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HomeMy WebLinkAbout02-3071FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION P.O. BOX 9430 DEERFIELD BEACH, FL 33443 TERM Plaintiff V. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER 18 DONEGAL DRIVE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. U2 - ,20'1/ CUMBERLAND COUNTY **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: F1587312150 JRK IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is CHASE MANHATTAN MORTGAGE CORPORATION P.O. BOX 9430 DEERFIELD BEACH, FL 33443 The name(s) and last known address(es) of the Defendant(s) are: BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER 18 DONEGAL DRIVE CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/00 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1622, Page 103. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 1/1/02 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $56,625.66 Interest 2,413.77 12/1/01 through 6/1/02 (Per Diem $13.19) Attorney's Fees 1,000.00 Cumulative Late Charges 154.07 6/23/00 to 6/1/02 Cost of Suit and Title Search 55o 00 Subtotal $60,743.50 Escrow Credit 0.00 Deficit 7229 Subtotal R 72.79 TOTAL $60,816.29 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $60,816.29, together with interest from 6/1/02 at the rate of $13.19 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FVqERMAN AND PE LP By: FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL that certain lot of ground situate on "A" Street in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows. ON the north by a 16 foot wide alley; on the east by property now or formerly of Sadie A. Bream; on the south by "A" Street; and on the west by property now or formerly of George Kramer HAVING s frontage of 25 feet on "A" Street and extending in depth 150 feet more or less to the alley on the north aforesaid. HAVING thereon erected the western half of a double brick dwelling house and the western half of a double frame garage. The eastern boundary line of the property hereby conveyed being the middle line of the partition wall between the eastern half and the western half of the said double brick dwelling and also the middle line of the partition wall between the garages on the said property. BFXVG the same property which Dixie S. Jumper and Simon P. Jumper, her husband, granted and conveyed unto Benjamin A. Schaeffer and Brand! M. Schaeffer, his wife, by deed dated June 26, 2000 and recorded in the Office of the Recorder of Deeds for Cumberland County Deed Book 224, Page 324. BEING KNOWN AS 123 A STREET, CARLISLE, PA 17013 VERIFICATION RYAN L REMAk*K SR hereby states the he/she is the ASSISTANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORTATION mortgage servicing agent for the Plaintiff in this matter, the he/she is authorized to take the Verification, and the statements made in the foregoing Civil Action are true and correct to the best of her/his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. RYAN L RERLMJER, SR ASSISTANT SECRETARY Date: 6 /So/o z R.3 c c c fl `n ? -? -1 7J SHERIFF'S RETURN - REGULAR CASE NO: 2002-03071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SCHAEFFER BENJAMIN A ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHAEFFER BENJAMIN A the PLAINTIFF , at 1500:00 HOURS, on the 12th day of July 2002 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE, PA 17013 by handing to BENJAMIN SCHAEFFER 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: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this ?,h,( day of L A.D. othonotary So Answers: R. Thomas Kline 07/18/2002 FEDERMAN & PHELAN ??rrBy : 'Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-03071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SCHAEFFER BENJAMIN A ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHAEFFER BRANDI M the DEFENDANT , at 2125:00 HOURS, on the 17th day of July 2002 at 323 W PENN STREET CARLISLE, PA 17013 by handing to BRANDI SCHAEFFER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this ,?,,o( day of c6 l 2?„, A.D. ? r th notar So Answers: R. Thomas Kline 07/18/2002 FEDERMAN & PHELAN By: 1 l n Deputy §IVeriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION P.O. BOX 9430 DEERFIELD BEACH, FL 33443 Plaintiff, V. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3071 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against BENJAMIN A. SCHAEFFER and BRANDI M. SCHAEFFER, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 6/2/02 to 8/20/02 TOTAL $60,816.29 $ 1,055.20 $61,871.49 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. 1 ? c „nn Can 7. FRANK FED RMAN, ESQUIIZE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT D. DATE: Zof ?? "??`??? PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s) TO: BRANDS M. SCHAEFFER 323 WEST PENN STREET CARLISLE, PA 17013 DATE OF NOTICE: AUGUST 7, 2002 Attorney for Plaintiff COLRT OF COMMON PLEAS CIVIL DIVISION CUMBERLAI\ID COUNTY NO. 02-3071 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedv Boulevard Suite 1400 Philadelphia, PA 19103-1814 (21 5) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s) TO: BENJAMIN A. SCHAEFFER 18 DONEGAL DRIVE CARLISLE, PA 17013 DATE OF NOTICE: AUGUST 7. 2002 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-3071 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12243 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia. PA 19103-1314 at 5) i61-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff vs. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant TO: BEMJAMIN A. SCHAEFFER 123 A STREET CARLISLE, PA 17013 DATE OF NOTICE: AUGUST 7. 2002 Attorney for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION CUMBERLAND COUNTY : NO. 02-307! THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2102-03071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SCHAEFFER BENJAMIN A ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHAEFFER BRANDS M the DEFENDANT , at 2125:00 HOURS, on the 17th day of July 2002 at 323 W PENN STREET CARLISLE, PA 17013 by handing to BRANDI SCHAEFFER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this day of A. D. So Answers: ?w R. Thomas Kline 07/18/2002 FEDERMAN & PHELAN Deputy riff Prothonotary SHERIFF'S RETURN - REGULAR CASE NQ:-_2.02-03071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS SCHAEFFER BENJAMIN A ET AL KATHY CLARKE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHAEFFER BENJAMIN A the PLAINTIFF , at 1500:00 HOURS, on the 12th day of July 2002 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE, PA 17013 by handing to BENJAMIN SCHAEFFER 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: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this day of A. D, So Answers: R. Thomas Kline 07/18/2002 FEDERMAN & PHELAN BY: Deputy Sheriff Prothonotary ? ? ? ?? ? ? ?v ??a? ?? ?, _ ?, . ?? ,; ? Yi. / ' _ ,_ . ?r; FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION P.O. BOX 9430 v. Plaintiff, BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3071 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant BENJAMIN A. SCHAEFFER is over 18 years of age and resides at, 18 DONEGAL DRIVE, CARLISLE, PA 17013. (c) that defendant BRANDI M. SCHAEFFER is over 18 years of age, and resides at, 323 WEST PENN STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. RANK FE ERMAN, ESQUIRE Attorney for laintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. No. 02-3071 BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $61,871.49 Interest from 8/21/02 to 12/4/02 $ 1,078.02 and Costs (per diem -$10.17) TOTAL $62,949.51 i RANK FED RMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. w? wa ?" z H ?a O O H ? Uz ? 00 ? HU x O? U? w wW ? ~" U O H O a? O ww Ux rn U z? A z? W Aq 0 U w w O 0 w a U a 0 0 0 0 M O n O ti a w ~' ?H UW F? .? A z z ? zw A3 00 "m M a w ' I Q DESCRIPTION ALL THAT CERTAIN lot of ground situate on "A" Street in the Borough of Carlisle, Count, of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows. ON the North by a 16 foot alley; on the East by property now or formerly of Sadie A. Bream; on the South by "A" Street; and on the West by properry now or formerly of George Kramer. HAVING a frontage of 25 feet on "A" Street and extending in depth 150 feet more or less to the aile_% on the North aforesaid. HAVING thereon erected the Western half of a double brick dwellinz house and the Western half of a double frame garage. The Eastern boundary line of the property hereby conveyed being the middle line of the partition wall between the Eastern half and the Western half of the said double brick dwelling and also the middle line of the partition wall between the garages on the said property. Tax Parcel #20-1798-082 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Benjamin A. Schaeffer, his heirs and assigns by reason of the following: BEING THE SAME premises which Dixie S. Jumper and Simon P. Jumper, her husband by Deed dated 6/26/2000 and recorded 6/29/2000 in the County of Cumberland in Deed Book 224. Page 12a conveyed unto Benjamin A. Schaeffer and Brandi M. Schaffer, his wife. AND BEING THE SAME premises which Benjamin A. Schaeffer and Brandi M. Schaeffer, his wife by Deed dated 1:25;2002 and recorded 126/2002 in the County of Cumberland in Deed Book 250 Page 4705 conveyed unto Benjamin A. Schaeffer, his heirs and assigns. V 1/3 1J i69. 1 f` ? C o r-t 69. `j r, FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, v. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3071 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: Q an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. RANK FE ERMAN, ESQUIRE Attorney for laintiff c-, ? ? .. ;,: ?-; ?_ ?? ??', ` <=' ?= ?_ _.. : :; ?- ?• ?? -., .. .:; - ?r, CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3071 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,123 A. STREET, CARLISLE. PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Last Known Address (if address cannot be reasonably ascertained, please indicate) 18 DONEGAL DRIVE CARLISLE, PA 17013 323 WEST PENN STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Last Known Address (if address cannot be reasonably ascertained, please indicate) 123 A. STREET CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. August 14, 2002 DATE RANK F DERMAN, ESQUIRE Attorney for Plaintiff CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. BENJAMIN A. SCHAEFFER BRANDI M. SCHAEFFER Defendant(s). CUMBERLAND COUNTY No. 02-3071 August 14, 2002 TO: BENJAMIN A. SCHAEFFER 18 DONEGAL DRIVE CARLISLE, PA 17013 BRANDI M. SCHAEFFER 323 WEST PENN STREET CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at 123 A. STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on DECEMBER 4, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $61,871.49 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESC IO` ALL THAT CERTAIN lot of ground situate on "A' Street in the Borough of Carl <ie. COnnr. of Cumberland and Commonw'eaith of Pennsylvania. bounded and described as foilo.v>. ON the Nor h by a 16 foot ailev: on the East by proper- now or forme-lv of Sadie A. Bream: , n ;he South by "A" Street: and on the West by proper n, or former,,; of Gecrge k ame- et and extending in depth 1f0 teet more or le» ro -he s:!`-' HAVING a frontage of Zd feet on "A" Stre on the North aforesaid. HAVING thereon erected the Western half of a double brick dwelling house and the ?bestera half of a double frame garage. The Eastern boundary line of the property hereby conveyed 'eeing the middle line of the partition wall between the Eastern half and the Western half of the said double brick dwellim2 . and also the middle line of Lie partition wall between the garages on the said proper- Tax Parcel #20-1798-082 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Benjamin A. Schaeffer, his heirs and assigns b,. reason of the following: BEING THE SAME premises which Dixie S. Jumper and Simon P. Jumper. her husband by Deed dated 6%26;2000 and recorded 6%29/2000 in the County of Cumberland in Deed Book 224, Page 321 conveyed unto Benjamin A. Schaeffer and Brandi N1. Schaffer, his wife. AND BEING THE SAME premises which Benjamin A. Schaeffer and Brandi -l. Schaeffer, his wife by Deed dated 1:25/2002 and recorded 326,200'_ in the County of Cumberland in Deed Book 250 Page 4705 conveyed unto Benjamin A. Schaeffer, his heirs and assigns. c; !- _ -- r= ' a _ , :-; -` c r _,_, .. i, i ?, ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-3071 Civil CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From BENJAMIN A. SCHAEFFER,18 DONEGAL DRIVE, CARLISLE, PA 17013 AND BRANDI M. SCHAEFFER, 323 WEST PENN STREET CARLISLE, PA 17013 (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 gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property (s) or otherwise disposing thereof; of the defendant (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 $61,871.49 L.L. $.50 Interest FROM 8/21/02 TO 12/4/02 (PER DIEM - $10.17) - $1,078.02 AND COSTS Atty's Comm % Any Paid $126.35 Plaintiff Paid Date: AUGUST 20, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Prothonotaa Deputy Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 IN THE COURT OF COMMON PLEAS OF CUMI3ERLAND COUNTY, PENNSYLVANIA RE: CHASE MANHATTAN MORTGAGE CORPORATION CIVIL ACTION vs. BENJAMJIM A. SHAEFFER ) CIVIL DIVISION BRANDI M. SHAEFFER ) NO. 02-3071 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, FRANK FEDERMAN, ESQUIRE attorney for CHASE MANHATTAN MORTGAGE CORPORATION hereby verify that on 8/20/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on ;8/20/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: November 4.2002 IrANK FEDERMAN, ESQUIRE Attorney for Plaintiff ? uo -3 O d A'J?'1 ? ? In A W N O ? ? J O? v? A W N ? Vl O. CD y a z o a W '=1 40 n? 0 w 88g?" ?+ q m A E " d vai 3?. gc. Npy??', 010 =0 N O O W P so c¢e O m ? c m o cn a? Qi a N ? .J m Q 6 a y ? n ? m {$ g 3 q s•na? v° °o c 5 c' m ? a a n??h Saga o" R" " C- ID b7 W -3 (") d z z z ° o 3 " .? a V ? ? A m a h7 N W TJ 3Cyy'i-' 7 ' a N W ti9 0 ? A 00 z O tT, < w v? ,?v d ? tt --?t O to _ w ? ? Y :h y r m J o N O a J a J O r x W Z O C O G7 ? N U n'3 i W r. ? a b a o J _ W O ' 7 "? ? ?{ry FY FS{JWES 02 1,1? $ 01.50° 0004300377 AUG20 2002 MAILED FROM ZIP CODE 1 91 03 w ?7 CCD rox? ? w c ? co O? ? b A C xx w v? y. a 9p ? E. d ? o C ? O a ///Ah PK?tq jc, C t a Cr N N , 7160 3901 9844 9257 6322 TO: BRANDI M. SCHAEFFER 323 WEST PENN STREET CARLISLE, PA 17013 SENDER: KNiD REFERENCE: F1587312 150 -- PS Form 3800 June,2000 RETURN Postage 1 RECEIPT Certified Fee SERVICE Return Receipt Fee i Restricted Delivery Total Postage & Fees US Postal jMail ( T Recei? m CertifieQ "r No Insurance CovDo Not Use for Int 7160 3901 9844 9257 6315 TO: BENJAMIN A. SCHAEFFER l8 DONEGAL DRIVE CARLISLE, PA 17013 SENDER: KMD REFERENCE: F1587312150 PS Form 3800 June 2000 RETURN Postage i RECEIPT Certified Fee I SERVICE Return Receipt Fee P- t Restricted Delivery 3.50_ ! Total Postage & Fees Q O ?, RKOR US Postal Service C IKORW ! Receipt for ID ,D Certified Mail No Insurance coverage Provided Do Not Use for international mail n r? _ C FJ L . _ U7? tom; c? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Chase Manhattan Mt Corp is the grantee the same having been sold to said grantee on the 4th day of Dec A.D., 2002, under and by virtue of a writ Execution issued on the 20th day of August, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3071, at the suit of Chase Manhattan Mt Corp against Benjamin A Schaeffer & Brandi M is duly recorded in Sheriff's Deed Book No. 255, Page 329. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 6k 3„ J L day of °G-? , A.D. 2002 of Deeds ftWd&o?0@e*CWftftW PA Chase ManhattanMortgage Corporation In The Court of Common Pleas of VS Cumberland County, Pennsylvania Benjamin A. Schaeffer and Brandi M. Writ No. 2002-3071 Civil Term Schaeffer Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on September 11, 2002 at 2:20 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Benjamin A. Schaeffer, by making known unto Benjamin Schaeffer, at 323 West Penn Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on September 11, 2002 at 2:20 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Brandi M. Schaeffer, by making known unto Brandi M. Schaeffer, at 323 West Penn Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2002 at 9:36 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Benjamin A. Schaeffer and Brandi M. Schaeffer located at 123 A Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Benjamin A. Schaeffer, by regular mail to his last known address of 323 West Penn Street, Carlisle, PA 17013. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Brandi M. Schaeffer, by regular mail to her last known address of 323 West Penn Street, Carlisle, PA 17013. This letter was mailed under the date of October 1, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Chase Manhattan Mortgage Corporation. It being the highest bid and best price received for the same, Chase Manhattan Mortgage Corporation of 3415 Vision Drive, Columbus, OH 43219, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $833.77, it being costs. Sheriffs Costs: Docketing 30.00 Poundage 16.35 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Certified Mail 2.07 Levy 15.00 Surcharge 30.00 Law Journal 330.50 Patriot News 241.75 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $833.77 Sworn and Subscribed to Before Me This 4 Day of 2003, A.D. r thonotary sw s: R. Thomas Kline, Sheriff By_b-188"(-(;" Real Estate Deputy 30 LTDL l . r??, -? i I7 5 OeL '33.Z3?S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-3071 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From BENJAMIN A. SCHAEFFER, 18 DONEGAL DRIVE, CARLISLE, PA 17013 AND BRANDI M. SCHAEFFER, 323 WEST PENN STREET CARLISLE, PA 17013 (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 $61,871.49 L.L. $30 Interest FROM 8/21/02 TO 12/4/02 (PER DIEM - $10.17) - $1,078.02 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $126.35 Other Costs Plaintiff Paid Date: AUGUST 20, 2002 CURTIS R. LONG Prothonota (Seal) Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale # 19 On August 30, 2002 the sheriff levied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, PA known and numbered as 123 A Street, Carlisle more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 30, 2002 By.J-A,,,?,- Real Estat? Deputy .0 1-3 C?=3 h . 4 P, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L 1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland La and State aforesaid, being duly sworn, according to law, deposes and says Law Journal, a legal periodical published in that the Cumberland orou h w Journal, of the County aforesaid, the Borough' , was established January g of Carlisle in the Coun periodical for the publication 2, 1 52, and da i has s' ?' the o State grated nc the local a!, as the official legal weekly in the said Count ince January been regul Y, and that the printed notice or publication attached hereto isrly exactly the same as was printed in the regular editions and issues of Journal on the following dates, the said Cumberland viz: Law OCTOBER 25, NOVEMBER 1, 8, 2002 Affiant further deposes that he is authorized to verify this state Law Journal, a legal periodical of general circulation, and that h ment by the Cumberland matter of the aforesaid notice or advertisement a is not interested in the subject statements as to time, place and character of publ cation are tallegations in the foregoing REAL ESTATE e' SSE NO. 19 Writ No. 2002-3071 Civil Chase Manhattan Mortgage Corporation vs. Benjamin A. Schaeffer and Brandi M, Schaeffer Atty.: Frank Federman ALL DESCRIPTION ground situate oTHAT CERTAIN lot A" Street in the of Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylva bounded and descri a bed, as follows. Oil O e the North by a 16 foot alley: merl by property now or for- t of Sadie A. e by Bream; on th South by "A" Street; and on the west Property now or formerly of George Kramer. HAVING a frontage of 25 feet on "A" Street and extending in depth 150 feet more or less to the alley on the North aforesaid Rog r M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this -?_day of NOVEMBE:R. 21 hUTARQAL SPEAL LOIS E. SNMER, fvataly PWI, Cars BOM, CuTimbedand County Aly Cwm, is Expiry Aft M 55, i HAVING thereon erected the West- ern half of a double brick dwelling house and the Western half of a double frame garage. The Eastern boundary line of the property hereby conveyed being the middle line of the partition wall between the East- ern half and the Western half of the said double brick dwelling and also the middle line of the partition wall between the garages on the said property. Talc Parcel #20-1798-082. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Benjamin A. his heirs and assigns by reason of the following: BEING THE SAME premises which Dixie S. Jumper and Simon P. Jumper, her husband by Deed dated 6/26/2000 and recorded 6/ 29/2000 in the County of Cumber- land in Deed Book 224 Page 324 conveyed unto Benjamin A. Schaef- fer and Brandi M. Schaffer, his wife. AND BEING THE SAME premises which Benjamin A. Schaeffer and Brandi M. Schaeffer, his wife by Deed dated 1/25/2002 and re- corded 3/26/2002 in the County of Cumberland in Deed Book 250 Page 4705 conveyed unto Benjamin A. Schaeffer, his heirs and assigns. } THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The 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 22nd and 29th day(s) of October and the 5th day(s) of November 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.E PUBLICATION ,? .;&--? ..................................................... COPY SALE #19 REAL ESTATE SALE No. 19 Writ No. 2002-3071 Civil Term Chase Manhattan Mort- gage Corporation vs Benjamin A. Schaeffer and Brandi M. Schaeffer Atty: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground situate on "A" Street in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: ON the North by a 16 foot alley; on the East by property now or formerly of Sadie A. Bream; on the South by" A" Street; and on the West by property now or formerly of George Kramer. Sworn to and subscribed before m /js 14th day o No r 2002 A.D. Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County NO ARY PUBLIC My Commission Expires June 6, 2006 Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 240.00 Probating same Notary Fee(s) $ 1.75 Total $ 241.75 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By ................................................................ HAVING a frontage of 25 feet on "A,, Street and extending in depth 150 feet more or less to the alley on the North aforesaid. HAVING thereon erected the Western half of a double brick dwelling house and the Western half of a double frame garage. The Eastern boundary line of the property hereby conveyed being the middle line of the partition wall between the Eastern half and the Western half of the said double brick dwelling and also the middle line of the partition wall between the garages on the said property. Tax Parcel #20-1798-082. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Benjamin A. Schaeffer, his heirs and assigns by reason of the following: BEING THE SAME premises which Dixie S. Jumper and Simon P. Jumper, her husband by Deed dated 6/26/2000 and recorded 6129/2000 in the County of Cumberland in Deed Book 224, Page 324 conveyed unto Benjamin A. Schaeffer and Brandi M. Schaffer, his wife. AND BEING THE SAME premises which Benjamin A. Schaeffer and Brandi M. Schaeffer, his wife by Deed dated 1/25/ 2002 and recorded 3/26/2002 in the County of Cumberland in Deed Book 250 Page 4705 conveyed unto Benjamin A. Schaeffer, his heirs and assigns. t, ?