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HomeMy WebLinkAbout02-2905FEDERMAN 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 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 V. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 02 -.NOS' (10 k'_O ? CUMBERLAND COUNTY LINDA B. NELSON WILLIAM H. NELSON, HI 16 KEVIN ROAD MECHANICSBURG, PA 17055 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, PA 17013 (717) 249-3166 Loan #: 1949962997 RMS IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: LINDA B. NELSON WILLIAM H. NELSON, III 16 KEVIN ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/25/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MARYLAND FINANCIAL RESOURCES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1580, Page 161. By Assignment of Mortgage recorded 10/30/00 the mortgage was assigned to FEDERAL NATIONAL MORTGAGE ASSOCIATION which Assignment is recorded in Assignment of Mortgage Book No. 658, Page 796. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 2/1/02 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 $104,304.36 Interest 3,366.80 1/1/02 through 6/1/02 (Per Diem $22.15) Attorney's Fees 1,250.00 Cumulative Late Charges 154.76 10/25/99 to 6/1/02 Cost of Suit and Title Search 550.00 Subtotal $109,625.92 Escrow Credit 815.89 Deficit 0.00 Subtotal 815.89 TOTAL $108,810.03 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. 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. § 1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $108,810.03, together with interest from 6/1/02 at the rate of $22.15 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. By. F DERMAN AND PH LAN LLP 1 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL THAT CERTAIN tract or parcel of land with improvements thereon erected, situate in the TOWNSI(IP OF uatippi N County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows, to wit. BEGINNING at a point on the Western side of Kevin Road which point is at the division line of Lots Nos. 67 and 68 on the hereinafter mentioned plan of lots; thence South thirty-nine (39) degrees eight (08) minutes West along the Western Jule of Kevin Road a distance of one hundred sixty and fifty-one one-hundredths (160 51)feet to a point, thence in an arc curving to the right with a radius of twenty (20) feet, the arc distance of thirty-rime and three one-hundredths (39 03) feet to a point on the Northern line of Edward Dnve; thence North twenty-rime (29) degrees four (04) mmutes West on the aforementioned Edward Dnve, a distance of one hundred five and rune one-hundredths (105 09) feet to a point at the division line of lots Nos 69 and 161 on the said plan of lots, thence North thuty-nine (39) degrees eight (08) minutes east along said division line and beyond a distance of one hundred forty and fifteen one-hundredths (140.15) feet to a point at the division line of Lots Nos 67 and 68, thence South fifty (50) degrees fifty-rwo (52) minutes Fast along said division line one hundred twenty-five (125) feet to a point the place of BEGINNING. BEING known as 16 Kevin Road IT BEING Lots Nos 68 and 69 on Plan of Lots entitled "Noll Acres", which plan is recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book 10, page 17. BEING the same pretenses which William 11 Nelson, Jr, -widower by Deed dated the 27th day of January, 1989, and recorded at Cumberland County in the Office of the Recorder of Deeds, m and for the County of Cumberland, on the 27th day of January, 1989, in Record Book U-33, Page 29, granted and conveyed unto William H Nelson, III and Linda b. Nelson, his wife UNDER AND SUBJECT TO restrictions and conditions as now appear of record. TAX PARCEL 10-19.1604-094 PREMISES BEING: 16 KEVIN ROAD VERIFICATION RYAN L. REITMAJER hereby states that she is ASSISTANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action are 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 unworn falsification to authorities. /O o2 DATE: 44 ? o ? C O C:D O N C_ J G Q 3 _ i (70 SHERIFF'S RETURN - REGULAR CASE NO: 2002-02905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS NELSON LINDA B ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon II the DEFENDANT , at 1439:00 HOURS, on the 19th day of June 2002 at 2110 WARREN WAY MECHANICSBURG, PA 17050 by handing to LINDA NELSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. 16 KEVIN ROAD IS VACANT. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 So Answers: R. Thomas Kline 06/20/2002 FEDERMAN & PHELAN Sworn and Subscribed to before me this ;Lyt day of n tProthonotary By: Deputy Sher SHERIFF'S RETURN - REGULAR CASE NO: 2002-02905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS NELSON LINDA B ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon the DEFENDANT at 1439:00 HOURS, on the 19th day of June 2002 at 2110 WARREN WAY MECHANICSBURG, PA 17050 by handing to LINDA NELSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents Additional Comments thereof. 16 Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this .zy'? day of ?br A. D. i n An_? }lota rothonotary who being duly sworn according to law, So Answers: R. Thomas Kline 06/20/2002 FEDERMAN & PHELAN By: Deputy Sheriff•`r FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for 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 V. Plaintiff, LINDA B. NELSON WILLIAM H. NELSON, III CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-2905 CIVIL 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 LINDA B. NELSON and WILLIAM H. NELSON, III, 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 6/02/02 to 7/23/02 TOTAL $108,810.03 $ 1,151.80 $109,961.83 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. I NK FE Ettorney for laintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ac.)o -ate 14 PROPROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 15)569-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s) TO: LINDA B. NELSON 2110 WARREN WAY MECHANICSBURG PA 17050 DATE OF NOTICE: JULY 10. 2002 `?11FCOP? THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION 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. 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION CUMBERLAND COUNTY : NO. 02-2905 CIVIL Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. LINDA B. NELSON WILLIAM H. NELSON, III Defendant TO: WILLIAM H. NELSON, III 2110 WARREN WAY MECHANICSBURG PA 17050 DATE OF NOTICE: JULY 10. 2002 `CIF c0Ay THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION 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. 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 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-2905 CIVIL 7? - - Fr nk Federman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2002-02905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS NELSON LINDA B ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NELSON LINDA B the DEFENDANT , at 1439:00 HOURS, on the 19th day of June , 2002 at 2110 WARREN WAY MECHANICSBURG, PA 17050 by handing to LINDA NELSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments 16 IS VACANT. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 06/20/2002 FEDERMAN & PHELAN By: Deputy Sheriff Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-02905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS NELSON LINDA B ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NELSON WILLIAM H III DEFENDANT the , at 1439:00 HOURS, on the 19th day of June , 2002 at 2110 WARREN WAY MECHANICSBURG, PA 17050 by handing to LINDA NELSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. 16 KEVIN ROAD IS VACANT. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 06/20/2002 FEDERMAN & PHELAN Sworn-and Subscribed to-before By- me -this - day of - --- Deputy Sheriff A.D. Prothonotary n w ? c? c, •..t G 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 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE V. Plaintiff, LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-2905 CIVIL 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 of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant LINDA B. NELSON is over 18 years of age and resides at, 2110 WARREN WAY, MECHANICSBURG, PA 17050. (c) that defendant WILLIAM H. NELSON, III is over 18 years of age, and resides at, 2110 WARREN WAY, MECHANICSBURG, PA 17050. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FE ERMAN, ESQUIRE Attorney for Plaintiff ??. ? ? 1 1': Il li r'? y ! ?'7 _y ,? -` PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. No. 02-2905 CIVIL LINDA B. NELSON WILLIAM H. NELSON, HI Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $109,961.83 Interest from 7/24/02 to 12/04/02 $ 2,422.72 and Costs (per diem -$18.08) TOTAL $112,384.55 RANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. DESCRIPTION ALL THAT CERTAIN tract or parcel of land with improvements thereon erected, situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Western side of Kevin Road which point is at the division line of Lots Nos. 67 and 68 on the hereinafter mentioned plan of lots; thence South 39 degrees 08 minutes West along the Western line of Kevin Road a distance of one hundred sixty and fifty-one hundredths (160.51) to point; thence in an arc curving to the right with a radius of twenty (20) feet the arc distance of thirty- nine and three hundredths (39.03) feet to a point on the Northern line of Edward Drive; thence North 29 degrees 04 minutes West on the aforementioned Edward Drive a distance of one hundred five and nine hundredths (105.09) feet to a point at the division line of Lots Nos. 69 and 161 on the said plan of lots; thence North 39 degrees 08 minutes East along said division line and beyond a distance of one hundred forty and fifteen hundredths-t140.15) feet to a point at the division line of Lots Nos. 67 and 68; thence South 50 degrees 52 minutes East along said division line one hundred and twenty-five (125) feet to a point in the place of beginning. HAVING thereon erected a dwelling house known and numbered as 16 Kevin Road. IT BEING Lots Nos. 68 and 69 on Plan of Lots entitled "Noll Acres", which plan is recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book 10, page 17. TAX PARCEL ##19-1604-094 TLE TO SAID PREMISES IS VESTED IN William H. Nelson, III and Linda B. Nelson, His Wife by Deed from William H. Nelson, Jr., Widower dated 1/27/1989 and recorded 1/27/1989 in Deed Book U, Volume 33, Page 29. w 0 a a z O O U w O a O O U x F z d z z a H z O U ?a C4 U W d a O d H C x W d U z O 0 U O .a w z x d a z O .a W z A z a z 0 WU W w O F x w a U d L VI 0 d L w d 0 5 a -6 w 0 0 r. d' a C7 a O U U d' z 3 N 45 d E a. ?n a • V a , •= - : z 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 CHASE MANHATTAN MORTGAGE CORPORATION V. Plaintiff, LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s). NO. 02-2905 CIVIL 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 unswom falsification to authorities. ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION 1 FRANK F DERMAN, ESQUIRE Attorney for Plaintiff n r. :1; T r'i3' ' ?, f!.. '1 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, v. LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-2905 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) 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,16 KEVIN ROAD MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name LINDA B. NELSON WILLIAM H. NELSON, III Last Known Address (if address cannot be reasonably ascertained, please indicate) 2110 WARREN WAY MECHANICSBURG, PA 17050 2110 WARREN WAY MECHANICSBURG, PA 17050 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) THE CHASE MANHATTAN BANK AS 1301 OFFICE CENTER DRIVE, #200 INDENTURE TRUSTEE C/O RESIDENTAL FORT WASHINGTON, PA 19034-3228 FUNDING CORPORATION 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 16 KEVIN ROAD MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 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 of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. July 17. 2002 DATE RANK FED RMAN, ESQUIRE Attorney for Plaintiff C> _ (-_ ?.- ;'J T, «" __ `' (/? I- f ?•? __,_ ,._ /_ .. 1 ?` ? _` CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. LINDA B. NELSON WILLIAM H. NELSON, HI Defendant(s). CUMBERLAND COUNTY No. 02-2905 CIVIL July 17, 2002 TO: LINDA B. NELSON WILLIAM H. NELSON, III 2110 WARREN WAY MECHANICSBURG, PA 17050 "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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. "" Your house (real estate) at, 16 KEVIN ROAD, MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriffs Sale on 12/04/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $109,961.83 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 MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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 if the 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 or parcel of land with improvements thereon erected, situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Western side of Kevin Road which point is at the division line of Lots Nos. 67 and 68 on the hereinafter mentioned plan of lots; thence South 39 degrees 08 minutes West along the Western line of Kevin Road a distance of one hundred sixty and fifty-one hundredths (160.51) to point; thence in an arc curving to the right with a radius of twenty (20) feet the arc distance of thirty- nine and three hundredths (39.03) feet to a point on the Northern line of Edward Drive; thence North 29 degrees 04 minutes West on the aforementioned Edward Drive a distance of one hundred five and nine hundredths (105.09) feet to a point at the division line of Lots Nos. 69 and 161 on the said plan of lots; thence North 39 degrees 08 minutes East along said division line and beyond a distance of one hundred forty and fifteen hundredthstt,10.15) feet to a point at the division line of Lots Nos. 67 and 68; thence South 50 degrees 52 minutes East along said division line one hundred and twenty-five (125) feet to a point in the place of beginning. HAVING thereon erected a dwelling house known and numbered as 16 Kevin Road. IT BEING Lots Nos. 68 and 69 on Plan of Lots entitled "Noll Acres", which plan is recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book 10, page 17. TAX PARCEL k19-1604-094 TITLE TO SAID PREMISES IS VESTED IN William H. Nelson, III and Linda B. Nelson, His Wife by Deed from William H. Nelson, Jr., Widower dated 1/27/1989 and recorded 1/27/1989 in Deed Book U, Volume 33, Page 29. CHASE MANHATTAN MORTGAGE CUMBERLAND COUNTY CORPORATION V. Plaintiff, No. 02-2905 CIVIL LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s). July 17, 2002 TO: LINDA B. NELSON WILLIAM H. NELSON, III 2110 WARREN WAY MECHANICSBURG, PA 17050 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY * * Your house (real estate) at. 16 KEVIN ROAD, MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriffs Sale on 12/04/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $109,961.83 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 MAY BE 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: 1111L563-7000. 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 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 if the 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 or parcel of land with improvements thereon erected, situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows, to wit_ BEGINNING at a point on the Western side of Kevin Road which point is at the division line of Lots Nos. 67 and 68 on the hereinafter mentioned plan of lots; thence South 39 degrees 08 minutes West along the Western line of Kevin Road a distance of one hundred sixty and fifty-one hundredths (160.51) to point; thence in an arc curving to the right with a radius of twenty (20) feet the arc distance of thirty- nine and three hundredths (39.03) feet to a point on the Northern line of Edward Drive; thence North 29 degrees 04 minutes West on the aforementioned Edward Drive a distance of one hundred five and nine hundredths (105.09) feet to a point at the division line of Lots Nos. 69 and 161 on the said plan of lots; thence North 39 degrees 08 minutes East along said division line and beyond a distance of one hundred forty and fifteen hundredtliFtI40.15) feet to a point at the division line of Lots Nos. 67 and 68; thence South 50 degrees 52 minutes East along said division line one hundred and twenty-five (125) feet to a point in the place of beginning. HAVING thereon erected a dwelling house known and numbered as 16 Kevin Road. IT BEING Lots Nos. 68 and 69 on Plan of Lots entitled "Noll Acres", which plan is recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book 10, page 17. TAX PARCEL #19-1604-094 ) ALE TO SAID PREMISES IS VESTED IN William H. Nelson, III and Linda B. Nelson, His Wife by Deed from William H. Nelson, Jr., Widower dated 1/27/1989 and recorded 1/27/1989 in Deed Book U, Volume 33, Page 29. FEDERMAN AND PHELAN, L.L.P. BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400, One Penn Center at Suburban Station 1617 John F. Kennedy Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff Vs. LINDA B. NELSON WILLIAM H. NELSON, III Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY : No. 02-2905 CIVIL FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief that the information in paragraph #3 of the Complaint in Mortgage Foreclosure is: On 10/25/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MARYLAND FINANCIAL RESOURCES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1580, Page 161. By Assignment of Mortgage recorded 11/03/99 the mortgage was assigned to FLAGSTAR BANK, FSB which Assignment is recorded in Assignment of Miscellaneous Book No. 629, page 259. By Assignment of Mortgage recorded 10/30/00 the mortgage was assigned to FEDERAL NATIONAL MORTGAGE ASSOCIATION which Assignment is recorded in Assignment of Mortgage Book No. 658, Page 796. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. Kindly change the information on the docket. n Date: August 21, 2002 Frank Federman, Esquire Attorney for Plaintiff C:) o C/), e-; ? -'f C) po rn : c AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION DEFENDANT(S) LINDA B. NELSON WILLIAM H. NELSON, III SERVE L AT 2110 WARREN WAY MECHANICSBURG, PA 17050 CUMBERLAND COUNTY KMD No. 02-2905 CIVIL ACCT. #1949962997 Type of Action - Notice of Sheriff's Sale Sale Date: 12/04/02 11 1 SERVED Served and made known to t e Y\ J:A `hkj&&?J••Defendant, on the ?4 day of? 2002 at? , o'clockR.m., at 0 ` Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: // Descr' tion: A'gI4m;)? Heightf55 Weight I&C Race SP - Other I> Law &y ,? competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subsc ibed before me this _-l07--day of,? 20 ?. Not }GGi PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED Cn the day of 200. at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1st Attempt: Time: Vacant 2"d Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF CHASE MANHATTAN MORTGAGE CORPORATION DEFENDANT(S) LINDA B. NELSON WILLIAM H. NELSON, III SERVE LINDA B. NELSON AT 2110 WARREN WAY MECHANICSBURG, PA 17050 CUMBERLAND COUNTY KMD No. 02-2905 CIVIL, ACCT. #1949962997 Type of Action - Notice of Sheriffs Sale Sale Date: 12/04/02 SERVED Served and made known to ?t C` ?k Defendant, on the It q 4K- day of _ .Mr, , 200 L) at as , o'clockc t".m., at Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is j _ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: on: OAgge * &e CS a'true and correct copy ofrth the address indicated above. r. Height Weight Race Sex Other a competent adult, being duly swom according to law, depose and state that I personally handed Sale in the manner as set forth herein, issued in the captioned case on the date and at Notarial Seal Cadiwe 80,n Linda J. Jumper, Notary Pic Sworn to and subscribed ?mberiand befo me this day Anwar ?E ?' d 2( of ?20 Assac?afi Of r* Not BY PLEASE. ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. On the day of Moved NOT SERVED 200, at o'clock _.m., Defendant NOT FOUND because: Unknown No Answer 1St Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200 Notary: By: Vacant 2nd Attempt: Time: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 0 c C:) CIO cn ?=- r7l ??= T =f j ? C rv ,'T rn A - C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: CHASE MANHATTAN MORTGAGE CORPORATION CIVIL ACTION vs. LINDA B. NELSON WILLIAM H. NELSON, III CIVIL DIVISION NO. 02-2905 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CHASE MANHATTAN MORTGAGE CORPORATION hereby verify that on 7/23/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 7123/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: November 12.2002 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff u, A W N p W J Q? V, A W N lz- C? R. c ;Z a z m 0 z ? o O rt ..Z 0 A w w = y g gn ? ?' y-i .. WJ Y ? R .°o g2 0? ? X a m w ? n Q a o 25 ? °N.c c u 6 ?. 5 k D ? ? 6 O Y W w "? r" C7 d : d CM O O a ai0 d It ria ? W > z o m a ?? !Tl a a? z x ro a y R G 0 to m a z O z ? z o ° 0 aW 0? _ '° x Cl _ c o > o a c >m d t7 o >? .a? n n b n ? o ? ? ? y p 7y C o m z n H zu, ? ? ? m ?C y W o A? ? a a m x WO 00d a o o o ° o z o r C N m °` m z d cvn H O r m ? n a H z a o _ _ J W rZ ? car --- _ 7160 3901 9844 9260 4575 TO: WILLIAM H. NELSON, III 2110 WARREN WAY MECHANICSBURG, PA 17050 SENDER: KMD-SALES REFERENCE: #1949962997 RETURN Postage "j RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service PO RK OR I Receipt for N O Certified Mail 6?147'J No Insurance Coverage Provided ' Do Not Use for International Mail 7160 3901 9844 9260 4582 TO: LINDA B. NELSON 2110 WARREN WAY MECHANICSBURG, PA 17050 SENDER: KMD_SALES REFERENCE: 1949962997 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail 74 81A1 K OR DATIP R o a 631 v?', ?% ii? i;_ C; ? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Natl Mtg Assoc is the grantee the same having been sold to said grantee on the 4th day of Dec A.D., 2002, under and by virtue of a writ Execution issued on the 25th day of July, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Tenn, 2002 Number 2905, at the suit of Chase Manhattan Mtg Corpe against Linda B Nelson & William H III is duly recorded in Sheriff's Deed Book No. 255, Page 317. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a 3,tk day of A9',P,c , A.D. 2002 Recorder of Deeds geeaMer of Deed, d?nEMrW diIIM, M My CadNWW Exwean FAR MI f at,M?? i00L Chase Manhattan Mortgage Corporation In The Court of Common Pleas of VS Cumberland County, Pennsylvania Linda B. Nelson and Writ No. 2002-2905 Civil Tenn William H. Nelson, III Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2002 at 7:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Linda B. Nelson, by making known unto William Nelson, II, husband of defendant, at 2110 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2002 at 7:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: William H. Nelson, III, by making known unto William Nelson 111, at 2110 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 11:04 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Linda B. Nelson and William H. Nelson, III located at 2110 Warren Way, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Linda B. Nelson, by regular mail to her last known address of 2110 Warren Way, Mechanicsburg, PA 17050. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: William H. Nelson, III, by regular mail to his last known address of 2110 Warren Way, Mechanicsburg, PA 17050. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Federal National Mortgage Association. It being the highest bid and best price received for the same, Federal National Mortgage Association of 1900 Market Street, Suite 800, Philadelphia, PA 19103, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $881.32, it being costs. Sheriffs Costs: Docketing 30.00 Poundage 17.28 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 16.56 Certified Mail 1.53 Levy 15.00 Surcharge 30.00 Law Journal 358.40 Patriot News 251.35 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $881.32 Sworn and Subscribed to Before Me This Day of 2003. A.D. r thonotary So Answers: O R. ?J R. Thomas Kline, Sheriff BY UC Real Estate D uty CIA? 0ti 3° -o 5 1 i3,?3z THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphinj ss Frank J. E ley p being duly sworn according to law, deposes and says. That he is the Controller of The Patriot News Co., Commonwealth of Pennsylvania, with its a corporation organized and existing under the law City of Harrisburg Count Principal office and place of business at 812 to 818 Market Stree t, in the Linda pa Y of Dauphin, State of Pennsylvania, owner and publisher of jFhe Patriot-News s of the triot-N ws newspapers of general circulation City, County and State aforesaid; that The Patriot-News and The Sun -81- S and The printed and published at 812 to 818 Market Street, in the and September 18th, 1949, respectively, and all have been continuous) Sunday Patriot-News were established March 4th, 1854, That the printed notice or Y published ever since; their regular tail publication which is securely attached hereto is exactly as printed and 5th day(s) y and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of November 2002. That neither he nor said Company published in notice ti advertising, and that all of the allegations of this statement as to stet in the subjec;t)mattOertobsaidndi he publication are true; and the time, place and character of pr nted That he has personal knowledge of the facts aforesaid and is dui statement on behalf of The Patriot-News Co. adopted severally if the stockholders and board tby virtue and ors of the said y authorized and empowered to verify this the office for the Recording of Deeds in and for said County of ai rsCo to a resolution unanimous) Volume 14, Page 317. Company and subsequently y passed and Dauphin in Miscellaneous Book duly recorded in PUBLICATION COPY , S A L E #9--- ............................................. REAL ESTATE SALE No. 9 Writ No. 2002.2905 Civil Term Chase Manhattan Mortgage Corporation Linda B. Nelson and William H. Nelson, 111 DESCRIAtt Frank Federman ALL THAT CERTAIN tract or parcel of land with improvements thereon erected, situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Western side of {evin Road which point is at the division line of .ots Nos. 67 and 68 on the hereinafter mentioned tan of lots; thence South 39 degrees 08 minutes Vest along the Western line of Kevin oad a distance of one hundred sixty and five.one mdredths (160.51) to point; thence i Notarial Seal is 14th day f No Terry L Russell, Notary p er 2002 A. D. City OF Harrisburg, ry ublic / Dauphin County MY Commission Expires June 6, 2006 Member.PennsytvaniaAssociation ofNotaties N ARY PUBLIC My commission expires June 6, 2006 CUM13ERLANp COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertisin Costs To THE PATRIOT-NEWS Cp Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same $ 249.60 Total Notary Fee(s) $ 1.75 $ nanarc The Patriot News n Publisher's Receipt for Advertisin g Co ;ulation, hereb Peceipher of The Patriot-News and The Sunda Patsyiot News 251.35 ?n dui y acknowledge recei t of the aforesaid notice and duly paid. publication costs and cer , same general tifies newspapers hahave By........ curving to the right with a radius of twenty (20) feet the arc distance of thirty-nine and three hundredths (39.03) feet to a point on the Northern lice of Edward Drive; 8wnce Nm* 29 diem 04 on the f,=xWiOnW Edward MWft West *JR&W five and d Of OW SW AiL- h i dredlh4 (105.09) f0A a a point at the line of Lots Nos. 69 and 161 on the said Ply t Ids; thence North 39 degrees 08 minutes &st along said division line and beyond a distance of one hundred forty and fifteen hundredths (140.15) feet to a point at the division line of Lots Nos. 67 and 68; thence South 50 degrees 52 minutes East along said division line one hundred and twenty- five (125) feet to a point in the place of beginning. HAVING thereon erected a dwelling house known and numbered as 16 Kevin Road. IT BEING Lots Nos. 68 and 69 on Plan of Lots entitled ,Noll Acres", which plan is recorded in the office of the Recorder of Deeds in and for the County of Cumberland in Plan Book 10, page 17. TAX PARCEL #19-1604-094• TITLE TG SAID PREMISES IS VESTED IN William H. Nelson, III and Linda B. Nelson, His wife by Deed from William H. Nelson, Jr., Widower dated 112711989 and recorded 112711989 in Deed Book U, volume 33, Page 29. PROOF OF PUBLICATION (Under AN No .U LAW OU OAL ' 587, approved May 16, 1929 p L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND:: ss. Roger M. Mor and State aforesaid genthal, Esquire, Editor of the Cumberland ? being Law duly swo wnberland urnal, a legal peri odical rn, according to law' deposes and La Lasays w Jthat th C the County aforesaid, was established Janu published in the B periodical for the ognat of Carlisle in the that the Oberland issued weekl publication of? le 1952, and desi Count State yin the said gal notices grated by the local courts ash Oa ficiial le al exactly the s County, and that the ' and has, since J Jou g ame as was the re printedu' 2, 952, been re rnal on the followin printed In notice or publication attached herego issly viz: g dates, gular editions and issues of the said Cumberland Law OCTOBER 25, NOVEMBER 1, g,2002 - Afflant further de Law JO poses that he is authorized to Veriurnal, a legal periodical of matter of the f1' this statement by the Cumberland general circulation aforesaid notice or advertise ? and that he is not interested in the su ' statements ment, and that all as to time, place and alle character of bJect gations in the fo publication are true, ;reg°ing REAL ESTATE SALE NO, 9 writ No. 20 20 2905 Civil Chase Manhattan Mortgage Corporation vs Linda B. Nelson and William H. Nelson, III Atty.; Frank Federman DESCRIPTION eel Of ALL TFIAT CERTAIN tract or n ere r landctedwith i par_ on mprovements there- , situate in the Townsh of Hampden, County ip and State of p of Cumberland more particulaii nnsylvania, being scribed y as bounded and de- follows, to wit: BEGINNING at a point on western side of Kevi the n Road which Nos. point 6is7 at the division line of Lots and 68 on the hereinafter mentioned plan of lots; thence South 39 degrees 08 rminutes West along the Western line of Kevin Road a 4R ger M• Morgenthal Editor S WORN TO AND S ?_day o f NTBSCRIBED before me this MBER 2'?? LOIS :' F ^ Sa ig (3lotmy Py ft ;Ouft -_Fjo 5,26M distance of one hundred sixty and fifty-one hundredths (160.51) to point thence in an arc curving 0 pthe right with a radius s oof hirty-nin feet the arc distan - and three hundredths (39.03) feet nt on the Northern 29 to a POI Drive; thence North Edward e of grew 04 minutes West on the afore- mentioned Edward Drive a d ethun of one hundred five feet to a point at dredths (105.09) is Nos. 69 and the division line of of lots: thence 161 on the said P minutes East North 39 degrees 08 and beyond along said division line an hundred a distance of one forty et to fifteen hundredths (140 line of Lots a point at the division line Nos. 67 and 68: thence South 50 degrees 52 minutes East along said division line one huiidreo. tin twenty-five (125) feet to a P the place of beginning. HAVING thereon erected a dwell- ing house known and numbered as 16 Kevin Road, is Nos. 68 and 69 IT BEING " on Plan of Lots entitled "Noll Acres' which plan is recorded in the Of- fice of the Recordoef Cumberland n for the County Plan Book 10, page 17. 094. TAX PARCEL # 1 PREMISES IS TITLE TO SAID H. Nelson. III VESTED IN William and Linda B. Nelson, His Wife by Deed from William H. Nelson, Jr.. Widower dated 1/27/1989 and re- corded 1/27/1989 in Deed Book U, volume 33. Page 29.