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Home My WebLink About06-4592IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/MI T MARGARETTEN & COMPANY, INC., Plaintiff, Vs. CRAIG A. WERT, Defendant. CIVIL DIVISION NO.: 0? - gc9k TYPE OF PLEADING C71 CIVIL ACTION-COMPLAINT IN EJECTMENT FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t TO DEFENDANT You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF C.,C,C. _. ATTRNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center 9th Floor Pittsburgh, PA 15222 (412)281-7650 AND THE DEFENDANT IS: 101 Water Street East,Pennsboro, PA 17025 ATTRNEY FOR PLAIN F CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS East Pennsboro Township (CITY, BORO, TOWNSHIP) (WARD) ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, S/B/M/T CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE NO.: CORPORATION, S/B/M/C MARGARET-TEN & COMPANY, INC., Plaintiff, VS. CRAIG A. WERT, Defendant. 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 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, S/BAV T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., CIVIL DIVISION NO.: 04- vs-q2 Plaintiff, VS. CRAIG A. WERT, Defendant. CIVIL ACTION - COMPLAINT IN EJECTMENT Chase Manhattan Mortgage Corporation, f/k/a Chemical Residential Mortgage Corporation, s/b/m/t Margaretten & Company, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Ejectment, as follows: 1. Plaintiff is a lending institution duly authorized to conduct business in the Commonwealth of Pennsylvania with a place of business located at 3415 Vision Drive, Columbus, OH 43219 2. The Defendant, Craig A. Wert is an individual whose last known address is 101 Water Street, East Pennsboro, PA 17025. 3. On or about June 7, 2006, the real property and improvements thereon commonly known as 101 Water Street, East Pennsboro, PA 17025 (hereinafter "Premises") were sold to Plaintiff pursuant to the Sheriffs Sale in Cumberland County. A true and correct copy of the legal description of said property is marked as Exhibit "A", attached hereto and made a part hereof. 4. At the time of the Sheriff Sale, Defendant was occupying the Premises. 5. Plaintiff, by virtue of said Sheriffs Sale, is the owner of the Premises and therefore right to immediate possession and title to the Premises is in Plaintiff and not in Defendant. 6. On July 17, 2006, counsel for Plaintiff sent written notice to the Defendant to vacate the Premises on or before August 2, 2006. A true and correct copy of said Notices are marked Exhibit "B", attached hereto and made a part hereof. 7. Defendant is unjustly and unlawfully occupying, using and enjoying the Premises without right and to the detriment of Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant for possession of the Premises known as 101 Water Street, East Pennsboro, PA 17025, together with such other relief as this Honorable Court may deem necessary. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire PA ID. #77991 Attorneys for Plaintiff 9' Floor, One Gateway Center Pittsburgh, PA 15222 (412) 281-7650 ALL that certain piece or parcel of land with improvements thereon erected in the Township of East Pennsboro, Cumberland County, Pennsylvania, being described in accordance with a survey made by Gerrit J. Betz, R. S. dated November 20, 1983, as follows, to wit: BEGINNING at a point of the Southwestern corner of Water Street and at a 16 foot wide alley; thence along said alley South 25 degrees East, 55.65 feet to a pin; thence along another 16 foot alley South 65 degrees West, 72.33 feet to a pin; thence along lands now or formerly of Kenneth E. Bitting North 24 degrees 46 minutes West, 101.44 feet to a hub; thence along said Water Street South 82 degrees 31 minutes East, 82.25 feet to a hub, the point and place of beginning. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record. BEING the same premises which Craig A. Wert and Julie R. Fisher, by Deed dated April 1, 1994 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 8, 1994, in Deed Book Volume 103, Page 778, granted and conveyed unto Craig A. Wert. GRENEN & BIRSIC, A p ATTORNEYS AT LAW ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PENNSYLVANIA 15222 TEL(412)281.7650 FAx (412) 281-7657 July 17, 2006 VIA CERTIFIED MAIL, RETURN RECEIPT REOUESTED/ FIRST CLASS MAIL, POSTAGE PREPAID Craig A. Wert or Current Occupant(s) 101 Water Street East Pennsboro, PA 17025 RE: NOTICE TO VACATE Dear Mr. Wert Or Current Occupant(s): As you may be aware, this firm represents Chase Home Finance, LLC in connection with the above-captioned matter. As you may also be aware, Chase purchased the property at a sale conducted by the Sheriff of Cumberland County on June 7, 2006. Accordingly, Chase is now the record title owner of the property. Our client has recently informed me that you remain on this property. The purpose of this letter is to notify you that you must vacate the premises on or before fifteen (15) days from the date of this letter. If you fail to vacate the premises on or before that date, Chase will institute formal legal action to have you removed from the premises. I trust that such will not be necessary. If you have any questions, please feel free to contact me. Very truly yours, Kristine M. Anthou KMA/cg US.PMAL SERVICE CERT1RC-- -r M/UL d WYZepaEO FOR DO-Eam mo Wrv6 "TON RIOVIOE N1, EniiwcE-FO A6 MM, DOER Iqf -' fbirN F,pe Grenen & Birsic, P.C. NAY sr? One Gateway en at, --f' me msb y n 307 0- -u? kt ?ei Lra? - r pr p lot o r 7 S- - c) o ',;O ro ram au 71, January 2M :/ v U.S. Postal Service,: CERTIFIED MAIL: RECEIPT (Domestic Mail Only; No insurance Coverage Provided) o[ OFFICIAL USI F Stw s O C Hed Fee O p Retum ReoelPl Fee Here (Endonemo?d HeWI eI O Reaukted oelhery Fee O" (Erdwcenwxd RegoMedj M rU Tole) Poo" 8 F:6 r o e' Q o VERIFICATION The undersigned, and duly authorized representative of Plaintiff, deposes and says subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities that the facts set forth in the foregoing Complaint in Ejectment are true and correct to the best of his information, knowledge and belief. A. Smith ASSISTANT SECRETARY jce, y t cn SHERIFF'S RETURN - REGULAR CASE NO: 2006-04592 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC ETAL VS WERT CRAIG A MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon WERT CRAIG A the DEFENDANT , at 1220:00 HOURS, on the 16th day of August , 2006 at 101 WATER STREET ENOLA, PA 17025 by handing to VERNA WERT, MOTHER ADULT IN CHARGE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.2 0? Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 41.20 ? 08/17/2006 9. yLL v L GRENEN & B I RS I C Sworn and Subscibed to By: 71 before me this day Deputy Sheri - of A.D. J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, SB/M/T CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE NO.: 06-4592 CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff, VS. CRAIG A. WERT, Defendant. TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Ejectment) FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, f/k/a Chemical Residential Mortgage Corporation, s/b/m/t Margaretten & Company, Inc., COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.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, SB/M/T CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE NO.: 06-4592 CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff, vs. CRAIG A. WERT, Defendant. PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT TO:PROTHONOTARY SIR/MADAM: Please enter a default judgment in the ejectment against Defendant, Craig A. Wert for possession of the premises known as 101 Water Street, East Pennsboro, PA 17025. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, squire Attorneys 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, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his 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. Sworn to and subscribed before me this_?day of SC) , 2006. Notary Public C0MM0NWEAL7H"0'F' PENNSYLVANIA NOWW saw patrida A. To%wmn i, Nofa (Y Public CRY of Pte, A080" County MY barar+i ton tyres June Z 2007 Member, Penny llama Association of Nowies IN THE COURT OF COON PLEAS OF CUMBERLAND COA, PENNSYLVANIA CHASE HOME FINANCE LLC, SIB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SIBNn MARGARETTEN & COMPANY, INC., CIVIL DIVISION NO.: 06-4592 Plaintiff, vs. CRAIG A. WERT, Defendant. TO: Craig A. Wert 101 Water Street East Pennsboro, PA 17025 DATE OF NOTICE: September 6, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 GRENEN & BIRSIC, P.C. By: Attorneys for PlairitIff' One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 FIRST CLASS MAIL, POSTAGE PREPAID to- -Z Z; 3? W VI Q IQ n c? G ? ?o 7i , co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, SB/M/T CIVIL DIVISION CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE NO.: 06-4592 CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff, VS. CRAIG A. WERT, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Craig A. Wert 101 Water Street East Pennsboro, PA 17025 ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on U? ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: in ejectment for possession of the premises known as 101 Water Street, East Pennsboro, PA 17025. L' .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff CIVIL DIVISION NO.: 06-4592 ISSUE NUMBER vs. CRAIG A. WERT, TYPE OF PLEADING Praecipe for Writ of Possession Defendants. CODE: FILED ON BEHALF OF PLAINTIFF: Chase Home Finance, LLC, s/b/m/t Chase Manhattan Mortgage Corporation, f/k/a Chemical Residential Mortgage Corporation, s/b/m/t Margaretten & Company, Inc., COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.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, CIVIL DIVISION SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL NO.: 06-4592 MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff VS. CRAIG A. WERT, Defendants. PRAECIPE FOR WRIT OF POSSESSION TO: PROTHONOTARY Kindly issue a Writ of Possession in the above-captioned matter for the premises known as 101 Water Street located in the Township of East Pennsboro, County of Cumberland, Pennsylvania and more particularly described in Plaintiff s Complaint in Ejectment filed in the instant proceeding. GRENEN & BIRSIC, P.C. BY: t? C c. cL_ Kristine M. Anthou, Esq ' e Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 V c J tO. V r-J 4._-? { ?_ All A' < 101 `2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., VS. CRAIG A. WERT No. 06-4592 Civil Term Costs Attorney's $ $120.70 Plaintiff's $ Prothonotary $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) CHASE HOME FINANCE, LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, S/B/M/T MARGARETTEN & COMPANY, INC., being: (Premises as follows): 101 WATER STREET LOCATED IN THE TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, PENNSYLVANIA (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Curti . Long, notary Common Pleas Court of Cu berland County, PA Date OCTOBER 5, 2006 (Seal) 2of2 No 06-4592 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC. VS. CRAIG A. WERT WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 120.70 Plff (s) $ Prothy $ 1.00 Sheriff $ Plaintiff (s) attorney name and address: KRISTINE M. ANTHOU, ESQUIRE GRENEN & BIRSIC, P.C. ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 412-281-7650 I.D.# 77991 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of . I caused the within named to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE, LLC, CIVIL DIVISION SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL NO.: 06-4592 MORTGAGE CORPORATION, S/B/M/T MARGARETTEN & COMPANY, INC., Plaintiff VS. CRAIG A. WERT, Defendant. MOTION FOR SERVICE OF WRIT OF POSSESSION PURSUANT TO SPECIAL ORDER OF COURT AND NOW, comes the Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, f/k/a Chemical Residential Mortgage Corporation, s/b/m/t Margaretten & Company, Inc., by and through its attorneys, GRENEN & BIRSIC, P.C., and files the within Motion for Service of Writ of Possession Pursuant to Special Order of Court under Pennsylvania Rule of Civil Procedure 430 as follows: 1. On or about October 15, 2006, Plaintiff filed a Writ of Possession against the Defendant, Craig A. Wert, at the above-captioned number and term. 2. On or about October 15, 2006, Plaintiff delivered to the Sheriff of Cumberland County a copy of the Writ of Possession filed by Plaintiff at the above-captioned number and term along with direction cards requesting that each Defendant be served a copy of the Writ of Possession at their last known addresses being 101 Water Street, Summerdale, PA 17093. 3. On or about January 8, 2006, Plaintiff received Notices from the Cumberland County Sheriffs Office indicating that Twenty Two attempts were made to serve the Defendant, Craig A. Wert with a copy of the Writ of Possession at his last known address being 101 Water Street, Summerdale, PA 17093 but Defendant was avoiding service. The Sheriff was unable to release a copy of the Sheriffs Return, due to office policy. 4. An Affidavit of the Plaintiff stating the nature and extent of the investigation which has been made to determine the whereabouts of Defendant, Craig A. Wert, and the reasons why service of the Writ of Possession cannot be made, is marked Exhibit "A", attached hereto and made a part hereof. WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the Sheriff of Cumberland County to serve Defendant, Craig A. Wert with the Writ of Possession by posting a copy of the Complaint on the property at 101 Water Street, Summerdale, PA 17093 and permit the Plaintiff to serve the Defendant by mailing a true and correct copy of the Writ of Possession by certified mail, return receipt requested and by First Class U.S. Mail, postage pre-paid to 101 Water Street, Summerdale, PA 17093. Service of the Writ shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. GRENEN & BIRSIC, P.C. ??.. BY: L,' Kristine, M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE, LLC, CIVIL DIVISION SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL NO.: 06-4592 MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff VS. CRAIG A. WERT, Defendant. AFFIDAVIT PURSUANT TO PA. R.C.P. 430 COUNTY OF ALLEGHENY ) ) SS COMMONWEALTH OF PENNSYLVANIA ) Before me, a notary public, in and for the foregoing county and commonwealth, personally appeared Kristine M. Anthou, Esquire, of GRENEN & BIRSIC, P.C. attorneys for Plaintiff and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of the Defendant, Craig A. Wert, named in the above-captioned matter: 1. On February 13, 2007, Plaintiff mailed to the United States Postmaster at Summerdale, PA 17093 a request to be furnished with a forwarding address of Defendant, Craig A. Wert. 2. On February 15, 2007, Plaintiff received a response from the United States Postmaster indicating that there is no change of address order on file for Defendant Craig A. Wert. A true and correct copy of that response is marked as Exhibit "1", attached hereto and made a part hereof. Examinations were made of the Summerdale Area Telephone Directory; said examination failed to yield any useful information regarding the whereabouts of Defendant, Craig A. Wert. 4. Examinations were made of the Cumberland County Voter Registration Records; said examination failed to yield any useful information regarding the whereabouts of Defendant, Craig A. Wert. 5. A computer records search of a nationwide database indicates that the Defendant, Craig A. Wert resides at 101 Water Street, Summerdale, PA 17093. A true and correct copy of said search is marked as Exhibit "2", attached hereto and made a part hereof Finally, affiant deposes and says that after the foregoing investigation, the Plaintiff believes and avers that the Defendant, Craig A. Wert resides at 101 Water Street, Summerdale, PA 17093. GRENEN & BIRSIC, P.C. BY: Lk Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Sworn to an subscribed before me this alp day of , 2007. tart' Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Palano, Notary Public City Of Pittsburgh, Allegh&W C=* My Conxnission Expires Jan. 6, 2006 Member, Pennsylvania Association Of Notaries EXHIBIT "1" .Postmaster Summerdale, PA 17093 City, State, ZIP Code Date February 13, 2007 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a box holder) for the following: Name: Craig A. Wert Address: 101 Water Street NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 165.6(d)(8)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney for Plaintiff 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): 3. The names of all known parties to the litigation: Chase Vs. Wert 4. The court in which the case has been or will be heard: Court of Common Pleas 5. The docket or other identifying number if one has been issued:064592 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Signature Carolyn Grimes Printed Name Grenen & Birsic, P.C., One Gateway Center, Nine West, Pittsburgh, PA 15222 (412) 281-7650 FOR POST OFFICE USE ONLY No change of address order on file. - Not known at address given. Moved, left no forwarding address _ No such address. POSTMARK NEW ADDRESS OR BOXHOLDER'S NAME and STREET ADDRESS r2 EXHIBIT ",2`9 LexisNexis(g): SmartLinxTM Pon Report Results Pagel of 8 I . 40 Source: Public Records > SmartLinx(TM) > SmartLinx(TM) - Person Summary Reports Terms: last-name(Wert) , first-name(Craig) , street(101 Water Street), city(East Ponnsboro) , state(PA) , zip(17025) (Edit ,Search) Permissible Uses: DPPA_- 1. _L0gatio0 ELBA - 2. Legal Compliance Click_to visualize .this, report Subject Summary I Others Using SSN I Address Summary (6) 1 Voter Registrations Licenses Personal Property I Real Property (2) I Bankruptcies-(3) Judg,ments_& Liens.(13) Relatives_.(1) I Associ.ated__Entities (_1.). I Neighbors (1) Sources (2ti,} FOR INFORMATIONAL PURPOSES ONLY Copyright 2005 LexisNexis, a division of Reed Elsevier Inc. All Rights Reserved Full Name Address County Phone 101 WATER ST # 107 WERT, CRAIG A SUMMERDALE, PA 17093 CUMBERLAND (000) 000-0( COUNTY: CUMBERLAND ADDITIONAL PERSONAL INFORMATION SSN DOB 206-38-XXXX 09/1959 (PENNSYLVANIA: 1964-1966) (Age: 47) Subject Summary Name Variations 1: WERT, CRAIG A 2: WERT, CRAIG GENDER Back Name Variations (2) I SSNs Summary Aj) I Dc View Name Variation SSNs Summary View SSN No. SSN State Iss. Date Iss. Warnings 1: 206-38-XXXX PENNSYLVANIA 1964-1966 DOBs View DOB 1: 09/1959 Address Summary Back Address Summary - 6 records found for subject: View Address # Address Actions 101 WATER ST # 107 Get Report 1: SUMMERDALE, PA 17093 COUNTY: CUMBERLAND View Details PO BOX 107 Get Report https://www.lexis.comlresearchlretrieve? m=2b58ce837bfleOd001ba2742e676342e&_fintstr=FUL... 1/1112007 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion for Service of the Complaint in Ejectment Pursuant to Special Order of Court and Order of Court cf? was mailed to the following on this day of 2007, by first class, U.S. Mail, postage pre-paid: Craig A. Wert 101 Water Street Summerdale, PA 17093 GRENEN & BIRSIC, P.C. . BY: Kristine -M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 CO -.., r`J ? f r i l? FEB 26 2007 01 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE, LLC, CIVIL DIVISION SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL NO.: 06-4592 MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff VS. CRAIG A. WERT, Defendant. ORDER OF COURT AND NOW, to wit, this ?? t h day of , 2007, upon consideration of the within Motion for Service of the Writ of Possession Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Sheriff of County is hereby directed to serve Defendant, Craig A. Wert with a true and correct copy of Plaintiffs Complaint in Ejectment by posting the property at 101 Water Street, Summerdale, PA 17093 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First Class U.S. Mail, postage pre-paid at 101 Water Street, Summerdale, PA 17093. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: 'dI`' VA1, -,N al?ri 1 .Z Vd LZ 83.E LODZ W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., Plaintiff VS. CRAIG A. WERT, Defendants. CIVIL DIVISION NO.: 06-4592 PRAECIPE TO REISSUE WRIT OF POSSESSION TO: PROTHONOTARY SH; /MADAM: Kindly reissue the Writ of Possession with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY- Kristine M. Anthou, Esquire Attorney for Plaintiff cw. `; -n K ?t'ssu ?. ]oft WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC., VS. No. 06-4592 Civil Term_ CRAIG A. WERT Costs Attorney's $ $120.70 Plaintiff's $ Prothonotary $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) CHASE HOME FINANCE, LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, S/B/M/T MARGARETTEN & COMPANY, INC., being: (Premises as follows): 101 WATER STREET LOCATED IN THE TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND, PENNSYLVANIA (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. - ? I & Curtis . Long, Pro otary, Common Plea ourt o Cum rland County, PA Date OCTOBER 5, 2006 (Seal) 2of2 No 06-4592 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE, LLC, SIB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, F/K/A CHEMICAL RESIDENTIAL MORTGAGE CORPORATION, SB/M/T MARGARETTEN & COMPANY, INC. vs. CRAIG A. WERT 'WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 120.70 Plff (s) $ Prothy $ 1.00 Sheriff $ Plaintiff (s) attorney name and address: KRISTINE M. ANTHOU, ESQUIRE GRENEN & BIRSIC, P.C. 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