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Home My WebLink About09-0200Syr Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 192730 PHH MORTGAGE CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM (~ ~ U ~ ~ v. NO. ~~' SOD KORY J. JONES MARJORIE E. JONES 18 PATTON ROAD MECHANICSBURG, PA 17055-2733 CUMBERLAND COUNTY Defendants CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 192730 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment maybe entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 192730 Plaintiff is PHH MORTGAGE CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) aze: KORY J. JONES MARJORIE E. JONES 18 PATTON ROAD MECHANICSBURG, PA 17055-2733 who is/are the mortgagor(s) andlor real owner(s) of the property hereinafter described. 3. On 03/14/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR WAYPOINT BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1900, Page 1002. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 192730 6. The following amounts are due on the mortgage: Principal Balance - -- - - - - - $161,564.38 Interest $7,175.50 06/01/2008 through 01/12/2009 (Per Diem $31.75) Attorney's Fees $1,250.00 Cumulative Late Charges $227.40 03/14/2005 to 01/12/2009 Cost of Suit and Title Search 750.00 Subtotal $170,967.28 Escrow Credit $0.00 Deficit $153 41 Subtotal . 153.41 TOTAL $171,120.69 7 8. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above maybe less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam ud j gment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 192730 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $171,120.69, together with interest from 01/12/2009 at the rate of $31.75 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP ~~~9~~ By: ~ ~ ~L.~--~ L~ ence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Attorneys for Plaintiff File #: 192730 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows to wit:- BEGINNING at the point of intersection of the western line of Patton Road and the line of adjoiner between Lots Nos. 10 and 11 on the hereinafter mentioned plan of lots; thence by said line of adjoiner South 79 degrees 48 minutes West a distance of 129.40 feet to a point; thence North 03 degrees 25 minutes East a distance of 77.17 feet to a point; thence North 79 degrees 48 minutes East along the line of adjoiner between Lots Nos. 9 and 10 on said plan a distance of 111.24 feet to a point on the western line of Patton Road; thence along said western line South 10 degrees 12 minutes East a distance of 75.0 feet to a point, the place of BEGINNING. BEING Lot No. 10, Block F, on Final Subdivision Plan for Wynnewood Park, Parts of Blocks E and F, as recorded in the Cumberland County Recorder of Deeds Office in Plan Book 45, Page 24. HAVING THEREON ERECTED atwo-story brick and aluminum home known and numbered as 18 Patton Road. PARCEL#: 18-22-0519-329 File #: 192730 VERIFICATION I hereby state that I am the attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.RC.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsifications to authorities. Attorney for Plaintiff DATE: ~ ~ L C N . 7 ~, w `r7 ~ ~; .~ ~ _ - ~ ~ ~~~ :~c : ~ o cz~ °~ 1~U ~1~~' } _. _. ~~=_ ~ J „f,,. 2010 J~~t~r ~$ ~,~ ~ S~ C `~ C ~,~t ,- SAN z 7 zo~oPs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PHH MORTGAGE CORPORATION Plaintiff v. KORY J. JONES MARJORIE E. JONES Defendants RULE Court of Common Pleas Civil Division CUMBERLAND County No. CIVIL 09-200 AND NOW, this 2 ~` ' day of 2010, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiffls Motion to Reassess Damages. Zo alar- 'e, ~. re,e-~sik Rule Returnable o e um er an oun y o ania. A~ ~ 151 CCU ~~ ~~~~~o BY THE COURT ~i P. J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PITH MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLE ~,a v. ° CIVIL DIVISION ~ KORY J. JONES MARJORIE E. JONES No. CIVIL 09-200 ;~ ~ Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 1 ~ - . COMMONWEALTH OF PENNSYLVANIA ) o CUMBERLAND COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attache d heret o Exhibit "A". ~ ~ n JET ltX ^ La nce T. Phelan, Esq., Id. No. 32227 rands S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ~~~ ~ !D Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 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N x ~ Q ~ ~ O - a rnC ~~'~ 0 O ~~~ c N ~~. ~ 3 A c0 fD ~ j N 7 `~ ~ ~ ~ ~.~< 7 ~ 7 ~ pl ~ m CI N+ X fD ~U j 4 y N N d _ 3 N 3 y m '' _' . °~ ° 3 °_' m o'oc _m ~~~ ~ '~, mm~d ti 9~ `1~` 8 y, ~ , i o ` ~-.~, ~B.d,a ~ d.Q2 ~ 02 1M ~ ~~ m o 0 3 { ~ 0004218010 SEP 24 2009 ~,>>' t9103_h MAILED FROM ZIF~COtpE`~~1 + ~ ~ c ~ y ~'~ I I I I I I ~ F!l E1-rICE '~F Tz'~ ~r~al~!-'~?fdOTARY 1010 FE8 -5 PPS 2~ fl4 CU1~~u L~::~ ti ~~~U~yITY t~c~ ~I~YLV~~+!'A Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 ~~Iichele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHH MORTGAGE CORPORATION Plaintiff v. KORY J. JONES MARJORIE E. JONES Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No. CIVIL 09-200 CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the January 27, 2010 Rule was sent to the following individual on the date indicated below. RICHARD C. SENECA SOUTHGATE BUILDING 409 SOUTH SECOND STREET HARRISBURG, PA 17104 DATE: C By: Phelan Hallinan & Schmieg, LLP ~~~. ~ U L' awrence"T. Phelan, Esq., Id. No. 32227 ^ F ancis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ATTORNEY FOR PLAINTIFF MAY 0320100 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PHH MORTGAGE CORPORATION Court of Common Pleas Plaintiff Civil Division v. KORY J. JONES MARJORIE E. JONES Defendants CUMBERLAND County No. CIVIL 09-200 ORDER AND NOW, this =~ day of r+ti/~ , 2010, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute; and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ordered to amend the judgment and the Sheriff is ordered to amend the writ nunc pro tunc as follows: Principal Balance Interest Through March 3, 2010 Per Diem $31.75 Late Charges Legal fees Cost of Suit and Title Sheriffs Sale Costs Property Inspections/ Property Preservation Appraisal/Brokers Price Opinion Mortgage Insurance Premium / Private Mortgage Insurance Non Sufficient Funds Charge Suspense/Misc. Credits Escrow Deficit TOTAL $161,564.38 $20,320.51 $227.40 $1,500.00 $1,377.00 $0.00 $2,045.25 $100.00 $0.00 $0.00 ($0.00) $5,058.32 $192,192.86 Plus interest from March 3, 2010 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. .off ~ ,~?j~."_ _, . __ - `.i^~~ +v ,.._ ~ m~~n ~....~. .~ '!'' - '7V ?~'`~ r J ij ~ ::j V.~~ r ~: , ~. ..., ,~.` ` W~~' Phelan Hallinan &Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHH MORTGAGE CORPORATION Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division v. KORY J. JONES MARJORIE E. JONES Defendants CUMBERLAND County No. CIVIL 09-200 MOTION TO MAKE RULE ABSOLUTE PHH MORTGAGE CORPORATION, by and through its attorneys, Phelan Hallinan &Schmieg, LLP, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. That it is the Plaintiff in this action. 2. A Motion to Reassess Damages was filed with the Court on January 26, 2010. 3. A Rule was entered by the Court on or about January 27, 2010 directing the Defendants to show cause why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit "A". 4. The Rule to Show Cause was timely served upon all parties on February 4, 2010, in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit "B". 5. Defendants failed to respond or otherwise plead by the Rule Returnable date of February 24, 2010. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. & Schmieg, LLP DATE: ,~ By: 1~J"L'a`wrence T. Phelan, Esq., Id. No. 32227 ^ rancis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ATTORNEY FOR PLAINTIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~atitnjr ~f ~rr~nt~r,/r~~ 2Q~0 ~Fw f L~ il~~ ~ ~ ~ v ~> ; . ~1 ~ i .r,._ c~ ,,; r-. ~)i~. PHH Mortgage Corporation Case Number vs. Kory J Jones (et al.) 2009-200 SHERIFF'S RETURN OF SERVICE 01/21/2010 10:12 AM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Marjorie E. Jones, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Marjorie E. Jones, defendant does not reside at 822 Highland Court, Mechanicsburg, PA, current resident has been there since September 10, 2009, no forwarding at post office. 01/21/2010 10:30 AM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 1/21110 at 1029 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 Kory J. Jones, located at, 18 Patton Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. 01!29!2010 Ronny R. Anderson ,Sheriff who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kory J. Jones, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. Dauphin County Return and now the, 21st day of January 2010, served the within Real Estate Writ, Notice of Sale and Description upon Kory J. Jones, the defendant, by making known unto Kory J. Jones ai 6692 Terrace Way, Harrisburg, Pennsylvania its contents and at the same time handing to him a true and correct copy of the same. So Answers: W. Conway, Deputy Sheriff of Dauphin County, Pennsylvania. 02/02/2010 07:15 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 2/2/10 at 1915 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Marjorie E. Jones, by making known unto, Marjorie E. Jones, personally, at, 23 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/01/2010 Property sale postponed to 5/5/2010. 05/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on May 5, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel G. Schmieg, on behalf of Fannie Mae, P.O. Box 650043, Dallas, TX, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 888.11 SHERIFF COST: $878.11 May 21, 2010 SHERIFF'S OFFICE OF CUMBERLAND Cn ~~'X ,~. ~i~~r v~ rlC,,~. ±ci Count, Suite Sheriff, telexsoft. arc. SO ANSWERS, '"~/~ RON R ANDERSON, SHERIFF ~oa ,,~~ ~ .~~ L~ ~~ ° ~~~~~o~` '~.~~~9~ On October 1, 2009 the Sheriff levied upon the `defendant's interest in the real property situated in ~:- `-' Borough of Mechanicsburg, Cumberland County, PA, Known and numbered as 18 Patton Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 1, 2009 By: Real Estate Coordina or - ~"'~' a ~~°~~ ~"~~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION PHH MORTGAGE CORPORATION -vs- Kory J. Jones & Marjorie E. Jones No. 2009 -200 ASSIGNMENT OF BID RIGHTS UNDER SHERIFF'S EXECUTION PHH MORTGAGE CORPORATION, hereinafter called Assignor, for and in consideration of the sum of $1,219.28 receipt of which is hereby acknowledged, do(es) hereby sell, assign, transfer and set over unto FANNIE MAE title and interest in and to the property more fully described in the list attached hereto, made a part hereof and marked Exhibit "A" under the bid knocked down to Assignor at the execution sale in the Court of Common Pleas of Cumberland County, Pennsylvania, on May 5, 2010, in the above captioned proceedings. IN WITNESS WHEREOF, the Assignor has hereunto set his hand and seal, this 6"' day of May 2010, intending thereby to be legally bound. ~~ ~1~1 (SEAL) Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL NORA M. FERRER, Not~y Pubac C~yy of Ph~adelphia, Phila. County Common Expires November 22, 2013 , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 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 February 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. .. wnt ipo. X009-~0o c;<~ isa Marie Coyne Editor PHH Mortgage Corporation vg. SWORN TO AND SUBSCRIBED before me this Kory J. Jones 5 day of February, 2010 Marjorie E. Jones Atty: Daniel Schmieg By virtue of a Writ of Execution No. CIVIL 09-200, PHH MORTGAGE CORPORATION vs. KORY J. JONES, MARJORIE E. JONES, owner(s) of NOtary /;" property situate in the BOROUGH ~ OF MECHANICSBURG, Cumberland County, (Municipality) Pennsylvania, being 18 PATTON ROAD, MECHAN- ICSBURG, PA 17055-2733. .~,. - --- (Acreage or street address) NOTARIAL SEAL Parcel No. 18-22-0519-329. DEBORAH A COLLINS Improvements thereon:RESIDEN- Notary Public TIAL DWELLING. CARLISLE BORO, CUMBERLAND COUNTY JUDGMENT AMOUNT: $178,169- My Commission Expires Apr 28, 2010 .19. PROPERTY ADDRESS: 18 Patton Road, Mechanicsburg, PA 17055. The Patriot-News Co. .8a2 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ~he~latriot News NOw you know CARLISLE PA 17013 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: Docket Number: 2009-200 Ctvtl ran, PHH Mortga~ C4rPpratlon v~. . ~y J Jonas Marjorla ~ Jones A1tJr: Daniel Schmleg By virtue of a Writ of Execution No. CIVII; 09- 200 PHH MGRTGAG~ CORPORATJON vs. KORYJ.JONES MARJORB? E, JONES... owner(s) of ~erty situate io the $ORO[7GJ1 OP MECHANIESBURG, Cumberland County, (Muuuiicipality) &~~ ROAD>.ME~HAIVICSBURG PA 17055-2733. , , (Aixeage of street address). Parcel No. )8-22-0519-.324 . DI.i.II G~ thereon: RESIDENTIAL; NDGMENf AMG[JNT: $178.169:19 PROPERTY ;ADDRESS: 1~8 Patton Road, MechanicsbNrg, PA 17055. 01 /22/10 01 /29/10 ~ ~-- -~ 02/05/10 Sworn to subscribed before me,this ay of February, 2010 A.D. Notary Public COMMONWF.ALT_H pF PENNSYLVANIA Notar~tl Sesl Sherrie L.1Gsner, Notary Public City Of Harrisburg; Dauphin County My Comrrrission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which FANNIE MAE is the grantee the same having been sold to said grantee on the 5TH day of MAY A.D., 2010, under and by virtue of a writ Execution issued on the 23RD day of SEPT, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 200, at the suit of PHH MTG CORP against KORY J JONES & MARJORIE E is duly recorded as Instrument Number 201013337. IN TESTIMONY WHEREOF, I have herej}nto set my hand and seal of said office this ~ / day of A.D. ~~~ Reco~r of Deeds Reoaderd Ciomly, tleiMe~ I'll NIyCAmn~bn II»FlrMMoi~din.~I4