Loading...
HomeMy WebLinkAbout08-7149 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY 7760 Office Plaza Drive South West Des Moines, IA 50266-2336 Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON 2 Mooreland Avenue Mount Holly Springs, PA 17065 Defendants #23613-DD CFC Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY 0p 111/1 el-VI t -PYm Case No: CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE Wn1r1r'F ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO. C:UMI3hKLANL) WUIN I Y 15AK ANJiUt-111 I wiV 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 -- 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE 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 ANYT 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 REQQEST 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 RECFEIPT 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. MARTHA E. VON ROSENSTIEL, P.C Martha E. Von Rosenstiel 649 South Avenue, Unit 7 PO BOX 307 SECANE, PA 19018 (610) 328-2887 Attorney ID # 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY 7760 Office Plaza Drive South West Des Moines, IA 50266-2336 Plaintiff VS. Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Case No: RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON 2 Mooreland Avenue Mount Holly Springs, PA 17065 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Nationwide Advantage Mortgage Company, a corporation organized and existing under state law, with offices for the conduct of business at 7760 Office Plaza Drive South, West Des Moines, IA 50266-2336. 2. Defendants, Richard L. Erickson and Christine M. Erickson are the mortgagors and real owners of premises 2 Mooreland Avenue, Mount Holly Springs, PA 17065, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to American Home Bank, N.A. on July 12, 2002, which mortgage was recorded on July 16, 2002 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1765, Page 1395, secured on premises 2 Mooreland Avenue, Mount Holly Springs, PA 17065 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff, Nationwide Advantage Mortgage Company by written assignment dated June 30, 2006 and recorded August 3, 2006 in Miscellaneous Book 729, Page 1503. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June, 2008 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 92,768.23 Interest from 5/1/2008to 12/1/2008 At $17.47 per diem $ 3,756.05 Accrued late charges $ 157.64 Accrued Escrow deficit $ 649.79 Corporate Advances $ 60.50 Attorney's fee (5% of unpaid Principal Balance) $ 4,638.41 Title Information Certificate $ 515.00 TOTAL $102,545.62 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to the Sheriff's sale, reasonable attorney's fees will be charged based on work actually performed. 10. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $102,545.62, plus per diem interest at $17.47 from December-2, 2008 to the date of judgment plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024( c ) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18. Pa C. S. Section 4904 relating to unworn falsification to authorities. LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89-3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one-fourth (84 1/4) degrees West, a distance of one hundred fifty- one (151) feet to a point, the place of beginning. BEING known and numbered as 2 Mooreland Avenue. MAP NUMBER: 23-32-2336-187 EXHIBIT y Nationwide Advantage Mortgage Company 7760 Office Plaza Drive South West Des Moines, IA 50266-2336 DATE: 10/29/08 23613-BP TO: Richard L. Erickson and Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 FOR PROPERTY ADDRESS: 2 Mooreland Avenue Mount Holly Springs, PA 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. EXHIBIT The name, address and phone number of Consumer Credit Counseling Agencies serving you County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S) Richard L. Erickson and Christine M. Erickson PROPERTY ADDRESS: 2 Mooreland Avenue, Mount Holly Springs. PA 17065 LOAN ACCOUNT NO: #: 0001980340 ORIGINAL LENDER/SERVICER: Nationwide Advantage Mortgage Company CURRENT LENDER/SERVICER: Nationwide Advantage Mortgage Company SERVICER FOR: Nationwide Advantage Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. -IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, -IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND •IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days plus three (3) additional days for mailing after the date of this meeting. The names addresses and telephone numbers of desi ng ated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANYTIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 2 Mooreland Avenue, Mount Holly Springs, PA 17065 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments 6/1/2008 to 10/1/2008 @ $1,095.00 per month $5,475.00 Late Charges $ 236.46 Corporate Advance $ 22.00 TOTAL AMOUNT PAST DUE $5.733.46 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,733.46 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Nationwide Advantage Mortga Mortgage Company, 7760 Office Plaza Drive South, West Des Moines, IA 50266-2336 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paving the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 8 months from the date set forth in this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Nationwide Advantage Mortane Company Address: 7760 Office Plaza Drive South, West Des Moines, IA 50266-2336 Phone Number: 1-800-356-3442 Contact Person: LOAN RESOLUTION DEPARTMENT EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney" fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: -TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTEHR LENDING INSTITUTION TO PAY OFF THIS DEBT. -TO HAVE THIS MORTGAGE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF -TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). -TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. -TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. -TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 171 l0 717.780.3940 or 800.342.2397 Ofd ?. 11 t n h r cn Xa rv i , ?V'1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07149 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONWIDE ADVANTAGE MORT CO VS ERICKSON RICHARD L ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ERICKSON RICHARD L the DEFENDANT , at 0017:03 HOURS, on the 9th day of December-, 2008 at 2 MOORELAND AVENUE MOUNT HOLLY SPRINGS, PA 17065 by handing to CHRISTINE ERICKSON WIFE OF DEFENDANT 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 /?21/510V So Answers: 18.00 5.40 /sx" .00 10.00 R. [Thomas Kline .00 33.40 12/10/2008 MARTHA VON ROSENSTIEL Sworn and Subscibed to By: before me this day of A.D. CASE NO: 2008-07149 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONWIDE ADVANTAGE MORT CO VS ERICKSON RICHARD L ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ERICKSON CHRISTINE M the DEFENDANT , at 0017:03 HOURS, on the 9th day of December-, 2008 at 2 MOORELAND AVENUE MOUNT HOLLY SPRINGS, PA 17065 by handing to CHRISTINE ERICKSON DEFENDANT 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 i'2111- 10f C?, So Answers: 6.00 .00 .00 10.00 R. Thomas Kline .00 j/ 16.00 12/10/2008 MARTHA VON ROSENSTIEL Sworn and Subscibed to By: before me this day of A. D. #23613CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONWIDE ADVANTAGE MORTGAGE COMPANY . Plaintiff V. NO. 08-7149 RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Richard L. Erickson and Christine M. Erickson for want of an answer. (X) Assess Damages as Follows Debt $ 102,545.602 Interest from 12/2/08 to 9/14/09 At $17.47 per diem $ 5,013.89 Total - $ 107,559.51 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A ;SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this; Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to„the-gle of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Attorney for iLintiff- Martha E. Von Rosenstiel Attorney I.D. #52634 Print/Type Name and ID Number Phone: (610) 328-2887 This atoday of `ZLf4EY1 hW , 2009 judgment is entered in favor of the Plaintiff and against Defendant(s), Richard L. Erickson and Christine M. Erickson by default for want of an answer and damages assessed at the sum of $107,559 as pe the abov ertification. rothonotary County P Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY 7760 Office Plaza Drive South West Des Moines, IA 50266-2336 Plaintiff vs. : Case No: 08-7149 RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON 2 Mooreland Avenue Mount Holly Springs, PA 17065 Defendants TO: Christine M. Erickson #23613-DD CTD 2 Mooreland Avenue Mount Holly Springs, PA 17065 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSVES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHINTEN 1){ YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION _..?? 2 LIBERTY AVENUE CARLISLE, PA 170.113- .?.."`..." ` 717-249-31'66 800490- Martha E. Von Rosenstiel Attorney for Plaintiff Dated: August 31, 2009 a? #23613CTD - DD Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY 7760 Office Plaza Drive South West Des Moines, IA 50266-2336 Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON 2 Mooreland Avenue Mount Holly Springs, PA 17065 Defendants Case No: 08-7149 TO: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES" OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Martha E. Von Rosenstiel - Attorney for Plaintiff Dated: August 31, 2009 I Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff vs. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 08-7149 NON MILITARY AFFIDAVIT #23613CFJ-DN Martha E. Von Rosenstiel, Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx'. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 reiatingt6" falsification to authorities. Dated: September 14, 2009 Martha E. Von Rosenstiel Attorney for Plaintiff F11 E-) L C17 THE": 2009 SEP 21 P111 2: -13 414.oo Pb AT" Gti' 3n wo e aQos53 004keA. a?.led .t OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Curt Long, Prothonotary Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY PLAINTIFF VS. RICHARD L. ERICKSON AND CHRISTINE : NO: 08-7149 M. ERICKSON DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that'd Judgment has been entered against you in the above proceeding as indic d b t amount of $107,559.51 on September 14, 2009. urt Lon Prothonotary ? Judgment by Default El Money Judgment g /,?, /pq ? Judgment in Replevin Judgment for Possession ? Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von'Rosenstiel, Esquire at this telephone number: 610-328-2887. i Y' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Curt Long, Prothonotary Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY PLAINTIFF VS. RICHARD L. ERICKSON AND CHRISTINE : NO: 08-7149 M. ERICKSON ; DEFENDANT(S) Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that A Judgment has been entered against you in the above proceeding as indi t ed low in amount: qf A 41e $107,559.51 on September 14, 2009. urt Long Proth tary FRI Judgment by Default Money Judgment qla I /p? Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von' osenstiel, Esquire at this telephone number: 610-328-2887. 23613CWE-DN ` Commonwealth of Pennsylvania COUNTY OF CUMBERLAND NATIONWIDE ADVANTAGE MORTGAGE COMPANY COURT OF COMMON PLEAS V. DOCKET NO. 08-7149 RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON ATTORNEY I.D. #52634 Praecipa for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 9/15/2009 to 3/3/2010 At6% TOTAL* *Plus costs to be endorsed $ 107,559.51 $ 3,005.60 $ 110,565.11 Martha E. Von Rosenstiel Attorney for Plaintiff .649 South Avenue, Unit 46 Secane, PA 19018 (610) 328-2887 PREM: 2 Mooreland Avenue, Mount Holly Springs, PA 17065 ' 0 p004 tLJ _ C ?v O h O h ? ?l i_:.: p MM y ?•I TT^^ V1 ? O z w ? ? W W • ? O ?? xU z° w zz z 4 •r °i o c ?n O v? I? M O o 69 6f? b C) N ? 0 O o ? N U d?o,Q? a V Ai ?too O V to V 110 wi O C1, , 00 00 > ??cv 00 .10 con w c #23613CAM - DN Martha-E- Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY Plaintiff VS. NO: 08-7149 RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 2 Mooreland Avenue, Mount Holly Springs, PA 17065: 1. Name and address of owners(s) or reputed owner(s) Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 2. Name and address of defendant(s) in the judgment: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 3. Name and address of every judgment creditor whose judgment is a record lien on the rera? property to be sold: James Costopoulous 13 South Carlisle Street Carlisle, PA 17013 Capital One Bank L5000 Capital One Drive Richmond, VA 23238 4. Name and address of the last recorded holder of every mortgage of record: Members First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. CIO Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Ab ,Oept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Occupant 2 Mooreland Avenue Mount Holly Springs, PA 17065 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 herd are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities ,r Martha E. Von Rosenstiel Attorney for Plaintiff Dated: September 15, 2009 F=LEL; -t +w ii ;u TpjE ^I 20095EA 21 Pit 2: 3b Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 6 P.O. Box 822 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 Nationwide Advantage Mortgage Company 7760 Office Plaza Drive South West Des Moines IA 50266-2336 Plaintiff COURT OF COMMON PLEAS CUMBERLANDCOUNTY VS. Richard L. Erickson and Christine M. Erickson : No: 08-7149 2 Mooreland Avenue Mount Holly Springs, PA 17065 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to :the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification W-a orrtie Martha E. Von Rosenstiel -- ` Attorney for Plaintiff Attorney for Plaintiff OF THE ;, " '? p r - A?Y 2009SEP 21 PH 2: 38 Vr 1.31.<t r.,i? ?rL{ #23613-CWE-DN Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 Phone: 610-328-2887 Attorney I.D. #52634 Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff vs. RICHARD L. ERICKSON AND CHRISTINE : No: 08-7149 M. ERICKSON Defendant(s) CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit XX That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false, sWe rt-gilmn herein. }.. Martha E. Von Rosenstiel °' Attorney for Plaintiff P"f 2:38 e?t?`F 23613CAM-DN ,10` Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Attorney for Plaintiff Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 08-7149 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 2 Mooreland Avenue Mount Holly Springs, PA 17065 will be sold by the Sheriff of Cumberland County on Date of Sale: March 03, 2010 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 7013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 08-7149 in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against Richard L. Erickson and Christine M. Erickson, Defendant(s). Judgment was entered on September 14, 2009 in the amount of $107,559.51. The pr6perty was seized and taken in execution as the property of Richard L. Erickson and Christine. Erickson. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Aven' 4e; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of twenty- Ch_Aian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89-3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the'Northern line of West Pine Street; thence along the Northern line of the said West Pine Street,. North eight-four and one-fourth (84 1/4) degrees West, a distance of one hundred fifty-one! (15 feet to a point, the place of beginning. BEING known and numbered as .2 Mooreland Avenue. Tax ID #23-32-2336-187 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 08-71.49. You should check with the Sheriff s Office by calling (717) 240-6390 to the g of determine the actual date of the filing of the schedule. No further notice of the filin : Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7149 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff (s) From RICHARD L. ERICKSON and CHRISTINE M. ERICKSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as 4 garnishee and is enjoined as above stated. Amount Due $107,559.51 L.L. $.50 Interest from 9/15/09 to 3/03/10 at 6% -- $3,005.60 Atty's Comm % Due Prothy $2.00 Atty Paid $168.40 Other Costs Plaintiff Paid Date: 9/21/09 1117,11 A urtis R. Long, onotary (Seal) By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQU IRE Address: MARTHA E. VON ROSENSTIEL, PC 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 #23613CAM - DN Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON Defendant(s) NO: 08-7149 AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on October 6, 2009 , true and correct copies of the Notice of Sheriff s Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to a'u1J1orities•.--w-7> Martha E. Von Rosenstiel Attorney for Plaintiff Dated: September 15, 2009 01j For Accountable Mall ,? S(Q r - ° 1 o 06 co CO 0) cn .0, w N d CL Ooa 0° a' z _ CL 7 W W m N -? zy ' W 3 FD ?m m z- 3 N i;?0 o v Kcn? n 0 S-0 OD-0 D N O? 0 o n C o A m o0 >v m SV>mT y ?cD 00 0-?m vnO 3 , 2cn? T V-,r D N C-I0> ?- o Q ) O ?X O 0 0 n >v o c 0-0 0 c z CD ??3 nco0D ? _ ? o 3 Oat 0 3 p) ?a - W 070) v 0 c w 0'a . ;j N mm m w O7U10 O c O 0 ar c`G CD 3 =-:E _'.o CA a, Q , g0o6o>3 ' c 3 (n O Q =0 3 N C Q O 3 3 3 N 0 O= O O ?••? O y O -- 7 02.0 C y " 0 C O x 0 O (O N S (D O O 7 0 C O 3 >( Nj . p C O= -, X lD O y O (D I S 0 U C O W-0 C 7 M ? N ? N (D 3 O (D ? ? X .O N y `< O y' fD `< (D d (D (D S -0O 0) (D -00 D S Dm D °•m 0 ?m -n -? ouv = n - rnr.: ? N •I "n Du) c 3 ? O N ? NCO o? m D c n Dc 0 0 D D° W C >0 o ? fD °; ? D ?auwo ?0 ? -?(D v3 ?Z ? n »D ?(D y < ? j ) D i, c S m @ - 0 m CL 0 - * Z to 3 r1 nj CD o< N n -wC O -+. U > = 7 - c Q •O V p0 Cn N ?, °c ? ?a) W0 V N C N O O O ° C (o to y' O C c 7 ? n y CO ."D N 00 - D CD N --' ( N :0 CO b y (D -V O n (n O O N oo n 0 W D) (D (p .,a - N O N N 00 O 1 N W CD W N'z (D (D D? C 2• toll <. (D V 0 n i C o x CD D < N > _ ? ?c = ?< C o x n nN m Z m cn d w C O N v 0 m O N C CD 0) Cn _ D ( C) CD :3 CD Ch N m m vI y w 3 r- (D o' p_ m °, 3 n r `l 0 N ??? ? (o O (D O to (D m 0 C cc 3 o (c (D (D - CD a m 0 < 1:10 N x a 60 -n O ( (D D y ( (D CD - N 0 C - =r SECgN 0 = =r a N n D) m _ a a CD X O ? 0 3 c = - (D D N CD m (D -a• 3 m o (p a n !I CD CO CD a) > o $ 19o v m y? ?C o C U oI Cr C O 7• cD C N C 0 O d (p C a .y. -N S .n U C d 7 - V! C C1 n ?' ?Cn Oj »m OOcm i 3 01? a -0 - . _ a 7 0 N O N 7 Q ) 0) 7 ' V d O 7 m O 3 ?. N W 3 N ?. ' % N CO T y o o O M O NfTE2q o c m U) Amoco r f rn W T _ c? us y i N ai 0 w U i a L r 3 N . n O 1 - 3 c S CD N C O t o C o 11) ? o g ' cc QG 6 m '; :. MAYBE USED FOR DOMESTIC AND T ERNA PROVIDE FOR ?N5URANCE-P05TMASTR?--^' Received From: MARTHA VON ROSE 649 SOUTH AVENUE UNIT 7 One piece of SECANE, PA ] 9018 or f f x [cc here in stamps r, meter pos?src and OC)0 $'001 • ' 3'P nr r)F n^c, MAILED FR tv ._ir i r eiarY marl addressed to; ?F t j 13 South Carlisle Street -__Carlls i i PS ?•orm 3R1 i, Mar.!9?c 2CC9 OCT 12 AIM 10: 2 c n.. PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT Richard L. Erickson and Christine M. Erickson SERVE UPON: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 AFFIDAVIT OF SERVICE COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 08-7149 23613-DN TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriffs Sale SPECIAL INSTRUCTIONS: please serve defendant personally Sheriffs Sale Date: 03/0312010 or adult in charge of premises ?. SERVED nr_ a Defendant personally served. adult family member with whom Defendant resides. Manager/Clerk of place of lodging in which Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual place of business. refused _ Other to give name/relationship. Description: Age Height Weight rA-5 Race w Sex r Other I, V-671/ Mb L` a competent adult, being duly sworn according to law, depose and state that I personally handed to Z?ruE IM a) a true and correct copy of the WRIT OF EXECUTION and Notice of Sherifrs Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscdn before me this day of ILI =g 20 Notary: By: NOT SE On the day to 20_, at Moved Unknown No Answer KIMBERLY C?JR- TY NOTARY PUBLIC STATE OF NEW' ;ERSEY MY COMMISSION EXPIRES 'MARCH 7, 2013 o'clock - M., Defendant NOT FOUND because: Vacant Date of Attempt., to before me this day of 200_. Notary: By: ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 T/Z? a i`t_E_.-i=F=AE R rAY 2009 DEC _3 Pig 3. 20 AFFIDAVIT OF SERVICE PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT Richard L. Erickson and Christine M. Erickson SERVE UPON: Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 SPECIAL INSTRUCTIONS: please serve defendant personally or adult in charge of premises to COURT OF COMMON PLEAS Cumbcriand COUNTY COURT NO. 08-7149 TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriffs Sale Sheriffs Sale Date: 03/0312010 SERVED °endant. on the 23613-DN Defendant personally served. Adult family member with whom Defendant resides. Manager/Clerk of place of lodging in which Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual place of business. refused _ Other to give name/relationship. Description: Age 46-5 Height Weight 1247 Race W Sex_j Other I, NAG L(. , a competent adult, being duly sworn according to law, depose and state that I personally handed to 1 / Feu a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subscribd before me this day KIMBERLY CURTY of 20 NOTARY PUBLIC N By. STATE OF N2EW JERSEY NOT T st E MY COMMISSION EXPIRES MARCH 7, 2013 On the day 20_, at o'clock _. M., Defendant N 50T F8WN9 Woo Moved Unknown No Answer Vacant Date of Attempt: before me this day of 200_, Notary: By: ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 9/?q' FAR ' e P t Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 7 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 #23613CAM - TM Attorney for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS n COMPANY CUMBERLAND COUNTY _ Plaintiff ;:nn -r j co VS. ? .a RICHARD L. ERICKSON AND CHRISTINE : NO: 08-7149 ? - 30 /i M. ERICKSON =r% ' Defendant(s) SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on January 28, 2010, true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. U.S. Treasury Department 1000 Liberty Avenue Pittsburgh, PA 15222-9974 The United States of America c/o the US Attorney for the Middle District of PA Ronald Reagan Federal Building, Suite 220 228 Walnut Street Harrisburg, PA 17108 The United States of America c/o The U.S. Attorney for PA 101h & Constitution Avenue, NW Washington, D.C. 20530 Internal Revenue Service 600 Arch Street Philadelphia, PA 19106 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January 27, 2010 Martha E. Von Rosenstiel Aftomey for Plaintiff For Accountable Mall p) -' O (O OD v ID (r a z C N Q ("- fD m CL m 0 ?d A W N C N N W Z D ? n ?m N D 7 0 a j ? G Q ? NI S1 4r~ p ? ?00" ?a S to NC 0 O cn 0 _3 Om =,v'ro Nam 3 c C. z 0 0 C? c 0.x0 C? ?d 3 cn M O a c (D CO) N m CO) CL c 0 ? a> a? ; vo D aa? ?a 0 -L A 0 N V -n rL O N tlf 7 'gyp lD C O) N 7 O i 0 m 0 N C w 0 y CD CD > (D -4,0 CL CD a) 3 CL P CD 8,3 !R- cn C -1 (D W S (D V (D p c CD (n ZD? CL 3 O S CL CA (in > c N O (D O (D d m T :r C5 co y C ? X V n ?? 0 0003 ca 0 A( In P? 0 N n ( (D ( (DD D CD as ?m -n CD CL CIO ? 0 m n X ?_ O ? 3 (n-4o c 3 W 2 0 :r = cu (D D x rn _ C 13 33 z ?(° a y c 8 _ 0 3x ''3a M j'@ CID m p? (cpnp 3 ?• c a m :(1 ? 7 CD 3 ?. "'. LU. W N O 7 • -w C N ?? O O lD y *(d c , " c x. 0 ? and d c 7 QN c (D C O (d Q 7 N 0 d 7 C N (D O Z CD y Cn N 3 1 c N N N O C 44 9 CL W N ( O r 3'd Om 0 > n f? 5 y Q00N O- CIO r 0C m 3 O - O T CL 0 .7 0 to m O, ?, a m 7 7 ;w 0 C j) 0 f_Qp? CD a O 3 ?= O (D O N C7 ¦ y J ( // ' 7 ° gm3° 2: M o tic?oaRa, 0' ? O O T .. N c> i i1NrP °e ?? c> U O al -1. -2 ' ° ? a t;? 4= 5 ov i v N(c 7 3 °c m J C9 y. y ,0 C 0 7 CL 0 ( D 3 O X ? y 4,& `j c A 7 ?n (D B '.OD . u X y CD' N CD rn y i T { Oro 0 . m (D a i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' 'Y Jody S Smith 44"n, at ???1,1:4,p?.l ??14 ,ti Chief Deputy Richard W Stewart Solicitor ?? r F Nationwide Advantage Mortgage Company Case Number vs. Richard L Erickson (et al.) 2008-7149 SHERIFF'S RETURN OF SERVICE 12/17/2009 05:27 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1719 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard L. Erickson, located at, 2 Mooreland Avenue, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 03/02/2010 Property sale postponed to 5/5/2010. 04/27/2010 Property sale postponed to 7/7/2010. 06/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Von Rosenstiel on 6/28/10 SHERIFF COST: $795.32 SO ANSWERS, June 28, 2010 RON R ANDERSON, SHERIFF e lI 76 7.3 5 ice` -7 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Eswire 649 South Avenue, Unit•6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 #23613CAM - DN Attorney for Plaintiff 4 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY Plaintiff : VS. RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON Defendant(s) NO: 08-7149 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 2 Mooreland Avenue, Mount Holly Springs, PA 17065: 1. Name and address of owners(s) or reputed owner(s) Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 2. Name and address of defendant(s) in the judgment: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: James Costopoulous 13 South Carlisle Street Carlisle, PA 17013 Capital One Batik 15000 Capital One Drive Richmond, VA 23238 4. Name and address of the last recorded holder of every mortgage of record: Members First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 N Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Occupant 2 Mooreland Avenue Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities: Martha E. Von Rosenstiel Attorney for Plaintiff Dated: September 15, 2009 23613CAM-DN Martha E. Von Ro nstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff vs. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : No: 08-7149 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 2 :Mooreland Avenue Mount Holly Springs, PA 17065 will be sold by the Sheriff of Cumberland County on Date of Sale: March 03, 2010 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 08-7149 in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against Richard L. Erickson and Christine M. Erickson, Defendant(s). Judgment was entered on September 14, 2009 in the amount of $107,559.51. The property was seized and taken in execution as the property of Richard L. Erickson and Christine M. Erickson. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-7149 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff (s) From RICHARD L. ERICKSON and CHRISTINE M. ERICKSON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $107,559.51 L.L. S.50 Interest from 9/15/09 to 3103110 at 6% -- $3,005.60 Atty's Comm % Due Prothy $2.00 Atty Paid $168.40 Other Costs Plaintiff Paid Date: 9/21/09 (Seal) urtis R. of on ary By: Deputy REQUESTING PARTY: Name: MARTHA E. VON ROSENSTIEL, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, PC 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 On October 1, 2009 the Sl?eril'Ilevied upon ?l?e defendant's interest in the real property SMKIted ill Borough Of Mount Holly Sp?-ings, C'umberlar?d C'uunty, PA, Known and numbered as ? 1Vloore.land AVenue, Mount I-folly Springs, mere I'Lilly described on 1"xhibit ".A- tiled with this writ and by this referc??ce iucorp??r:?(c?cl herrin. Date: October 1, 2009 13y: 1ycal Lstale Cmwdill," W, 77 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1. 784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22, January 29, and Febru 5 2010 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. Li Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 5 day of February 2010 I -1 -401 Notary - ' NOTARIAL SEAL DE80RAI? A CO!.'-INS Notary Public CARLISLE 80P0, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 v Writ No. 2008-7149 Civil Nationwide Advantage Mortgage Company VS. Richard L Erickson Christine M Erickson Atty: Martha Von Rosenstiel ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Penn- sylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89- 3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one-fourth (84 1/4) degrees West, a distance of one hundred fifty-one (1 51) feet to a point, the place of beginning BEING known and numbered as 2 Mooreland Avenue. IMPROVEMENTS: Residential dwelling. Tax Parcel # 23-32-2336-187. BEING THE SAME PREMISES: Richard L. Erickson and Christine M. Erickson, husband and wife, by Deed from Thomas E. Clement and Yvonne D. Clement, husband and wife, dated 7/5/2002 and recorded 7/16/2002 in Deed Book 252, Page 3531. PROPERTY ADDRESS: 2 Moore- land Ave, Mount Holly Springs, PA 17065. The Patriot-News Co. r 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe Patriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/22/10 C 01/29/10 02/05/10 Sworn to a bscribed before met is "y fFebruary, 2010 A.D. Y - Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Sherrie L Kisner, Notary Public City Of Harrisburg, Dauphin County MY COrnmission Ewes Nov. 26, 2011 Member, Pennsylvania Association of Notaries Docket. Number: 2008-7149 Civil Term Nationwide Advantage Mbrtgage Company vs. f Richard L Erickson Christine M Erickson Atty: Martha Von Rosenstiel AtL le[.'? ?. ? - the. ` ._ ? `o[ Mnerf liily Bptgs, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Momeland Avenue; thence along Mooreland Avenue, North one-fourth. (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in he of lands now or formerly of Cbristian Otto; thence by :land now or formerly of the said Christian Otto, South eighty-nine. and three-fourths (89-314) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moors Trine; thence along other lauds now or formerly of the said Emelyn Moore Trine, South one-fourth (114) degree West, a distance of one hundred for"ne (141) feu, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one-fourth (84114) degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of beginning BEING known and numbered as 2 Mooreland Avenue. IMPROVEMENTS: Residential dwelling Tax Parcel 4 23-32-2336-187 BEING ITIE SAME PREMISES: Richard L. Erickson and Christine M. Erickson, husband and wife, by Deed from Thomas E. Clement and Yvonne 1). Clement, husband and wife, dated 71 51'2002 and recorded 7116J2002 in Deed Book 252, Page 3531. PROPERTY ADDRESS: 2 Mooreland Ave, Mount Holly Springs, PA 17065 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/ No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE; COMPANY Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON Defendant(s) #23613CAM - DN 3 COURT OF COMMON PLEAS 77 CUMBERLAND COUNTY `-= MW CD -, M C-) NO: 08-7149 AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Mkt E. Vern ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on (Q -,5-11 , true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSAIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff ( b ? For Accounbbl. Mail (? r -f r N O CO OD ?I O) CT1 A W N _a N 0 D m B o am Z < 3 a N a , c 3 ' 0 N 7 .. C o N z D ^ CD W 3 m 0 y - D3 !Z-1 c R ° ' ;D- o 5 m C '2 Kc'K cDOm M 007-O m cD O KNO Q o 2-op m m 0 =-oDW-0 m cy O ? C)-T m m 0 3 :ccl) -u m?sD m *-oC-40> m?= y ox OO 00 0 m o c 0 0 m c o (j;* > ;o Q Q - m - . ? ) 3 O N 3 m f m 3. m N W m v ty a0 = .0 3. ? CO CO ? 3 m W CD C/) m p CCD U ? 4/ C 3 Da 3. CD p fN CD aQ 7 W p 0 >3 ym 5 r 3 p! .. `< =. 3 U! C Q CD 3 c 3 -i CD C M_ • o r DO mo C H -, NO m rm O 901 co 1 N( 0= a '0 NCD Oe - 0 .D0 00 m_e 0) O om< C Nd yK m 0 0) _(D -0 O 0?) '0 Q =r D y> rn -° CD a? T! ' aD? a rn ??n? 3 Dc 3 3 N?? m W D c a D y a y ?' -?? r <m tu - g n? D?i (D ?y 0 vQ CD CD O M ?? o-ii m - -43 -'•M M 0 a ?? °1 O ? y D m O ? W <, . >L" >"W3 ? "OfD? -4CD ? c x 3 v m CD =r ?p O C fG Off' C On iN oc f m Z . -. -4 7C N O BCD (D D ° CD C O Va m" O 7 7 C N C D •Q ~' c W m N -4 _R N U) W m y+ W m fOD y OD C 0 w .? W p CD C, s N ;u QD m M m O A 01 C N CD .U C70 a @ m @ .a 5 N. CD OD _a < O c- 3 ? ` O ? <D d N n y ?. - m O ? x m m D < , o m N = C s m < CD w O ?, x ' a ? rn -j Z CA CL O N D " -4 ? ? 3 O C CD m T C O O m C @ CA -i C CD D O rn 0 CD 3 2 tr y °? 3 ? !- m . O Q O : n M m ??? ? T 005 x N oC CO . p 3 CD ? CD CD a a ,0 ? ? d X a 60 T N CD O. CO 0 . = N d 3 ) C =r w m ;J CD m CL CD M ?Xm a p V/C D CD 0 c c = a CD '. 3 m am m < m 3@ ^ g 0 !A CD ??? o .m o m m d N C? (p e 0 m a -0 y ?, N 0 c c m N n . + O fl7 N- d -0 N c I ? ? @ N m CL 0 N ? o 3 .:3 OM O v M N O q.+61 v? 1 a CL 0 0 0 3 -n. - a? i= M m 0a :3 o j. =5 °-'o 0 a) o iCD m m vn CA tG 0 m to ? CL : 3 cr 0 r _ W - 3 a tm na i A 3 ?m _ - d iax N m rn , N fee hcrt in sumps MAY BE USED FOR DOMESTIC AND rMTER PROVIDE FOR INSURANCE-POSTMASTER Received From: MARTHA VON ROSEN59H 649 SOUTH AVENUE a I ? n?frz P. -?' _ 1, kS r , i _ UNIT 3 SECANE, PA 19018 One piece of ordinary mail addressed lo: James Costopoulous 13 South Carlisle Street Carlisle PA 17013 PS Form 3917. Mar.1999 ` 1? ?y f , S C? 3 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff F-11, - E D- O F F I P for Plaintiff r" T#€: FP?OTNONOTA°"ey 2012 FEB -2 PM 2: 2B CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) NO: 08-7149 #23613CAM - SS SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on January 31, 2012, true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. The United States of America c/o The US Attorney for the Middle District of PA 235 North Washington Avenue Scranton, PA 18501 The United States of America US Attorney for PA 10th & Constitution Avenue NW Washington, DC 20530 I verify that the statements made in this affidavit are true and correct upon information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 04 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire l Attorneys for Plaintiff Dated: January 31, 2012 f U. .POSTAL 5ER V ICE CERTIFICA I = . - MAYBE USED FOR Do?a5,nC AND fNTERNAT- ES 107 PROVIDE FOR rNSIYR ANCE-POSTMASTER ; Received From: MARTHA VON ROSENS77EL, P'. C'. 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: The United States ofAmerirn c/o The US Attorney for the Middle District of PA 2,35 North Washington Avenue Scranton. PA IRS01 PS Fnrm'IR1? kA.. 11320 A WIx fee heR_in stamps 01 meW posWc and Post mark. in0frre of t mim"Iel for c-c l U.S. POSTAL SERVICE CERTIFICATE'4w- IL.1l G Am. fee here in stamps MAY BE USED FOR DOMESTIC AND f MRNAT)t'A1."Wk*-1 ESWO1 Or arcu? posta?c and PROVIDE FOR INSI R ANCE-POSTMASTER Post mart. Inquite Of Received From- N4ARTHA VON ROSENSTIEL, P.C. 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One piece of ordinary mail addressed to: - United States of America US Attorney for PA - 10* & Constitution Avenue NW Washington, DC 20530 V PS Form 3917. Mar. 19R9 7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson J-' ?L, r?7 Sheriff Jody S Smith Chief Deputy 2 !2 A R 2 56 5 7 Richard W Stewart ?. , Solicitor PEN14SYLVANfA ` f Nationwide Advantage Mortgage Company vs. Case Number Richard L Erickson (et al.) 2008-7149 SHERIFF'S RETURN OF SERVICE 12/29/2011 04:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 2 Moreland Avenue, Mount Holly Springs, Cumberland County, PA 17065. 03/15/2012 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 7, 2102 at 10:00 AM. He sold the same for the sum of $131,601.00 to Attorney Karl Ledebohm, on behalf of Members 1 st Federal Credit Union. Members 1st Federal Credit Union at 5000 Louise Drive, Mechanicsburg, PA 17055, being the buyer in this execution, paid to the Sheriff the sum of $138,073.02. SHERIFF COST: $3,807.70 April 11, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF OZA t16-oo rd. Proposed Schedule of Distribution Posted March 23, 2012 Writ No. 2008-7149 Civil Term Nationwide Advantage Mortgage Company VS Richard L. Erickson and Christine M. Erickson 2 Mooreland Ave. Mt. Holly Springs, PA 17065 Sale Date: March 7, 2012 Bid Price: $131,601.00 Buyer: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Real Debt: $107,559.51 Interest: $ 16,001.31 Atty Paid: $ 985.22 Total: $124,546.04 RECEIPTS: Received on November 3, 2011 (check 47923) Received on March 7, 2012 (check 694553) Received on March 14, 2012 (check 696058) $ 1,500.00 $ 13,900.00 $124,173.02 TOTAL RECEIPTS $139,573.02 I DISTRIBUTION: Refund to Members 15t FCU for overpayment at settlement: Sheriff's Costs: Barbara Boise - Local Tax Collector: Mt. Holly Springs Borough - Water, Sewer & Refuse: Refund of advance costs to Attorney Daniel Schmieg Nationwide Advantage Mortgage Company For Writ No. 2008-7149 Civil Term Members 15t Federal Credit Union For Writ No. 2009-2416 Civil Term Total Distribution: Balance $ 3,540.00 1 $ 3,807.70 $ 634.51 $ 293.55 $ 1,500.00 $124,546.04 $ 5,251.22 ($139,573.02 ) 0.00 So An5?vgers: R nny R. Anderson Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2008-7149 Held March 7, 2012 EFFECTIVE DATE: March 7, 2012 PREMISES: 2 Mooreland Avenue, Borough of Mount Holly Springs, Cumberland County, Pennsylvania, Tax Parcel No. 23-32-2336-187 (the "Premises") RECITAL: Being the same Premises which Thomas E. Clement and Yvonne D. Clement, husband and wife, by their deed dated July 5, 2002 and recorded July 16, 2002 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 252, Page 3531, granted and conveyed unto Richard L. Erickson and Christine M. Erickson, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriff s sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2012. 20. Mortgage in the amount of $120,000.00 from Richard L. Erickson and Christine M. Erickson to American Home Bank, N.A. dated July 12, 2002 and recorded July 16, 2002 in Mortgage Book 1765, Page 1395, assigned August 3, 2006 in Misc. Book 729, Page 1503 to Nationwide Advantage Mortgage Co. -2- . . 0 , 21. Mortgage in the amount of $46,000.00 from Richard L. Erickson and Christine M. Erickson to Members 1" F.C.U. dated September 5, 2006 and recorded September 29, 2006 in Mortgage Book 1967, Page 3658. 22. Judgment against Richard L. Erickson and Christine M. Erickson in the amount of $107,559.51 entered September 21, 2009 in favor of Nationwide Advantage Mortgage Co. to No. 2008-7149. 23. Judgment against Richard L. Erickson and Christine M. Erickson in the amount of $49,139.66 in favor of Members 1St F.C.U. entered June 1, 2009 to No. 2009-2416. 24. Judgment against Christine Erickson and C & R Transportation, Inc. in the amount of $7,440.27 entered October 7, 2008 in favor of Capital One Bank to No. 2008-4188. 25. Judgment against Christine M. Erickson in the amount of $8,302.95 in favor of United States Treasury Department entered November 20, 2009 to No. 2009-8071. 26. Subject to the restrictions noted in Deed Book "J", Volume 23, Page 878. 27. Subject to the rights granted Mount Holly Water Company in Misc. Book 159, Page 1032. 28. Subject to the rights of others in and to any portion of the Premises within or adjoining West Pine Street or Mooreland Avenue. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: AKeith O. Brenneman -3- ., e , Writ No. 2008-7149 Civil Term Nationwide Advantage Mortgage Company VS. Richard L. Erickson and Christine M. Erickson Atty.: Martha E. Von Rosenstiel ALL THAT CERTAIN lot of ground situate in the Borough of Mount o ly Penn- Springs, Cumberland County, sylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or land rly of Christian now or Otto; thence by of the said Christian Otto, South eighty-nine and three-fourths ( one 3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four d a one- fourth (84 1/4) degrees West, dis tance of one hundred fifty-one (1 fectBEING point, known and numbered as 2 Mooreland Avenue. IMPROVEMENTS: Residential dwelling. Tax Parcel # 23-32-2336-187. TITLE TO SAID PREMISES IS VESTED IN Richard L. Erickson and Christine M. Erickson, husband and wife, by Deed from Thomas E. Clement and Yvonne D. clement, 02 husband and wife, dated 7/5/ and recorded 7/16/2002 in Deed Book 252, Page 3531. EXHIBIT A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff s oustiip ofat?nrir?rt? Jody S Smith 'Chief Deputy Richard W Stewart Solicitor OFFICE OF Tr-E S?-ERIFF Nationwide Advantage Mortgage Company Case Number vs. 2008-7149 Richard L Erickson (et al.) SHERIFF'S RETURN OF SERVICE 12/29/2011 04:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 2 Moreland Avenue, Mount Holly Springs, Cumberland County, PA 17065. 03/15/2012 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 7, 2102 at 10:00 AM. He sold the same for the sum of $131,601.00 to Attorney Karl Ledebohm, on behalf of Members 1st Federal Credit Union. Members 1st Federal Credit Union at 5000 Louise Drive, Mechanicsburg, PA 17055, being the buyer in this execution, paid to the Sheriff the sum of $138,073.02. SHERIFF COST: $3,807.70 March 15, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Tel©osoft. Irc MARTHA E. VON-ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE : M. ERICKSON , Defendant(s) #236113 CAM - DN COURT OF COiviMON PLEAS CUMBERLAND COUNTY NO: 08-7149 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1. Martha E. Von Rosenstiel ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 2 Mooreland Avenue, Mount Holly Springs, PA 17065: 1. Name and address of owners(s) or reputed owner(s) Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 2. Name and address of defendant(s) in the judgment: Richard L. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 Christine M. Erickson 2 Mooreland Avenue Mount Holly Springs, PA 17065 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: James Costopoulous 13 South Carlisle Street Carlisle, PA 170 13 'Capita'l One Bank 15000.Capital One Drive Richmond, VA 23238 4. Name and address of the last recorded holder of every mortgage of record: Members First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 171128-0603 Occupant 2 Mooreland Avenue Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 lating to 11-sworn falsification to authorities. Respectfully S bmitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff t Dated: September 02, 2011 1 23 613 CAM-DN 01 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE COURT OF COMMON PLEAS MORTGAGE COMPANY CUMBERLAND COUNTY Plaintiff VS. RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON Defendant(s) : No: 08-7149 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 2 Mooreland Avenue Mount Holly Springs, PA 17065 will be sold by the Sheriff of Cumberland County on Date of Sale: March 07, 2012 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 08-7149 in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against Richard L. Erickson and Christine M. Erickson, Defendant(s). Judgment was entered on September 21, 2009 in the amount of $107,559.51. The property was seized and taken in execution as the property of Richard L. Erickson and Christine M. Erickson. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of ` Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89-3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or 'less, to a point "ron pin), in ?l -he Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one-fourth (84 1/4) degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of beginning. BEING known and numbered as 2 Mooreland Avenue. Tax ID #23-32-2336-187 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 08-7149. You should check with the Sheriff s Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 • Ilk ? MARTHA E. VON ROSENSTIEL, P.C. Mart:'ia E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire /No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATI iONWIDE ADVANTAGE MORTGAGE: COMPANY Plaintiff VS. ARD L. ERICKSON AND CHRISTINE : A.1%_1 M. ERICKSON Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 08-7149 LEGAL DESCRIPTION #23613-DN ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89-3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one-fourth (84 1/4) degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of beginning. BEING known and numbered as 2 Mooreland Avenue. IMPROVEMENTS: Residential dwelling Tax' Parcel # 23-32-2336-187 TITLE TO SAID PREMISES IS VESTED IN Richard L. Erickson and Christine M. Erickson, husband and wife, by Deed from Thomas E. Clement and Yvonne D. Clement, husband and wife, dated 7/5/2002 and recorded 7/16/2002 in Deed Book 252, Page 3531. WRIT OF EXEC'?'-ION anc/or,,k77ACHjNTENT t COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7149 Civil CIV 1 ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUTITY: To satisfy the debt, interest and costs due NiiTIONWIDE ADVANTAGE MORTGAGE COMPANY, Plaintiff (s) From RICHARD L. ERICKSON AND CHRISTINE M. ERICKSON (1) You are directed to levy upon the property o 'the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment :has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $107,559.51 L.L. Interest FROM 9/15/2009 TO 3/7/2012 AT 6% - $16,001.31 Atty's Comm % Due Prothy $2.00 Atty Paid $985.22 Plaintiff Paid Date: SEPTEMBER 9, 2011 (Seal) REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQ. Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 Other Costs TRUE CORY FROM RECORD in Testimooy wheys of, l here unto set my hand and the of said at C`.sdisle, Pa..?? This of 2(3 _,.L_, . .1 41 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Plaintiff Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. RICHARD L. ERICKSON AND CHRISTINE M. NO: 08-7149 ERICKSON Defendant(s) #23613CAM - SS SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on January 31, 2012, true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. The United States of America c/o The US Attorney for the Middle District of PA 235 North Washington Avenue Scranton, PA 18501 The United States of America US Attorney for PA 10th & Constitution Avenue NW Washington, DC 20530 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: January 31, 2012 so It U.S POSTAL SERVICE CERTIFICA TE-1OT ~3L1NC MAY BE USED FOR DOMESTIC AND 1NIpRNA'r10NAL [,, - Ilk DOES N07 PROVIDE FOR INSUR ANCE-POSTMASTER ` Received From: MARTHA VON ROSEW 11EL, PC 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One Piece of ordirmiy mail addressed to: The United Stat of Arnari? cao The US Attorney for the Middle District of Pa 235 North Washington Avenue Scranton PA 18501 PS F n r m 3R /. Mar. 19R9 S? 3 Alftx fee here in stamps Oi, mclet postage and Post rrvsirk.; -inquire--of Fnsfiniixi for -arncnt U.S. POSTAL SERVICE CERTIF]CAT:E-,QF K, ,A.1.,L,)1?tC Affix fee heft in stamps MAY BE USED FOR DOMESTIC AND INTERNATIONAL MA 1 T>DE '7407 Or 'meter postage and PROVIDE FOR rNSUR ANCE-POSTMASTER Post mark. `lriquire of Received From: 1,0SIM&SICI -for "ent :MARTHA VON ROSENSTIEL, P--C. " 649 SOUTH AVENUE UNIT 7 SECANE, PA 19018 One Piece of ordinary mail addressed to: - United States of America US Attorney for PA - 10th & Constitution Avenue NW - Washington, DC 20530 x (,, ;' J 1?S Fnrm 39 17. Mar.19fi9 - -J?? ?. i-i?' 1,_ , 4• 6 CUMBERLAND LAW JOURNAL Writ No. 2008-7149 Civil Term Nationwide Advantage Mortgage Company VS. Richard L. Erickson and Christine M. Erickson Atty.: Martha E. Von Rosenstiel ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs, Cumberland County, Penn- sylvania, bounded and described as follows: BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue; thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and three-fourths (89- 3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore Trine; thence along other lands now or formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one hundred forty-one (141) feet, more or less, to a point (iron pin), in the Northern line of West Pine Street; thence along the Northern line of the said West Pine Street, North eight-four and one- fourth (84 1/4) degrees West, a dis- tance of one hundred fifty-one (151) feet to a point, the place of beginning. BEING known and numbered as 2 Mooreland Avenue. IMPROVEMENTS: Residential dwelling. Tax Parcel # 23-32-2336-187. TITLE TO SAID PREMISES IS VESTED IN Richard L. Erickson and Christine M. Erickson, husband and wife, by Deed from Thomas E. Clement and Yvonne D. Clement, husband and wife, dated 7/5/2002 and recorded 7/16/2002 in Deed Book 252, Page 3531. 36 '. 6 % 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: January 27, February 3, and February 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. I" -- Lv?' - Li Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 10 da of Februai 2012 Notary WTARiAL SEAL DEBORAH A COLLINS Notary Public [CA RLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. .2020 jechnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 14t Patti* ot News Now you k11ow 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 Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted-severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 7149 Chr11 Term 01/27/12 N Advw t " Mortg"e Comtny 02103/12 L-Er+elcson and ( ( 02!10/12 Chrlsd w K.Erlckson Atty. Mutt E Yon Rosonstlel ALL CERTAIN lot of ground ? ... .. . Kr - situate the Borough of Mount Holy - iv Spring Cumberland Connty,'Pcnarytvan Y ' K bounded anddarnbedasfollows Sworn to an' subscribed b f m his dar of February, 2012 A.D. ?m BEG44NING st a point at the intersection ? Of West Pine Street and Mooreland d, A-;' thence along Mooreland Avenue, w, North One-fourth (1/4) degree,East, a distance of one hundred t%e=ty-five(lu) Notary Public I s _ feet, more or less,-W' a point (iron pm), in ,ur line of now or formerly of Christian lands! (htqrcd by land now or fomerly of 3u the n Otto South eighty-pine COMMONWEALTH OF PENNSYLVANIA p and urths (8963/4) degrees East, Notarial Seal o a one hundred frhy (150) feet Sherrie L. Owens, Notary Pubk to a potnt (iron pin) in hne'of othir lands Lower Paxton /Yap., Dauphin County now or formerly of Emelyn Moore Ifine; My Commission Ex #m Nov. 26, 2015 thence along other lands now or formerly MEMBER, PENNSYLVANIA ASSOMTION OF NOTARIES of the said Emelyn Moore Mine, South one-fourth (1/4) degree Rest, a distance of ! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Members 1 st Federal Credit Union is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 9 day of September, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 7149, at the suit of Nationwide Advantage Mortgagee Co against Richard L. Erickson and Christine M. Erickson is duly recorded as Instrument Number 201212110. IN TESTIMONY WHEREOF, I have here}?nto set my hand and seal of said office this '73 ° -? day of A.D. Ilk of Deeds Recorder of Deeds, dnbatnd 0r, Cwft, PA DIY Wwdssbl DOW the Fret IJoedaY of Jan. 2014