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HomeMy WebLinkAbout09-183511b 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 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 191940 CITIFINANCIAL SERVICES, INC. COURT OF COMMON PLEAS 1111 NORTHPOINT DRIVE BUILDING 4, SUITE 100 CIVIL DIVISION COPPELL, TX 75019 TERM Plaintiff V NO. o I- 19`3 S . CUMBERLAND COUNTY SCOTT J. ROBINSON SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 191940 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE 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 #: 191940 1. Plaintiff is CITIFINANCIAL SERVICES, INC. 1111 NORTHPOINT DRIVE BUILDING 4, SUITE 100 COPPELL, TX 75019 2. The name(s) and last known address(es) of the Defendant(s) are: SCOTT J. ROBINSON SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11/14/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Instrument No. 200743252. 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 #: 191940 6. The following amounts are due on the mortgage: Principal Balance $151,299.80 Interest $12,814.29 06/01/2008 to 03/20/2009 Attorney's Fees $1,300.00 Cumulative Late Charges $0.00 11/14/2007 to 03/20/2009 Cost of Suit and Title Search 750.00 Subtotal $166,164.09 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $166,164.09 7 8 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be 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 judgment) 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 #: 191940 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 $166,164.09, together with interest from 03/20/2009 at the rate of $28.40 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 HALLIN & SCHMIEG, LLP By: awrence T. Phelan, Esquire /Francis S. Hallinan, Esquire 6?-QDaniel 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 #: 191940 LEGAL DESCRIPTION ALL that certain tract of land situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at comer of Lot No. 7 (to be conveyed to Ronald G. Plasterer, et ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at corner of Lot No. 5 now or formerly of William Parr, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an existing railroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & McCans, Inc., R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Commission and the Board of Supervisors of Southampton Township, Cumberland County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. BEING that same real estate that Glenn P. Asper and Doris K. Asper, husband and wife, by their deed dated May 3, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book'Y', Volume 33 at Page 97, conveyed to Randy L. Bell and Robin M. Bell, husband and wife, Grantors herein. PREMISES: 949 BALTIMORE ROAD PARCEL#: 39-36-2428-023 File #: 191940 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.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are. basod 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 unworn falsifications to authorities. Attorney for lain tiff ??PS DATE: N :3c ` n r r j i°Il ? I-Tl A \. t?) Sheriffs Office of Cumberland County R Thomas Kline 'QoV of cltmbrrtI R Edward L Schorpp Sheriff, Solicitor Ronny R Anderson r Jody S Smith Chief Deputy cjfFi'-'E F T "E `KERIF-F Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 07:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1900 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the with named defendant, to wit: Scott Robinson, by making known unto himself personally, defendant at 949 Baltimore Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same tim, handing to him personally the said true and correct copy of the same. 03/30/2009 07:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1900 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the with named defendant, to wit: Sondra L. Robinson, by making known unto Scott Robinson, husband of defendz at 949 Baltimore Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $62.00 March 31, 2009 2009-1835 CITIFINANCIAL SERVICES, INC. VS SCOTT J. ROBINSON SO ANSWERS, R THOMAS KLINE, SHERIFF By Deputy Sheriff HLED- ?OFF?? ?ry OF THE PIlq T'ARY 1M9 APR -2 FM 3: 3Q CUM13z.r 4,." 1;?; t.' J: NIY PEASYNAN 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 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 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIFINANCIAL SERVICES, INC. VS. SCOTT J. ROBINSON SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against SCOTT J. ROBINSON and SONDRA L. ROBINSON, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $166,164.09 Interest - 03/21/2009 to 05/112009 1$ ,476.80 TOTAL $167,640.89 I hereby certify that (1) the addresses of the Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, opy a 7T. Lawrence T. Phelan, Esquire ?F`rancis 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 Joshua I. Goldman, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: S 13 (? PHS # 191940 PROTHONOTARY 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 CITIFINANCIAL SERVICES, INC. VS. SCOTT J. ROBINSON SONDRA L. ROBINSON : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. 0?- /?3S VERIFICATION OF NON-MILITARY SERVICE ` ?L1n?J ,hereby verifies that she/he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, she/he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant SCOTT J. ROBINSON is over 18 years of age and resides at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428. (c) that defendant SONDRA L. ROBINSON is over 18 years of age and resides at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. "? z I ?? ?11_? Lawrence T. Phelan, Esquire ancis 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 Joshua I. Goldman, Esquire Attorney for Plaintiff 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 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CITIFINANCIAL SERVICES, INC. Plaintiff V. SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s) TO: SCOTT J. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 DATE OF NOTICE: April 21, 2009 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DI/V?ISON' a NO. CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Q22LQ2tL:0a nnifer L. McAnney Legal Assistant PHS # 191940 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 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CITIFINANCIAL SERVICES, INC. v Plaintiff SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s) TO: SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 DATE OF NOTICE: April 21, 2009 ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISON NO. CUMBERLAND COUNTY 4 . THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 ?4 Y t J fifer L. McAnney Legal Assistant PHS # 191940 R ED-+ji=r CI: OF THE 2009 MAY 13 AM 10: 4 2 CP?? "ply 10, ?'L% as ?l olo (Rule of Civil Procedure No. 236) - Revised CITIFINANCIAL SERVICES, INC. VS. SCOTT J. ROBINSON SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. Notice is given that a Judgment in the above captioned matter has been entered against you on 13'/? y By: If you have any questions concerning this after ple a contact: F ? ?k?w_ ? Lawrence 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 Joshua I. Goldman, Esquire Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY." i CITIFINANCIAL SERVICES, INC. vs. SCOTT J. ROBINSON SONDRA L. ROBINSON CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.2009-01835 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE The undersigned attorney hereby verify as follows: 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 attached hereto Exhibit "A". DATE: R By: (/ ~-- Lawr a .Phelan, q., Id. No. 32227 Fran is S. allinan, sq., Id. No. 62695 Da iel G. S m' ,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 Attorneys for Plaintiff 2 ~ ~ .~`W Z ~ ~ (lt~.-'~ ' 02f~ 03lIbW , .~~~~~ .. 0 l08 LZb000 ~ aZC1'ZQ%$! wt zo \S~M1OH A3Nlld` ! _ ~ % 0 ,,~ ~b~SOd S31dy5 m 0. _~ a 'a H~" u W ~o ~ W o ~'~~ as ti p~c+: 03W a ~o~~ x ~ QUp° ~"o d U UAa., d ..._ , 0 Z ~i N ~ O fl ~ ~ am Q C /] Q4 ~ a I .-. I N ,~~...11 ~1 N ..O O a_ O •' A c O M •~ ~w N H -d a 3 b ~H ~~ o •~ o ~x> ~ ~ ~ W o A O N 0 O ~~ `~ .-~ wa ~~ ~~ ~x U an Gz, w „~'~ o 30 3 U O N ~'~ a ~~c7 r ~ 3 oa~H~' 3~' °' ~ ~W o o ~ ~ ~'~ a~i°O o M W ~ ~ O z °` o w °y' ~ a~i O ~~v~U~caca. Aa M F A as 0 a~ W _~ w u 6.. ~ry ~~~444 ~ U U a~~ ao ~ 0 ~° ~ h o •v ~ ~o 5w~ o =,~~Ll ~E( ~y ~, ~' fd J ~ U ~ ~ [-+ O H C V N ~ ~j k G ~.~ .O C 6 ~ U O O ~ ~ T a~ ~ U D ~_ G A E] ~t}~'~ ~ ~. ~ ^ ^ d .5 h „ ~ ~ 8 cu''6o x E v u W .~ .. u ~ ~ w -o° ~ ~ o _ y ~ m ~ :" ~ ~ N w 'O UUO L O Q~ O ~ G ~ A N 4'~ C o ~ ~~ 0 0° 'e o w d ~ ,~ w o ,,, cs o ° o ~rn .~ iy .. 'O 'r0 _° ~~~ ~~~oo 0 F~~7~a .~ .~ x a 0 ~ v ~ ~ a o~ ~ z~ U ~~ ~ F tL' v h ~ T v ~ a u M ~ h ~p l~ 00 01 ~ ."". ~ M t7 h ~• .-7 ~" I ,I 2~~i:1 i:~.. ~ t ~ 1~~ E i(~' .. 1 ..V; ~ C'~'- ._ _._. ~ . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Citifinancial Services Inc. vs. Scott J. Robinson (et al.) ~~,~.~ti~, ~{ 4urnt~~~~r„4 ~F: F - ~ -,EG ,..~~r~~ ~~, ~ _ ,~ T r~~ .r 11 h (: r~} Ct~~v Case Number 2009-1835 SHERIFF'S RETURN OF SERVICE 09/25/2009 04:19 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at 1617 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 Scott J. Robinson & Sondra L. Robinson, located at 949 Baltimore Shippensburg, Cumberland County, Pennsylvania according to law. 09/25/2009 04:19 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at 1617 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: Scott J. Robinson, by making known unto, Sondr L. Robinson, adult in charge, at 949 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 09/25/2009 04:19 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at 1617 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: Sondra L. Robinson, by making known unto, Sondra L. Robinson, personally, at 949 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/08/2009 Property sale postponed to 3/3/2010. 03/01/2010 Property sale postponed to 4/7/2010. 04/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Schmieg on 4/6/10 SHERIFF COST: $807.44 SO ANSWERS, April 07, 2010 RON R ANDERSON, SHERIFF CK~" 7S~' ~ ,c; Cow,~yguitrn She;r,fi, Te,eooft. li~c. ~~ CITIFINANCIAL SERVICES, INC. - CUMBERLAND COUNTY .. Plaintiff, v, COURT OF COMMON PLEAS SCOTT J. ROBINSON CIVIL DIVISION SONDRA L. ROBINSON N0.09-1835 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129..1 CITIFINANCIAL SERVICES, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution. was filed the following information concerning the real property located at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257- 9428 . 1. Name and address of Owner(s) or reputed Owner(s): Name SCOTT J. ROBINSON SONDRA L. ROBINSON Address (if address cannot be reasonably ascertained, please indicate) 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) .~ None ~. Name and address o~ every other person who has any record interest in the property and whose interest may be affected by the sale. Name None Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program ascertained, please indicate) 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13`h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsificatio uthorities. August 4, 2009 DATE ^ awrence 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 E1~Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 CITIFINANCIAL SERVICES, INC. Plaintiff, v. SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s). CUMBERLAND COUNTY No. 09-1835 August 4, 2009 TO: SCOTT J. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN BANKR UPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428, is scheduled to be sold at the Sheriff s Sale on DECEMBER 9, 2009 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $167,640.89 obtained by CITIFINANCIAL SERVICES, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) Y TO SAVE YOUR PROPERTY AND YOU HTS EVEN IF THE SHERIFF'S SALE DOES 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be .paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale.. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain tract of land situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, et ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at corner of Lot No. 5 now or formerly of William Parr, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an existing railroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & McCans, Inc., R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Commission and the Board of Supervisors of Southampton Township, Cumberland County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. TITLE TO SAID PREMISES IS VESTED IN Scott J. Robinson and Sondra L. Robinson, h/w, by Deed from Randy L. Bell and Robin M. Bell, h/w, dated 11/12/1998, recorded 11/24/1998 in Book 189, Page 903. PREMISES BEING: 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 PARCEL NO. 39-36-2428-023 SHORT DESCRIPTION By virtue of a Writ of Execution No. 09-1835 CITIFINANCIAL SERVICES, INC. vs. SCOTT J. ROBINSON and SONDRA L. ROBINSON owner(s) of property situate in the TOWNSHIP OF SOUTHAMPTON, Cumberland County, Pennsylvania, being (Municipality) 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 Parcel No. 39-36-2428-023 (Acreage or street address) Impro e thereon: RESIDENTIAL DWELLING PHE AN HALLINAN & SCHMIEG, L.L.P. ^ Lawrence T. Phelan, Esq., Id. No. 32227 D Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 D Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 D 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 ^ Chrisovaiante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ ourtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215)563-7000 LEGAL DESCRIPTION ALL that certain tract of land situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, et ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at corner of Lot No. 5 now or formerly of William Parr, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an existing railroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & McCans, Inc., R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Commission and the Board of Supervisors of Southampton Township, Cumberland County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. TITLE TO SAID PREMISES IS VESTED IN Scott J. Robinson and Sondra L. Robinson, h/w, by Deed from Randy L. Bell and Robin M. Bell, h/w, dated 11/12/1998, recorded 11/24/1998 in Book 189, Page 903. PREMISES BEING: 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 PARCEL NO. 39-36-2428-023 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N009-1835 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC. Plaintiff (s) From SCOTT J. ROBINSON SONDRA L. ROBINSON (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 $167,640.89 L.L. $.50 Interest FROM 5/12/2009-12/9/2009 -PER DIEM -$27.56 -- $5,842.72 Atty's Comm % Due Prothy $2.00 Atty Paid $181.00 Other Costs Plaintiff Paid Date: 8/6/09 (Seal) Curtis R. Lon on tar By: Deputy REQUESTING PARTY: Name: ANREW C. BRAMBLETT, ESQ. Address: PHELAN HALLINAN AND SCHMIEG ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 208375 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA Known and numbered as, 949 Baltimore Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: ~/r Real Estate Coordinator ,~, J r ~~~ ~ ,:,. ~~^ t.`. q,~.. ~~~ . ,~ ~? i rn -, 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: October 23, October 30 and November 6, 2009 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 6 day of November, 2009 ~. Notary NOTAR EAL DEBORAH A COLI.INS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 wit xo. Zoo9-is3a civil Citifinancial Services, Inc. vs. Scott J. Robinson Sondra L. Robinson Atty: Daniel Schmieg LEGAL DESCRIPTION ALL that certain tract of land situ- ate in the Township of Southampton, County of Cumberland and Common- wealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, Ct ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at corner of Lot No. 5 now or formerly of William Pan, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an exist- ingrailroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & Mc- Cans, Inc R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Com- mission and the Board of Supervisors of Southampton Township, Cumber- land County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. TITLE TO SAID PREMISES IS VESTED IN Scott J. Robinson and Sondra L. Robinson, h/w, by Deed from Randy L. Bell and Robin M. Bell, h/w, dated 11/ 12/ 1998, re- corded 11/24/1998 in Book 189, Page 903. PREMISES BEING: 949 BALTI- MORE ROAD, SHIPPENSBURG, PA 17257-9428. PARCEL NO. 39-36-2428-023. The Patriot-News Co. 812 Marl~et St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e~latriot 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 Leslie Kramer, 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: 10/23/09 10/30/09 Sworn to pfd subscribed before rye thi~'16 dy~y o~Npvember, 2009 A. D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisser, Notary Public City OF Harrisburg; Dauphin County My Commi3sion Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 11/06/09 Writ No. Z00l~t i3~ CIvN Tirtn G11`IFINAM~.tAL 8arvtcas, Inc. Vs Scott J. Robinson. Sondra L. Robinson Atty6 Denial $chmfeg LEGAI~DESCRIPI40N ALLthat certain tract of land situate in the Townahig of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and. described as follows: BEGINNING at a parker-1'aloa nail and washer in .the cemerline .of Legislative Route 21048 (Baltimore Ro~j az corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, Crux); thence by Lot No. 7, Nottti 17 deg~es 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper,. husband and wife; thence by Asper lead, South 72 dcgrces 7 minutes 0 seconds East,144 feet to an existing iron (fiuu at comer of Loi No, 5 now pr formerly of William Parr, et ux; thence. by Lot No. 5, South f7 degrees 53 minutes 0 second¢ West, 150 feet to an existing railroad spike in the' centerline of Legislative Route' 2]048; thence by the centerline of said mad, South 72 degrees 7 minutes 0 saxinds Went, 144 f~ to the point .and place of BEGINNING." CONTAIlYMG a total area of 21,600 square feet eta being Lot Na. 6 on the draft of Dougal. & McCans, Inc R.S., for Glenn $. Asper, :which ;itlan has been approved by the Cumberland County. Planaiag Commission and the Board of Supervisors of Southampton Towirship, Cumberland County, Pennsylvania:, Said; plea is "recorded in Cumberland Cdupry,Plaa Book 36 az page 96. T1TL,2;' TO SAID ~BMISES IS VESTED 1N Scott J. ltohias<m and Sondra L, Robinson, blw, by Deed frorir Randy L. Berland Robin M, $ell, h/w, dated 11111!1998, recorded i 1124!1998 in Bank ] 89; Page 903. PREMLSES BEING: 949 BALTIMORE ROAM, SHIl'PENSBURG. PA 17257.9428 PARCEL N0.39-36.2428-023 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CITIFINANCIAL SERVICES, INC. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v SCOTT J. ROBINSON SONDRA L. ROBIN50N Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 05/12/2009 to Date of Sale ($27.56 per diem) TOTAL ~d~f.oo Pp Prr~ loa.o0 C,BF' 807.44 u '18•Sb ~~ I'~ . oo d~ • oo N '~ 1ooQ.Q~ - PA A-ny Note: Please attach description of property. PHS # 191940 ~a.oo ~ueCo ~ ~ 4ss3a.l ~~ acl a'I8.3 2c u~~~ N0.2009-01835 CUMBERLAND COUNTY C Q --i ~ ~„ _ _~ _ =c --~ ~; $167,640.89 / ~~ -~s. - :' -- $13,366.60 4 -o ~ .. _ `', -~ ~ $181,007.49 yt,Q, U ~ Attorney for Plaintiff 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 ^ eter 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 b a~ ~ ~ ~ ° y ~ O~ v O~ ~ ~ ~ Vl A~ ~ Vl zA~ ~ zo¢ °o¢ ~a:a Ewa °" ~O~ ~O~ .~ ~~~ a~~ 3 N tiaz H¢w r ~aZ ¢w ~ ~ ¢ O a, o~ ~ U ~ z a rn ~ ~ x ,v~ v io .r o n w~ z O ~ O N v'~ ~~11 HI ~ ~ ~ ~l ~ ~ U N~N~~'~c~~M o~vo °'r'oN IiryJ _ ~ ~ G ~ O M _ O~ N O O QI ~ W ~ Qwz O Oz ~ZO~O~N h~ O pb ~ GZ. W Gtr O "1 Zzbzb o o °~ ozZ ~zz'.° W ~.. ~ U O~ fri p ~' ~W W W.tiW,N'N'm°"^,~o ~"W W~W W a~i QU a ~p~q~ 3 y '~~~~~a~i,~+-p°o~WW~rrW;~~k"~ ~ ~ on ~, o~ ,~ .5 ' ~ ~ ~ ~ > ~ > as a ~ F-H x ~ H ~ ° ~ OUP ~a aaA ~~" w, ca a ~~~H~~~~ °~ 3~ ~~ ~ 3 Fri ~ ~ ~ ° [ ~ ~ ~ .~ '~ ~ .~ ~ .' A i ~ ~ ti O ~ U U > v~ v~ a w ¢ a ^^^^^^^^^^ ~ ^^^^ IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: SCOTT J ROBINSON SONDRA L ROBINSON Chapter: 13 Debtor(s) CHARLES DEHART TRUSTEE Movant(s) vs. SCOTT J ROBINSON SONDRA L ROBINSON Respondent(s) Case Number: 1-0909422 ORDER DISMISSING CASE Upon consideration of the Trustee's Motion to dismiss case and it having been determined after notice and no response that the case should be dismissed, it is ORDERED that the above-named case of the debtor(s) be and it hereby is dismissed. By the t;ouri, Date: A ril 16, 2010 p cn~ ~ ~~ This document is electronically signed and filed on the same date. MDPA-Dismiss Casa.WPT-REV 03109 Case 1:09-bk-09422-MDF Doc 24 Filed 04/16/10 Entered 04/16/10 09:44:34 Desc Main Document Page 1 of 1 Notice Recipients District/Off: 0314-1 User: EFeder Date Created: 4/16/2010 Case: 1:09-bk-09422-MDF Fonn ID: pdtU01 Total: 24 Recipients of Notice of Electronic Flling: ust United States Trustee ustpregian03.ha.ecftt,t>sdoj.gov h' Charles J. DeHart, III (Trustee) dehartstaf ~pamdl3trustee.eorn cr Recovery Management Systems Corporation claims cr recoverycorp.com aty Shawn B. Cohen spawn@,attyshawncoheu.com TOTAL:4 Recipients submitted to the BNC (Bankruptcy Noticing Center): db Scott J Robinson 949 Baltimore Road Shippensburg, PA 17257 jdb Sondra L Robinson 949 Baltimore Road Shippensbrug, PA 17257 3437924 Amca 2269 S Saw Mill Elmsford, NY 10523 3540708 American General Financial Services 801 Wayne Avenue Charnbersburg, PA 17201 3528738 CitiFinancial Services, Inc. P.O. Box 70919 Charlotte, NC 28272-0919 3437927 Collection PO Box 9134 Needlraur, MA 02494 3437928 Credit Management Co 2121 Noblestown Rd Pittsburgh, PA 15205 3437929 Credit One Bank PO Box 98875 Las Vegas, NV 89193 3499544 LVNV Funding LLC Resurgent Capital Services PO Box 10587 Greenville, SC 29603-0587 3437931 Lvov Funduig LLC PO Box 740281 Houston, TX 77274 3437932 Metablaze 500E 60th St N Sioux Falls, SD 57104 3472681 Midland Credit Management, Inc. 8875 Aero Drive, Suite 200 San Diego, CA 92123 3437933 Midland Credit Mgmt 8875 Aero Dr San Diego, CA 92123 3437935 NCO - Medclr 507 Prudential Rd Horsham, PA 19044 3437934 Nco PO Box 15087 Wihuington, DE 19850 3444618 PRA Receivables Management, LLC As Agent Of Portfolio Recovery Assocs. PO Box 12914 NORFOLK VA 23541 3437936 Portfolio Recovery Attn: Bankruptcy 120 Corporate Blvd Saute 100 Norfolk, VA 23502 3463569 Recovery Management Systems Corporation 25 S.E. 2nd Avenue, Suite 1120 Mianri, FL 33131-1605 3437937 Seventh Ave 1112 7th Ave Monroe, WI 53566 3471367 Seventh Avenue C/O Creditors Bankrprptcy Service P.O. Box 740933 Dallas, TX 75374 TOTAL: 20 Case 1:09-bk-09422-MDF Doc 24-1 Filed 04/16/10 Entered 04/16/10 09:44:34 Desc PDF all creds ptys UST IRS: Notice Recipients Page 1 of 1 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIFINANCIAL SERVICES, INC. Plaintiff v. SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s) 'V Attorneys for Plaintiff 2~{0flr~'t'2i ~=` I~ ~; COURT OF COMMON PLEAS r~~~~w ' ' ~'~`+ ~'`" CIVIL DIVISION CERTIFICATION N0.2009-01835 CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: °~ c ~,~p~ Attorney for Plaintiff 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 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 CITIFINANCIAL SERVICES, INC. Plaintiff FILF~` ~ ~'~ ='~~' SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s) Z~Ea ~','j ~~ c t: 33 Cut, _ - ',ti~,~; COURT OF COMMON PLEAS CIVIL DIVISION N0.2009-01835 CUMBERLAND COUNTY PHS # 191940 AFFIDAVIT PURSUANT TO RULE 3129.1 CITIFINANCIAL SERVICES, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428. Name and address of Owner(s) or reputed Owner(s): Name SCOTT J. ROBINSON SONDRA L. ROBINSON 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. , Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. May 26, 2010 By: ~~ ~~~ Attorney for Plaintiff 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 ^ P ter J. Mulcahy, Esq., Id. No. 61791 ndrew 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 CITIFINANCIAL SERVICES, INC. vs. N0.2009-01835 SCOTT J. ROBINSON CUMBERLAND COUNTY SONDRA L. ROBINSON Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SCOTT J. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 is scheduled to be sold at the Sheriff's Sale on 09/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $167,640.89 obtained by CITIFINANCIAL SERVICES, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF' S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution N0.2009-01835 CITIFINANCIAL SERVICES, INC. vs. SCOTT J. ROBINSON SONDRA L. ROBINSON owner(s) of property situate in the TOWNSHIP OF SOUTHAMPTON, Cumberland County, Pennsylvania, being (Municipality) 949 BALTIMORE ROAD, SHIPPENSBURG. PA 17257-9428 Parcel No. 39-36-2428-023 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $167,640.89 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL that certain tract of land situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, et ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at corner of Lot No. 5 now or formerly of William Parr, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an existing railroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & McCans, Inc., R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Commission and the Board of Supervisors of Southampton Township, Cumberland County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. TITLE TO SAID PREMISES IS VESTED IN Scott J. Robinson and Sondra L. Robinson, h/w, by Deed from Randy L. Bell and Robin M. Bell, h/w, dated 11/12/1998, recorded 11/24/1998 in Book 189, Page 903. PREMISES BEING: 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 PARCEL N0.39-36-2428-023 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1835 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC., Plaintiff (s) From SCOTT J. ROBINSON and SONDRA L. ROBINSON (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 $167,640.89 L.L.$.50 Interest from 5/12/09 to Date of Sale ($27.56 per diem) -- $13,366.60 Atty's Comm Due Prothy $2.00 Atty Paid $1,009.94 Other Costs Plaintiff Paid Date: 5/27/10 David D. B ell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 r_ rl~~ ~.~ {~ ~'~ 2010 ~F~~_ 2~ PM 2~ 50 CUB" ;~~;~3'`{ JUL 16 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CITIFINANCIAL SERVICES, INC. Court of Common Pleas Plaintiff Civil Division v. CUMBERLAND County SCOTT J. ROBINSON SONDRA L. ROBINSON No. 2009-01835 Defendants RULE 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 Plaintiff's Motion to Reassess Damages. I Rule Returnable oi~~- ~af ~n '-~...~~a;n Co BY THE COURT J. ~~£s r-aat 1. ~ J.~~~ . I b~;uca~ ~/a~ J ~v ~~ 191940 H,!_, ~'v !, ~ J ~ ,~ ~ .. ; ~~1 r.~~~ 3 FQm K~otp ~~ ;e ~~~ '-_ i .4f , ~[ ~, Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF 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 CITIFINANCIAL SERVICES, INC. Court of Common Pleas Plaintiff Civil Division v. CUMBERLAND County SCOTT J. ROBINSON SONDRA L. ROBINSON No. 2009-01835 Defendants CERTIFICATION OF SERVICE 191940 I hereby certify that a true and correct copy of the Rule Returnable dated July 20, 2010 was sent to the following individual on the date indicated below. SCOTT J. ROBINSON SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 Phelan Hallinan & Schmieg, LLP ~( C DATE: f Z O 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 ATTORNEY FOR PLAINTIFF 191940 AF,~'IDAVIT OF SERVICE PLAIIVTIFF CUMBERLAND COUNTY CITIFINANCIAL SERVICES, INC. PHS # 191940 DEFENDANT SCOTT J. ROBINSON SONDRA L. BOBINSON SERVICE TEAM/ loco COURT NO.: 2009-01835 SERVE S(.'OTT J. ROBINSON AT: 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 TYPE OF ACTION XX Notice of SheliR's Sale SALE DATE: 09/i08/2010 SF~RVID r~ ~..> ~': .~ ~ . Served and made known to SC . ROBINS Defendant on the 14~'day of TuNlc , 20 ~ at _ ~ --~ 0'~i ,o'clock A. M., at ~_ 6A~t_-rt Nco ~.E ~ R , in the manner described below: ~ -,-f / Defendant personally served- SN-i AP6avs9v46 ~ pA, _ ~ _ Adult family member with whom Defendant(s) reside(s)- ~, ReL-tionship is 'o _ Adult in charge of Defendant's residence who refused to give name or relationship. 3 _ Nlanager/G7erk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. _ _ an officer of said Defenndant's company. .,,,a other: ,~,~5 / ,, Description: Age ~_ Height 5 ~f J ~ ~ Weight ~ ~ Race W Sex /" ` Other I, ~ll~}-L1~ ! VIbLL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct ropy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed Kir~?g~RLY CIJRTY day before me this 4~ ' - of -t N E , 201 _ Y PUBLIC N01~RR ST.~•fE '~F ~,'f;~l~ 3);RSEY B ~`~ O~IMISSION E`. iRF.S MARL(-I 7; lOl3 y: Notary: NOT SERVED On , 20_, at ~ o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other. Sworn to and subscribed before me this day - of -, 2~ By- Notary: ATPORNL~Y FOR PLAIM7FF la~nmT./Y1r, 4. fi t1~ 30'E- l~~dt 8 B~i~/4 ~. /i. M~ iillS Ord G BtYiq 6}, Y.Ii Q]lS IlOade 1L Mdw{ g+ Y Na f MM J~iiT. R~ ~ hL IV~l/~6 a~Wli a1~Jr. vy. Y. W.Ot7i0 JsirR Onq,L4, ILNwSJr7l IasR7~OS.lilLfiiif Nit SdwMw~, ~ Y !la 712iJ1 JgLJ~4 g.li p~~fiW Ar11~dF.tiNail7ll A~Baw 68~Irrt, iA, tili~ M~7! . - .. ~ 7i~YeGi~~1q. Y.N~fMA Od~wHrr~ ~i~.04. Y.I1~f1G0 J,i~LCd~-84.YNw7B{7 CwY~R 0~4 a.,,Y. Ww>x71! Ai~a~Ga~W, YM~~ifS ~ ~~ ~ NN JM~ ~/ al 9 AFFIDAVIT OF SERVICE pLAIIVTII~'F CUMBERLAND COUNTY CITIFIIVANCIAL SERVICES, INC. PHS # 191940 DEFENDANT SERVICE TEAM/ IQc SCOTT J. ROBINSON SONDRA L. ROBINSON COURT NO.: 2009-01835 SERVE SONDRA L. ROBINSON AT: TYPE OF ACTION 949 BALTIMORE ROAD XX Notice of ShaiB's Sole SHIPrPENSBURG, PA 17257-9428 SALE DATE: 09/08J21110 ~ ~a ~_ -- tis i 2 Served and made known to SONDRA L. ROBINSON . Defendant on the /!''day of ~uN E , 20 jQ.~`A~ =~ ~` _~"` 7. ~ in the tnanner described below: ~ - (D~ ~ , oclock A. M., at Q44 B~4~=Ldd~.~E QAA~D - . i _ Defendant personally served 3 tF~ PPeN s Bu a.6~ PIl , ~ - _ / Adult family member with whom Defendant(s) reside(s). ~ Relationship is ~~D _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/~Clerk of place of lodging in which Defendant(s) reside(s). 1" _ Agent or person in charge of DefendaM's office ~ usual place of business. 1 cS,r.- r an officer of said Defendant's company. v -Other Description: Age .~_ Height ~l ~~ Weight OD Race ~1 Sex _~ Other I, ~Bl~c.a ~~ . a competent adult, being duly sworn g to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed _ before me this I day r 1. of ~, 201v KII~B~~LY C 1RTY .. ~7v,R.' PU3LIC . N~y. ~ ~ y: ~ ~L l` Cr ~ yr ~. ur 3'ERSEY -- v , My' C~~~y , ~,~~,~r~ E,ti iR~S MARCH 7, 2013 NOT SERVED On 20_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of ~'6= By: 11lp~ry; ATTORNEY FOR PLA1N17FF l...voer. nr,.,~ ~tva~ n~aaa~oF,xN.a®s D~idG B~Iq, 6{. Y. W-itiS lYii~M.l~~y,ii}~(!M ~i~ T. a.~.,y,1i NalF6 8YW L aliJ~4b4+ti Na il'!W ]ie R Aiwa, R4,1i tip fIR! lwe L 7'rrV sA,li Nw lS.D7 Ylwt Sdw~~, 4. Y TIC 712)31 ma>,..~a~.ir.n.al~ laert ure+,ti a4.la n. a~s1 Ad,ew L9liweJ<R3,14l1-MtM 3~tMdii~114.1i p~f~l3~ O~bw~lr /Yw,i7. Y.PN.fQi Jwv L 6~~~Lq,1i Ply 2iwA Cw~lsd ~.0~ i~., l/.Nw 71iTJf A~ia~Calrlrl,~ii17-iT/S - IW7Jl~~~lr ~.1~~8Wp1, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Or ct C+rarib"tt '7 OIL ED 0 t h,E P ? 1 ??' OPEC 21 pH 2: C,3 Richard W Stewart Solicitor CUMBERLA.IjI l COUNTY PENNSYLVANIA Citifinancial Services Inc. vs. Scott J. Robinson (et al.) Case Number 2009-1835 SHERIFF'S RETURN OF SERVICE 06/25/2010 10:31 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 25, 2010 at 1020 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 Scott J. Robinson and Sondra L. Robinson, located at 949 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania according to law. 06/29/2010 05:12 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2010 at 1712 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: Sondra L. Robinson, by making known unto Sondra L. Robinson personally, at 949 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/2912010 05:12 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2010 at 1712 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: Scott J. Robinson, by making known unto Sondra L. Robinson, spouse, at 949 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania it,, contents and at the same time handing to her personally the said true and correct copy of the same. 09/09/2010 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on September 8, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg on behalf of Citifinancial, Inc., 6400 Las Colinas Blvd, Irving, TX, 75039, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $777.69. SHERIFF COST: $777.69 SO ANSWERS, December 13, 2010 RbNl`V R ANDERSON, SHERIFF -`So . sd '?C-( cry ?'Qsz S s:;nur- 7 ?. She *t fr:.- ;;fl. ??x ^, to ?r Q CITIFINAACIAL SERVICES, INC. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION V. SCOTT J. ROBINSON SONDRA L. ROBINSON Defendant(s) NO. 2009-01835 CUMBERLAND COUNTY PHS # 191940 AFFIDAVIT PURSUANT TO RULE 3129.1 CITIFINANCIAL SERVICES, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) SCOTT J. ROBINSON SONDRA L. ROBINSON 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 949 BALTIMORE ROAD SIHPPENSBURG, PA 17257-9428 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. A 7. • Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. May 26, 2010 By: c Attorney for Plaintiff 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 ? P ter J. Mulcahy, Esq., Id. No. 61791 drew L. Spivack, Esq., Id. No. 84439 Jaime e 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 4r CITIFINANCIAL SERVICES, INC. VS. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO. 2009-01835 SCOTT J. ROBINSON CUMBERLAND COUNTY SONDRA L. ROBINSON Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SCOTT J. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 SONDRA L. ROBINSON 949 BALTIMORE ROAD SHIPPENSBURG, PA 17257-9428 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 is scheduled to be sold at the Sheriff's Sale on 09/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the courtjudgment of $167,640.89 obtained by CITIFINANCIAL SERVICES, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. r - 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 2009-01835 CITIFINANCIAL SERVICES, INC. vs. SCOTT J. ROBINSON SONDRA L. ROBINSON owner(s) of property situate in the TOWNSHIP OF SOUTHAMPTON, Cumberland County, Pennsylvania, being (Municipality) 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 Parcel No. 39-36-2428-023 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $167,640.89 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 w LEGAL DESCRIPTION ALL that certain tract of land situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a parker-kalon nail and washer in the centerline of Legislative Route 21048 (Baltimore Road) at corner of Lot No. 7 (to be conveyed to Ronald G. Plasterer, et ux); thence by Lot No. 7, North 17 degrees 53 minutes 0 seconds East, 150 feet to an iron pin at other land now or formerly of Glenn P. Asper and Doris K. Asper, husband and wife; thence by Asper land, South 72 degrees 7 minutes 0 seconds East, 144 feet to an existing iron pin at comer of Lot No. 5 now or formerly of William Parr, et ux; thence by Lot No. 5, South 17 degrees 53 minutes 0 seconds West, 150 feet to an existing railroad spike in the centerline of Legislative Route 21048; thence by the centerline of said road, South 72 degrees 7 minutes 0 seconds West, 144 feet to the point and place of BEGINNING. CONTAINING a total area of 21,600 square feet and being Lot No. 6 on the draft of Dougal & McCans, Inc., R.S., for Glenn S. Asper, which plan has been approved by the Cumberland County Planning Commission and the Board of Supervisors of Southampton Township, Cumberland County, Pennsylvania. Said plan is recorded in Cumberland County Plan Book 36 at page 96. TITLE TO SAID PREMISES IS VESTED IN Scott J. Robinson and Sondra L. Robinson, h/w, by Deed from Randy L. Bell and Robin M. Bell, h/w, dated 11/12/1998, recorded 11/24/1998 in Book 189, Page 903. PREMISES BEING: 949 BALTIMORE ROAD, SIEIPPENSBURG, PA 17257-9428 PARCEL NO. 39-36-2428-023 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-1835 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC., Plaintiff (s) From SCOTT J. ROBINSON and SONDRA L. ROBINSON (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 $167,640.89 L.L.$.50 Interest from 5/12/09 to Date of Sale ($27.56 per diem) -- $13,366.60 Atty's Comm % Due Prothy $2.00 Atty Paid $1,009.94 Other Costs Plaintiff Paid Date: 5/27/10 . k7G1.1?%`?lJ David D. Buell, Prothono (Seal) Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 On June 14, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Down and numbered as, 949 Baltimore Road, Shippensburg C''•: mere fully described on Exhibit `A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: al Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a-legal periodical published in the Borough of Carlisle in the County and.State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 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. writ No. 2009-1835 C" Citifinancial Services Inc. Vs. Scott J. Robinson Sondra L. Robinson Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 2009-01835, CITIFINANCIAL SERVICES, INC. vs. SCOTT J. ROB- INSON, SONDRA L. ROBINSON, owners of property situate in the TOWNSHIP OF SOUTHAMPTON, Cumberland County, Pennsylvania, being 949 BALTIMORE ROAD, SHIP- PENSBURG, PA 17257-9428. Parcel No. 39-36-2428-023. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $167,640- .89. isa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this 0 da of Jul , 2010 Notary NOTAR""?EAL •••• DEBORAH A COLLINS Noury pwflio CARLISLE BOROUGH, CUMBERLAND COUNTY My Coaanission Explns Apr 28, 2011 1A3Z lAI?iATC9V4 IWO' r?`n ailadyur yd I(4 7 The Patriot-News Co. 2020 Technology Pkwy , Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Z4e PNow 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 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 81.2 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 unarimously 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: Writ No. 2009-1835 Civil Citifinancial Services Inc. 07/09110 Vs 07/16/10 Scott J. Robinson Sondra L. Robinson Atty: Daniel Schmieg By virtue of a Writ of Execution NO. 2009- 07123/10 M 01835 ....... ? ( J CITIFINANCIAL SERVICES, INC. i vs. / / C SCOTT J.ROBINSON Sworn to;,and subscribed before me this 5 d .of August, 2010 A.D. SONDRA L. ROBINSON % . owner(s) of property situate in the TOWNSHIP _ OF SOUTHAMPTON, Cumberland County, Pennsylvania, being Notary Public (Municipality) 949 BALTIMORE ROAD, SHIPPENSBURG, PA 17257-9428 Parcel No. 39-36-2428-023 (Acreage or street address) ('OF ' Improvements thereon: RESIDENTIAL t f:NNSY1 VA '=----_. _ rPJIA Notaraai S t DWELLING ea ? Sherrif, L Kisner, Notary publi JUDGMENT AMOUNT: $167,640.89 c Lower Paxton Ttn po, Dauphin Cc MT V unty - C_ c rltw rt Earpires N ov 26 ,?r.a^.`?N ' pen".,. "7ors _-^--.--_----_i?2?11 ;??7C4?f,Off 4f I?'Otd+7.°S 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 Citifinancial Inc is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 27th day of May, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 1835, at the suit of Citifinancial Ser Inc against Scott J & Sondra L Robinson is duly recorded as Instrument Number 201037943. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of &=-23az? , A.D. 0 D I of Deeds d%Cwdx ndC=*CaftPA b**ftFlntft*dJn=