The URL can be used to link to this page

Home My WebLink About04-0264 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ" Id. No. 32227 FRANCIS S, HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATIORNEY FOR PLAINTIFF MORTGAGEELECTRONlC REGISTRATION SYSTEMS, INe. 8201 GREENSBORO DRNE, SUITE 350 MCLEAN. VA 22102 COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff v. NO. IJi( - ;)fv'/ !!ad CUMBERLAND COUNTY ROBERTD, STANACHER NKJAROBERTD. STRANACHER 9 DULLES DRNE EAST CAMP HILL, PA 17011 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE 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 MAYBE 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 File #: 85718 File #: 85718 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. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. 1. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: AURORA LOAN SERVICES, INC. 601 5TH AVENUE SCOTTSBLUFF, NE 69361 2. The name(s) and last known address(es) of the Defendant(s) are: ROBERT D. STANACHER NK/A ROBERT D. STRANACHER 9 DULLES DRNE EAST CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3, On 05/15/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1812, Page 2825. 4, The premises subject to said mortgage is described as attached, 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/0112003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #; 85718 6. The following amounts are due on the mortgage: Principal Balance futerest 08/01/2003 through 01/2012004 (Per Diem $22.94) Attorney's Fees Cumulative Late Charges 05/15/2003 to 01/20/2004 Cost of Suit and Title Search Subtotal $106,253.20 3,968.62 1,250.00 108.90 $ 550.00 $ 112,130.72 Escrow Credit Deficit Subtotal - 190,12 0.00 $- 190,12 TOTAL $ 111,940,60 7, The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice offutention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) haslhave failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000, WHEREFORE, PLAINTIFF demands an in!:@ Judgment against the Defendant(s) in the sum of $ I I 1,940.60, together with interest from 01/20/2004 at the rate of $22,94 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. FED~AN AND PHEf:r\N:, L,LP; / ' 2/!4-n-~ SS ''1>p4~ By: - I ' IsIFrancis S. Hallman FRANK FEDERMAN, ESQUIRE LAWRENCE T, PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 85718 ALL THAT CERTAIN piece. parcel and tract of land situate in East Pennsboro Township. Cumberland County, Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on the northerly line of Dulles Drive (East) which point is 83 feet East of the northeasterly comer of Glenwood Drive (East) and Dulles Driv,,, (Ea~) and at dividing line between Lots nos. 18 and 19, BlOC!< "J", on the hereinafter mentioned Plan of Lots; thence along said dividing line North 29 degrees 20 minutes East 107.08 feet to a point at the southerly line Of other land now or late of Glenwood Park, Inc.; thence along same South 50 de:Jrees 34 minutes East 90.05 feet to a point at dividing line I::etween lots Nos. 17 and 18, Block "J" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 100 feet to a point on the northerly line of Oulles Orrle (East); thence along same, North 50 degrees 34 minutes West 9.89 feet to a point; thence further along the northerly line of Dulles Drive in an arc having a radius of 350 feet to the left in 8 westerly direction t:i1.70 feet to a point, the place of BEGINNING. BEING Lot No. 18, Block. J". in Plan No.1 of Ridley Park. which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County. Pennsylvania, in Plan Book 11. Pagl3 26. known as Dulles Drive (East). < BEING 'tHE SAME PREMISES which Frank A. Freet and James M. Freet, Administrators of the Estate of Faye A. Carpenter, deceased, by deed dated Suptember 10, 2001 and recorded September 25. 2001 in the Recorder of Deeds Office In and for Cumberland CoUn1y, Pennsylvania in Record Book 248, Page 2499 granted and conveyed unto Terry E. Chestnut and Joan R. Chestnut. PllEIfiSES BEING: 9 DULLES DRIVE EAST VERIFICATION Richard T. Martin hereby states that she is SENIOR VICE PRESIDENT .of AURORA LOAN SER VICES mertgage servicing' agent fer .PJainliff in this matter; ,that she u,authorized ,10 take this Verificatien, and that the statements made in the feregeing Civil Action in Mertgage Fereclesure are true and cerrect te the best .of her knewledge, infermatien and belief. The undersigned understands that this statement is made subject te the penalties .of 18 Pa. e.S. See, 4904 relating te unswern falsificatien te authorities. {2t/;Y-=> Richard T. Martin DATE: I \ ~\n~ Sr. Vice President ~ (r" 0'\ \^, ~ ~ ~ V-, ~' , , '^ "\ ~ ~, ~. ~ ~. \ '-0 ~ ) \ '- \ ~ \ "- '- '" " ~ " ~ ~ ~~ ~ '{J l r--,1 (', , ~ I '- --~ (..- '0'", ,.) r'-' c.' SHERIFF'S RETURN - REGULAR CASE NO: 2004-00264 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS STANACHER ROBERT D A/K/A ROBER RON KERR , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STANACHER ROBERT D A/K/A ROBERT D STRANCHER the DEFENDANT at 2014:00 HOURS, on the 22nd day of January , 2004 at 9 DULLES DRIVE EAST CAMP HILL, PA 17011 by handing to CLAUDIA STANACHER, WIFE 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 Service Affidavit Surcharge So Answers: 18.00 11.04 .00 10.00 .00 39.04 "'~,.,:< ,/,.,~ , R. Thomas Kline 01/23/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: e~ ~ty Sheriff me this ~ 'f'!;' day of Cm ,JtJO'f A.D. (tw c: ~ IAP,,~ rPt:"othonotary~r" FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. 8201 GREENSBORO DRIVE, SillTE 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURTOFCO~ONPLEAS CIVIL DIVISION Plaintiff, v. NO. 04-264-CIVIL ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against ROBERT D. STANACHER AlKlA ROBERT D. STRANACHER . Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale ofthe mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/20/04 to 2/23/04 TOTAL $111,940.60 $802.90 $112,743.50 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ]~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICA';.~P. /, ~ '-- /J DATE: ~,~.2,$ J...OO,/ ~ j J< - ~ , PRO PROTHY C/ ' FEDERMAN AND PHELAN, LLP . . FRANK FEDERMAN, ESQ., Jd. No. 12248 LAWRENCE T, PHELAN, ESQ.. Id. No, 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SillTE 1400 PHILADELPHIA, PA 19103 (71 ,) 161-7000 MORTGAGE ELECTRONIC REGISTRATION: COURT OF COMMON PLEAS SYSTEMS, INC. A TIORNEY FOR PLAINTIFF Plaintiff : CIVIL DIVlSION Vs, : CUMBERLAND COUNTY ROBERT D. STANACHER NK/A ROBERT D. STRANACHER : NO. 04-264 CNIL Defendants FILE COpy TO: 'ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER 9 DULLED DRIVE EAST CAMP IllLL, P A l70ll DATE OF NOTICE: FEBRUARY 12, 20114 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. TInS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT TIlE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAlNED FROM YOU WILL BE USED FOR '!HAT PlJRPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSJRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LlEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE F AlLED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH TIfE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITIfIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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 FORTIf BELOW, TIfIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTI AVENUE CARLlSLE,PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQillRE Attorneys for Plaintiff SHERIFF'S RETURN - REGULAR . CASE NO: 2004-00264 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS STANACHER ROBERT D A/K/A ROBER RON KERR Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STANACHER ROBERT D A/K/A ROBERT D STRANCHER the DEFENDANT , at 2014:00 HOURS, on the 22nd day of January 2004 at 9 DULLES DRIVE EAST CAMP HILL, PA 17011 by handing to CLAUDIASTANACHER, WI FE a true and attested COpy of COMPLAINT - MORT FORE, toge,ther with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: IB.OO 11.04 .00 10.00 .00 39.04 ,~/' - .. ':"."''''-'''':/' ,r'~~ << ,.'.-,-,~-~ R. Thomas Kline 01/23/2004 FEDERMAN & PHELAN Swornand,Subscribed to before By: ~Tn~ ,Qeput ySherif f me this day of "A.D. Prothonotary FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHILADELPillA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SillTE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 04-264-CIVIL ROBERT D. STANACHER A/K/A ROBERT D. STRANACHER Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey 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 ROBERT D. STANACHER AlKfA ROBERT D. STRANACHER is over 18 years of age and resides at , 9 DULLES DRIVE EAST, CAMP HILL, P A 17011 . This statement is made subject to the penalties of 18 Pa. CoSo Section 4904 relating to unsworn falsification to authorities. j~~~ FRANKFEDERMAN,ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL mAT CERTAIN pi_. parcel and lellCt of land ~ilUale in East Pennsboro Township, Cumberland Coullty, Petm.olylv<ll1ia ttlOl'C particularly bounded and described as foUows, to wit BI1GJNNINO at a point on the NOItberly line of Dulles Drive (Easl) which point is 83 feC! !:!as! of lhe Northeaslerly '-'OI1Ier of Olcnwood Drive (F.a.<;t) and Dulles Drive (Bast) ana III dividing liJw OOlWCCII Lots Nos, 18 alld 19. Block ~J", on the berm/rer memioned Plan of Lots; Ihcmce along said dividing line North 29 degrees W minutes East 107.08 feet to a point at me Southerly line of other land IIOWor laIc of G1enwood Park, Inc; thence along same 50uUl 50 degrees 34 minuws Ea'll 90.05 feel 10 3 poilll al dividing line belwel:n Lots Nos. 17 and HI. 810ck ~J" on satd PIIllJ; thence along said dividing line South j9 degrees 26 mjllUteS WelIl 100 Ccetlo II poinl on the Nnnherly line of Dullcs Drive (East); thence along same North 50 d~ 34 minul~ WeSl 9.89 feel w a poinl; lbellCe further along the Northerly line of Dulle! Drive in an arc having a radins of 350 feet lO the left in II We.sterly din:dioo. 61.70 feel to a puinl, rile place of beginning, BEING Lot No. IS, Block "r, in Plan No. I of RIdley "ark, wwch plan ;~ recorded in dle Office of the Recorder of Deeds in and foe Cllmbcrland COllDty. Pennsylvania. in Plan Balllc 11. hge 26, known as Dullcs Drive (E;.r>t). TITLE 'fO SAID PRBMISES IS VESTED IN Rebert D. Slllnacher, adull individual by Deed from Terry n. Che$ll1Uf and J<lall R. Chc8tnUI. husbaad and wife, daled 5115/2003 and recorded 5fWI2003 In Dl:ed Book 1.57. Page 651. (-;N ~-<Q. ~ tt.- II,' :-0 _ I:::; C> R- ~ f:; 0 ~ t w ~ lU' ~ \' t: D) C) !'..) c..) , ~~ .....--:- -q ~;,,: [ ~'"";' -'":' i ~l (,;"'l i '-~ ,- t.., . (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. 8201 GREENSBORO DRIVE, SffiTE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 04-264-CIVIL ROBERT D. STANACHER A/K/A ROBERT D. STRANACHER Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ~h.;bS 269$. ~: An"JoI7~[J.7n~ DEPUTY ;' L'- If you have any questions concerning this matter, please contact: 3~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBLVD" SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBT A1NED WILL BE USED FOR TRA T 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." FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPffiA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION ROBERT D. STANACHER AlK!A ROBERT D. STRANACHER NO. 04-264-CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J./141tJi JcJJ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff t"-..J 0;;-,) (" r~.; ..~., c;-. ,--' PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. No. 04-264-CIVlL ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $112,743.50 Interest from 2/23/04 to JUNE 9, 2004 (per diem -$18.52) $1,982.71 and Costs TOTAL $114,726.21 dM-~ ~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, P A 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. ... ... 0 t-- ... ~ cr: .$ [:3 .... .... ~ = ~ 1<.~ ~ ~ :z; j O:Z; 0 "J~ .... ..: "J ,.. <.... u ~ ~ "J ] foil.... u:Z; U < t: :S:"J ........ !:2 ~f S foil :z; . foil " :z;~ '" O"J foil foil = - > " " cr:~ = '" ..0 o foil 1<. 0 ~ .~ ~ ,..foil 0 0" i5: >. ~Q, ut;; cr: " OJ ~ . ,.. ... I-< 8 O~ foil.... ~ ;~ <2 "J '" ...."J .; >. foil I-< .... " U:Z; foil:z; ... ~~ " go 1<.~ S .... foil 0 cr:~ ~ A 00 e".... cr: E Ot: ~< ~ " ,..U <,.. [:3 I-< ~ 0 =" " cr:~ e,,~ ~e \') ~ ~< ,..,.. U ~~ ~ '" 8; .... '" 1 u ~ ~e" foil "2 [:3 foil ~ ,.. ~ "0 - -< ,..~ "J ~ ~ ~ i:s~ ,.. u cr: 11 foil 1:5 cr: --f-- 1'"0 .~ - , l"._ .c? ~ 3 '. ~C' -, - ~ ~ , - ~ - j - ~r) c:::tt, (\~i' ,.".' 2 G::l - - , - d Q L.:,J \1\1 , , , ~ f"? ,"- ..>> f' - ~e:.: (,) r~-..) "'> ~ (.~::;) c" r I M () \) J f'? -J '::r 0 J f2 ~ () 0; () Q 4 0 0 -....:. ~ tJ VI 0"- 4 . "( - ~ ti ....... (V) l.JjQ-. '" 'l),. - -i.s- LEGAL DESCRIPTION ~ THAT CERTAIN pie.::c, parcel and tracl of land ~iluale in Easl l'CIIIlSOOro Tl>Wll8hip, Cumberland ;oo!lty, Pennsy!vani~ 1\10l'e particularly bounded llnd dewribcd as follows, 10 wit: BEGINNING at a poillt on !he Northerly line of Pulles Drive (Easl) which point is 83 feet East of lbc Northeasterly corner of Glcnwood Drive (FJlm) and Du:Jlc$ Drive (East) lIlIl1 at dlvidlllg line betwl!Cll LuIs Nos. 1 S aoo 19. BlOC\( "J", tin the l1erci!1llflcr lIlelllioned Plall of Lots; them:e alOl1& saW dividi1l3 line North 29 degrees 20 minutes East 107,08 feet 10 a point at the Southerly line ofod1er land now or late of GJenwood Park, IlIc; thence aJoog same South ~ degrees 34 minUle9 Ea.'It 90,05 feet to a poiat lit dividing line belw~n IAts Nos, l7 and 18, Block "J" 011 said Plan; thence along said dividlllg line South .39 dej:rees 26 minutes Wesl 100 fect to a point 011 the NOlthet'ly 1ille of 0ul1cs Drive (FASt); thence along SlllllC North 50 degrees 34 minutes West 9.89 feet to a pOint; theDCe further along the Northerly line of O\llles Drive ill an arc having a radius of 350 feet to the left in It We8lerly dircctiWl 61.70 feet t(> a poilll, tire place of beginning, BEtN'O Lot No. 18, Illock "1", in Plan No J of Ridley Park, wWch plan i~ recorded mille otfIoe of the Recorder of J)e(.'lls ill and for CIlmocrland County, Penllsylvania, in Plan 800Ic 11. Page 26, !mown as Dillies Drive (Ea:;t} , 'ITLE TO Sf>.lD PReMISES IS VES'f1ID IN Robert I), Slllnacher, adult individual by Deed from 'ccl)' E. ChesmUf and Juan R. Che.stlmt, h\l$band 3Ild wiCe, dated 5/15/2003 and recorded 'WI2003 in lXled !look 257, Page 651. -~ ---- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-264 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTSRATION SYSTEMS, INC., Plaintiff (g) From ROBERT D. STANACHER A!KIA ROBERT D. STRANACHER (I) You are directed to levy upon the property of the defendant (g)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to allachment is found in the possession of anyone other than a named garnishee, you are directed to notifY himiher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $112,742.50 L.L. $.50 Interest FROM 2/23/04 TO 6/9/04 (PER DIEM - $18.52) - $1,982.71 AND COSTS Atty's Comm % Due Prothy $1.00 Ally Paid $121.D4 Plaintiff Paid Date: FEBRUARY 25, 2004 Other Costs (Seal) CURTIS R. LONG Prothon~ ~ Bv: dt:::/lO.."'. P -7f0'24C:~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Suprerne Court ID No. 12248 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT D. STANACHER AIKIA ROBERT D. STRANACHER NO.04-264-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC.. 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 ,9 DULLES DRIVE EAST, CAMP HILL, P A 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT D. STANACHERA/KlA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 9 DULLES DRIVE EAST CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 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 ofl8 Pa. CoSo Sec. 4904 relating to unsworn falsification to authorities. ..... February 24. 2004 DATE j~ },L1IM't4.-Yl FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~_'\ c:-; C~2.' C i ~_ -II -,., r-...., cr~' ::;. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, No. 04-264-CIVIL v. ROBERT D. STANACHER A1K1A ROBERT D. STRANACHER Defendant(s). February 24, 2004 TO: ROBERT D. STANACHER AlKlA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A 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 ONL Y ENFORCEMENT OF A LIEN A GAINST PROPERTY. " Your house (real estate) at, 9 DULLES DRIVE EAST, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriff's Sale on JUNE 9, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $112,743.50 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (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 Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the 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 ifthe buyer pays the Sheriff the full amount due in the sale. To find out ifthis 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 ofthe 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, P A 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL mAT CERTAIN pie-.:;:, parcel and tEatl of land ~iluale in Eallt PClUl~boro Township, CumbertllJll:l Coullty, rennsylvunia mOl'C particularly bounded and described all (OUOW5, tQ wit: BEGINNING at a point on !he Northerly line of Dunes Drive (East) which point is 83 feet East of !he Northeasterly comer of Glcnwllod Drive (F.aml and Dulles Drive (llast) llIId at dividing line between LoIS Nos. 18 and 19. BIQ(;\( "J", Oil the hereinatlcr melllioned Plan of Lots; thence alol1& said dividing line North Z\l d~s:W minutes East 107,08 feet to a point at !he Southerly line of other land now or laIe of Olel1WoOO Park. Illc; thence aJoog same Soulb SO degrees 34 minutes Ea.'lt 90.05 iblllO a point at diViding line between Lots Nos. 17 and 18. nlock "f' on saId Plan; thence along said dividing line SoUlb 39 degrees 26 minutes Wesl 100 fecI to a poinl on tbe Northerly line of DuIla DrtyC (F.ast); thence along same North 50 degrees 34 minutes WeS4 9.89 fect to a point; thence further along the Hurlberty line (If DIllies Drive in an arc having a radiu~ of 3SO feel 10 tin: left in a Westerly dircctioo 61. 70 feet to a poinl,. Ute place of beginning" BEING Lot No. 18. Block" J". in Pllln No, I of Ridley I'ark. ""bien plan j~ recorded in dle OtrlCe af the Recorder of ~~ in and for CUmberland County, pcnnlylvania, in: Plan Book 11. Page 26, known as Dulles Drive (East), TITLE TO SAID PRBMtSES IS VESTED IN RQbert D. StlInacher. adult individual by Deed from Terry E. ClwS111Ul and Joan R. ChesUlUl. husband and wife. dllted 5/15/2003 and recorded 5/2012003 in D/;l<:a 80011:257, Page 6.51. ( ") <':-.:J , -~., f c.. n- " (, (,;, AFFIDAVIT OF SERVICE PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No. 04-264-CIVIL CUMBERLAND COUNTY PJT DEFENDANT(S) ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER ACCT. #0015292030 SERVE ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER AT 9 DULLES DRIVE EAST CAMP ffiLL, P A 17011 Type of Action - Notice of Sherifrs Sale Sale Date: JUNE 9, 2004 SERVED Served and made known to ROb<2<<.. ~ t>. S{ ~~~~!.l\ Defendant, on the at (} ;-:2(; ,o'clockf'm., at 1 V) 0 ~ <"5 k) yo. [;:;3'+-) C;,,,,,,, f' I;z. /l.. H\l( day of J4art..J..-. , zoo},- , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served, . X Adult family member with whom Defendant(s) reside(s), Relationship is _~, Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s), Agent or person in charge of Defendant(s)'s office or usual place of business, an officer of said Defendant(s)'s company. Other: 'q t Description: Age +?)" Height 5" 7 Weight/8o Race 10~ Sex Lather '1 (>-fi '5 e ~ !, ~\ ':>....... 'foJC-'-- k. Q~ J;a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the N tice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above, NOTARIAL SEAl.. Sworn to and subscri!)ed ~ H. CARTY, =. PubIc ~~fO~~:its ~;:day , =~~Nov.1~ Notary~~ BY:~Kd?~_ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDIC~A4~ TIMES OF SERVICE ATYEMPTER NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND bel,ause: Moved Unknown No Answer Vacant 1 st Attempt: I I Time: 2nd Attempt: I I Time: 3rd Attempt: I I Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 ,..." C:::;:J C? ~- :;...~ . , \.0 C' -n ...... ~- ri1;D -"'J 1',; ~:J~ ~~~, ;:..c\:rl :..('"") ~--:,;Ti ':? (.11 o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ) CIVIL ACTION ) vs. ROBERTD. STANACHERNKlA ROBERT D. STRANACHER ) CIVIL DIVISION ) NO. 04-264-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. hereby verify that on ,March 2. 2004 true and correct copies ofthe Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Aoril27, 2004 ~hmaJ) FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff ;l-;;l g E. v; - ;:2 ... - - - H w N - - 0 0.0 00 --J a, U. r-< ",' ... W N 5 ~ 0 - if ~ '" ~ ~ ~ (i' (0' Z to "... 3 ~ ~ E5 CT <1l ~'z 00 ~ a ~ 25 -I n 0 d'~ -I ~ 0 z 00 0 . . 0 ~ 3 0;;; ~ tr1 ~ ~ " Ci 0 aln' ~ tr1 ~ g a 0 CjJ ~ 0 -I ~ ~ ~ ~ 0 n ~ CjJ () ~ ~ n tr1 ~ 0 " :=;; 1:: ~ 0 ~ -I ? ~ - n :r: -I .- '" - . ~ :r: 0 ~ 0 ~ 0 i~ fiJ 0.0 .." .. W "' CjJ ~ , 0 - ~~ ? C ~ 0 0 00 E5 ~ .." ~ ~ !l..!l r-< '" ;r 00 ? r-< CjJ [3 ~ "" tr1 tr1 -< ~ ." ;>0 CjJ ~ ~ z Ci 0 0 ~ , " 0 ~ 00 00 ~ ., ~ ~ ~ ~ ~ !-< Q -I 1:' CjJ ;; ~ ~ tr1 ." ~ ~ 0 Z 3 :s: ? 0 'C .. ~ CjJ tr1 () ." .-1 "' ~ ~ () ~ 0 <:;~.if ~ z ? '2 8 g&: ~ 1; ~ -I "' ~ .-< ~~~I!1; :r: :r: ~ - -I W ;'a~~g r-< ::I >'l _. - ~ s- o z ~Er['5,5 0.0 .." 0 ~ 3 sa,;; g' 0 ~ :<: ;>0 O"[t::;'g, P - ~ -I ;~.8H ~ --J :r: f;; 0 :r: ~,~, 8~ ~, - .~ ? CjJ - o-'1il1il ::t.;;; 0 Z o ... ~ a N 0 6l~ g n..c c; 2,~~ g~' "' ;;j ;;j 0 g;;;. a 6- 00 ;>0 ~lC~ ::I tr1 0 CjJ ~~~;;;~ ? X -I ~i I~ ~ N ~ a, --J tr1 a ~.~ g. () o~ ;-, ~'!l" ~ ~ :r: g ~ a ~ ri _. II> S' ~ o.ii.~~ iI ~ ~i1 :s - F'q'gg, r-< CjJ CjJ hI!. or-< 00 r-< -~ . "" ~ .tr1 ~.g. '*~. ? "' '>l, ~ ~ I - oCl ? .g g a --J "" - - ::t,ttl51 p. 8 Ii. ~H~ ? --J .~.- - - 8 It, 51 ~ g';1 --J W ~( ~ :::: -, ~ - Jj t;:; ~fl iI I . 11 ~ " II ."""'" \ Iii if " . ~ 0 ~;;;. .' . ty, ,"~_ "'9- """ ~ ~t:[ . z .1 y.~n,"%- (ll ~o (ll , :l ~~ ~~lC~""~o, H31~~~ is !l g, 0-' . ~:_ ,_,__;,!!!",'i;;:lii$!i,;!-~ ~ p~ . $: . u2 l' ",,,,,7",,- ~ i~ ;.tj 000/- $ 0 'ow" ~- I'" 3,037- 1 200 [II> '''0 Z 1 ~.(ll ,''''LcD FW" "',AP ,0: (ll Q' '''''_'1 ZIPCO ...:: 200cl OE ". ' ,,,,03 0>2 -.Q." [{'~3 =' <1l ." Q."''' ." '" =' ... Q. "tJ-~- :T "," ';::....:_ tT1 ~ -....] (1l t::l fr~~tT1 -B'g.~~ or () '" 'T1 , (1) "tJi"" >(1)ft~ 5 ;.; (1) ~ ~CZl~ oo&gJ g~t'"' ~~~ ~ uo- o..6tr-< ::t, t'"' uoo"tJ to " [t' ~ '" o o ~;l/I o c s:: <lOJ mrr, ~.... Z.k~ cbs.:- -<-.~ ~C~; :l> zC) .~O >c ~ -, ~ = 0 ~ "f1 ~ :r! ::0 m::O N i8r- ~ ~J .. 0 N ~ 0.. ~ Mortgage Electronic Registration Systems, Inc. VS Robert D. Stanacher a/k/a Robert D. Stranacher In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-264 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Frank Federman. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Postpone Sale Surcharge Law Journal Patriot News Share of Bills 30.00 14.81 15.00 15.00 .50 1.00 15.00 20.70 20.00 20.00 284.00 290.20 29.26 $ 755.47 Sworn and subscribed to before me So Answers: This J~' daYOf~ r~~ Chv R. Thomas Kline, SHeriff 2004, A.D. Q Iu..</b-v, ~~ . II BY ~ Prothonotary Real Es e Deputy I.:P / Ut..'111/~ ~ /$03'10 MORTGAGE ELECTRONIC REGISTRATICN SYSTEMS,INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT D. STANACHER AIKIA ROBERT D. STRANACHER NO. 04-264-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., 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 .9 DULLES DRIVE EAST. CAMP HILL. P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None , 4. Name and address ofIast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 9 DULLES DRIVE EAST CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 24. 2004 DATE jJl44A-/'{ 'JyL/I~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, No. 04-264-CIVIL v. ROBERT D. STANACHER AIKIA ROBERT D. STRANACHER Defendant(s). February 24, 2004 TO: ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A 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 A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN A GAINST PROPERTY. .. Your house (real estate) at, 9 DULLES DRIVE EAST. CAMP HILL, PA 17011. is scheduled to be sold at the Sheriffs Sale on JUNE 9. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$112.743.50 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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, P A 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL TIlAT CERTAIN pieu\, parccl and trllC! of land ~itullte ill East PcllJl.~boro ToWIl8hip,CumbcrJllnd CouAly, PelWylvllIlia more panicuJllI'l,y boulIlkd and described lIll foUows, to wit: BEGINNING at a point on the Northerly line of Dulles Drive (East) wllicll point is 83 feet EaSfof,lbc Northeasterly ~'OOIeI' O'f Olcnwood Drive (fiam) and DuJlcs Drive (East) lIIId at dividing 1iIle be1wem will Nfls. IS and 19, B1~1\ "J", on tile hereinall.cr IncnciOlled Plan of Lots; thern:e along$8iddividing line North 29 d~s 20 minutes East 107,08 feet to'il point at the Soulberly line of otIu:rJaIld lIOW"r laIe of 01euwood Park, Ine; thence aJoog same South ~ degrees j4 minUles Ea.'lt 9O.0Sfeet IDa poiDt III dividinllline between Lots Nos. 17 and 18. 8loclc"r on said Plan; tbenw aloog said dividillg JiM South 39 degrees 26 minutes West 100 teet to Ii point 011 tbe Northerly JiM of DuIlcs Drit'e {~(); thence along same North 50 degrees 34 minutes We$( 9.89 feet 10 II pOint; thellCe furtherrdong the Norlhl:rly line of Dulles Drive In an arc having II \'&dillS of 350 reet to the left in II Walerly direction 61. 70 feet co II poinl, tile place of beginning, BEING Lot No. 18, Block oJ", in Plan No, I of Ridley Park. which plan iJ; recorded in dlc Office of tbe Recorder of Deeds in and for Olmbcrland CWlUY, Pe!lnsylvllllill. in' Plan Book II, Pag~ 26,.lrnown as Dulles Drive (East), TITL!; TO SAID f'RBMlSES IS VESTED IN Robert D. Sbnacller, adult individual by ~ from Terry E. Cheslllut ami Joan R, Chestnut, husbMd and wile, dated 5/15/2003 and recorded 5IW(ZOO~ in Deoo BOOk 2.57, Page 651. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-264 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTSRATION SYSTEMS, INC., Plaintiff (s) From ROBERT D. STANACHER AlKlA ROBERT D. STRANACHER (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 iu 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 $112,742.50 LL $.50 Interest FROM 2/23/04 TO 6/9/04 (PER DIEM - $18.52) - $1,982.71 AND COSTS Atty's Corum % Due Prothy $1.00 Atty Paid $121.04 Other Costs Plaintiff Paid Date: FEBRUARY 25, 2004 (Seal) CURTIS R. LONG Prothonot~ ~I'I~. -p_ /7!-4~_r~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No, 12248 TRUE COPY FROM RECORD InTlItimOnyw:.: '!,u~untosetmrhlnd .... tile seal (I ' '~ at Cal1islI. Pa- Jk'- ~~ cay J' ;;J-~" - ~ '--. /?4."-.. P ~~""_J' :i-Y'~ vii...., Real Estate Sale #51 On March 04, 2004 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 9 Dulles Drive East, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 04, 2004 B>J eeL,!, ,),vu.-\:.l '\ Real Estafe Deputy ! , ;,-- ~ ~ ~ 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 Joumal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 16,23,30,2004 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. 51 Wrtt No, 2004-264 CMI Mortgage Electronic Regtstra tlon Systems. Inc. vs. Robert D. Stanacher. a/k/a Robert D. Stranacher Atty.: Frank Fedennan LEGAL DESCRIPTION ALL THAT CERTAIN pIece. par- cel and tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania more partlcu. larly bounded and described as fol~ lows, to wit: BEGINNING at a point on the Northerly line of Dulles Drive {East) which point 15 83 feet East of the Northeasterly corner of GlenwQod Drive (East) and Dulles Drive (East) and at diViding I1ne between Lots Nos. 18 and 19. Block "J", on the ,.,A.....I..."'fhu'tnent1~dPbl.n of TLlt~~ L~)L(Y~ (!)s~'M~ie Coyne, E11t~r SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004_ ~~).). .d/JUAdlA-/ NOi\l.IffJtl SEAL f LOIS E. SNYDER, Notary Public Carlisle BOil), Cumberland County My Commission Expires March 5, 2005 , REAL ESTATE SALE NO. 51 Wr1t No, 2004-264 Civil Mortgage Electronic Registration Systems. Inc. vs, Robert D, Stanacher. a/k/a Robert D. Stranacher Atty.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN piece. par- cel and tract ofland situate In East pennsboro Township, Cumberland County, Pennsylvania more particu- larly bounded and described as fol- lows, to wit: BEGINNING at a point on the Northerly line of Dulles Drive (East) which point is 83 feet East of the Northeasterly corner of Glenwood Drive (East) and Dulles DIive (East) and at dividing line between Lots Nos. 18 and 19, Block "J", on the hereinafter mentioned Plan of Lots; thence along said dividing line North 29 degrees 20 minutes East 107.08 feet to a point at the Southerly line of other land now or late of Glen. wood Park. Inc.; thence along same South 50 degrees 34 minutes East 90.05 feet to a point at dividing line between Lots Nos. 17 and 18. Block .. J" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 100 feet to a point on the Northerly line of Dulles Drive (East); thence along along same North 50 degrees 34 minutes West 9.89 feet to a point; thence further along the Northerly line of DulIes Drive in an arc having a radius of 350 feet to the left in a Westerly direction 61.70 feet to a point, the place of beginning. BEING Lot No, 18. Block 'J-. In Plan No. 1 of Ridley Park, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County. Pennsylvania. in Plan Book 11. Page 26. known as DulIes Dlive (East). TITLE TO SAID PREMISES IS VESTED IN Robert D. Stanacher. adult individual by Deed from Terry E. Chestnut and Joan R Chestnut. husband and wife. dated 5/15/ 2003 and recorded 5/20/2003 in Deed Book 257. Page 65 L ~~~ SWORN TO AND SUBSCRIBE 30 day of APRIL 2( ~-u'J. i . .A41-(j N~l\lM. SEAL {I LOIS E. SNYDER, Notary Publi Carlisle Bore, Cumberland Cour My Commission Expires March 5, : r 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and~ 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 andlor Sundayl Metro editions which appeared on the 27th day(s) of April and the 4th and 11th day(s) of May 2004. 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 Coun f Dauphin in~ Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #51 Sworn to an:::ib db fOrem 28th day ~;Lr Terry L Russell. Notary Public NO ARY PUBLIC Oty of Harrisburg, Dauphin County My Commlsslon Expires June 6. 200 commission expires June 6, 2006 Memb.r, PennlylvanlaAlloclatlonof Notarl., CUMBERlAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 R~~~~11 j~,~;tJ ".;j,,<"~..,.Fl.l~~ '~Ii:~", ..:..; AlL1BA1'~=t:"I"''''' Statement of Advertising Costs , ~ ~f'i'~~_b_~ To THE PATRIOT-NEWS CO" Dr. ~1loJIlIoI_' "l'..~1o For publishing the notice or publication attached wit,""" ",' ';, ',' hereto on the above stated dates of~~==:t:t Total ~~~~"'liCJr~ Publisher's Receipt for Advertising Cost !"I-~~""l~""" ,:yr,:= IS Co., publisher of The patriot-Ne~s and The Sun~av Patriot-News.. newspapers of general said 'lIiIe Naitl29"" ',,~ wledge receipt of the aforesaid notice and pubhcallon costs and certifies that the same have ~l!!i4_ >, '."f.f ~""r=' l~.... 1.olahJ71i1dI""" ."""l'lii; ;,)".\ "..""~~,r~ ~~V;., "~E ~~I'.~~ 1I<<llliiWiIIII. ".'..... . - cit1!tlllit ,~f;A'Ih. w-Iy ~~tJi~.~\.}'~,\!'1plaee of :1lIIllIlil.ci'fII>;tli}IlM'm:.'tIi.No. t of_~I:'lOCOIdo4iJdle 0lIice ol dIt' ' ..,... iJ .... fm ~'atm~zt:~ -- ,,=~~=:~~ .~lltDaol'Book ,,,,,,fin, ,'" $ 290.20 By,."..........""........,..,.............,.,..........,.,."...... . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R-C.P.3180-3183 PHS#85718 MORIGAGE.ELECTRONIC REGIS.TRATlON.8YS.TEMS,.1NC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. .o.4"2M.CIY.IL Term 2006.u....___.muuu.__um.... ROBERT.D..S.TANACHER Al.KLA_ROBERT.D_STRANACHER PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Director ofthe Office of the Prothonotary Issue writ of execution in the above matter: Interest from 2/24/04 to 9/6/06 Per diem $18.53 Total $112..7A3..5.Q $11..15.8...7.& $129,902.28 Amount Due Add'l Costs _~Q;j~uu_______..._m._____._muu.____ Attorney for the Plaijiff(S) Note: Please attach description of Property. cj ~ [:) en < ~ 10. 6 ~ :>-" 8~ ~o ~~~ o;:2~ ~~ ~ ~~ w9 N ~ ~;~ 2E {-)c b is'" -.. w'-L .." ==! lLJ >- LL:r::. :;E F=; "'- u.. ~ o = '''' \0 o o N ~ ~ d ~ U -i \0 N ,. oq; c:i ~ 13 E=: ~ en S ~ ~ !:: u f.1l ..:l . ~~ (j . <en (j~ g~ ,0 ~ ~::E en -~7 ~ !il :Ii ~ ~~ <en ~ci Eo-g enf.1l 'I]:l ClO g~ f.1l< I]:l:;;a ~~ ~::.) "~'I _'f ,':JiE ,'~::.. .::J ~' U ~ ... -t , '- ... ~J ~ ... ~ ... , '- I <J I I , :r ~ () () ":J' ~ () J 0 () vi 0- ti It) Qo:.Lj -e;;:N) ~ l.JJ ..... z 9 5 u ~V' f.1l !3 on ~~ ~ ~ i$~ ~f ~6 u ~ ~ , :::: -- () ~ ~ ~ .;,; ~ iL: () () -........: ~ !il :Ii ~ en Cl :'Vi' f-I ! lE' fil ::;::: ""'" :" .... ,.... 0 :.s '" :10. .... i.B~ < :;:., :" : e ~ ~ : 0 gjen_ :;:: <- :< U f.1lR : < f.1l- i ~?: < : Eo- 1:210. reno,s p:",u in on " :g < ~ .. r 1 Ji -+ '2 3 ~ ~~ ~:r; ~ taJ --.J 1: ZtJ (j ". J,Er.AJ, nESCRJPTION ALL THAT CERTAIN piece, parccl and tract of land situate in East Pcnnsboro Township, Cumberland County, Pennsylvania morc particularly bounded and described as follows, to wit; BEGINNING at a point on the Northerly line of Dullcs Drive (East) which point is 83 fcct East of the Northeasterly corner of Gicnwood Drive (Ellst) and Dulles Drive (East) and at dividing line betwecn Lots Nos. 18 and 19, mock" J" , on the hereinancr mentioned Plan of Lots; thence along said dividin.g line North 29 degrees 20 minutes East 107.08 feet to a point at the Southerly line of other land now or late of Glenwood Park, lnc; thence along same South 50 degrees 34 minutes East 90.05 feet to a point at dividing line between Lots Nos. 17 and 18, Block "J" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 100 fect to a point on the Northerly line of Dulles Drive (East); thence along same North 50 degrees 34 minutes West 9,89 feet to a point; thence further along the Northerly line of Dulles Drive in an arc having a radius of 350 feet to the left in a Westerly direction 61.70 feet to a point, the place of beginning. BEING Lot No. 18, Block "J", in Plan No.1 of Ridley Park, which plan is recorded in thc Office of thc Recorder of Deeds in and for Cumbcrland County, Pcnnsylvania, in Plan Book 11, Page 26, known as Dullcs Drive (East). TITLE TO SAID PREMISES IS VESTED IN Robert D. Stanacher, adult individual by Deed from Tcrry E. Chestnut and Joan R. Chestnut, husband and wifc, dated 5/1512003 and recorded 512012003 in Deed Book 257, Page 651. Premises being: 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Tax Parcel No. 09-16-1050-237 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-264 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER (I) 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) Ifproperty 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 himlher that helshe has been added as a garnishee and is enjoined as above stated, Amount Due $112,743.50 LL Interest FROM 2/24/04 TO 9/6/06 - PER DIEM $18.53 - $17,158.78 Arty's Conun % Due Prothy $1.00 Arty Paid $889.01 Other Costs ADD'L COSTS - $5,022.00 Plaintiff Paid Date: MAY 31, 2006 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: SillTE 1400 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 62205 PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ATTORNEY FOR PLAINTIFF Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-264 CIVIL ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). rF.RTTflTrA TTON DANIEL G. SCHMIEG, ESQUIRE, hereby states that he is the 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: ( ) an FHA Mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. sec.4904 relating to unsworn falsification to authorities. DANIEL G. SC G, ESQUIRE Attorney for Plain . (') r-' c:;: = ~ ''''' =' -p ;,~, ..,.. ~-n [I) r:~ 5; L~ -~ m~ (0 C,.-> -0' -<': i2i6; '<-' }:,~-. -0 g~ '~ l~~ ::z c::~ r:-? :::1 ~ ,< 0 -< -- 'lVtORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-264 CIVIL ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 9 DULLES DRIVE EAST, CAMP HILL, PA 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT D. STANACHERA/KJA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .-. .-' 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TENANT/OCCUPANT 9 DULLES DRIVE EAST CAMP HILL, P A 17011 DOMESTIC RELATIONS CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT FO WELFARE P.O. BOX 2675 HARRISBURG, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo '4904 relating to unsworn falsification to authorities. May 10 7001i Date DANIEL G. SC G, ESQUIRE Attorney for Plainti f ",-A~. ~."'.... '''' e-::;;:;; (:;'.;) "'" :J: :;:.- -< o "'11 =l ::L-n rnf".;;;! -am ~;\crJ ::;~!:;~ .- ~,.\ \-;~('''S ;":-.-rn .) >! :n -< w "'" :z r:Y c. . ~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04.264 CIVIL ROBERT D. STANACHER AlKlA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). Please be advised that this firm is a debt collector attempting to collect a debt. Any Information received 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. NOTTCR OF SHRRTFF'S SAT ,R OF RRAT, PROPRRTV TO: ROBERT D. STANACHER A!K/A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Your house (real estate) at 9 nTTT,T.F,S nRTVR F,AST, CAMP HTT.T., PA 17011, is scheduled to be sold at the Sheriffs Sale on SRPTF,MRF,R Ii, 2001i, at 10:00 a.m. in the CUMBERLAND County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $112,74l "i0 obtained by MORTGAGR RT.RCTRONTr RRGTSTRATTON SVSTFMS, TNC (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., 3129.3. NOTTCR OF OWNF,R'S RTGHTS YOTTMAYRF ARTF TOPRFVFNTTHT~ ~HFRJFF'~ ~ATF To prevent this Sheriff's Sale, you must take immediate arnon' 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay, you may call: (Jl"i) "i/il-7000 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. ... 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) VOl! MAY STlT.I. RF. ARI,F. TO SAVF. YOIlR PROPF.RTY ANDYOl! HAVF. OTHF.R RTGHTS RVF.N IFTHR SHRRTFF'S SAT.F. nORS TAKR PI.ArK 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 (7.1 'i) 'ifi1- 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) 7.40-fi1QO. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the Sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 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 TillS 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. Lawyer Referral Service: Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 .. ,. .. I ,F-r.AI, OF-SCRIPTION ALL THAT CERTAIN piece, parccl and tract of land situate in East pcnnsboro Township, Cumberland County, Pennsylvania more particularly bounded and described as follows, to wit; BEGINNING at a point on the Northerly line of Dunc.~ Drive (East) wh ich point is 83 feet East of Ihe Northeasterly corner of Glcnwood Drive (East) and Dulles Drive (East) and at dividing line between Lots Nos. 18 and 19, Dlock "1", on the hereinaftcr mentioned Plan of Lots; thence along said dividing Iinc North 29 degrees 20 minutes East 107.08 feet to a point at the Soulilerly line of other land now or late of Glenwood Park, Inc; thence along same SOltlh 50 degrees 34 minutes East 90.05 feet to a point at dividing line between Lots Nos. 17 and 18, Block "1" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 100 fect to a point on the Northerly line of Dulles Drive (East); thence along same North 50 degrees 34 minutes West 9,89 feet to a point; thence furlher along the Northerly line of Dulles Drive in an arc having a radius of 350 feet to the left in a Westerly directiun 61. 70 feet to a poim, the place of beginning. BEING Lut No. 18, Block "J", in Plan No.1 of Ridley Park, which plall is recorded in thc Office uf the Recorder of Deeds in and fur Cumbcrland Cuunty, Pennsylvania, in Plan Book 11, Page 26, known as Dulles Drive (East). TITLE TO SAID PREMISES IS VESTI:;D IN Robert D. Stanacher, adult individual by Deed from Terry E. Chestnut and Joan R. Chestnut, husband and wifc, dated 5/1512003 and recorded 5/20/2003 in Deed. Book 257, Page 651. Premises being: 9 DULLES DRIVE EAST CAMPHILL,PA 17011 Tax Parcel No. 09-16-1050-237 (") ,..., 0 <= <;; '.:~ -;1 eX'" -' ::1t ~4'1 .- , :t.., rnr:=: -'- c..> 41~ --\) - (~f;, -0 :::;t; t;? 6rn -, - 'Jfi 0 -<. PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney I.D. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION ROBERT D. STANACHER NKJA ROBERT D. STRANACHER NO. 04-264-CIVIL Defendant MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, LLP, petitions this Honorable Court for an Order directing service of the Notice of Sale upon the above-captioned Defendant, ROBERT D. STANACHER A/K1A ROBERT D. STRANACHER , by certified mail and regular mail to 9 DULLES DRIVE EAST, CAMP HILL, P A 17011, and in support thereof avers the following: 1. A Sheriffs Sale of the mortgaged property involved herein has been scheduled for SEPTEMBER 6, 2006. 2. Pennsylvania Rule of Civil Procedure (Pa.R. C.P.) 3129.2 requires that the Defendant be served with a notification of Sheriffs Sale at least thirty (30) days prior to the scheduled sale date. 3. Attempts to serve Defendant with the Notice of Sale have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". 4. Pursuant to Pa.R.C.P. 430, Plaintiffhas made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to 9 DULLES DRNE EAST, CAMP HILL, PA 17011 . PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL G. SCHM G, ESQUIRE Attorney for Plainti PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney I.D. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION ROBERTD. STANACHER A/KJA ROBERT D. STRANACHER NO. 04-264-CIVIL Defendant PLAINTIFF'S MEMORANDUM OF LAW Pursuant to Pennsylvania Rule of Civil Procedure, Rule 3129.2, it is necessary in a foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the Sale ofthe mortgaged premises. Specifically, Pa.R.C.P., Rule 3129.2 (c) provides in applicable part as follows: The written notice shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the Notice shall be made: (i) upon a defendant. . . (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402 (a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy of the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in the subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court. Because the whereabouts of Defendant, ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER , are unknown, a reasonable investigation of their last known address was made in accordance with Pa.R.C.P. 430(a). Pennsylvania Rule of Civil Procedure, Rule 430 (a) provides as follows: (a) If service cannot be made under the applicable rule the Plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A Sheriffs Return or Affidavit of Service of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs.Polis, 238 Pa.Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address. Adoption of Walker, 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations oflocal telephone directories, voter registration records, local tax records and motor vehicle records. As indicated by the attached Affidavit of Return of Service, marked hereto as Exhibit "A", the Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale in accordance with Pa.R.C.P., Rule 430 by certified and regular mail to 9 DULLES DRIVE EAST, CAMP HILL, P A 17011 . Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP DANIEL G. SCH Attorney for Plainti By: FULL SPECTRUM LEGAL SERVICES, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 85718 Attorney Firm: Phelan, Hallinan & Schmieg, LLP Subject: Robert D. Stanacher Property Address: 9 Dulles Drive East, Camp Hill, PA 17011 I, Brendan Booth, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Robert D. Stanacher - 451-04-6181 B. EMPLOYMENT SEARCH Robert D. Stanacher - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Robert D. Stanacher reside(s) at: 9 Dulles Drive, Camp Hill, P A 17011. II. INQUIRY OF TELEPHONE COMPANY A. DIRECfORY ASSISTANCE SEARCH Our office contacted directory assistance, which indicated that Robert D. Stanacher reside(s) at: 9 Dulles Drive East, Camp Hill, PA 17011. On 06-27-06 our office made several telephone calls to the subject's phone number (717) 728-9959 and received the following information: answering machine. On 06-27-06 our office made several telephone calls to the phone number (717) 731-9199 and received the following information: answering machine. III. INQUIRY OF NEIGHBORS On 06-27-06 our office made several phone calls in an attempt to contact Frank Derose, (717) 728-9597, 10 Dulles Drive East, Camp Hill, PA 17011: answering machine. On 06-27-06 our office made several phone calls in an attempt to contact David M. Fruhwirth, (717) 975-1611, 8 Dulles Drive East Camp Hill, PA 17011: no answer. On 06-27-06 our office made several phone calls in an attempt to contact Andrew D. Smith Jr., (717) 732-4097, 12 Dulles Drive East Camp Hill, P A 17011-1105: answering machine. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 06-27-06 we reviewed the National Address database and found the following information: Robert D. Stanacher - 9 Dulles Drive, Camp Hill, P A 17011. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. V. DRIVERS LICENSE INFORMATION A. MOTOR VEHICLE & DMV OFFICE Per the P A Department of Motor Vehides, we were unable to obtain address information on Robert D. Stanacher. VI. OTHER INQUIRIES A. DEATH RECORDS As of 06-27-06 Vital Records and all public databases have no death record on file for Robert D. Stanacher. B. COUNTY VOTER REGISTRATION The county voter registration was unable to confirm a registration for Robert D. Stanacher residing at last registered address. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Robert D. Stanacher - 07-06-1953 ... Our accessible databases have been checked and cross-referenced for the above named individual(s). ... Please be advised our database information indicates the subject resides at the current address. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing states made by me are willfully false, I am subject to punishment. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa e.S. Sec. 4904 relating to unsworn falsification to~ . . _...MMONWEAl.TH or NOTARIALSEAL AIIII \ MOAAM.==,CaIIIIr CIV~~' ...22. AFFIANT - Brendan Booth Full Spectrum Legal Services, Inc. Sworn to and subscribed before me this 27th day of June, 2006. The above information is obtained from available public records and we are only liable for the cost of the affidavit. INO 06 z 7y),- AFFIDAVIT OF SERVICE CQSlpaw PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. CUMBERLAND County No. 84-164 CIVIL Our File tJ: 85718 DEFENDANT(S) ROBERT D. STANACHER AlKJA ROBERT D. STRANACHER Please serve upoo: ROBERTD.STANACHER AlKJA ROBERT D. STRANACHER Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 6, 2006 SERVE AT: 9 DULLES DRIVE EAST CAMP HILL, PA 17011 SERVED Served and made known to 200-. at~' 5' ( , o'clock lm., at , Defendant, on the day of Commonwealth of Pennsylvania. in the marmer described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(sYs residence who refused to give name or relationship. Manager/Oerk of place of Jodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(sYs office or usual place of business. an officer ofsaid Defendant(s)'s company. Other: Description: Age_ Height _ Weight _ Race _ Sex _ Other I, . a competent adult, being duly sworn according to law, depose and state, that I personally handed a true and correct copy of the Noti~" of Sheriff'!: S;lle in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of , 200. Notary: By: , -~.. NOT SERVED On the It)'" '" day of ~~ .200'. at 8~~ l o'clock..e.m.. Defendant NOT FOUND because: ~OVed ~nknown_ No Answer _ Vacant 1st attempt Date: Time: . 2nd attempt Date: Time: .3rd attempt Date: Time: Other: Sfbirc:. wi "f:'''.~CIf..' .f ~o..SC.l +".'( s..ccl "....'1 Pw-t'....scJ "'''e J.......Jt'" Iq"t S.AC4--~su - 4 1wr- SI-h& ~..P~~ /l1J ,R.o/:,J... s.f.~/fc.Iw.,...r.1.$I,~,..4t,~- ~~~ rtt.I'\J""'/{Q . prCVI ~ \S,,_~ G)r CII~'1 Ot.#/L".o-t"""'{'ftI,.-.-I-, efi re e this . ~ /J II ' .". 0: - 2 ..'-- ~BY: /j~ ~ Daniel G. mieg, Esquire - I.D. No. 62105 ::,o;;~::. F~U." .....,- PbiI~~~~RIS (lIS) n ExPlfes June 16, 2008 \ Ie{ VERIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby states that he is the attorney for the Plaintiff in this action, that he is authorized to take the verification and that the statements made in the foregoing Motion for Service of Notice of Sale pursuant to Special Order of Court are true and correct to the best of his knowledge, information and belief. The undersigned also understands that this statement herein is made subject to the penalties of 18 Pa. Sec. 4904 relating to unsworn falsification to authorities. Date: July 26. 2006 ,ESQUIRE PHELAN HALLINAN & SCHMIEG, LLP BY: DANIEL G. SCHMIEG, ESQUIRE Attorney I.D. No.: 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. CIVIL DIVISION ROBERTD. STANACHER AlK/A ROBERT D. STRANACHER NO. 04-264-CIVIL Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy ofthe foregoing Motion for Service of Notice of Sale Pursuant to Special Order of Court, Proposed Order, Memorandum of Law, Certification of Service and Verification in the above captioned matter was sent by first class mail, postage prepaid to the following interested parties on the date indicated below. ROBERT D. STANACHER A/K1A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Daniel G. Schmieg, Es Attorney for Plaintiff Date: July 26. 2006 c' c ,:..,'''''' '" -.J f',) c...) -,"-~ JUl 2 8 20061f' "- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CIVIL DIVISION Plaintiff v. NO.04-264-CIVIL ROBERT D. STANACHER AIKIA ROBERT D. STRANACHER Defendant r- ORDER AND NOW, this LJ!:.. day of ~- ,2006, upon consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of Court and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service ofthe Notice of Sale on the above-captioned Defendant, ROBERT D. STANACHER A/K1 A ROBERT D. STRANACHER , by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to 9 DULLES DRIVE EAST, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of service. fl-r::JJ ~~ C5 J. r,O 1<'\' """f'\>" "'''P-\'''IJ1 "":',... t I j~ w ~l.. ,,' I~, : d ]~tL l~iT:1 . SALE DATE: SEPTEMBER 6. 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. No.: 04-264 CIVIL vs. ROBERT D. STANACHER AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 9 DULLES DRIVE E. CAMP HILL. PA 17011. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. DZd~d~ Attorney for Plaintiff September 1, 2006 ,. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS : Plaintiff, CIVIL DIVISION v. NO. 04-264 CIVIL ROBERT D. STANACHER AlK/A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). : AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 9 DULLES DRIVE EAST, CAMP HILL, P A 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT D. STANACHER AlK/A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None . ", 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TENANT/OCCUPANT 9 DULLES DRIVE EAST CAMP HILL, PA 17011 DOMESTIC RELATIONS CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, P A 17013 COMMONWEALTH OF PENNSYL VANIA DEPARTMENT FO WELFARE P.O. BOX 2675 HARRISBURG, PA 17105 I verifY that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. '4904 relating to unsworn falsification to authorities. MAY 10.1.006 Date DANIEL G. SC G, ESQUIRE Attorney for Plainti ~ . DATE: Mil)' 11, 200/i MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. vs. ROBERT D. STANACHER AfKfA ROBERT D. STRANACHER TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): ROBERT D. STANACHER AIKlA ROBERT D. STRANACHER PROPERTY: 9 DULLES DRIVE EAST CAMP HILL, PA 17011 Improvements: Residential Property CUMBERLAND COUNTY NO.: 04-264 CIVIL Judgment Amount: $112,743.50 The above-captioned property is scheduled to be sold at the CliMBER' ,ANn Sheriffs Sale on SF.PTF.MBER ii, 200/i at 10:00 a.m. in the CUMBERLAND County Courthouse, South Hanover Street, Carlisle, PA 17013. Our records indicate that you may hold a mortgage, judgment, or other interest on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. If you have any questions regarding the type oflien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACf YOUR OWN A1TORNEY, as we are not permitted to give you legal advice. The Sheriff will file a schedule of Distribution 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. CQS -~ - a.)ooZ i1 i ~~~ l:l i" ..... ..... ... ~ ~ Ii ..., ..... 0:> "" ~ ... C\ V> .f>o "" ..., ..... "" '" 1. r ~ ~. ~ iJ t I i~~f t;~ rJ> ~:t .. i~i ~\ ~ ~ll, ~ 1i!nt n a ~~~ )00 . ~ ~l'If. ~ .... ~ii~ ... ~ ..... .-1Dli\\I:' 0:> 'v>' ~.l; ~\ t\ i . ; tlI eel 1. IP' c t ~ ~p~ 1 , 1ie ~ ~ i \: ... ~ .. l\\\i\ ... l:<l ~ i~ ~ \ ~ . ~\.~\\\, toO ~ In"~''i ~ ;~~t~\. ~~, ~" '\<i" ~\ I \\h, \~ 81 \ \ // ".-0 ltt~ ~ ,,\\,tR ~. - \ l .,'~'~I v.rf' i~&' \ . ~. l. .~at I ~;; \ l\6 . ' i ;:;1 '2) ~~ . <f!' .. ~. ift" . ',' L~/ . f uz;;j"~ ~ \ 'i\\ . ""'::"'J:'~"# =---- .._~ I 11 :;i '", 02 1'" $ 00.950- ~g~\ 0004~09625 MAY 31 200/f' ~ l~l ,~ Wollf.O~OMZlPcoDE 19103 l .. ~\ t ~ ' o ,; < ~,>,'.( d':(: r,;; C,l 0-' u> \--r1 --::; ~ .. \ <J1 Q. :t-n n'r: -1"'1 rr1 -(IC:? 7~~\~i, l--!\ C)(~ -:--':-r\l oj ,C4 ~ """ -- -'--'" ~ .r::- 0::> COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Aurora Loan Services Inc is the grantee the same having been sold to said grantee on the 6th day of Sept A.D., 2006, under and by virtue of a writ Execution issued on the 31 st day of May, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 264, at the suit of Mortgage Electronic Registration Systems Inc against Robert D Stanacher aka Robert D Stranacher is duly recorded in Deed Book No. 276, Page 3771. and seal of said office this day of , Mortgage Electronic Registration Systems, Inc. VS Robert D. Stanacher a/k/a Robert D. Stranacher The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-264 Civil Term Jessica Hermansen, Deputy Sheriff, who being duly sworn according to law, states that on July 6, 2006 at 11 :23 0' clock AM, 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: Robert D. Stanacher a/k/a Robert D. Stranacher, by making known to Claudia Stranacher, wife of Robert D. Stanacher, personally, at 9 Dulles Drive East, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2006 at 12:29 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert D. Stanacher a/k/a Robert D. Stranacher located at 9 Dulles Drive East, Camp Hill, Pennsylvania 17011 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: Robert D. Stanacher a/k/a Robert D. Stranacher, by regular mail to his last known address of 9 Dulles Drive East, Camp Hill, Pennsylvania 17011. This letter was mailed under the date of July 13, 2006 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 September 06, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg for Aurora Loan Services, Inc. It being the best and highest bid, Aurora Loan Services, Inc., of 60 1 5th Avenue, Scottsbluff, NE 69361, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $949.83. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Prothonotary Mileage Levy Surcharge Law Journal Patriot News $30.00 18.62 15.00 15.00 30.00 10.00 1.00 26.40 15.00 20.00 377.00 308.00 Share of Bills Distribution of Proceeds Sheriffs Deed 19.31 25.00 39.50 $ 949.83 So Ans~~:/ .~~/L", R. Thomas Kline, Sheriff 11'9- )1>/03/0(, " ' vi) jD' , ( lJi> . LIe. s~5 'tV ~ If3173-- / . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-264 CIVIL ROBERT D. STANACHER AlKlA ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 9 DULLES DRIVE EAST, CAMP HILL, P A 17011. I. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT D. STANACHER AlK/A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as Above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address ofthe last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TENANT/OCCUPANT 9 DULLES DRIVE EAST CAMP HILL, P A 17011 DOMESTIC RELATIONS CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, P A 17013 COMMONWEALTH OF PENNSYL VANIA DEPARTMENT FO WELFARE P.O. BOX 2675 HARRISBURG, P A 17105 I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. '4904 relating to unsworn falsification to authorities. May 10, :WOn Date DANIEL G. SCH G, ESQUIRE Attorney for Plainti f MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, STE. 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-264 CIVIL ROBERT D. ST ANACHER A/K1A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Defendant(s). Please be advised that this firm is a debt collector attempting to collect a debt. Any information received 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. NOTTCR OF SHRRTFF'S SAT ,R OF RRAT, PROPRRTY TO: ROBERT D. STANACHER A/K1A ROBERT D. STRANACHER 9 DULLES DRIVE EAST CAMP HILL, P A 17011 Your house (real estate) at 9 DnLLRS DRTVR 'FAST, CAMP HTTJ'1 PA 17011, is scheduled to be sold at the Sheriffs Sale on SRPTF.MRRR 6, 2006, at 10:00 a.m. in the CUMBERLAND County Courthouse, South Hanover Street, Carlisle, P A 17013 to enforce the court judgment of $112,743.50 obtained by MORTGAGR 'FT,RCTRONTC RRGTSTRATTON SYSTRMS, TNC (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., 3129.3. NOTTCR OF OWNRR'S RTGHTS YOI J MAY BE A BI.F. TO PRF.VF.NT TffiS SHFRTFF'S SA T oF. To prevent this Sheriffs Sale, you must take immediate aetion: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (21 ~ 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOlT MAY STTlJ, RF. ARLF. TO SAW YOUR PROPF.RTV AND YOlT HAW OTHF.R RIGHTS F.WN TFTHF. SHF.RIFF'S SAI,F. DOF.S TAKF. PI,ACR 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 (21 '5) '561-7000. 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 fmd out if this has happened, you may call (717) ?40-6190. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the Sheriff and will be made available for inspection in his office. 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 filing ofthe proposed schedule. 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. Lawyer Referral Service: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 . , I ,EGAJ, DESCRIPTION ALL THAT CERTAIN piece, parcel and tract of land situate in East Pcnnsboro Township, Cumberland County, Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northerly line of Dunes Drive (East) which point is 83 feet East of the Northeasterly corner of Glenwood Drive (East) and Dulles Drive (East) and at dividing line between Lots Nos. 18 and 19, Block "J", on the hereinafter mentioned Plan of Lots; thence along said dividing line North 29 degrees 20 minutes East 107.08 feet to a point at the Southerly line of other land now or late of Glenwood Park, (IlC; thence along same South 50 degrees 34 minutes East 90.05 feet to a point at dividing line between Lots Nos. 17 and 18, Block ..]" on said Plan; thence along said dividing line South 39 degrees 26 minutes West 100 feet to a point on the Northerly line of DutIes Drive (East); thence along same North 50 degrees 34 minutes West 9.89 feet to a point; thence furlher along the Northerly line of DutIes Drive in an arc having a radius of 350 feet to the left in a Westerly direction 61.70 feet to a point, the place of beginning. BEING Lot No. 18, Block "J", in Plan No.1 of Ridley Park, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 11, Page 26, known as Dulles Drive (East). TITLE TO SAID PREMISES IS VESTED IN Robert D. Stanacher, adult individual by Deed from Terry E. Chesumt and Joan R. Chestnut, husband and wife, dated 5/1512003 and recorded 5/2012003 in Deed Book 257, Page 651. Premises being: 9 DULLES DRIVE EAST CAMP HILL, PA 17011 Tax Parcel No. 09-16-1050-237 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-264 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From ROBERT D. STANACHER A/KJA ROBERT D. STRANACHER (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) Ifproperty 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 hinv'her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $112,743.50 L.L. Interest FROM 2/24/04 TO 9/6/06 - PER DIEM $18.53 - $17,158.78 Atty's Comm % Due Prothy $1.00 Atty Paid $889.01 Plaintiff Paid Date: MAY 31,2006 Other Costs ADD'L COSTS - $5,022.00 ~. (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: SUITE 1400 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone : 215-563-7000 Supreme Court ill No. 62205 lrre~1b~s ~Wls3 I'B~lI ~ hp9r :Ag ") "-0 8:5 ::;; " g2::;-,., '0 :.::31"" bO ':"""'r'J :::;-; :.;::c .l> .::, n, -- (/) 900Z 'zo ~unf :~lfa'~~ "-> :-< - _ -0" :p;""7l '- c:: <: I "-> 'U!~l~l{ P~l'BlOd.IO~U! ~~U~l~J~l S!l{l Aq PU'B l!.l.M S!l{ll{l!M P~IY "v" l!q!l{XtI uo p~qp~s~p AIItlJ ~lOW 'IHH dw~;) 'lS'BtI ~Apa s~IIna 6 S'B p~l~qwnu PU'B UM.OU)l Vd 'i\lunO;) PU'BIl~qwn;) 'd!l{SUM.Ol oloqsuu~d lS~tI U! P~l'BT1l!S 4I~dOld I'B~l ~l{l U! lS~l~lU! s, lU'BpU~J~P ~l{l uodn P~!A~I JJP~l{S ~ql 900Z 'zo ~unf uQ I L # ~I'BS ~l'BlstI I'B~lI ~ ~ ~ ~ I.::::a oF ,. 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 ofthe Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever SInce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. 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 S ALE #71 VlVANIA CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 : .~. " -;' I!-' ~ AU.'lBA1:''''pielle, ... _lfICtof 1aIIl''',' lB..l!it ~. ~ ~. ' ~ . t\..itjyl\_ lIIlft ~~lliJI'~~jl'" to wife' '," "" ' . . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July 21, July 28, and August 4, 2006 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. SWORN TO AND SUBSCRIBED before me this 4 day of August. 2006 i NOT AR Al SEAL ~ LOIS E. SNYDER. Notary Public . 'Carlisle Bore, Cumberland County I ~,.~~~=::'v1!,rCh ~'..2009 , :REAL ESTATE BALE NO. 71 Writ No. 2004-264 Civil Mortgage Electronic Registration Systerns, Inc. vs. Robert D. Stanacher a/k/a Robert D. Stranacher Atty.: Daniel G. Schmieg LEGAL DESCRIPTION ALL THAT CERTAIN piece, par- cel and tract of land situate in East Pennsboro Township, Curnberland County, Pennsylvania rnore particu- larly bounded and described as fol- lows, to wit: BEGINNING at a point on the Northerly line of Dulles Drive (East) which point is 83 feet East of the Northeasterly comer of Glenwood Drive (East) and Dulles DriVe (East) and at dividing line between Lots Nos. 18 and 19, Block "J", on the hereinafter rnentloned Plan of Lots; thence along said dividing line North 29 degrees 20 rninutes East 107.08 feet to a point at the Southerly line of other land now or late of Glenwood Park, Inc; thence along same South 50 degrees 34 minutes East 90.05 feet to a point at divid. ing line between Lots Nos. 17 and 18. Block "J" on said Plan; thence along said dividing line South 39 degrees 26 rninutes West 100 feet to a point on the Northerly line of Dulles Drive (East); thence along same North 50 degrees 34 rninutes West 9.89 feet to a point; thence further along the Northerly line of Dulles Drive in an arc having a ra- dius of 350 feet to the left in a West- erly direction 61. 70 feet to a point, the place of beginning. BEING Lot No. 18, Block "J", in Plan No. 1 of Ridley Park, which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 11, Page 26, known as Dulles Drive (East). TITLE TO SAID PREMISES IS VESTED IN Robert D. Stanacher, adult individual by Deed from Teny E. Chestnut and Joan R. Chestnut. husband and wife, dated 5/15/ 2003 and recorded 5/20/2003 in Deed Book 257, Page 651. Premises being: 9 Dulles Drive East, Camp Hill, PA 17011. Tax Parcel No. 09-16-1050-237.