
Sworn to and subscribed before me
this S ~
,2005.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Siial
Elizabeth M. Paiano. Notary PubliC
City Of Pittsburgh. Allegheny County
My Commission Expires Jan 6, 2008
Member. Pennsylvania Association Of Notaries
. IN THE COURT OF CO~ON PLEAS OF CUMBERLAND C~Y PENNSYLV ANlA
CHASE HOME FINANCE, LLC, s/b/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CNIL DNISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
Defendants.
TO: Andrew E. Redmond
2028 Fletcher Cove
Hummelstown, P A 17036
DATE OF NOTICE: June 23, 2005
IMPORT ANT 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 DA YS 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 TillS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, TillS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(800) 990-9108
FIRST-CLASS MAIL, POSTAGE PREPAID
GRENEN & BlRSIC, P.C.
-/~ .L~/a ' 1
V -' L~0,,~_L-cA.....S---~
By: .
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, P A 15222
(412) 281-7650
. IN THE COURT OF CO.!.ON PLEAS OF CUMBERLAND COLy PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CNIL DNISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, a!k!a
JENNIFER L. REDMOND,
Defendants.
TO: Jennifer L. Will, a!k!a Jennifer L. Redmond
2028 Fletcher Cove
Hummelstown, P A 17036
DATE OF NOTICE: June 23,2005
IMPORT ANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HA VB 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 TENDA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
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 ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(800) 990-9108
FIRST-CLASS MAIL, POSTAGE PREPAID
GRENEN & BIRSIC, P.C.
d~
By: j . i2L<...y9?LCl~tZ-ez../
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, P A 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, s/b/m/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Andrew E. Redmond
2028 Fletcher Cove
Hummelstown, P A 17036
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
011 ), J '-J I r ' ;U:b.S
I I
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $93,700.12.
with interest on the principal sum at the rate of$17,73 per diem from July 5, 2005, and additional
late charges, additional reasonable and actually incurred attomeys' fees, plus costs (including
increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/m/t
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Jennifer L. WiJI, aIkIa Jennifer L. Redmond
2028 Fletcher Cove
Hummelstown, PA 17036
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on ...JuJ,,\ \\ \ )..,DQS
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $93,700.12.
with interest on the principal sum at the rate of$17.73 per diem from July 5,2005, and additional
late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including
increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises.
~rJq( ~.~~
Deputy
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
ISSUE NUI\IlBER:
Plaintiff,
vs.
NO.: 05-2669 Civil
ANDREW E. REDMOND and
JENNIFER L. WILL, alk/a
JENNIFER L. REDMOND,
TYPE OF PLEADING:
PRAECIPE TO SATISFY JUDGMENT
Defendants.
CODE-
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance, LLC, slb/mlt Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. J.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.: 05-2669 Civil
Plaintiff,
vs,
ANDREW E, REDMOND and
JENNIFER L. WILL, a!k/a
JENNIFER L. REDMOND,
Defendants.
PRAECIPE TO SATISFY JUDGMENT
TO: PROTHONOTARY
SIR:
Kindly satisfy the judgment at the above-captioned matter and mark the docket
accordingly.
GRENEN & BIRSIC, P,C.
By:
~~{2L {,cf/iCt-{-<- h-
Kris 'e M. A~thou, Esquire
Attorney for P'laintiff
Sworn to and subscribed before me
this J \* day of - ~}" , 2005.
?~~\t~.ffi .\A~
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial ~I
Elizabeth M. Paiano. Notary Public
City Of Pittsburgh. Allegheny County
My Commission Expires Jan. 6. 2008
Member, Pennsylvania ASSOCiation Of NotarIes
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CNIL DNISION
ISSUE NUMBER:
Plaintiff,
vs.
NO.: 05-2669 Civil
ANDREW E. REDMOND and
JENNIFER L. WILL, a/k/a
JENNIFER L. REDMOND,
TYPE OF PLEADING:
Defendants.
PRAECIPE TO SETTLE AND
DlSCONTnWE WITHOUT
PREJUDICE
CODE-
FILED ON BEHALF OF PLAINTIFF:
Chase Home Finance, LLC, slb/mlt Chase
Manhattan Mortgage Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. LD. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CHASE HOME FINANCE, LLC, slb/mlt
CHASE MANHATTAN MORTGAGE
CORPORATION,
CIVIL DIVISION
NO.: 05-2669 Civil
Plaintiff,
vs.
ANDREW E. REDMOND and
JENNIFER L. WILL, aIkIa
JENNIFER L. REDMOND,
Defendants.
PRAECIPE TO SETTLE AND DISCONTINUE
WITHOUT PREJUDICE
TO: PROTHONOTARY
SIR:
Kindly settle and discontinue without prejudice the above-captioned matter and mark the
docket accordingly.
GRENEN & BIRSIC, P.C.
By:~:e.'Z{( '<-)"1( a~-<:LJ-J
Kristine M. Ailthou, EsqUire
Attomey for Plaintiff
Sworn to and subscribed before me
,2005.
COMMONWEALTH OF PENNSYLVANIA
Notanal S&al
Elizabeth M. Paiano, Notary Public
City Of Pittsburgh, Allegheny County
My Commission Expires Jan. 6, 2008
Member. Pennsylvania Association Of Notaries
n
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