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HomeMy WebLinkAbout06-7275IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, CIVIL DIVISION NO.: -- ???5 l:. f U rL 1.? vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. TYPE OF PLEADING: CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation TO DEFENDANTS You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF C2? i ` l Cam( ?C -i k z? AT-rCrRNEY FOR PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANTS IS: 1 West Lake Drive Carlisle, PA 17013 L7 C. ATT RNEY FOR PLAINTIFF CERTIFICATE OF LOCATION 1 HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 1 West Lake Drive Lower Frankford Township (CITY, BORO, TOWNSHIP) (WARD) ATTO " EY FOR P AINTIFF 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.. 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 CASE NO: 2006-07275 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS LEBO JOEL A ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LEBO JOEL A the DEFENDANT , at 1916:00 HOURS, on the 29th day of December , 2006 at 1 WEST LAKE DRIVE CARLISLE, PA 17013 JOEL LEBO, HUSBAND by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. before me this day of , SHERIFF'S RETURN - REGULAR 18.00 5.28 .00 10.00 .00 33.28 1,aV DI Sworn and Subscibed to Dp Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: R. Thomas Kline 01/02/2007 GRENEN & BIRSI By: eputy Sheriff A. D. .w c- ..r - ¦ • ' SHERIFF'S RETURN - REGULAR CASE NO: 2006-07275 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS LEBO JOEL A ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE LEBO MIRANDA S was served upon the DEFENDANT , at 1916:00 HOURS, on the 29th day of December , 2006 at 1 WESTLAKE DRIVE CARLISLE, PA 17013 JOEL LEBO by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00, 01/02/2007 ` AGRENEN & BIRSIC c Sworn and Subscibed to By: before me this day puty Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, CIVIL DIVISION NO.. CAL. - .IS vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Joel A. Lebo and Miranda S. Lebo, are individuals whose last known address is 1 West Lake Drive, Carlisle, PA 17013. 3. On or about September 20, 2004, Defendants executed a Note in favor of Gateway Funding Diversified Mortgage Services in the original principal amount of $115,900.00. 4. On or about September 20, 2004, as security for payment of the aforesaid Note, Defendants made, executed and delivered to Gateway Funding Diversified Mortgage Services a Mortgage in the original principal amount of $115,900.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Mortgage Book Volume 1881, Page 3101. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A," attached hereto and made a part hereof. 5. Gateway Funding Diversified Mortgage Services assigned all of its right, title and interest in and to aforesaid Mortgage to Plaintiff pursuant to a certain Assignment of Mortgage recorded in the Office of the Recorder of Deeds of Cumberland County on December 5, 2006, at Mortgage Book Volume 732, Page 2752. 6. Defendants are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the August 1, 2006 payment. 8. On or about October 5, 2006, Defendants were mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal $113,567.29 Interest to 11/28/06 $ 3,053.22 Late Charges to 11/28/06 $ 468.44 Escrow Deficiency to 11/28/06 $ 164.34 Corporate Advances $ 30.00 Attorney's fees $ 1,250.00 Title Search, Foreclosure and Execution Costs $ 2.500.00 TOTAL $1 21,033.29 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $121,033.29 with interest thereon at the rate of $20.22 per diem from November 28, 2006, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. Kristine 1VI. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281 7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" 11-30-'06 13;59 FROM- Roy-9U UUO II:?Opm rrom- I ROBERT P. ZIEOLER- T qfr {G? MEMADER CF DEEDS d.. X009 BE? 22 FIR 12 15 mp oAwn to Lwl r%w4smPri MORTGAGE ' DEFW1110"s :: Words aced do muldlda terJiplt orallt doewnans,rc defpad below ad ouNr spMt aro em?ar da Saalmis 9. if. 13, 16.20 a,d 23. Cntaiv isle MON" 41111 sage of wdrda Used IN tW downs W alto provided In socuta 16. (J? "smanoy loufto " mrmM do doaimm which is da nd seplandw 20, 2001 op). w ai as Riche w dolt "Mm Alt •ddotswc- is JQEL A Laic arld MR1ANM 3 uma Borrower Is the mmvw to d r ulis 3wv q IMVAWrIL ?.. 10 vseada." Ic caw"y Fundln0 tUWralllad 11ommo 90110 as 1 P Laderesa Umftd Pdmw"hlp t 300 Vft" ftmdr 0"09 f• H09111% POW"I YAN1A Im" tar?er'a tddrwr 1111 L kilos is dK sw"m wdsr this ty IMmlmont. 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BLodit SS MtM%mw 3f4kM Lie. 11YnMr Na0b% PM MVLVr IA 120" cERTIMa?6OF RMWMC8 I. yvAW , oral w.a wnd<. cos wM.tt nr, euaao c, Www awybmdthu 2001 day or MotwLVAMA -**- Fn„Yy..-M* xrT-d&:4w vNoG01tD19P110?Mt owsw lw(snl 04slad/eppw aiBeiPG3116 T-662 P25/26 U-858 11-30-'06 14;02 FBOM- NOV-30-2006 12:01pm From- aH eff A ALL the fosovdng desaibW real astate lying and bring oihtete In Lower Franldord Township, Cumberland County Pennsylvania, bounded and limited as follows: t3EGMNQ at a point in Township Road (T-450) at a Corne? of Ion a now or forme* of Jewb F. Hoover and PaAw IE HOOiwer, his wife; therm in and along TrllrrmNp Road (T4W Ngrth 5T da9'rees 02 mleules 07 seconds ct. 259.47 feet to an exists P.K,; therm in 'std ant the same: North 39 1it mlnutse sr seconds Lust. 32,80 feel to r ywl.%t at a bonier of Let 2 on @to subdiWeion plan herein tar ?red to; Miens a" Lot No. 2. South 61 deoreec Ali rrrnt11M 00 semb EWL 107,40 feat to a POM a" the same. South 57 degrees 18 minutes 34 seconds East, "feet to past at a comer of lands now or formerly of Viola FM*OWIrrdK thence along rum or formerly of Vioh Finkenbinder, South 04 degrees 48 minutes 50 East, 125.13 feet to an existing iron Pin at a comer of lands now or fontwy Jacob F. Hoover and Pautins E. Hoover, his wife; Ihrrroe s" lands now or of Jacob F. Hoover and Pa" I- Hoover, hit wife, North 34 deCFeas [???111444 minutes 28 seconds West, 438.40 feet to a point In Township RCS (T-US), ZPa place of BEGINNING. II CONTAINING 1.080 acnes- ?. OEM Lot No.1 as shown on a Final Subdivision Prepared by Grier kesod Ina. doled November 18, 1903, which together with the rte municipal approvals, is nmf Jwd lot Cw„Le,l.,.l County Man Debt 89, Pago 106. 99ING part of the same Premises which Martha B. Markby by Deed rated June 3, 1877, and recorded June e, wfor, in the union of to R9Gadoo DPm6 id and for CumberW4 County, Pennsyivenie, in Deed Gook 27F, a X134, granted and oomayed unto Clarence E. Young and Y1 nt"3.. Youngs BEING the same promises which C E. Young and Yvonne J was, by Deed dated dePlanraer ?• 2004, NOW row,J-J 2004, In the 0ltree of the Rtearder of Deeds in mid for County, Penraryhrartra, in Dead Beait _ J Page , I conveyed unto Joel A. Lebo and WIN S. Lebo, hit WNe, Alarigagt Young, his ntod and hereK 7 Certify this to be rcr?rdl-d ht Curnhc:lunrl C`ri„nrr ?. I. ?, T-662 P26/26 U-858 VERIFICATION Cindy A. SITO ASSISTANT SECRETARY , Assistant Secretary, and duly authorized representative of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation 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 are true and correct to his/her knowledge, information and belief. CHASE HOME FINANCE LLC, s/b/m/t Chase Ma*Qa;LM e Corporation A. Sr ft, Assistant Secretary tol a 1 A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 the last known address of Defendants is: 1 West Lake Drive Carlisle, PA 17013 GRENEN & BIRSIC, P.C. NO.: 2006-07275-Civil TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation 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 Atto eys for Plaintiff 06. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. TO: PROTHONOTARY SIR: NO.: 2006-07275-Civil PRAECIPE FOR DEFAULT JUDGMENT Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Joel A. Lebo and Miranda S. Lebo, in the amount of $122,388.12, which is itemized as follows: Principal $113,567.29 Interest to 1/30/07 $ 4,277.45 Late Charges to 1/30/07 $ 527.04 Escrow Deficiency to 1/30/07 $ 164.34 Corporate Advances $ 102.00 Attorneys' Fees $ 1,250.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $1 22,388.12 with interest on the principal sum at the rate of $20.22 per diem (as may change from time to time in accordance with the terms of the Note) from January 30, 2007, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorney for Plaintiff 4 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendants are not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Sworn to and subscribed before me this 1ST day of 2007. k otary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2008 Member, Pennsy!vania Association Of Notaries 4 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 DATE OF NOTICE: January 19, 2007 CIVIL DIVISION NO.: 2006-07275-Civil 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. FIRST CLASS MAIL, POSTAGE PREPAID By: v n- Attorneys or Plaintiff 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, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. TO: Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 DATE OF NOTICE: January 19, 2007 NO.: 2006-07275-Civil 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 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. Y: Attorneys or Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 .? ?- ? ?? o ? ? ? ? ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 2006-07275-Civil vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on I ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $122,388.12 with interest on the principal sum at the rate of $20.22 per diem (as may change from time to time in accordance with the terms of the Note) from January 30, 2007, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. w. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 2006-07275-Civil vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on S ?O'r ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $122,388.12 with interest on the principal sum at the rate of $20.22 per diem (as may change from time to time in accordance with the terms of the Note) from January 30, 2007, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. r? '., F. r ? __:? _ ?, -? . ,. , ? ?, ? ?+ 3 _?„- -; ,;:,± ..., ? - - ? ?e . , t'"3 '' i -i .. , ?-. ?M :{ 4?Y !f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: , Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation , VS. , Joel A. Lebo and Miranda S. Lebo TO THE PROTHONOTARY OF SAID COURT: ( ) Confessed Judgment (X ) Other (Default Judgment) File No. 2006-07275-Civil Amount Due _$122,388.12 Interest _ $ 2,860.77 (1/31/07 to sale) Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs, upon the following described property of the defendant(s) 1 West Lake Drive Carlisle PA 17013 (Please see attached legal description) PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ? (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date %/o 0 `7 Signature: Print Name: Kristine M. Anthou Address: One Gateway Center, 9`' Floor Pittsburgh, PA 15222 Attorney for: Plaintiff Telephone: (412) 281-7650 Supreme Court ID No.: 77991 (over) .q •1 1 1 fA 't l N 'Ap cc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, NO.: 2006-07275-Civil Defendants. LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. a... , .,4 BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7275 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOEL A. LEBO AND MIRANDA S. LEBO (1) 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 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 $122,388.12 Interest $2,860.77 (1/31/07 TO SALE) Atty's Comm % Atty Paid $131.28 Plaintiff Paid Date: MARCH 2, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curti . Long, Pr By: Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 TRUE COPY FROM RECORD Teethr ? a?r% 1RrI1 Set R* toa P disle f ?? the Sea; ? ?. . ?: ?. , • ,,. Xy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 1 West Lake Drive, Carlisle, PA 17013 are Defendants, Joel A. Lebo and Miranda S. Lebo, who reside at 1 West Lake Drive, Carlisle, PA 17013, to the best of her information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE ME T'.. DAY OF R 2007. gL NotaryTublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal [Rebecca G. Btatna, NN WY Pub§O ly Of Pit?sbur9h, Alle9 COMM?kr rnxpres June 2, 2007 r--? ., ? , ; T? ?;? .,-.-? ? a '' : `? , ` ..- `-- 3 ?. . ?? ? ? ?, . •? ._._- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974,41 P.S.101, ET. SEQ. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Kristine M. Anthou, attorney for the Plaintiff, who being duly sworn according to law deposes and says that on October 5, 2006, Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 and Act 6 Notices of Intention to Foreclose by certified mail, return receipt requested, and first class U.S. Mail. SWORN TO AND SUBSCRIBED BEFORE ME KA DAY OF ?(/,)V < (a / (2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rebeoca G. Blaana, Notary Public City Of Pit burgh, Allegheny County My Commissian P)Vres June 2, 2007 MRlr bF? K> ? A.sc;;_i,finn o?Notaries F= FTI l . C 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 i Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name .and address of the defendants in the judgment: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. C Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 1 DAY OF Lta 2007. Notar? Public COMMONWEALTH O PPENNSYLVANIA Notarial Seal Rebecca G. Blazina, Notary Pubk Qty Of Pftburgh, Alleg°ieny County My Commis, Fx6i m June 2, 2007 _-- ? T r f ?A ?? Q z 1 - = -s? : T r- R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on June 13, 2007, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. Ir The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $125,248.89. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. ax -z- By. Kristine : Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 J, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. s I BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. Kristine M Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 ?-"? ? ? ?'- ? -n ,,; ,. ??? .,_ ?? s ,? .? i ?/ _... ?.? i _ ?},> ?? yt , ' p?f;,. .. ??? "i f? _ t ? ` f i :3-? ` ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on June 13, 2007, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $125,248.89. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. B? Kristine Anthou, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, NO.: 2006-07275-Civil Defendants. LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. Kristine Nl-. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 r""? ? _ ..? ? ....- -.i'- -n 1 x . . `? ?"'E" ? ^ i ? ? r^ _',, •..r ? _ .,..t 5 .•.,?- _ ; `^v r ? `+? ? ?+r J0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation 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 Sale date: 6/13/07 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows: By letters dated March 6, 2007, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. 46 I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BYE- e'C Kristine Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF IVY 2007. No Public COMMONWEALTH OF PENNSYLVANIA Notarial Sod Elizabeth M. Paiam, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2008 Member, Pennsylvania Association Of Notaries E r? u 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALLTHE,RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS I WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 I 4b 6 9 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name .and address of the defendants in the judgment: Joel A. Lebo Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS J? DAY OF ?JL 2007. Notar? Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rebecca G. Blazina, Notary Pubic City OF Pittsburo, ABW*ny CM* My CortynWon Expires June Z 2007 iMernber, Pe?rns±.ha Asxaatrors OF Notaries ?! PG 1 6 ? {s ! Qua 1 5 N $ W O O LL O N 1 N l f a a ; CO W Oi W O a K U. c S Q Q? c < _ 59?a yIL, 4 La o - M W nun o ' Vo • FAD i' a U O r+ m 7 ? a7 C7 l6 ? w Q L. a L cm U I m m d) = a?m ' amE a _ 4 E m ' y1-a E o x t,y at LL 0 M 0 M 0 co Q? b a°o" c M M M s a ? W E r O U ' a 2 N E C 1 8 p N N d ? O . zwcr U) m O m [1001 N $ 0 . 5 N Op C C 2' to 4 O 16 m € co ?i CY) co Q O 4) o ?? m Em 64 ova < ??a ? o j xa IN 2) m X rn o a H c'?UOU'S5 ? v O m O O m w E O O m $ N On [1[1[1[1[1 c = 0 W m 0 U aU ma= oa= a O O o f9 - LL co 3 c N > C C E m N V 0. LO E E o o ? IX A (D E (D cc Co N Q co ca C n C Al ? v+-' 0 C. O 0 E c . m N(D? ?o C O CO) 7 U Q a O U ?a z E 2 C Z 0 0 a o ~ J r N ch 46 o GO a S a Y c w a A) m CL E V N 0 0 7N a LL ? N ch O (O LL ar- 1?1? n p ,r °° ? C 7 N3 t `17 Chase Home Finance LLC, s/b/m/t Chase In The Court of Common Pleas of Manhattan Mortgage Corporation Cumberland County, Pennsylvania VS Writ No. 2006-7275 Civil Term Miranda S. Lebo and Joel A. Lebo William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 20, 2007 at 2024 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Miranda S. Lebo and Joel A. Lebo, by making known unto Joel Lebo, personally and adult in charge for Miranda S. Lebo, at 1 West Lake Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1401 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Miranda S. Lebo and Joel A. Lebo, located at 1 West Lake Drive, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named defendants, to wit: Miranda S. Lebo and Joel A. Lebo, by regular mail to their last known address of 1 West Lake Drive, Carlisle, PA 17013. These letters were mailed under the date of April 4, 2007 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Kristine Anthou. Sheriffs Costs: Docketing 30.00 Poundage 18.46 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 11.52 Levy 15.00 Surcharge 30.00 Law Journal 407.00 Patriot News 381.95 Share of Bills 16.17 Postpone Sale 40.00 $ 981.60 ? (?„? So Answers: R. Thomas Kline, Sheriff BY "'Jw?-J&V ' Real Estate Sergeant jG/vdb I v S 40 s(' y .M v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name.and address of the defendants in the judgment: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. (- ki ??7- tx_ ? Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF Y 2007. Lai Nota Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rebecca G. Blazina, Notary Public City Of Pittst irgh, Alle9.`ieny Cody My Conxnis.4m+ Exmirrs June 2, 2007 ,Mwben r$ n( VVgni8 s. ,; lat& Of NV-Afies IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on June 13, 2007, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $125,248.89. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. Kristine Zhou, Esquire kA- Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on June 13, 2007, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $125,248.89. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. By. j_,? , rC z Kristine T?F Anthou, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. i BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. Kristine M Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-7275 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOEL A. LEBO AND MIRANDA S. LEBO (1) 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 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 $122,388.12 L.L. $30 Interest $2,860.77 (1/31/07 TO SALE) Atty's Comm % Due Prothy $1.00 Arty Paid $131.28 Other Costs Plaintiff Paid Date: MARCH 2, 2007 Cu is R. Lon honota (Seal) By: Deputy REQUESTING PARTY: Name KRISTINE M. ANTHOU, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 77991 Real Estate Sale # 71 On March 13, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as 1 West Lake Drive, Carlisle, more fully described on Exhibit "A" C filed with this writ and by this reference incorporated herein. Date: March 13, 2007 By: Real Estat ?,eir?'gve AaL'nt 'U -' L'L. 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 Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with 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 Sunday 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 in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. 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#71 Sworn to and subscribed before me this 18th day of May 2007 A.D. COMMONWE tt_IN vi-1,FNNSYLVANIA Notarid Seal ?"erry l.. Hussell, Nutary Public City Of Hanish ?, Dauphin County ommission ° Aires June 6, 2010 Me er, P nn J ie. Association of Notaries NOT AY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 aed ? =? and. a s pa?f?!?+P?$(T 459} ae jt. e llM aef l?ltl? ties y ca ,. Jacob vwn 1118 SYIfln _ ??"?-. 459} M rir 07 mcdods Past ° ' ?aaoe in wd 12 1 #: k .,, . 98.20 feat to r pm at 'a own of 1e6 ww of fotmmy of Yet odirdrr: 6t= aloes I mq* Wane X40 ka to 'adad- 1-4591. tk if 81mqG U Pfa. i ; LOW on a I:AW S?iO ' Elder AssodAm, lnc., dA1ed which "ed- with the mmur.` , is secaded in Car artred 3W 68, P?e4o5 BEWtl O, it s, ptt.o. 0'" Clu=e E your ietY? 1. Y44 W wife, by Dw Of1ix ?e ? iR.?le Coue4y oa 22 '?AR?i, x volume 266, 1771, and coeveyed uwo Joel A..(abq*4#Apo 5.-f-ebo, Ned No.14*4027445 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, 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: April 20, 27, May 4, 2007 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. i Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 4 day of May, 2007 _ NOTARIAL SEAL LOOS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My ICAmmission Expires March 5, 2009 REAL ESTATE SALE NO. 71 Writ No. 2006-07275 Civil Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation vs. Joel A. Lebo and Miranda S. Lebo Atty.: Kristine Anthou LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Town- ship Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 de- grees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 min- utes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a cor- ner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated Sep- tember 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on Septem- ber 22, 2004, at Deed Book Vol- ume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. Parcel No. 14-06-0027-045. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation vs. Joel A. Lebo and Miranda S. Lebo ( ) Confessed Judgment (X ) Other (Default Judgment) File No. 2006-07275-Civil Amount Due $122,388.12 Interest $ 13,593.62 (1/31/07 to sale) Atty's Comm Costs TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs, upon the following described property of the defendant(s) 1 West Lake Drive Carlisle PA 17013 (Please see attached legal description) PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of attachment to the, Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ? (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date G 0'd Signature: yc Print Name: Brian M. Kile Address: One Gateway Center, 9" Floor Pittsburgh, PA 15222 Attorney for: Plaintiff Telephone: (412) 281-7650 Supreme Court ID No.: 89240 (over) !s Y ..Q C wI 0CC S' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. By: ?3- LL Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7275 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOEL A. LEBO AND MIRANDA S. LEBO (1) 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 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 $122,388.12 Interest $13,593.62 (1/31/07 TO SALE) Atty's Comm % Atty Paid $1,134.38 Plaintiff Paid Date: JUNE 23, 2008 L.L. Due Prothy $2.00 Other Costs d"r7j-w C R. Long onota (Seal) REQUESTING PARTY: Name BRIAN M. KILE, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 By: Deputy Supreme Court ID No. 89240 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 i Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name and address of the defendants in the judgment: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations PA Department of Revenue Commonwealth of Pennsylvania P.O. Box 320 Carlisle, PA 17013 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Brian M. Kile, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS NQt DAY OF 2008. otary Public COMMONWEALTH OF PENNSYLVANIA Notarial seal E91061h M. PaWno, Notary Pdit 2012 City Of My Carjr&dw Expires Jan. 6,2D12 Member, Pennsylvenie Assaaietlon Notaries -ra W p? .w. \-Zi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Brian M. Kile, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 1 West Lake Drive, Carlisle, PA 17013 are Defendants, Joel A. Lebo and Miranda S. Lebo, who reside at 1 West Lake Drive, Carlisle, PA 17013, to the best of his information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS D OF I 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiara, Notary Public City Of Pb btxgh, Ale"W Courtly My Conyrrhaw E*res Jan. 6, 2012 Member, Pennsylvania Association of Notaries r"? ?' ? ?{} c? ?.-t ' '* ? ' t'?1 ? ,. ?? ti.r :.r? ? ' ? s ? 5 R , i "V ? +, \.+ ??,. ' ?: . _ ?,..y. ? , ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101 ET. SEO AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Brian M. Kile, attorney for the Plaintiff, who being duly sworn according to law deposes and says that on October 5, 2006, Defendants were mailed a combined Act 91 and Act 6 Notice, via certified mail, return receipt requested, and by first class mail, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P. S. §101, et seq. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2008. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Ekabeth M. Palano, Notary PubNc City Of Pb bjo, Aftheny County My Caorr mt E*1m Jan. 6, 2012 Member, Pennsylvania Association of Notaries co --4 t r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on December 10, 2008, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL 414-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $135,981.74. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. By: Brian M. Kile, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. By: Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 ?? ?' w? ?? `:? ?w ,,. r??? ---+ ?sz W y ,..?? ' =:: _ ? j .? x-? L ?? - ? • -,? ,:G• .".? Cy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on December 10, 2008, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $135,981.74. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. By. Brian M. Kile, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. By: Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 = TTj z? rQ IL WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7275 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, SB/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOEL A. LEBO AND MIRANDA S. LEBO (1) 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 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 $122,388.12 Interest $13,593.62 (1131/07 TO SALE) Atty's Comm % Atty Paid $1,134.38 Plaintiff Paid Date: JUNE 23, 2008 (Seal) L.L. Due Prothy $2.00 Other Costs AhA &?? C is R. Long, onot By: Deputy REQUESTING PARTY: Name BRIAN M. KILE, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 89240 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Sale date: 12/10/08 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Kristine M. Anthou, Attorney for Plaintiff, Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows: By letters dated June 30, 2008, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. B Kristine . Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS _% DAY OF 2008. N ary Public C;OMMOWM,ru.TH of P gY IVANIA w" Sea F.nb m A OWN IX Nola yRM my? E*n jam 6. 2012 of Noted" . fe " EXHIBIT "A" • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo I West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name and address of the defendants in the judgment: Joel A. Lebo Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE n u 0 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Brian M. Kile, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ?q DAY OF 2008. a , A a Notary Public COMMONWEALTH OF PENNSYLVANIA Ntft Sad Eftobdh M. PaW06 Nolry RM City Of PNAbx9K A189herN My Owmdoon EOW Janan ? Z Nlsmbsr. p«wnylvsnls Ass00ist , of HoWWs O oc N OC fJ r fJ LL * 4h ul ?C a' Q K LL N LL ' r Q U rot ? LL - h LL s N ? Q $Nn O Q . ?? C S m ?U CL J 'aa a i I o 40 ai A of t . O L as E ,e 0000 . r z o M N $? O m H 1130000 0 U ca aU L N _O O W N ' v a. cn c 4 E E ?AUV z Q c s c ca rn CD 4) U L 00a I I It ?IIt M N V N ,M O W ti 0 ti ova ??a 000 W O t0 C X X m y m * ° ?0ca '0m ' ma= ? a= N C N N 4) a _ m o E o E a v N IM 'I7 Li C6 ti ^10 ~- ao m C C V V a m a c a_ Y C H a a s N O $1 E N Z g g N F Z. LL `L IL ch W. Za a ? CL ti {?} _ ..7 } ?.?? "r^ °r , __,.? ?-,,, ?,y:, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which HOMESALES INC DBA HOMESALES INC is the grantee the same having been sold to said grantee on the I OTH day of DEC A.D., 2009, under and by virtue of a writ Execution issued on the 23 day of JUNE, A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 7275, at the suit of CHASE HOME FINANCE LLC against JOEL A LEBO & MIRANDA S is duly recorded as Instrument Number HOMESALES INC DBA HOMESALES INC. 100q i 0m-I IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ?- day of A.D. 07, of Deeds R6m=xW 0.,:,d9. Ctmib ftW County, CW"' PA My 64*8 to First MOVIRY01Jm. 2010 i ChaiO Home Finance, LLC s/b/m/t Chase In the Court of Common Pleas of Manhattan Mortgage Corporation Cumberland County, Pennsylvania VS Writ No. 2006-7275 Civil Term Joel A. Lebo and Miranda S. Lebo William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 26, 2008 at 2014 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Joel A. Lebo and Miranda S. Lebo by making known unto Joel Lebo, personally and husband of Miranda S. Lebo, at 1 West Lake Drive, Carlisle, 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 8, 2008 at 1108 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joel A. Lebo and Miranda S. Lebo, located at 1 West Lake Drive, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named defendants, to wit: Joel A. Lebo and Miranda S. Lebo, by regular mail to their last known address of 1 West Lake Drive, Carlisle, PA 17013. These letters were mailed under the date of October 6, 2008 and never returned to the Sheriff s 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, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Brian M. Kile, on behalf of Homesales, Inc. d/b/a Homesales, Inc. of Delaware. It being the highest bid and best price received for the same, of Homesales, Inc. d/b/a Homesales, Inc. of Delaware, of, 3415 Vision Drive, Columbus, Ohio 43219, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 1,098.97 Sheriffs Costs: Docketing $30.00 Poundage 11. S; Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.00 Mileage 21.00 Levy 15.00 Surcharge 30.00 Post Pone Sale Law Journal 401.00 Patriot News 401.00 Share of Bills 14.92 Distribution of Proceeds 25.00 Sheriffs Deed 49.50 $ 1,098.97 3)"109 gall '? So Answers: R. Thomas Kline, Sheriff BY Real Estate Coordinator as r. L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Joel A. Lebo and Miranda S. Lebo located at 1 West Lake Drive, Carlisle, PA 17013 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. 1. The name and address of the owners or reputed owners: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 F Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 2. The name and address of the defendants in the judgment: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 Miranda S. Lebo 1 West Lake Drive Carlisle, PA 17013 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 4. The name and address of the last record holder of every mortgage of record: Chase Home Finance LLC, s/b/m/t Chase [PLAINTIFF] Manhattan Mortgage Corporation 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NONE 0 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Brian M. Kite, Esquire Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS JA DAY OF 2008. Notary Public commoNwEAI.TH OF PENNSYLVANIA Nataliei Seal Ek3balh K Palermo. NolarY Rkk City Of PftbjgK Ak9twny County ?M Oon gntmdon Egli w ism 6,2012 Member, Penneylvenla AsegWo lon of Notaries f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Joel A. Lebo 1 West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on December 10, 2008, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $135,981.74. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. By: ? ?- t L Brian M. Kile, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. i as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. 1 By: ? ? ?--l L Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, NO.: 2006-07275-Civil Plaintiff, VS. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Miranda S. Lebo I West Lake Drive Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 on December 10, 2008, at 10:00 A.M., the following described real estate, of which Joel A. Lebo and Miranda S. Lebo are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF JOEL A. LEBO AND MIRANDA S. LEBO OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE LOWER FRANKFORD TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1 WEST LAKE DRIVE, CARLISLE, PA 17013. DBV 265, PAGE 1771. PARCEL #14-06-0027-045. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Chase Home Finance LLC, s/b/mlt Chase Manhattan Mortgage Corporation, Plaintiff, VS. Joel A. Lebo and Miranda S. Lebo, Defendants, at Execution Number 2006-07275-Civil in the amount of $135,981.74. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. By:.' Brian M. Kile, Esquire Attorney for Plaintiff 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, s/b/m/t CIVIL DIVISION Chase Manhattan Mortgage Corporation, Plaintiff, vs. JOEL A. LEBO and MIRANDA S. LEBO, Defendants. NO.: 2006-07275-Civil LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Township Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a comer of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T-459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the necessary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated September 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. GRENEN & BIRSIC, P.C. By: Brian M. Kile, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel No. 14-06-0027-045 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) "COUNTY OF CUMBERLAND) NO 06-7275 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, S/B/M/T CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From JOEL A. LEBO AND MIRANDA S. LEBO (1) 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 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 $122,388.12 Interest $13,593.62 (1/31/07 TO SALE) Atty's Comm % Atty Paid $1,13438 Plaintiff Paid Date: JUNE 23, 2008 L.L. Due Prothy $2.00 Other Costs 24'? Curtis R. Long, Pro y (Seal) By: Deputy REQUESTING PARTY: Name BRIAN M. KILE, ESQUIRE Address: ONE GATEWAY CENTER, 9Tn FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 89240 T {UE COPY FROM REGORU fn ToWp q whrW, I labs unto set my hand X14 do Nil of UN at Carlis?, Pu r? irot? Real Estate Sale # 18 On August 18, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Township, Cumberland County, PA Known and numbered as 1 West Lake Drive, Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 18,200& By: Real Estat Sergeant ti o a - .K INO _ri O `_r - e?? Ttiie Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ?latriot News Now you know 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant 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 Sunday 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 date(s) indicated below. 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 This ad ran on the date(s) shown below: , 10/29/08 11/05/08 r 11/12/08 ......... rJ .?j? 'r' V??/ • .... . Sworn to aryd` ribed before m this,25 y of November, 2008 A.D. / '91 Notary Publ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Public City Of Harrisburg, Dauphin County My Commission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries PAd folM BMIa 110.1• Avg***. 0M "We 61tt!TOM 1?IIta ? L?6rr>wl?? t .t el A. I abo and lYthttutida S. LO A#ornsy Btlest ft KHe LEGAL DESCRIPTION ALL the following described real estate lying and being situate is Lower HuMord Tmwbip, CSimbesland CoumJ; Pennsylvania, bounded and limited as follows: BEGMING at a point in 3'awaship Road (T- 459) st:a cornet of lands now or, formerly of Jacob ..Hoover ana Patine E. How m his wife: thence m and along Township Road (r- .459) NoM 57 degrees 02 miomes 07 seconds East, 253.47 fed,to ameMsting .S.. thence in and along the same Nofth 39 degrees 12 mimnes 37•secoads East 52.66 fed ton point at a comer of •Lot No. 2 on drsabdiwision plan bminda R* W to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East; 107.46, feet to a p ft thance along the same, South 57 degres 19 minutes 34 seconds East, 9810 feet to a post at a comer of lands now or formerly of Viola Finken6i , 1hence along lands now or fiormedy,of Viola Fmkambhxkr, South •04 degrees 46,66W 50 seconds 'East, 125.13 feet to au existing iron pin at a comer of lands now or fotmerly nfJ" F. Hoover and Pauline E. knower, his wife, bence along lands now or foemetiy of Jacob F. Hoover and Pauline E. Homer, his wife, North 84 degrees 04 minutes 28 seconds West; 438.40 fed to a point in Township Road (r459), the place of BEGINNING. CONTAINING 1.236 am. BEING Lot No. 1 as shown, on a Final Subdivision psepaned,by Crier Associates, Inc., dated Noeauber IC 1993,.which together with the ceoessary-municipal approvals, is recorded in Cmnberleod Cauntlr Plan Book 68; Page 105. BEING the same premises which Clarence E. Young and Yvowo J. Young, his wife, by Deed dated September. 20, 2904 and teowded in the Office of the Recorder of Deeds of Cumberland County on September 22, 20%, at Deed Beck Volume 265, Page 1711, grained and conveyed unto Joel A. Ldm Miranda S. Lebo. Parcel No.14-"27-045 ?the Patriot-Muss Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL 10/29/08 11/05/08 11/12/08 Of Ad Sheriff Sale 18 9.06 $14.57 $ 132.00 Sheriff Sale 18 9.06 $14.57 $ 132.00 Sheriff Sale 18 9.06 $14.57 $ 132.00 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 401.00 JLC PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, 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: October 31, November 7 and November 14, 2008 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. Coyne, Editor SWORN TO AND SUBSCRIBED before me this 14 day of November, 2008 Notary RAH A COLLINS FCARLISLE TARIAL SEAL tary Public , CUMBERLAND COUNN n Explres Apr 28, 2010 WYE. need= a" na is Writ No. 2006-07275 Civil Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation VS. Joel A. Lebo and Miranda S. Lebo Atty.: Brian M. Kile, Esquire LONG FORM DESCRIPTION ALL the following described real estate lying and being situate in Lower Frankford Township, Cumber- land County, Pennsylvania, bounded and limited as follows: BEGINNING at a point in Town- ship Road (T-459) at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence in and along Township Road (T-459) North 57 degrees 02 minutes 07 seconds East, 253.47 feet to an existing P.K.; thence in and along the same, North 39 degrees 12 minutes 37 seconds East, 52.66 feet to a point at a corner of Lot No. 2 on the subdivision plan hereinafter referred to; thence along Lot No. 2, South 64 degrees 30 minutes 00 seconds East, 107.46 feet to a point; thence along the same, South 57 degrees 19 minutes 34 seconds East, 98.20 feet to a post at a corner of lands now or formerly of Viola Finkenbinder; thence along lands now or formerly of Viola Finkenbinder, South 04 degrees 46 minutes 50 seconds East, 125.13 feet to an existing iron pin at a corner of lands now or formerly of Jacob F. Hoover and Pauline E. Hoover, his wife; thence along lands now or for- merly of Jacob F. Hoover and Pauline E. Hoover, his wife, North 84 degrees 04 minutes 28 seconds West, 438.40 feet to a point in Township Road (T- 459), the place of BEGINNING. CONTAINING 1.236 acres. BEING Lot No. 1 as shown on a Final Subdivision prepared by Grier Associates, Inc., dated November 16, 1993, which together with the neces- sary municipal approvals, is recorded in Cumberland County Plan Book 68, Page 105. BEING the same premises which Clarence E. Young and Yvonne J. Young, his wife, by Deed dated Sep- tember 20, 2004 and recorded in the Office of the Recorder of Deeds of Cumberland County on September 22, 2004, at Deed Book Volume 265, Page 1771, granted and conveyed unto Joel A. Lebo and Miranda S. Lebo. Parcel No. 14-06-0027-045.