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HomeMy WebLinkAbout02-1051 FEDERMAN 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 (215) 563-7000 ATIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION CHASE MANHATIAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 TERM Plaintiff v, NO.O~ - 16S7 C/U d_ ~"'" CUMBERLAND COUNTY CANDACE L. WHITE NKJA CANDACE L. HOCH 440 MT. ROCK ROAD NEWVILLE, P A 17241 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE ..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, P A 17013 (717) 249-3166 Loan #; 1504606631 IF TIDS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TIDS 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 AFfER 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. 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2, The name(s) and last known addressees) of the Defendant(s) are: CANDACE L. WHITE AIK/ A CANDACE L. HOCH 440 MT. ROCK ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3, On 9/20/00 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE INC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1642, Page 898, By Assignment of Mortgage recorded 10/3/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No, 656, Page 321. 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 11/1/01 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, 6, The following amounts are due on the mortgage: Principal Balance Interest 10/1/01 through 2/1/02 (Per Diem $29.10) Attorney's Fees Cumulative Late Charges 9/20/00 to 2/1/02 Cost of Suit and Title Search Subtotal $119,699.30 3,608.40 1,000.00 86,31 550.00 $124,944,01 Escrow Credit Deficit Subtotal 0.00 954.91 $ 954.91 TOTAL $125,898,92 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00, 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. 91680.403c. 10. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $125,898,92, together with interest from 2/1/02 at the rate of$29,10 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, FEDERMAN AND ~ BY:~~~ . FRANK FEDERMAN, ESQUIRE LAWRENCE T, PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL that certain tract of land situate in Monroe Township, Cumbcrhand County,I)I:nnsylvania. being identified as Lot No.4 as shown on n plan of lots known Llll "rinal Subdivision IJI.m for BRF.F.CHILS BEND" Prepared by Hoover Engineering Services. Inc.. tinted September 23. 1997. ^I~pl'()ved Fcbrunry 26. 1998 and recorded March II. 1991; in the nllicc ofthc Recordor orl)ccds in ' nnu for Cumberlnl1l.l County, PCI111:'lylvani.l ill Plan [look 76 Oil page 60. and heing more fully described as follows to 'wit: BEGINNING at a point in PA Route 74 (11 thirty-three toot llltim..te righHlf..wny). at a common prC>perly comer of Lot No.3 and Lot No.4 as shown Oil the above reterenccd Final Subdivision Plan of Breeches Bend, snid point also being referenced ::md located upproximatcl)' 585 feet in a. Southeasterly direction from the intersection ofIhe Southern Right..or.. Way Line ofP A Route 74 and the Ellstern Right-of-Way Line ofMiIler Boulevard; thence from suid point of beginning alollg said Lot No. J South 15 degrees] 9 minutes 01 second West. n distance off our hundred thirty (430,00) feet to an iron pin at Lot No.8; thence along said Lot No.8 and Lot No.6 North 74 degrees 40 minutes S9 seconds West, a dist:mce of two hundred (200.00) feet In t\n iron pin at Lot No.5: thence along said Lot No.5 North 15 degrees 19 minutes 01 soco",J Eu:'!t. n tlistnnce offuur hundred thirty (430.00) feet to a paint in P A Route 74; thence through 1) A Route 74 South 74 degrees 40 minutes_ 59 seconds East, a distance of two hundred (200.00) feet to a point, said point being the place of beltinninlL IT BEING part of the same premises which Clark L. Slothower and Dorothy M. Slothower, his wife, by deed dated August 8, 1997 and recorded in the office of the Recorder of Deeds in.and for Cumberland County, Pennsylvania in Record Book 162 at page 957, gronted and conveyed title unto Greeley Rodgers, Incorporated. IT BEING THE SAME PREMISES AS Greeley RodgerS Incorporated by deed dated December , 1999 and recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 214 at Page 303, granted and conveyed to HAM Y L. RAMAGE and DA vrD A. KRULAC. the GRANTORS herein, FURTIiER UNDER AND SUBJECT to the Protective Covenants and Restrictions set forth in that certain instrument recorded in d\e office of the Recorder of Deeds in and for Cumberland County. Pennsylvania in Record Book 584 at page 201. N WITNESS WHEREOF, said Grontar has caused this Deed to be signed and sealed to be hereunto ftixed, the day and year first above wriuen: ,~ :,;"'1::-.. BEING KNOWN AS: 1141 YORK ROAD . VERIFICATION RYAN L. REITMAJER hereby states that she is ASSISTANT SECRETARY of CHASE MANHATIAN 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 true 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, ~~O-~)L~ DATE: 02,61/0:9- RYAN L REITMAJER, SR. AS8ISTANT SECRETARY 1f~ - ,~ ~ ~ ~!3 ~ ~ Ct) t, D- . . . d B ~ I (). \ ~~ i- ,g (') a C I'V -0 55 ~ nlrrl :::0 -:7:11 ZC I (]}.o:;: .1="' e6 ;r:.. ):; ::J:: ZO )> ~ c;:? Z N ~ .&:"" (:;~ --~ ~r;l :2 "nfl1 , -1? ':~o ;.,~3J 1_-._.() 6m ~ -< . g SHERIFF'S RETURN - REGULAR CASE NO: 2002-01051 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS WHITE CANDACE L A/K/A CANDACE BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WHITE CANDACE L A/K/A CANDACE L HOCH the DEFENDANT , at 1136:00 HOURS, on the 13th day of March , 2002 at 440 MT ROCK ROAD NEWVILLE, PA 17241 by handing to PATRICIA KNECHT, GRANDMOTHER 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 Affidavit Surcharge So Answers: 18.00 6.21 .00 10.00 .00 34.21 r~"-,,~~~ R. Thomas Kline 03/14/2002 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~ lJ~1 ' Dep y Sheriff me this /9 t!:: day of ~..d../ J-oo :L A. D . Q.I~ a '~jJ1 ~ ~ P othonotary , . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney fOf Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 02-1051-CIVIL CANDACE L. WHITE, AIKJA CANDACE L. HOCH Defendant( s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against CANDACE L. WHITE. AlK/A CANDACE L. HOCH, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 2/2/02 to 4/16/02 TOTAL $125,898,92 $ 2,153.40 $128,052.32 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237,1, copy attached, ~O~A1V\l'i~ ' RANK F ERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICC. ~27-- DATE: ~L 1(" UX>-- ~A-I:-.;., , /) PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (11 'i) 'i()1-7000 Attorney for Plaintiff CHASE MANHATTAN CORPORATION MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY CANDACE L. WHITE A/K/A CANDACE L. HOCH NO. 02-1051 CIVIL Defendant(s) TO: CANDACE L. WHITE A/K/A CANDACE L. HOCH 440 MOUNT ROCK ROAD NEWVILLE PA 17241 OF NOTICE: APRIL 5. 2002 ~~ THIS FIRM IS A DEBT COLLECTOR ATT~9~ COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY NFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, DATE IMPORTANT NOTICE You are in default because you have failed 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 (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 '2f?:7/ Frank Federman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-01051 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS WHITE CANDACE L A/K/A CANDACE BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WHITE CANDACE L A/K/A CANDACE L HOCH the DEFENDANT , at 1136:00 HOURS, on the 13th day of March , 2002 at 440 MT ROCK ROAD NEWVILLE, PA 17241 by handing to PATRICIA KNECHT, GRANDMOTHER 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 Affidavit Surcharge So Answers: 18.00 6.21 .00 10.00 .00 34.21 r~~;~~ R. Thomas Kline 03/14/2002 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~ !, 2~ ( , Dep y Sheriff day of me this A.D. Prothonotary ~~ - lJ ~ - -< ..... r: 4Q ...0 . o o p r ~ ~ (:) ~ () c: s: -0 OJ mrtl -'7 -r'j ~~ ~E <::: ~;>('- 2C',' J>C~ Z ~ - "<) (tv ~ ...0 \:" o l'> :J:lOO ..,., ;:;0 o ...., -..... :.C::!] lni ~.:2rn .~? C)rJ ~-.;.:1 ~~i ,'-:n '20 i'jrt1 ..'--1 ~ -< 0" ::>a ::::: ',,0,) FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO.02-1051-CIVIL CANDACE L. WHITE, A/KiA CANDACE L. HOCH Defendant( s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant CANDACE L. WHITE, AlKlA CANDACE L. HOCH is over 18 years of age and resides at 440 MOUNT ROCK ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~OM~ RANK F ERMAN, ESQUIRE Attorney for Plaintiff (') 0 0 c: I'.) -n s: :00 .--4 "UOJ -0 ;1: :n mg:; ;;0 ':~~ Z " Z)=; '" ~.:; en _,' ,~ ~6 _...."~ .. - ;0. ,-:n 7'5-'9 )>(") :x: =....0 Zo om ::t>e: :;! ~ w ~ (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 02-1051-CIVIL CANDACE L. WIDTE, A!KJA CANDACE L. HOCH Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on flpn:;..l ll_ 200.:2.. If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD" SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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.** PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, v. No.02-1051-CIVIL CANDACE L. WIDTE, A/KJA CANDACE L. HOCH Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $128,052.32 Interest from 4/16/02 to 9/04/02 (per diem -$21.05) $ 2,968.05 and Costs TOTAL $131,020.37 1~~~. ~N. RANK FED RMAN, ESQUIRE- One Penn Center at Suburban Station 1617 John F, Kennedy Boulevard, Suite 1400 Philadelphia, P A 19103 -1814 Attorney for Plaintiff Note: Please attach description of property. No. - . .... "'" N r-- .... -( =- ~ f,lil ..J ..J - == > U ~ r..:!: 0 f,lil == Z Z O~ 0 ~ f,lil ..J - rFl> Eo< < <..J ~ f,lil ;l ~ f,lil> ~ u as ..JrF1 ~~ i:: =-Z ~ Q ~ 0 Zz ~ f,lil = U '" Of,lil Oz '" 0 0 r.. 0 ,D ~=- ~O U 0"0 l:l:: ~ ~ ~ ~~ ~ Q,l Eo< Eo< ... S O~ ;!ri: Z Eo<~ <Ii ;l ~ UZ > < r..;l ~O ~~ 0 ~ ~ l:l::~ ~ 00 ==~ f,lil 0.. U Eo< 01:: Q 0 ~Q ~O - "'" ... == r.. 0 "'" ] ;lZ ~U ~ f,lil6 ~ 0< =- tn .J - U~ f,lil U en rF1 f,lil ~ -i::i .t3 f,lilf,lil -( === U 0 ~ == - Eo<~ -( '... U Q =- ~ Z;l ~ -U U ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, being identified as Lot No, 4 as shown on a plan of lots known as "Final Subdivision Plan for Breeches Bend" Prepared by Hoover Engineering Services, Inc. dated September 23, 1997, Approved February 26, 1998 and recorded March 11, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 76 on page 60 and being more fully described as follows to wit: BEGINNING at a point in PA Route 74 (a thirty-three foot ultimate right-of-way), at a common property comer of Lot No.3 and Lot No.4 as shown on the above referenced Final Subdivision Plan of Breeches Bend, said point also being referenced and located approximately 585 feet in a Southeasterly direction from the intersection of the Southern Right-of-Way Line of PA Route 74 and the Eastern Right-of-Way Line of Miller Boulevard; thence from said point of beginning along said Lot No.3 South 15 degrees 19 minutes 01 seconds West, a distance of four hundred thirty (430.00) feet to an iron pin at Lot No.8; thence along said Lot No.8 and Lot No.6 North 74 degrees 40 minutes 59 seconds West, a distance of two hundred (200.00) feet to an iron pin at Lot No, 5; thence along said Lot No, 5 North 15 degrees 19 minutes 01 seconds East, a distance of four hundred thirty (430.00) feet to a point in PA Route 74; thence through PA Route 74 South 74 degrees 40 minutes 59 seconds East, a distance of two hundred (200.00) feet to a point, said point being the place of beginning, SAID lot containing 86,000.00 square feet or 1.9743 acres. FURTHER UNDER AND SUBJECT to the Protective Covenants and Restrictions set forth in that certain instrument recorded in the Office pf the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 584 at page 201. Tax Parcel #12-0348-241 TITLE TO SAID PREMISES IS VESTED IN Candace L. White by Deed from Harry I. Ramage, a married man, and David A, Krulac, a married man, each the owner of an undivided one-half interest as tenants in common, Diane E. Krulac joins her husband on this deed, Grantors, dated 4/5/2000, recorded 7/18/2000, in Record Book 225, Page 500, BEII!IG DOWN AS: 1141 YORK ROAD MECBAlfICSBURG. PA 17055 . ~ 4 "- ~ ~~ 0 ~ ~ w ...... ~ ~ 6' ..Q -t' ~ . . , . . 1-.> V, 0 (;> 1--> 0 d 8 0 () - 0 - , j I , 1U "- I f ~ (') 0 ~ ~ f'::::J c I"U ..c: ~ s.: %00 .-1 ..... .,..... ~ -OeD -0 '1: " ~ , ~r:p ;;:c I'll fIJ /' , , .. .... um l' ~ ... .... , z~- E?6 b (j) ,:: C7'> -<~ tV -+- !;20 :t>o t53J .... , Po :::c: , , .... Zj z~ .... -. .... ~+-- )>0 - 0 ~ .. '--j =< w ~ -< FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION CANDACE L. WHITE, A/KfA CANDACE L. HOCH NO. 02-1051-CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities, r~lkAMiAH' RANK FE ERMAN, ESQUIRE- Attorney for Plaintiff (") c <'" "w fT1 rT1 Z::c ZC (/'),!-,,: -<L., kC ~O ~c >c ~ o f'.) - -0 ;:0 o >l -I ;:;~, FQ -"(jm cJ't i,:)U -~:j ~.lt .:-"n r)- ?:~ o --i ~ '< a-> - :::r. w CHASE MANHATTAN MORTGAGE CORPORA nON CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION CANDACE L. WHITE, AnUA CANDACE L. HOCH NO.02-1051-CIVIL Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1141 YORK ROAD, MECHANICSBURG, PA 17055. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CANDACE L. WHITE, A/K/A CANDACE L. HOCH 440 MOUNT ROCK ROAD NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4, Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 1141 YORK ROAD MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S, Sec, 4904 relating to unsworn falsification to authorities, April 12, 2002 DATE f ",^~EA \/III.I)~- RANK FE RMAN, ESQUIRE ttomey for Plaintiff - . (") 0 0 C tv " s:: :::> :~i ""00::; V _i. ::rJ !:p rT~ ;;0 mj=- ...::...:n 'Tlm z~; (J> :"'7 cJ5. :; g~? -(~. !;::O ):Do _I~ -n ;;;>0 :::s: Q('5 Zc "'~rn )>c' 0 z J.) );! ::;! r-.:> ~ .. CHASE MANHATTAN MORTGAGE CORPORA nON CUMBERLAND COUNTY Plaintiff, No. 02-1051-CIVIL v. CANDACE L. WmTE, A/KJA CANDACE L. HOCH Defendant(s). April 12,2002 TO: CANDACE L. WHITE, AlK/A CANDACE L. HOCH 440 MOUNT ROCK ROAD NEWVILLE, PA 17241 UTHIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. U Your house (real estate) at 1141 YORK ROAD. MECHANICSBURG. PA 17055. is scheduled to be sold at the Sheriffs Sale on 9/04/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$128.052.32 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you, In the event the sale is continued, an announcement will be made at said sale in compliance with Pa,R,C.P" Rule 3129,3, NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FlND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tr~ct of land situate in Monroe Township, Cumberland County, Pennsylvania, being identified as Lot No.4 as shown on a plan of lots known as "Final Subdivision Plan for Breeches Bend" Prepared by Hoover Engineering Services, Inc. dated September 23, 1997, Approved February 26, 1998 and recorded March II, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 76 on page 60 and being more fully described as follows to wit: BEGINNING at a point in PA Route 74 (a thirty-three. foot ultimate right-of-way), at a common property comer of Lot No.3 and Lot NO.4 as shown on the above referenced Final Subdivision Plan of Breeches Bend, said point also being referenced and located approximately 585 feet in a Southeasterly direction from the intersection of the Southern Right-of-Way Line of PA Route 74 and the Eastern Right-of-Way Line of Miller Boulevard; thence from said point of beginning along said Lot No.3 South 15 degrees 19 minutes 01 seconds West, a distance of four hundred thirty (430.00) feet to an iron pin at Lot No.8; thence along said Lot No. 8 and Lot No. 6 North 74 degrees 40 minutes 59 seconds West, a distance of two hundred (200.00) feet to an iron pin at Loi No.5; thence along said Lot No, 5 North 15 degrees 19 minutes 01 seconds East, a distance of four hundred thirty (430.00) feet to a point in PA Route 74; thence through PA Route 74 South 74 degrees 40 minutes 59 seconds East, a distance of two hundred (200,00) feet to a point, said point being the place of beginning, SAID lot containing 86,000.00 square feet or 1.9743 acres, FURTHER UNDER AND SUBJECT to the Protective Covenants and Restrictions set forth in that certain instrument recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 584 at page 201. Tax Parcel #12-0348-241 TITLE TO SAID PREMISES IS VESTED IN Candace L. White by Deed from Harry I. Ramage, a married man, and David A, Krulac, a married man, each the owner of an undivided one-half interest as tenants in common, Diane E, Krulac joins her husband on this deed, Grantors, dated 4/5/2000, recorded 7/18/2000, in Record Book 225, Page 500, BEIliIG DOWN AS,: 1141 YORK ROAD MECllAlHCSBURG. PA 17055 (') 0 0 c: r.> "'T1 s: :p- :,J -U lTI -0 i-,:;;;Q mrn ::0 Z::O 'Cl~ ZC' (j'I ,) ~2: (:) .J r:::C i..,. :<>0 l:ij ~O ::II: r~ (") 0 t5 rll 5>c: ~ Z w =<! r-.:> -< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1051 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From CANDACE L. WHITE, A/KJA CANDACE L. HOCH, 440 MOUNT ROCK ROAD, NEWVILLE, PA 17241 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: . and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $128,052.32 L.L. $.50 Interest FROM 4/16/02 TO 9/4/02 (PER DIEM-$21.05) $2,968.05 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $106.21 Other Costs Plaintiff Paid . Date: APRIL 16, 2002 CURTIS R. LONG Prothonotary, Civil Division Jly: ~ g~ P. 71;C/l/J~~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No, 12248 . AFFIDAVIT OF SERVICE F-T'IV PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION No.02-1051-CIVIL CUMBERLAND COUNTY KMD DEFENDANT(S) CANDACE L. WIDTE, A/KJA CANDACE L. HOCH ACCT. #1504606631 SERVE CANDACE L. WIDTE, AlKJA CANDACE L. HOCH AT 440 MOUNT ROCK ROAD NEWVILLE, PA 17241 Type of Action - Notice of Sheriff's Sale Sale Date: 9/04/02 SERVED ~ Served and made known to C"OllVd~c~ L, ~.\*~ ,Defendant, on the ~ 'I at 7:J./,O'Clockf-,m.,at 116 PI!t tfOck ~d,/ N~wv~ll~ daYOf~'200...;l.. , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served, j \ )<. Adult family member with whom Defendant( s) reside( s), Relationship is U slo ~ tJ ~ Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefenclant(s)'s office or usual place of business, an officer of said Defendant(s)'s company, , ~~y \)J~\..I~ Other: NOT SERVED On the day of , 200_, at o'clock _,m" Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 o c <' -uij'j rTlf";"1 '2'::c Z" ef) ...,. "< r'''' .- ~2~ .Pc Z ~ , \ Cl fv :::r: ~ I f'0 o 11 :.~ -lJ ,- .,~ ':~=1 (1) "',l --'1 ;() ~'::~rn ::::::-1 -,........ :0 -< :.n (}1 Chase Manhattan Mortgage Corporation VS Candace L White a!kIa Candace L Hoch In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1051 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman Sheriff's Costs: Docketing Surcharge Law Library Prothonotary Mileage Levy Advertising Posting Handbills Share ofBiIIs Poundage Law Journal Patriot News Postpone Sale Certified Mail 30.00 20.00 .50 1.00 15.18 15.00 15.00 15.00 25.20 17.83 423.50 308.95 20.00 2.29 $909.45 paid by attorney 09120/02 Sworn and subscribed to before me So Answers: This ~O~ day of .-4,7::..;". . r~ ~ /1 R. Thomas Kline, Sheriff 2002,A.D.( 1.",. f;)n.,dk"a.r' ~t~' 'I 'r' BY,. ~ Prothonotary Real Esta e Deputy l.~ 0/ Ul.-Jr.:1~:.., fdv. 13bO Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.02_1051-CIVIL CHASE MANHATTAN MORTGAGE CORPORATION v. CANDACE L. wroTE, AIKIA CANDACE L. HOCH Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1141 YORK ROAD, MECHANICSBURG, PA 17055. L Name and address ofOwner(s) orreputed Owner(s): Last Known Address (if address cannot be reasonably ascertained, please indicate) Name CANDACE L. WHITE, AlK1A CANDACE L. HOCH 440 MOUNT ROCK ROAD NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the re property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TenanUOccupant 1141 YORK ROAD MECHANICSBVRG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. April 12.2002 DATE 1,o..,~'A '^~O"'_ RANK FE RMAN, ESQUIRE ttorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No.02-lOS1-CIVIL v. CANDACE L. WIDTE, AlKJA CANDACE L. HOCH Defendant(s). April 12, 2002 TO: CANDACE L. WHITE, AlK/A CANDACE L. HOCH 440 MOUNT ROCK ROAD NEWVILLE, PA 17241 ..THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. Your house (real estate) at 1141 YORK ROAD, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on 9/04/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of$128,052.32 obtained by CHASE MANHA TT AN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, being identified as Lot No.- 4 as shown on a plan of lots known as "Final Subdivision Plan for Breeches Bend" Prepared by Hoover Engineering Services, Inc. dated September 23, 1997, Approved February 26, 1998 and recorded March 11, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 76 on page 60 and being more fully described as follows to wit: BEGINNING at a point in PA Route 74 (a thirty-three. foot ultimate right-of-way), at a common property comer of Lot No.3 and Lot No.4 as shown on the above referenced Final Subdivision Plan of Breeches Bend, said point also being referenced and located approximately 585 feet in a Southeasterly direction from the intersection of the Southern Right-of-Way Line of PA Route 74 and the Eastern Right-of-Way Line of Miller Boulevard; thence from said point of beginning along said Lot No.3 South 15 degrees 19 minutes 01 seconds West, a distance of four hundred thirty (430.00) feet to an iron pin at Lot No.8; thence along said Lot No.8 and Lot No.6 North 74 degrees 40 minutes 59 seconds West, a distance of two hundred (200.00) feet to an iron pin at Lot No.5; thence along said Lot No. 5 North 15 degrees 19 minutes 01 seconds East, a distance of four hundred thirty (430.00) feet to a point in PA Route 74; thence through PA Route 74 South 74 degrees 40 minutes 59 seconds East, a distance of two hundred (200.00) feet to a point, said point being the place of beginning. SAID lot containing 86,000.00 square feet or 1.9743 acres. FURTHER UNDER AND SUBJECT to the Protective Covenants and Restrictions set forth in that certain instrument recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Record Book 584 at page 201. Tax Parcel #12-0348-241 TITLE TO SAID PREMISES IS VESTED IN Candace L White by Deed from Harry I. Ramage, a married man, and David A. Krulac, a married man, each the Owner of an undivided one-half interest as tenants in common, Diane E. Krulac joins her husband on this deed, Grantors, dated 4/5/2000, recorded 7/18/2000, in Record Book 225, Page 500. BEING KNOWN AS.: 1141 YORK ROAD KEC!lANICSBURG. PA 17055 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff(s) From CANDACE L. WillTE, AlK/A CANDACE L. HOCH, 440 MOUNT ROCK ROAD, NEWVILLE, P A 17241 NO 02-1051 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant( s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof: (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $128,052.32 LL $.50 Interest FROM 4/16/02 TO 9/4/02 (PER DIEM-$21.05) $2,968.05 AND COSTS Atty's Conun % Due Prothy $1.00 Atty Paid $106.21 Other Costs Plaintiff Paid Date: APRIL 16, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: ~e~--,P 7r;/I~R5' Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 . Real Estate Sale # 27 On May 13,2002 the sherifflevied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, P A known and numbered as 1141 York Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 13,2002 By:\.JO~ J~ Real Estate Deputy ~ ~ <::::::J G?> GVU '" /i ' : i.3 d -:'{, 2 [5 L I UdV AiN, , ~~llJ:H', "I;"!'.,) . .:ii,jO THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true: and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#27 ~...~.....................................~................. Sworn to and subscribed before me this 14th day of gust 2 AD. Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin C My Commission Expires June 6, 2006 Member. Pennsylvania Association OfNo~commission expires June 6, 2006 '7t!J~ CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 307.20 1. 75 308.95 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... r R~L ESTATE SALENG. ~ 'WItt He.2CIIlI>fOI1 ' Chili""" ~'....~....... -..... CoI'jli:l...""'. ... c.~L~"" C...... L. ~ Ally: Fl'81lk Fada_ . llESCRIPl'IOI! All THAT CBKrMN _ of land ."aIe in MOIItoe, Towniiiip,Cuinborl.Dd ,County, I'emilylvania, ~ iden1ifi<d,.. Lot No.4 .. .- OIl . pian'of 1018 jaIOwn.. "I'inaI SnlldlvisionPllllifor~Bead"!\<porod by H...... ~ ,SeMCeS. foe.. dallld Seplember 23; 19f7, Approvad FeIJrnary 26, 1998 and _ Maltb II, 1998 in the om.. of the -CltllooolsiJr....,fo,(\o_ County,PennlylmiaiD PIlIIiBopkilf."", 60 andllcing.....fullydoJcrilJed..~"wit BEG~ lhpOlntin PA ~ 74 (. tbirty. IIu<e foot,~rlIhl""W"~'al'_ property oomer of Lot No.3...r Lot No.4 .. .- oil the al>QveltRrooltil!fbilUnlldm.ioll Planof~Bend;salcIpOInt""'being ~and-~mfootin . South"""ly dinocIIon'm..lbe ~ of the -1liPMIf.WayLine oI'PA _ 74 and the '1laaIliiu ~1h1,,*Way Line' of Miller ~-'fnnilsalclpOIntofbeginnins .....aaid Lot__1$ "'19_ OI_"*-'~offootlnllld...llIIirty (430.00) foet to.. iJon pin aI'Lot No.8; _ aInns saIcI Lot No.1 alIlI Lot No.6 North 74 des- 40 miaUl<s 59 SOCotak w..,~' di_ of , two ~1~1M! &it III an iJon pi. aI Lot No.5; _ 1&1,' '1I!d, Lot Noll North 15 des- 19_bl..llas~ . dislance of fourh~lflirty(4JO.llIl)footfO.pnlntinPA ROOI< 74; thence _;. fA Il"I'I< 74 Sooth 74 degreet4O_19'__.di."""'of two hundied !ltl8.00) felt to ap<riJfl; 1aid poinl being the place of BEGINNING, SAID kit ""'tainlng 86.000;00 squm' foot IX 1.9743 _. 1VRIIlilRUNDI'R ANI> S~ to the Protective Covenan~ and Roatriction. set furlh in thal<ertain inatnunentlll<ilol<d in the om.. of tho RetllIlIer of IlmIl- in and for' Cumberland County,I'emilyt/ania inloliord _ $11411 page 201. ,_ Tat _ #I2-iJl18.241. TnLE ,TO SAI!l PREMISIls i. Yelled in Candace' L. WbItc br Iloed froml!alry I. Ramago, · --.J fIIan; and David A. Krolac, . -"""'OIdIliIeownct..anundividedone- IIIIf-...._in -. Diane E, Kru1ac Jo;m hlt htIabaI,d '" thiJ deed;, GranlOn, dated W1fm. _7tISJ2(JOO, in_ _22S,~lOO; BEING KNOWN, M: 1141 York Road, Mechanicaburg, PA i 7055, r'" 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. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2,9,2002 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 true. REAL ESTATE SALE 27 I Roger M. Morgentha1, Editor Writ No. 2002-1051 CMl Chase Manhattan Mortgage Corporation VS. Candace L. White. a/k/a Candace L. Hoch Atty.: Frank Federman ALL TIiAT CERTAIN tract of land situate in Monroe Township. Cumberland County. Pennsylvania. being identified as Lot No. 4 as shown on a plan of lots known as "Final Subdivision Plan for Breeches Bend" Prepared by Hoover Engi- neering Services. Inc. dated Sep- tember 23. 1997, Approved Febru- ary 26. 1998 and recorded March 11, 1998 in the Office of the Record- er of Deeds in and for Cumberland County, Pennsylvania in Plan Book 76 on page 60 and being more fully described as follows to wit: BEGINNING at a point in FA Route 74 (a thirty-three foot ultimate right-of-way), at a common property corner of Lot No.3 and Lot No.4 as shown on the abovf>: referenced Fi- nal Subdivision Plan of Breeches Bend, said point also being refer- enced and located approximately 585 feet in a Southeasterly direc- tion from the intersection of the Southern Right-of-Way Line of PA Route 74 and the Eastern Right- of-Way Line of Miller Boulevard; thence from said point of beginning along said Lot No.3 South 15 de- grees 19 minutes 0 I seconds West. a distance of four hundred thirty (430.00) feet to an iron pin at Lot No.8: thence along said Lot No. 8 and Lot No.6 North 74 degrees 40 minutes 59 seconds West, a dis- tance of two hundred (200.00) feet tn ",n irnn nin ~t T L'lt No. !')~ thp.n~~ SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 \.I!., '..,) ~ ~;ldh1./ NOlAR " LOIS E. SNYDER. Nol8ry NIle Cartlale Boro. CuT...1d Comly My CoI1lmI8Ilon EJcpir8I MIn:Il5. 2005 1"""'0' SIl'--'V1'.!.J V[, u~ -....-- ----- nal Subdivision Plan of Breeches Bend. said point also being refer- enced and located approximately 585 feet in a Southeasterly direc- tion from the intersection of the Southern Right-of-Way Line of PA Route 74 and the Eastern Right- of-Way Line of Miller Boulevard: thence from said point of beginning along; said Lot No. 3 South 15 de- grees 19 minutes 01 seconds West. a distance of four hundred thirty (430.0Q) feet to an iron pin at Lot No.8: thence along said Lot No. 8 and Lot No, 6 North 74 degrees 40 minutes 59 seconds West, a dis- tance of two hundred (200.00) feet to an iron pin at Lot No.5; thence along said Lot No. 5 North 15 de- grees 19 minutes 01 seconds East. a distance of four hundred thirty (430.0Q) feet to a point in PA Route 74; thence through PA Route 74 South 74 degrees 40 minutes 59 seconds East, a distance of two hundred (200.00) feet to a point. said point being the place of begin- ning. SAID lot containing 86.000.00 square feet or 1.9743 acres. FURTHER UNDER AND SUB- JECT to the Protective Covenants and Restrictions set forth in that certain instnunent recorded in the OffIce of the Recorder of Deeds in and for Cumberland County. Penn- sylvania in Record Book 584 at page 201- Tax Parcel # 12-0348-241- TITLE TO SAID PREMISES IS VESTED IN Candace L. White by Deed from Harry L Ramage. a mar- ried man. and David A Krulac. a married man. each the owner of an undivided one-half interest as ten- ants in common. Diane E. Krulac joins her husband on this deed. Grantors. dated 4/5/2000. re- corded 7/18/2000. in Record Book 225. Page 500. BEING KNOWN AS: 1141 YORK ROAD. MECHMICSBURG. PA 17055,