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Home My WebLink About07-3377A4cCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company P.O. Box 8604 Elmhurst, IL 60126 V. Michael L. Coyle a/k/a Michael Lee Coyle 391 Crossroad School Road Newville, PA 17241 and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 426 Dogwood Court Carlisle, PA 17013 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 07 --?377 01U6 CCIVIL ACTION/MORTGAGE FORECLOSURE NOTICE AVISO 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una conparencia escrita o en persona o ccn un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company P.O. Box 8604 Elmhurst, IL 60126 V. Michael L. Coyle a/k/a Michael Lee Coyle 391 Crossroad School Road Newville, PA 17241 and Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 0,1 - 3 51 LL, u- Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 426 Dogwood Court Carlisle, PA 17013 CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Michael L. Coyle a/k/a Michael Lee Coyle, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 391 Crossroad School Road, Newville, PA 17241. 3. The Defendant is Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 426 Dogwood Court, Carlisle, PA 17013. 4. On 02/22/2005, mortgagors 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 Book1898, Page 509. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 391 Crossroad School Road, Newville, PA 17241. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/22/2006 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. 7. The following amounts are due on the mortgage: Principal Balance $ 182,852.78 Interest through 06/05/2007 $ 13,114.32 (Plus $ 41.24 per diem thereafter) Attorney's Fee $ 9,142.64 Late Charges $ 935.00 Corporate Advances $ 1,385.00 Title Search $ 200.00 GRAND TOTAL $ 207,629.74 8. 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 Sheriff s Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $207,629.74, together with interest at the rate of $41.24 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE RG AND CONWAY, P.C. BY: _,2 Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 06/20/2000 AND RECORDED 06/23/2000, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 223 AND PAGE 1041. TAX PARCEL ID: 46-08-0587-036 Exhibit q (? '?. --..? 1 ? 4 (? 'r` ? ?,, : ? ?? '? ? ? ?,_; _v` cc.? G .-G SHERIFF'S RETURN - REGULAR t CASE NO: 2007-03377 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS COYLE MICHAEL L ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COYLE MICHAEL L AKA MICHAEL LEE COYLE the DEFENDANT , at 1140:00 HOURS, on the 12th day of June , 2007 at 391 CROSSROAD SCHOOL ROAD NEWVILLE, PA 17241 MICHAEL COYLE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.52 Affidavit .00 Surcharge 10.00 .00 I B?oRlo9 `?"' ? 39.52 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 06/29/2007 MCCABE WEISBERG,)NWZ?Y By: eputy Sheriff A. D. SHERIFF'S RETURN - REGULAR t CASE NO: 2007-03377 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS COYLE MICHAEL L ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon rnVT,F: ATMPA T. AKA ATMRA LYNN COYLE the DEFENDANT , at 2026:00 HOURS, on the 26th day of June at 426 DOGWOOD COURT CARLISLE, PA 17013 by handing to 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 9.60 Affidavit .00 Surcharge 10.00 .00 25.60 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 06/29/2007 MCCABE WEISBERG CONWAY By. day Deputy Sheri f A. D. 2007 SHERIFF'S RETURN - NOT FOUND e CASE NO: 2007-03377 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS COYLE MICHAEL L ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named COYLE AUDRA L AKA AUDRA LYNN unable to locate Her in his t' nNAT)T T TMM _ M()D'T Pa nV V ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT COYLE but was bailiwick. He therefore returns the NOT FOUND as to the within named DEFENDANT COYLE AUDRA L AKA AUDRA LYNN COYLE 391 CROSSROAD SCHOOL ROAD NEWVILLE, PA 17241 DEFENDANT DOES NOT LIVE AT 391 CROSSROAD SCHOOL ROAD Sheriff's Costs: So answe Docketing 6.00 Service .00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 S(?bq?b7 21.00 MCCABE WEISBERG CONWAY 06/29/2007 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-03377 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS COYLE MICHAEL L ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TENANT/OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT , TENANT/OCCUPANT 391 CROSSROAD SCHOOL ROAD NOT FOUND , as to NEWVILLE, PA 17241 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: So answers --''' Docketing 6.00 Service .00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 1/60-1 4, 21.00 MCCABE WESIBERG CONWAY 06/29/2007 Sworn and Subscribed to before me this day of A. D. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $207,629.74 Interest from 6/6/2007 - 8/07/2007 $ 2,598.12 TOTAL 10,227.86 BY: CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUI MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE AND NOW, this A/ day of Ily , 2007, Judgment is entered in favor of Plaintiff, Household Finance Consumer Discount Company and against Defendant(s) Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle and damages are assessed in the amount of $210,227.86, plus interest and costs. BY THE PROTHONOTARY: 10 --' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company VS. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND: The undersigned, being duly sworn according to law, deposes and says that the Defendant is 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; and that the Defendant(s), Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle, is over eighteen (18) years of age, and resides at 391 Crossroad School Road, Newville, PA 17241. CONWAY, P.C. BY: SWORN TO AND SUBSCRIBED BEFORE ME THIS 7th DAY OF Aug, 2007. T- /NOTARY PUBLIC Plaintiff TERRENCE J. McCABE, ESQU MARC S. WEISBERG, ESQUI EDWARD D. CONWAY, ESQ MARGARET GAIRO, ESQUIRE COMP. ONWrALTH of PENNSYLVANIA NOTARIAL SEAL GI_v^RiA 0. tATCHELL, Notary Pubic C;ty of PfWad*", Phla. Cody My Comn?ssion FynW a tune ,7 2611 ' Request for Military Status Department of Defense Manpower Data Center e e Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUL-17-2007 06:38:24 Last Name First/Middle Begin Date Active Duty Status Service/Agency COYLE Michael C Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. &tk Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/fau/t)is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc Select 7/17/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: UDPDZRJGVX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/17/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 JUL-17-2007 06:36:20 Last Name First/Middle Begin Date Active Duty Status Service/Agency COYLE Audra L Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 01 $11,4- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/17/2007 Request for Military Status Page 2 of 2 See: http://www.defenselink_milif4d/pis/PC09SLDR.htm1 Report !D: UL ULAILICW https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/17/2007 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". Y, P.C. CONWA- SWORN TO AND SUBSCRIBED BEFORE ME THIS 7th DAY OF Aug, 2007. 11 BY:??-< y,' Q--' Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIR MARC S. WEISBERG, ESQUIRE_ EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ARY Pr r?^rcvy ALTn yr s ?...-- - PtOTARiAI SF1?L GLOR1'+ D.1M7C11L ?Fabric ..? ? ??as Jrne 2, ?411t OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary July 17, 2007 To: Michael L. Coyle a/k/a Michael Lee Coyle 391 Crossroad School Road Newville, PA 17241 Household Finance Consumer Discount Company VS. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a3da Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGIIN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 MCCABE, WEISBERG AND CONWAY, C. i BY/? ??- Attorneys for Plaintiff TERRENCE J. McCABE, E MARC S. WEISBERG, ESQ EDWARD D. CONWAY, ESQ RE MARGARET GAIRO, ESQUIRE TJM/kpa OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary July 17, 2007 To: Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 426 Dogwood Court Carlisle, PA 17013 Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y LISTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMA06N ACERCA DE EMPLEAR A UN ABOGADO. S1 USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS EL£GIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue- Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: '?V<- Atto eys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE TJM/kpa VERIFICATION The undersigned, , ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to aut??iti CONWAY, P.C. BY: for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUII? MARGARET GAIRO, ESQUIRE C U r' 771. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Michael L. Coyle a/k/a Michael Lee Coyle 391 Crossroad School Road Newville, PA 17241 Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Curtis R. Long Prothonotary If you have any questions concerning this Judgment, please call McCabe. Weisberg and Conway. P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 426 Dogwood Court Carlisle, PA 17013 Household Finance Consumer Discount Company VS. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curtis R. Long Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg, and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 07-3377 Civil Term Household Finance Consumer Discount Company V. AMOUNT DUE: $210,227.86 Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle INTEREST: from 8/8/2007 - 12/5/2007 $4,147.20 at $34.56 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 391 Crossroad School Road Newville PA 17241 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: N 7 2 1 Signature: ?'?'' ? Print Name: MCCABE, WEISBERG AND Address: 123 S. Broad Street. Suii Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. Y IV 'R! ? S j C n n z b a y r r aj WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-3377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Household Finance Consumer Discount Company Plaintiff (s) From Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 391 Crossroad School Road Newville, PA 17241 (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 axe directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $210,227.86 L.L. $.50 Interest from 8/8/2007-12/5/2007 $4,147.20 at $34.56 Per Diem Atty's Comm % Due Prothy $2.00 Atty Paid $226.12 Other Costs Plaintiff Paid Date: August 14, 2007 (Seal) REQUESTING PARTY: Name Edward D. Conway, Esq. McCabe, Weisberg and Conway, P.C. Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215)790-1010 Curtis R. Long, Prothonotary--' Deputy Supreme Court ID No. A w McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 07-3377 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 391 Crossroad School Road, Newville, PA 17241 (Tax Parcel #46-08-0587- 036), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: Name Address Michael L. Coyle a/k/a Michael 391 Crossroad School Road Lee Coyle Newville, PA 17241 Audra L. Coyle a/k/a Audra 426 Dogwood Court Lynn Coyle a/k/a Audra Coyle Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Name Address Michael L. Coyle a/k/a Michael 391 Crossroad School Road Lee Coyle Newville, PA 17241 Audra L. Coyle a/k/a Audra 426 Dogwood Court Lynn Coyle a/k/a Audra Coyle Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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 Address Tenants 391 Crossroad School Road, Newville, PA 17241 Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. Section 4904 relating to unswom falsification to authorities. 11 August 7, 2007 McCA"EISBR , A" CONWAY, P.C. BY: _'V GAG Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE) MARGARET GAIRO, ESQUIRE 7T- L nI i McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company VS. Cumberland County Court of Common Pleas Number 07-3377 Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 391 Crossroad School Road Newville, PA 17241 Your house (real estate) at 391 Crossroad School Road, Newville, PA 17241 (Tax Parcel #46-08-0587-036) , is scheduled to be sold at Sheriffs Sale on December 5, 2007 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $210,227.86 obtained by Household Finance Consumer Discount Company against you. 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 canceled if you pay to Household Finance Consumer Discount Company, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P. C. at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 2 4 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 McCabe, Weisberg and Conway, P.C. at (215) 790- 1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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. You have a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 t-J r,? ^ F5 ....J4 c - LEGAL DESCRIPTION ALL 7SAT C.LR' m tmja or i=d situate in West Peambaro'tb nship. CumberUnd Comttr, VMnsylrardo, amn rulkr bouvdcd arrd door1W as Lot 20 on tM 8ubditdsion Plan for CrW R"d School Road ftta ts. s;4 prep and by Sb xky J=m1e jo, R.S., dated $aptember 29, 29P and mmdcd 5a Cumbcrlwrd t'mmty PWn Soak 66, Pop 198. w%d iL rdw bounded and daafl ed as follows: MQIN=o at a. point to die oftthtn=t dcdle tad daht afwV Rea of Crov* Roafl ilchod Rd (I- 43al at tiro AWAbg Hm botwtm Lot No. 20 and Lat Ha*. 21 and 26 on the herokwbow rderdW tad SubdhritIM Man; theft e QqnS said crnWSM Tina, NorM 29 dgp=n 10 ndauws $1 $eoows Wcat, 57$.71 ket to alt Ima pfd; theaee alc rrg Lawb mw or fbCt wly of M. ViW. North 61 degrees 30 ramutes 00 aoconds rU41%02 feet to a polsit; dmnoa alcog the d1Y1&dg Hu bebamm Lot Kos. 19 and 20 oa said Platt. South 29 dcaftG IS rrnacim 51 mmuds took 57!5.53 &0 to a pta act In tfta nordmu d edla&W dem of way Um of Cmw Road Sbltoo! Road; Owme x3mW oltid rltht d vV Pao South 60 dek"s 41 atin%Ats 09 scacsade We*4150 feet to st paint. the phum of 2001MUNG. CONTAINING 1. 18 acres. m1mimc of dedkated A& of way. SUBJECT to mzUiCdl" and tights of tasty and owm rtts of rew d and as r4tod In ptiw deoft. BEING KNOWN AS 391 Crossroad School Road, Newville, PA 17241 Being the same premises which Douglas E. Phillips, by deed dated the 6/20/2000, and recorded 6/23/2000 in the Office of the Recorder in and for Cumberland County in Deed Book 223, Page 1041, granted and conveyed to Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle, in fee. TAX MAP PARCEL NUMBER: 46-08-0587-036 .4 € fib McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE -ID#16496 MARC S. WEISBERG, ESQUIRE -ID#17616 EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID#34419 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount Company Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Number 07-3377 Civil Term AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: SS: COUNTY OF PHILADELPHIA : The undersigned, hereby certifies that he is the attorney for Plaintiff in the within matter, being duly sworn according to law, deposes and says that a true and correct copy of the Notice of Sheriff's Sale was served upon the Defendant, Audra L. Coyle a/k/a Audra. Lynn Coyle a/k/a Audra Coyle, by regular mail, certificate of mailing, and certified mail, return receipts requested, dated August 24, 2007, and addressed to 391 Crossroad School Road, Newville, PA 17241, Lansdowne, PA 19050. The regular mail was never returned, and the certified mail was personally signed for by the Defendant Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle on August 21, 2007. A true and correct copy of the letter, certificate of mailing, certified receipt numbers 7005-1820-0002-3156-0622, signed green card is attached hereto, made part hereof, and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS 59 4AY OF , 2007. [M- . CaAC NOTARY PUBLIC MCCABE, WEISBERG AND CONWAY, P.C. ?i BY: Attorneys for Plaintiff TERRENCE J. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE W1'AXi ii SEAL ? HdA@k NOWY hbHo 14•1=WNbR W*WMW& 28,1409 LAW OFFICES *** McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE SUITE 600 MARC S. WEISBERG** 216 HADDON AVENUE EDWARD D. CONWAY SUITE 2080 WESTMONT, NJ 08108 MARGARET GAIRO 123 SOUTH BROAD STREET (856) 858-7080 LISA L. WALLACE+t PHILADELPHIA, PA 19109 FAX (856) 858-7020 BRENDA L. BROGDON* (215) 790-1010 MICHELLE M. MONTE ^^ FAX (215) 790-1274 SUITE 205 MONICA G. CHRISTIE + 53 WEST 36711 STREET FRANK DUBIN NEW YORK, NY 10018 ANDREW L. MARKOWITZ (917) 351-1188 ROBERT W. CUSICK * FAX (917) 351-0363 BONNIE DAHL* ANGELA M. MICHAEL) SUITE 302 SCOTT TAGGART* 8101 SANDY SPRING ROAD DEBORAH K. CURRAN*• LAUREL, MD 20707 LAURA H.G. O'SULLIVANt- (301) 490-1196 STEPHANIE H. HURLEY- FAX X (3 (3011) ) 490-1568 SUITE 206W 6800 JERICHO TURNPIKE • Licensed in PA & NJ SYOSSET, NY 11791 •• Licensed in PA & NY (917) 351-1188 ^ Licensed in NY Licensed in NJ FAX (917) 351-0363 Licensed in PA & WA •" Licensed in PA. NJ & NY Of Counsel t Licensed in NY & CT . Licensed in MD & DC PITNICK & MARGOLIN, LLP^ - NY Licensed in MD DEBORAH K. CURRAN • - MD & DC Managing Attorney for for NY MD i Managing Attorne LAURA H.G. O'SULLIVAN• - MD & DC STEPHANIE H. HURLEY-- - MD JOSEPH F. RIGA* - PA & NJ August 15, 2007 Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 391 Crossroad School Road Newville, PA 17241 Re: Household Finance Consumer Discount Company v. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle CUMBERLAND COUNTY C.C.P. NUMBER 07-3377 Civil Term Dear Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle: Enclosed please find a true and correct copy of a Notice of Sheriff's Sale regarding the above-captioned matter. Very truly yours, `S Z?_ alb? Maleekah Wiltbanks, Legal Assistant to McCABE, WEISBERG AND CONWAY, P.C. TJM/mwi Enclosures Exhibit SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7005 1820 0002 3156 0622 RETURN RECEIPT REQUESTED This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. i 4 if AervtnGt? D~ to reveme non nd by f NWM) C. R'iRa!s i 6-01 6 Your name a d d ¦ so that we c? ? t> of the rr?' g, 17 { ipgrn ¦ Attach tfiis , if space ???' or on the (3 W D. b ? adder ??, ttie1? K YES, enter , wy to, 1. ArtiC? ?? + v? 1 r?55C s. Md a a g tOf N DA- f CS0110. 13 yes pa5 .013 0622 2. Article Mun'OW tT"' ? FW;,rr? Receipt PS Form X811, F 2004 ..... ..... b ??'bitA :li v nr-DTIFIP- ) VILl (Dott:estlo H7arl 0nl):: ??r<3 e F'rt t,tld -D Ln a m ru 0 0 0 0 ti co r-I Ln 0 0 r- itA r ? ? v n h a? n Z -?a L d p r J C3 0 O. ?y e C? et) r col o ? nnr?? ell- ?] ce IJ O `„? ? o u C 7r+ r ? ? t s ft a ? ? A 9 S .Z V 5{ O a ? 3 S r 3 ? g F ;' ?. 'Tt tJ"t 50 ' T C h --<K p 4: y r } C's 2 ti ^n F, s Y ? F M1 x ,'", E a 9 .K s p r. a r-? .,.?s ? tr,.% ?.. tJ?? 3-fi ? '.??_ ??- '? ?1. ? 5? ,,..., ?; :`_ ? .?- .:,? t,,. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE -ID#16496 MARC S. WEISBERG, ESQUIRE -ID#17616 EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID#34419 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (M) 790-1010 Household Finance Consumer Discount Company V. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 07-3377 Civil Term AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: SS: COUNTY OF PHILADELPHIA : The undersigned, hereby certifies that he is the attorney for Plaintiff in the within matter, being duly sworn according to law, deposes and says that a true and correct copy of the Notice of Sheriff's Sale was served upon the Defendant, Michael L. Coyle a/k/a Michael Lee Coyle, by regular mail, certificate of mailing, and certified mail, return receipts requested, dated August 15, 2007, and addressed to 391 Crossroad School Road, Newville, PA 17241. The regular mail was never returned, and the certified mail was signed for by the Defendant Michael L. Coyle a/k/a Michael Lee Coyle on August 28, 2007. A true and correct copy of the letter, certificate of mailing, certified receipt numbers 7005-1820-0002-3156-0615, signed green,card is attached hereto, made part hereof, and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS3AAY OF &t po( , 2007. V"( /,/ , X? ??C' NOTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ) I 0TAI"LSLAI. IYiANd dk,W"yPW& s?1?1lWVi?i'hibMlift Co" 11??o?r?b?apinrlAN?M3& M TERRENCE J. MCCABE*** MARC S. WEISBERG** EDWARD D. CONWAY MARGARET GAIRO RITA C. BUSCHER*t MONICA G. CHRISTIE +t FRANK DUBIN BRENDA L. BROGDON* SEAN GARRETT*+ BONNIE DAHL* BETH L. THOMAS SVEN E. PFAHLERT* JOSEPH VACCARO* MICHELE DELILLEA CATANIA TRIGO^ LAW OFFICES MCCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 SUITE 600 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 205 53 WEST 36"' STREET NEW YORK, NY 10018 (917) 351-1188 FAX (917) 351-0363 JOSEPH F. RIGA* Of Counsel • Limnad in PA R NJ •• Limucd in PA & NY •+ Li-wW in PA & NM ••• Liwwd is PA. NJ R NY t Licensed in NY & CT ^ Licensed in NY Mangging Attanny for NJ + Managing Anormy for NY August 15, 2007 Michael L. Coyle a/k/a Michael Lee Coyle 391 Crossroad School Road Newville, PA 17241 Re: Household Finance Consumer Discount Company v. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle CUMBERLAND COUNTY C.C.P. NUMBER 07-3377 Civil Term Dear Michael L. Coyle a/k/a Michael Lee Coyle':',, Enclosed please find a true and correct copy of a Notice of Sheriffs Sale regarding the above-captioned matter. Very truly yours, Z)-;? G?-if-'? -?> Maleekah Wiltbanks, Legal Assistant to MCCABE, WEISBERG AND CONWAY, P.C. TJM/mwi Enclosures ExhiNt A SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7005 1820 0002 3156 0615 RETURN RECEIPT REQUESTED This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. VW&Oo se and aftem an to It WO can WkW 00 oard ID YOU. Vft cad to to tack of the rr Apism, #w to* ff ommm J L U-0 .5 5; rOqd o ?3 ROM ROO@" for Mul e E3 kwxod and t3 ao: 4- RMbkftd D*m r aft Pdo p *a 7005 1820 0002 3156 0615 Rabam PACO t' t teao Eblobiltn Ln a Ln C O ?r F a m _ ti C7 OerWisd Fes a C3 ?R.aipt ru o.-wy ?don,c+r+ r-R fiw Psshps a Fees C3 / r- A.;& AM L N.. MbitA t' Flo O o a ti .o •L 0 8 0 a v O U ? ? I 'v o oU 4» 0 H m L ¢3 E ? cd v U pats N til y$1 e $ q pp q a ?35m N ?I O sy? p 3 i1R N e3A Ln LL C3 G i <L W a NpZ 9 Be non oo ? ? ? ? B S n ? B a a R?3 O ~ ? U as A 0 ell CZ V ? o U c ° a ?-a y ; U b y a a U U ?? 1 > 1o? Mz QMz 0 o Fz'?: z B d :t c> z r a n a 3 GW (? 4 z x x ? ? z ? U2 c ? r-. N ? V a d N f1. '"' ) N Y a C .Q a m m o` a F a c E 0 U °o N A Y w M 0 w a. 0 ?J c -n McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARETCAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Ilousehold Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 AFFIDAVIT OF SERVICE I, the undersigned, Esquire, attorney for the Plaintiff in the within matter, hereby ccrtily that on the 3`d day of October 2007, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hercol and marked as Exhibit "B." MCC , WEISBE AND C NWAY, P.C. BY: ??- Attorneys for Plaintiff TERRF,NCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE SWORN TO AND SUBSCRIBED BFFORE ME THIS 3'd DAY OF OC1'0I3W. 2007. NO'TARY JBI,1C !l?lirf_. or PENNSAMAW NoW M S M &AW J. Markowitz. Nobry Pubft Y Via. PtAnds0hW County Commission ExpWes Feb. 13.2011 00 is AsiddAw- of McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 07-3377 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 391 Crossroad School Road, Newville, PA 17241 (Tax Parcel #46-08-0587- 036), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Address Michael L. Coyle a/k/a Michael 391 Crossroad School Road Lee Coyle Newville, PA 17241 Audra L. Coyle a/k/a Audra 426 Dogwood Court Lynn Coyle a/k/a Audra Coyle Carlisle, PA 17013 ?cfl IBIT A 2. Name and address of Defendants in the judgment: Name Address Michael L. Coyle a/k/a Michael 391 Crossroad School Road Lee Coyle Newville, PA 17241 Audra L. Coyle a/k/a Audra 426 Dogwood Court Lynn Coyle a/k/a Audra Coyle Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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 Address Tenants 391 Crossroad School Road, Newville, PA 17241 ExH IBIT A Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. Section 4904 relating to unworn falsification to authorities. August 7, 2007 NWAY, P.C. BY: -z . e (?-' <f Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE' MARGARET GAIRO, ESQUIRE EXHIBIT q McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - 11) # 17616 EDWARD D. CONWAY, ESQUIRE - Ill # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 DATE: October 3, 2007 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNFR(S): Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle PROPERTY: 391 Crossroad School Road, Newville, PA 17241 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on December 5, 2007, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Exii 18 IT B r-= .A ' cn c yo,ryG ? i. r } 41. z ? n O?^r'J7n 'b.--? C7 ?.bdp y ?G OCR t'rD.?? (D ?31 ?yl b-9 zi O <v q C"`O •"zs "rt O-s (D P ?? O .Z in G' (6D .y - O w O ' rn t O „? ?` y c? x rn ? -; O 'l% .J rc ?- v. C Y O` ? G O Jo 00 P '--.. a, ?. CD n Q -1 S C/? ,^ ^? -_ O (D e y; Jo ?.j w J N ?.• N Q- O (; i b O D G? ;? rc _ w C x C ' O T1 C.0 •+ X • r 2t ,r ?-, G- t J sv ^ Y :Z;- > V' a - ..-. a n C ?. y Q` 't3 Dp , 04 ... (( D ' c ? . h "y "? O iv y •=t O O n CD "? :n 1 ? ? J ? r r» .Ty j? CD O G '17 CD ? ? ? -*+ •^, 6 n• ? w v G `? O ?: J CD Ti CD CD _ __ x 00 .?..?r (D v fv N ` CD CD 00 C (D C -L iJ G .J ... ?p Oo CD N ' t N tD fil cv ? CD N. ? Lv pOElu1-1 c x ? ? ry o. 7 n .. y T" rn ? v p11 ;r7 zzcc r? r ,.-a . m ? raF f, n 'L - ?Y ti p ry J n ? -r ?> ? ? fit ? - r '-? ? te 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 Household Finance C D C is the grantee the same having been sold to said grantee on the 5th day of 07 A.D., 2014, under and by virtue of a writ Execution issued on the Aug day of 07, A.D., 203377, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 3377, at the suit of Household Fin C D C against Michael L Coyle ka Michael Lee Audra L aka Audra Lynn aka Audra is duly recorded as Instrument Number 200801484. IN TESTIMONY WHEREOF, I have unto set my hand an d eal of said office this ly` day of A.D. vZ 019 n P?e4 Ret-order of Deeds Reno of Deeds, Cumberland County. CadW9, PA MY CW0*910n EVkes IN RV Monday of Jan. 2010 Household Finance Consumer Discount Company In the Court of Common Pleas of VS Cumberland County, Pennsylvania Michael L. Coyle a/k/a Michael Lee Coyle Writ No. 2007-3377 Civil Term And Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Sgt. Jody Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2007 at 0936 hours, 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: Michael L. Coyle a/k/a Michael Lee Coyle, by making known unto Michael Coyle personally at The Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on October 12, 2007 at 2055 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle, by making known unto Audra Coyle personally at 426 Dogwood Court, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1036 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle located at 391 Crossroad School Road, Newville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Michael L. Coyle a/k/a Michael Lee Coyle by regular mail to his last known address of 703 Sandbank Road, Mt. Holly Springs, PA 17065. This letter was mailed under the date of October 16, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle by regular mail to her last known address of 426 Dogwood Court, Carlisle, PA 17013. This letter was mailed under the date of October 16, 2007 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, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Terrence McCabe, on behalf of Household Finance Consumer Discount Company. It being the highest bid and best price received for the same, Household Finance Consumer Discount Company, of 961 Weigel Drive, Elmhurst IL 60126, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,041.06. Sheriffs Costs: Docketing $30.00 Poundage 20.41 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 12.48 Levy 15.00 Surcharge 30.00 Law Journal 395.00 Patriot News 367.25 Share of Bills 14.92 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 1041.06 So Answers: R. Thomas Kline, Sheriff BY ',C Real Estate rgeant d McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 07-3377 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, the undersigned attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 391 Crossroad School Road, Newville, PA 17241 (Tax Parcel #46-08-0587- 036), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: Name Address Michael L. Coyle a/k/a Michael 391 Crossroad School Road Lee Coyle Newville, PA 17241 Audra L. Coyle a/k/a Audra 426 Dogwood Court Lynn Coyle a/k/a Audra Coyle Carlisle, PA 17013 2 3 4. 5. 6 Name and address of Defendants in the judgment: Name Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Address 391 Crossroad School Road Newville, PA 17241 426 Dogwood Court Carlisle, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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 Address Tenants 391 Crossroad School Road, Newville, PA 17241 J, Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. Section 4904 relating to unworn falsification to authorities. Aug c ust 7 2007 McCABE'",'EIS ANb NWAY, P.C. __ BY:. r <= ---? Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE.. _ MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Household Finance Consumer Discount Company VS. Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Cumberland County Court of Common Pleas Number 07-3377 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 391 Crossroad School Road Newville, PA 17241 Your house (real estate) at 391 Crossroad School Road, Newville, PA 17241 (Tax Parcel #46-08-0587-036), is scheduled to be sold at Sheriffs Sale on December 5, 2007 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $210,227.86 obtained by Household Finance Consumer Discount Company against you. 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 canceled if you pay to Household Finance Consumer Discount Company, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 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 McCabe, Weisberg and Conway, P.C. at (215) 790- 1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway.. P.C. at (215) 790-1010. 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 a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LEGAL DESCRIPTION ALL THAT CERTAW bett of toad situate is Weal Pedmboro TwneWp. C nd C *%=W, 13 ecanaylvanw, more lt* bounded and dew!Wd as Lat 20 on the Subdidsim Phut far C2ro44 RMW School Road EstatN. *; prepared by Staalay imuokriw, LB., dated Sapbembeer 29, 2987 arsti reeardad in CumberimA County Pl= Book 66, Pages 278. wA farffitrbottttded Ond dturibed 9A [ol7nws; BEOiUl+ HO at K point to tht rcathrsa dcdioAted debt Ofwv Rea a[Crma R4sd &Jwd Road tT- 4381 at th4: d:Vxffzg Hm betwom t.at W04 24 and Lot Nay. 71 and 26 an ibc hcrolmabdw rneadomd SubdWtian Plan; thcnoo along said d'i kling line, North 49 d V=0 10 Dduutaa $1 **aotula West, 5T$,?i feet to aA **a Vid, tilmm ekmd latch mw or f6MU!rlr of M. Yapper. North 61 deames 30 minutes 00 acooudt iaa4 15 02 test to a point; thence alvag the dtvidjag HM bebsce a Lot Itos. 19 and 20 on said Platt. Sm& 29 dgreea 18 minuted 51 aebmde lt*#4 576.53 ft*t to a pit act In the nortbem nou dedlcktrA right of way lira of Cmae Road School Hand; thence along Wd right of vew me, dcgrtee 41 win%des 09 aceande Wesl,154 feet to a poem, the platen of SEGIMUNG. CONTAINING 1.90 aQics, p7tC uAve ad dCdkgted d& of way, 9U13JEC1'to reauiWotw and riv%ta of way end awa a is of rewd and a3 mcd In plot daodn. BEING KNOWN AS 391 Crossroad School Road, Newville, PA 17241 Being the same premises which Douglas E. Phillips, by deed dated the 6/20/2000, and recorded 6/23/2000 in the Office of the Recorder in and for Cumberland County in Deed Book 223, Page 1041, granted and conveyed to Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle, in fee. TAX MAP PARCEL NUMBER: 46-08-0587-036 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-3377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Household Finance Consumer Discount Company Plaintiff (s) From Michael L. Coyle a/k/a Michael Lee Coyle Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle 391 Crossroad School Road Newville, PA 17241 (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 $210,227.86 L.L.$.50 Interest from 8/8/2007-12/5/2007 $4,147.20 at $34.56 Per Diem Atty's Comm % Due Prothy $2.00 Atty Paid $226.12 Plaintiff Paid Other Costs Date: August 14, 2007 (Seal) REQUESTING PARTY: Name Edward D. Conway, Esq. McCabe, Weisberg and Conway, P.C. Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215)790-1010 !s/ tuto Curtis R. Long, Prothonotarf, By: ?9'? Deputy Supreme Court ID No. V&AA MIT3 .LI&M. Real Estate Sale # 35 On August 16, 2007 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA Known and numbered as 391 Crossroad School Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 16, 2007 By: j ;;,,J, Real Estate Sergeant L l'UZ The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND' COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*otwXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: PAM adift Oak MIL x 10124107 YIMt "0401 174 w7 Thecae 10131/07 I 11/07/07 i Wh*AN L Coyb a" Uk*&sd Aft IS D S 1o Sworn to an crib d efore me this 30 day of November, 2007 A.D. E u 1.411 1W CEMM tract of led weals in Meat lfasabono'litasatf?, 4?ssibetYod Caaat? Notary Public mane ?y boaaded sad tlescnbed in Lot 20 as the Sobdiviaioa /Acts for Crows lltoad School Road E* Am sa 1 1. 11 by COMMONWEALTH OF PENNSYLVANIA S? Ista>oksku R;S•, &kd S9boto 19,. 1997 and mowded in Corabode d Cmvq Plan Notarial Seai Book W 17B, and tt dtsca?al>sfollorvs: James L Clark, Notary Ptac City Of Hantsbuq Dauphin County BEGNOM at a point in th aaffiem My Commission Expires June 2,2W8 dedicated 4* of my be at` Cross RW School Red (T439)a tale dtlg fix Member, Pennayivanis Association of Notaries betwWo Lot No. 20 sad Lot Nos. It sad 26 on ee iaaeiftboae FW. dwoe d" ON If 29 I I so 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 : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 35 Writ No. 2007-3377 Civil Household Finance Consumer Discount Company vs. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Lynn Coyle a/k/a Audra Coyle Atty.: Edward Conway DESCRIPTION ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more fully bounded and described as Lot 20 on the Subdivision Plan for Cross Road School Road Estates, as prepared by Stanley Jarmolenko, R.S., dated September 19, 1987 and recorded in Cumberland County Plan Book 86, Page 17B, and further bounded and described as follows: BEGINNING at a point in the northern dedicated right of way line Li Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this day of November, 2007 r-? d - ?? I", Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My COMM13 On Expires Apr 28, 2010 A McCABE,WEISBERG AND CONWAY,P.C. BY: MARGARET GAIRO,ESQUIRE-ID# 34419 Attorneys for Plaintiff 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Household Finance Consumer Discount Company CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. No. 07-3377 Civil Term Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Coyle Defendants rri(DD Z cnr- t.a ;:; PRAECIPE r— TO THE PROTHONOTARY: w ® Please mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Please Vacate the Judgment entered. DATE: dII L$/I 3 McCABE,WEISBERG AND CONWAY,P.C. BY: btea-c/ Margar Gairo, Esquire Attorneys for Plaintiff au..‘ CK-t4 9 P9 ucQW McCABE,WEISBERG AND CONWAY,P.C. BY: MARGARET GAIRO,ESQUIRE-ID# 34419 Attorneys for Plaintiff 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CUMBERLAND COUNTY Household Finance Consumer Discount Company COURT OF COMMON PLEAS Plaintiff No. 07-3377 Civil Term v. Michael L. Coyle a/k/a Michael Lee Coyle and Audra L. Coyle a/k/a Audra Coyle Defendants CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff,hereby certifies that a true and correct copy of the within Praecipe was served on the below persons by regular first class mail,postage prepaid,on the 2. day of September,2013. Dorothy L. Mott Dorothy L. Mott Law Office LLC 125 State Street Harrisburg, PA 17101 DATE: C SI )3 McCABE,WEISBERG AND CONWAY,P.C. BY: Margar Gairo,Esquire Attorneys for Plaintiff