Loading...
HomeMy WebLinkAbout02-3859FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL1NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff SHARON R. LANTZ 101 WEST GREEN STREET MECHANICBURG, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY Defendant(s) CIVIl, ACTION - I,AW COMPI,AINT IN MORTGAGE FORECI,O,qlIRE NOTICE **THIS FIRM 1S 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 wamed 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 #: 1516227878 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 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/19/01 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to WASHINGTON SAVINGS BANK, FSB which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1735, Page 1076. PLAINTIFF is now the legal holder of the mortgage and is in the process of formalizing an assignment of same. 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 4/1/02 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. The following amounts are due on the mortgage: Principal Balance Interest 3/1/02 through 8/1/02 (Per Diem $18.98) Attorney's Fees Cumulative Late Charges 9/19/01 to 3/1/02 Cost of Suit and Title Search Subtotal $92,351.66 2,922.92 1,250.00 129.68 $97,204.26 Escrow Credit 510.65 Deficit 0 O0 Subtotal (51 510 65) TOTAL $96,693.61 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $96,693.61, together with interest from 8/1/02 at the rate orS18.98 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PHELAN LLP By: ¢~ ~~ FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALL/NAN, ESQUIRE Attorneys for Plaintiff ~rec~lc~ Street, ~ If'Jm Fmmh Ward et t~e B(m~Jgh o~ Uet~ha~ic~bt~l, C<x.m~y ~f Gumbar~mcl and 8tara of PenneytvanM, ~ouno~ end W u car garage Pgme~ Being Known as: 100 West Green Street A D~VlD I-~EFf ~ hereby states the he/she is the SSISTANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORTATION mortgage servicing agent for the Plaintiff in this matter, the he/she is authorized to take the Verification, and the statements made in the foregoing Civil Action undersigned understands that th~s statement is made subject to are true and correct to the best of her/his knowledge, information and belief. The the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. A,.~,~$T~ S~CRETARy SHERIFF'S RETURN - CASE NO: 2002-03859 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE MANHATTAN MORTGAGE CORP VS LANTZ SHARON R HAROLD WEARY Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE LANTZ SHARON R REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the DEFENDANT at 1504:00 HOURS, on the 15th day of August at 101 WEST GREEN STREET 2002 MECHANICSBURG, PA 17055 by handing to TIM CLOUSER, ROOMMATE 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 2~ day of ~x~,~ ~ ~L A.D. ! d P~othonotar~ So Answers: R. Thomas Kline 08/16/2002 FEDERMAN & PHELAN Deputy Sh~fi 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 {2151 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff, SHARON R. LANTZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3859 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against SHARON R. LANTZ, 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 Plaintiff's damages as follows: As set forth in Complaint Interest from 8/2/02 to 9/17/02 TOTAL $96,693.61 $892.O6 $97,585.67 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. Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS 1NDICA/~D. . C_~ DATE: ~::~"'/, ~3..00~... ,_~/_.x.,? _'~' 3 PRO PROTHY FEDERMAI~ AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19 103 - 1814 (915) 56'4-7000 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. Attorney for Plaintiff FILE COPY : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY SHARON R. LANTZ : NO. 02-3859 Defendant (s) TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: SEPTEMBER 5, 2002 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, AiqD 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 NOTI E 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 SHERIFF,S RETURN - REGULJIR CASE NO: 2002-03859 P COMMONWEALTH OF PENlqSYLVkNIA: COUNTY OF CUMBERLAND CHASE N[ANHATTAN MORTGAGE CORP VS LANTZ SHARON R HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon the LJkNTZ SHARON R DEFENDANT , at 1504:00 HOURS, at 101 WEST GREEN STREET MECHANICSBURG, PA 17055 TIM CLOUSER, ROOMMATE a on the 15th day of August , 2002 by handing to 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 Affidawit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this day of A.D. So Answers: R. Thomas Kline 08/16/2002 FEDERMAN & PHELAN Deputy Prothonotary PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, SHARON R. LANTZ Defendant(s). No. 02-3859 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/17/02 to MARCH 5, 2003 (per diem -$16.04) TOTAL $97,585.67 $2,710.76 and Costs $100,296.43 ~RANK FED~R~I, 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. ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of West Green Street and North Frederick Street, in the Fourth Ward of the Borough of Mechanicsburg, Count.,,' of Cumberland and State of Pennsylvania, bounded and described as follov, s, to -,att: PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID pREMISES IS VESTED IN Sharon R. L~,a Singlewoman by Deed from Paul R. Berrier, joined by Molly Berrier, his wife dated 9/19/2001 and recorded 10/5/2001 in Deed Book 248, Page 3418. BEGINNING at a point at the corner of said West Green Street and North Frederick Street; tk~ence extending along the line of North Frederick Street, Northward, one hundred nineteen (I !.9) feet four (4) inches, more or less, to a point at the comer of a fifteen (155 foot alley; thence extending along said alley. Westward forty-one (4I) feet and three (3) inches, more or less, to the comer of Lot now formerly of William ~3. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or less, to West Green Street. aforementioned; thence extending along West Green Street, Ease,yard forty-five (455 feet, more or less, to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story, frame dwelling house and t~-o car known and numbered as 100 West Green Street, Mechanicsburg, Pennsylvania. FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CHASE MANHATTAN MORTGAGE CORPORATION 3415 VISION DRIVE Plaintiff, SHARON R. LANTZ Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS : CML DIVISION : NO. 02-3859 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 SHARON R. LANTZ is over 18 years of age and resides at, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~RANK~ FEDt~RM~N, I~SQIJIRE Attorney for Plaintiff 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, SHARON R. LANTZ Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3859 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: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~AN I~ FI~DI~IS,.~MAI~I ~E ~ 0U~RE Attorney for Plaintiff CitASF~ NI~i~OO~~TNN NIogSl2G3'G~ COP'I' OP'N plaintiff, s~o;q g. L~dqTz CO~g~ O~ CO~t~ON ~0.0~'3559 Defendal~t(s)' Pd?~IDp~x/¥T pL~S. Xj ,A;~IqNTo~ p. XJLE 3,29 o~e acdoa, b~ kts . · ~iatheab e~fito~ ~ pl~mU~ .... cite ~ot th _ -"~S~ LaSt ~o. eaMned, pie 1. reaSonablY nsc MECB~iCSB~RG, PA 1q055 o[ De[endant(.s) in the ~udgment" blame and address 2. . -dent is a recOrd lien on same as above ..... ~, creditor whose 3ua~ prop ~ ~as '-1 asceaam~ '- reaSOaaU ~ l~olle 4. Name and address of last recorded holder of every mortgage of record: Nalne None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 100 WEST GREEN STREET MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 9, 2002 DATE FEDERMAN, ESQUIRE Attorney for Plaintiff CHASE MANHATTAN MORTGAGE : CORPORATION : Plaintiff, : SHARON R. LANTZ : Defendant(s). : TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 CUMBERLAND COUNTY No. 02-3859 September 9, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THATPURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN A GAINST PROPERTY. ** Your house (real estate) at ~ 100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055, is scheduled to be sold at the Sheriff's Sale o,,n ,M.A, R~CH _5 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, canisle, PA 17013, to enforce the court judgment of $97,585.67 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. ~IOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI,I ,; To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215} 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 O'l'HEltt RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAI(F, 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 mount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of V~'est Green Street and North Frederick Street, in the Fourth Ward of the Borough of Me:hanicsburg. County of Cumberland and State of Pennsylvania. bounded and described as follows, to v, it: BEGINNING ar a point at the comer of said West Green Street and North Frederick Street: thence extending along the tine of North Frederick Street, Northward, one hundred nineteen (119) feet four (4) inches, more or less, to a point at the comer of a fifteen (I5~ foot alley: thence extendin,, alon,, sa~d alley, Westward forty-one (41) feet and three (3) inches, more or less, to the comer of Lot now o~ formerly of William O. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or tess, to West Green Street. aforementioned; thence extending along West Green Street, Eastward forty-five (45) feet, more or less. to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story frame dwelling house and two car gar~g~__e known and numbered as 100 West Green Street, Mechani~sburg, Pennsylvania. PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID PRElvlISES IS VESTED IN Sharon R. La~,a Singlewoman by Deed from Paul R. Berrier, joined by Molly Berrier, his wife dated 9/19/20ff1 and recorded 10/5/2001 in Deed Book 248, Page 3418. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE M.a~NHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Comm % Atty Paid $111.90 Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) Due Prothy $1.00 Other Costs CURTIS R. LONG Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 FEDERMAN AND PHELAN, L.L.P. One Penn Center at Suburban Station 1617 John F. Kennedy Suite 1400 Philadelphia, PA 19103.1814 215-563.7000 Main Fax 215-563.5534 Kristin.demum~fedphe-pa.com Kristin M. DeMuro Legal Assistant, Ext. 1283 November 7, 2002 Via Telefax (717)240-6397 Representing Lenders in Pennsylvania and New Jersey Memorandum To: Office of the Sheriff CUMBERLAND County Atth: Real Estate Dept. Re: CHASE MANHA'I-~'AN MORTGAGE CORPORATION v. SHARON R. LANTZ No. 02-3859 Premises: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 Dear Sir or Madam: Please STAY the Sheriff's Sale of the above referenced propeAy which is scheduled for 315/03, return the odginal writ of execution to the Prothonotary's office and refund any unused money to our office. The Defendant(s) filed a Chapter 13 Bankruptcy (#02-05673) on 10/16/02. No funds were received in consideration for the stay. Should you have any questions or concerns do not hesital~ to contact me. Very truly yours, Kristin M. DeMuro WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Corem % Due Prothy $1.00 AttyPaid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) CURTIS R. LONG Prothono~ Cr~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 TRUE COPY FROM RECORD Tc.s~im~r~y wh~r~o~, I here unto s~t my hand Pr ohot - ' Real Estate OnOcto~b 29, 2002 the sheriffle defendant's ,'st in Mechanicsburg known and numbered Mechanicsburg, fully filed with this by this 12 upon the situated in ~erland County, PA West Green Street, on Exhibit "A" incorporated herein. Date: ,2002 By: Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) CURTIS R. LONG Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 TRUE COPy FROM RECORD tn Testimony v~h~reof, ! here Irate set my hand ~lld ilia S~I 01 ~ ~ ........ day o , ' Real Estate Sale # 12 On October 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA known and numbered as 100 West Green Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) Y°u are als° 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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 CURTIS R. LONG Prothono~,~ "~ /~(-~ O..~ o · Ct~ Deputy Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand ~d the ~f said Counkat Carlisle, Pa. Real Estate Sale # 12 On October 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA known and numbered as 100 West Green Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 &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 defendam (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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Corem % Due Prothy $1.00 Arty Paid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 # 12 On October 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA known and numbered as 100 West Green Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 gamishee and is enjoined as above stated. Amount Due $97,585.67 L.L $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Corem % Due Prothy $1.00 Atty Paid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) CURTIS R. LONG Prothono,~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 COPY FROM RECORD ,. ~,.,~,r~., I h~,re unt~ ,-~' my hand P~thonota~ ' - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff (s) From SHARON R. LANTZ, 101 WEST GREEN STREET, MECHANICSBURG, PA 17055 (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 $97,585.67 L.L. $.50 Interest FROM 9/17/02 TO MARCH 5, 2003 (PER DIEM - $16.04) - $2,710.76 AND COSTS Atty's Comm % Due Prothy $1.00 AttyPaid $111.90 Other Costs Plaintiff Paid Date: SEPTEMBER 17, 2002 (Seal) CURTIS R. LONG REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIARE 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 TRUE COPY FROM RECORD ..... -,,,~ s~t my hand 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. SHARON R. LANTZ Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3859 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: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant 0 Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Attorney for Plaintiff .So. CH~SE MANHATTAN MORTGAGE CORPORATION Plaintiff, Vo SHARON R. LANTZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-3859 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) 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 ~100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055. 1° Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 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: maine None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) Natne 5. Name and address of every other person who has any record lien on the property: 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may he affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 100 WEST GREEN STREET MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 9, 2002 DATE Attorney for Plaintiff ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of West Green Street and North Frederick Street, in the Fourth Ward of the Borough of Mechanicsburg. Count.,,' of Cumberland and State of Pennsylvania. bounded and described as follows, to ,a it: BEGINNING at a point at the comer of said West Green Street and North Frederick Street; ~ence extending along the line of North Frederick Street, Northward, one hundred mneteen (l i9) feet four (4) inches, more or less, to a point at the comer of a fifteen (155 foot alley thence extendin,2 alonz said~- alley, Westward forty-one (41) feet and three (o) inches, more or less, to the comer of Lot now formerly of William O. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or less, to West Green Street, aforementioned; thence extending along West Green Street, East~vard forty-five (45) feet, more or less, to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story, frame dwelling house and t~vo car garw~_e known and numbered as 100 West Green Street, Mechanicsburg, Pennsylvania. PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID PREMISES IS VESTED IN Sharon R. L~,a Singlewoman by Deed from Paul R. Berrier, joined by Molly Berrier, his wife dated 9/19/2001 and recorded 10/5/2001 in Deed Book 248, Page 3418. 17HASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. SHARON R. LANTZ Defendant(s). TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 CUMBERLAND COUNTY No. 02-3859 September 9, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, B UT ONLY ENFORCEMENT OF A LIEN A GAINST PROPERTK ** Your house (real estate) at ~ 100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055;~ is scheduled to be sold at the Sherifl's Sale on MARCH 5~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97~585.67 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 Sherifl~s Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: {215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of West Green Street and North Frederick Street, in the Fourth Ward of the Borough of Mechanicsbur~, County' of Cumberland and State of Pem-isylvania, bounded and described as foltows, to wit: PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID PR_Eh, riSES IS VESTED IN Sharon R. L~,a Singlewoman by Deed from Paul and recorded I0/5/2001 in Deed R. Berrier, joined by Molly Berrier, his wife dated 9/19/2001 Book 248, Page 3418. BEGINNING at a point at the comer of said West Green Street and North Frederick Street: thence extending along the line of North Frederick Street, Northward, one hundred nineteen (l 19) feet four (4) inches, more or less, to a point at the comer of a fifteen (15) foot alley; thence extending along said alley, Westward forty-one (41) feet and three (3) inches, more or less, to the comer of Lot now off" fmmerly of William O. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or less, to West Green Street. aforementioned; thence extending along West Green Street, Eastward fort~. -five (45) feet, more or less, to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story flame dwelling house and txvo car known and numbered as 100 West Green Street, Mechanicsburg, Pennsylvania. CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. SHARON R. LANTZ Defendant(s). TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 CUMBERLAND COUNTY No. 02-3859 September 9, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055_a is scheduled to be sold at the Sheriffs Sale on MARCH 5~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97~585.67 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 complizrace with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges. costs and reasonable attorney's fees due. To find out how much you must pay, you may call: {215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 ~nay 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 Sheriffthe 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. 3?his schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of Vv'est Green Street and North Frederick Street, in the Fourth Ward of the Borough of Mechanicsburg, County' o~~ Cumberland and State of Pennsylvania, bounded and described as follows, to ~it: BEGINNING at a point at the comer of said West Green Street and North Frederick Street: ~enc;.~ extending along the tine of North Frederick Street, Northward, one hundred nineteen ('~ 19) feet four (4) inches, more or less, m a point at the comer ~f a fifteen (15) foot alley; thence extending along alley, Westward forty-one (41) feet and three (.~) inches, more or less, to the comer of Lot now or formerly of William O. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or tess, to West Green Street, aforementioned; thence extending along West Green Street, Easr~vard forty-five (45) feet, more or less, to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story frame dwelling house and m-o car g~.~'~ known and numbered as 100 West Green Street, Mechanicsburg, Pennsylvania. PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID PREMISES IS VESTED IN Sharon R. L~,a Singlewoman by Deed from Paul and recorded 10/5/2001 in Deed R. Berrier, joined by Molly Berrier, his wife dated 9/19/200I Book 248, Page 3418. CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. SHARON R. LANTZ Defendant(s). TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 CUMBERLAND COUNTY No. 02-3859 September 9, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055_a is scheduled to be sold at the Sheriffs Sale on MARCH 5~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97~585.67 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 SheriWs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. 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 Sheriffthe 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 Sheriffwithin 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 fights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of West Green Street and North Frederick Street, in the F~urth Warct of the Borough of Mechanicsburg, Count.,,' of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: .J PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 TITLE TO SAID PREMISES IS VESTED IN Sharon R. L~,a Singlewoman by Deed from Paul 9/19/200 I R. Berrier, joined by IvIolly Berrier, his wife dated and recorded 10/5/2001 in Deed Book 248, Page 3418. BEGINNING at a point at the comer of said West Green Street and North Frederick Street; ~ence extending along the line of North Frederick Street, Northward, one hundred nineteen (l [9) feet four (4) inches, more or less, to a point at the comer of a fifteen (15) foot alley; thence extending along said alley, Westward forty-one (41) feet and three (3) inches, more or less, to the comer of Lot now of" formerly of William O. Myers; thence extending along the line of said Lot now or formerly of William O. Myers, Southward one hundred nineteen (119) feet, more or less, to West Green Street, aforementioned; thence extending along West Green Street, Eastward fort?-five (45) feet, more or less, to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story frame dwelling house and two car known and numbered as 100 West Green Street, Mechanicsburg, Pennsylvania. CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff, V. SHARON R. LANTZ Defendant(s). TO: SHARON R. LANTZ 101 WEST GREEN STREET MECHANICSBURG, PA 17055 CUMBERLAND COUNTY No. 02-3859 September 9, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 100 WEST GREEN STREET~ MECHANICSBURG~ PA 17055~ is scheduled to be sold at the Sheriffs Sale on MARCH 5~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97~585.67 obtained by CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 R/GHTS EVEN IF THE SHF~RIFF'S SALE DOES TAKE PLACE,-- 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only 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 Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN house or lot of ground, situate in the Northwest corner of West Green Street and North Frederick Street, in the Fourth Ward of the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, to v~it: BEGINNING at a point at the comer of said West Green Street and North Frederick Street: tk, ence extending along the line of North Frederick Street, Northward, one hundred nineteen (I 19) feet four (4) inches, more or less, to a point at the ailey, Westward forty-one (41) feet andc°mer o~f a fifteen (15) foot alley; thence extendinz alon~ said tltree (o) inches, more or less,' to the comer of ~-ot nc~w o formerly of William O. Myers; thence extending along the line of said tot now or fom~erly of William O. Myers, Southward one hundred nineteen (119) feet, more or less, to West Green Street, aforementioned; thence extending along West Green Street, East~vard forty-five (45) feet, more or less. to the point and place of beginning. HAVING THEREON ERECTED a two and one-half story frame dwelling house and two car g ~ar~g~e known and numbered as 100 West Green Street, Mechani~sburg, Pennsylvania. PREMISES BEING: 100 WEST GREEN STREET, MECHANICSBURG, PA 17055 T~ITLE TO SAID PREMISES IS VESTED IN Sharon R. I_~/, a Singlewoman by Deed from Paul R. Berrier, joined by Molly Berrier, his wife dated 9/19/7001 and recorded I0/5/2~)01 in Deed Book 248, Page 3418. - FEDERMAN AND PHELAN, L.L.P. One Penn Center at Suburban Station 1617 John F. Kennedy Suite 1400 Philadelphia, PA 19103-1814 215-563-7000 Main Fax 215-563-5534 Peter J. Tremper Legal Assistant, Ext. 1481 May 10, 2004 Office of the Sheriff Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 ATTENTION: JODY Repv; :ating Lenders in Penn · :.vania and Nel~Je .fsi,y. FAX [7-240-6397 Re: CHASE MANHATTAN MORTGAGE CORPORATIOI~ v. SHARON R. LANTZ No. 02-3859 Premises: 100 WEST GREEN STREET, MECHANICS], RG, PA 17055 Dear Jody: Please STAY the Sheriff's Sale of the above referenced pre; rty, which is scheduled for September 8, 2004._ A short sale of the property was completed in cousiderafior ir the stay. Please reO~m the original writ of execution to the Pmthonol ~ ii' as soon as possible. Very truly yours, ' Peter J. Tremper cc: AMERICA'S SERVICING COMPANY Attention: FileNo. 1172002697 Vr/ /,w.I copy FEDERMAN AND PHELAN By: DANIEL SCHMIEG IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (.215) 563-7000 CHASE MANHATTAN MORTGAGE CORP. Plaintiff VS, SHARON R. LANTZ Defendant(s) ATTORNEY FOR PLAINTIFF County Court of Common Pleas CIVIl. DIVISION NO. 02-3859 PRAFCIPI= TH RATIRFY JUD~*~MI=NT WITHOUT pRFJUI~ICI= TO THE PROTHONOTARY: Kindly satisfy the Judgment which was entered on 9/17/02 against SHARON R. LANTZ, Defendant(s), in the amount of 97,585.67 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. ..E~N~_ SCH ~/~tEG,-~'SQU I RE/.~ Attorney for Plaintiff Dated: July 29, 2004