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HomeMy WebLinkAbout09-3516Phelan 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 206928 AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 Plaintiff V. SERAFEIM CHONDROS MARIA CHAMILOTHORIS 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 0 /-3?5- /4 cam./ -fe-on CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 206928 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 #: 206928 1. Plaintiff is AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 2. The name(s) and last known address(es) of the Defendant(s) are: SERAFEIM CHONDROS MARIA CHAMILOTHORIS 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/21/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to OPTION ONE MORTGAGE CORPORATION, A CALIFORNIA CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1928, Page 2930. By Assignment of Mortgage recorded 09/25/2006 the mortgage was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED which Assignment is recorded in Assignment of Mortgage Book No. 730, Page 3291. 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 02/01/2009 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 File #: 206928 by written notice sent to Mortgagor, the entire principal balance and all interest due 6. thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $160,736.68 Interest $4,758.39 01/01/2009 through 05/27/2009 . (Per Diem $32.37) Attorney's Fees $1,300.00 Cumulative Late Charges $170.28 10/21/2005 to 05/27/2009 Cost of Suit and Title Search 750.00 Subtotal $167,715.35 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $167,715.35 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 File #: 206928 discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 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 $167,715.35, together with interest from 05/27/2009 at the rate of $32.37 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. PHELAIY HALLINAN & SCHMIEG, LLP By: ZLa enc T. Phel squire cis al ' ,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 ,Ioshua I. Goldman, Esquire %#2-6SU4-- Courtenay R. Dunn, Esquire Attorneys for Plaintiff File #: 206928 LEGAL DESCRIPTION ALL that certain lot or tract of land situate in Southampton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point along the southern right of way line of Hilltop Drive along the dividing line between Lot 5 on the hereinbelow referenced plan and line of lands now or formerly of Thomas E. and Doris E. Shuman and line of lands now or formerly of Donald W. and Mildred M. Daihl; thence along said dividing line South 37 degrees 24 minutes 26 seconds West 327.64 feet to a point; thence along line of lands now or formerly of Robert D. and Yvonne M. Shoop, North 67 degrees 34 minutes 13 seconds West 211.88 feet to a point in the centerline of Newburg Road (SR 0696); thence along the dividing line between Lot 5 and Lot 6 on the hereinbelow referenced plan, North 52 degrees 55 minutes 49 minutes East 398.26 feet to a point; thence along the southern eight of way line of Hilltop Drive by a curve to the left having a radius of 175.00 feet and an arc length of 6.50 feet to a point; thence continuing along the southern right of way line of Hilltop Drive, South 51 degrees 52 minutes 55 seconds East 91.60 feet to a point, the place of BEGINNING. CONTAINING 52,417.29 square feet and being known ad Lot 5 as set forth on the Subdivision for Middlespring Estates, prepared by Fisher, Mowery, Rosendale and Associates, Inc., dated May 21, 1993, and recorded October 11, 1994, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 68, Page 124. PARCEL #: 39-12-0318-053 PROPERTY ADDRESS: 4 HILLTOP DRIVE File #: 206928 VERIFICATION The undersigned attorney hereby states that I am the attorney for the 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 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 vcrification 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. Att ey or Plaintiff y IV EF ?oLbrvV?N S-t? -oPl ?? ? ?sa-« DATE: : 5-0 G?G ri I I?? a..?- Sid 7 Sheriffs Office of Cumberland County R Thomas Kline ? lp of Cam,& Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFF )GE OF r-E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/29/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Serafeim Chondros, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Sarafeim Chondros. Per neighbor the defendant moved to Virginia May 26, 2009. The Shippensburg Postmaster has advised mail is delivered to address given. An exact address is not available. 05/29/2009 07:45 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Maria Chamilothoris, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Maria Chamilothoris. Per neighbor the defendant moved to Virginia May 26, 2009. The Shippensburg Postmaster has advised mail is delivered to address given. An exact address is not available. SHERIFF COST: $72.00 June 02, 2009 SO ANSWERS, _ R THOMAS KLI E, SHERIFF 2009-3516 Aurora Loan Services, LLC VS Serafeim Chondros r-, rv ' d t. r • r 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 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-1563-7000 AURORA LOAN SERVICES, LLC. COURT OF COMMON PLEATS Plaintiff CIVIL DIVISION vs. SERAFEIM CHONDROS MARIA CHAMILOTHORIS CUMBERLAND COUNTY No. 09-3516-CIVIL TERM Defendants PRAF,CIPF. TO RF,INSTATF. CY"L ACTION/MORTGAGF FORF.CLOSITRF a t TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHEL LIN & SCHMIEG, LLP By: 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 Courtenay R. Dunn, Esquire Attorneys for Plaintiff Date: June 11, 009 /jrm, Svc Dept. File# 206928 7 FILED-40rRCE OF THE PR-' H1,DNOTARY 2004 JUN 12 Ate 11: 13 ia?JUVY 1 Sheriffs Office of Cumberland County R Thomas Kline X4„1~, etumbrpr Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy orr'4E '"E $"ERIFF Civil Process Sergeant Aurora Loan Services, LLC Case Number vs. Serafeim Chondros 2009-3516 SHERIFF'S RETURN OF SERVICE 07/02/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Serafeim Chondros, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Serafeim Chondros. The Shippensburg Postmaster has advised the defendant has moved and left no forwarding address. An exact address is not available. 07/02/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Maria Chamilothoris, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Maria Chamilothoris. The Shippensburg Postmaster has advised the defendant has moved and left no forwarding address. An exact address is not available. l ?? SHERIFF COST: $72.00 July 02, 2009 SO KLINE, SHERIFF C- r [A-4 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff VS. SERAFEIM CHONDROS MARIA CHAMILOTHORIS Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-3516-CIVIL TERM : CUMBERLAND COUNTY PHS #: 206928 PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff _ By: A4 ? Lawrence T. Phelan, 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 Date: 7/10/09 PHS #: 206928 VERIFICATION Y hereby states that he/she is of AURORA LOAN SERVICES, LLC., servicing agent for Plaintiff, AURORA LOAN SERVICES, LLC, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: DATE: Title: CHERYL MARCHANT VICE PRESIDENT Company: AURORA LOAN SERVICES, LLC. Loan: 0 1 1 8260876 File #; 206928 Chondros 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff VS. SERAFEIM CHONDROS MARIA CHAMILOTHORIS Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-3516-CIVIL TERM : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: SERAFEIM CHONDROS 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 MARIA CHAMILOTHORIS 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 Phelan Hallinan & Schmieg, LLP Attorney for Plai ff w 1 By: ? Lawrence T. Phel q., 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 Date: 7/10/09 OF T-: r, r 11?EY 20x9.JL. It 3 PI 33 :29 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 15-56'~-7000 AURORA LOAN SERVICES, LLC. Plaintiff vs. SERAFEIM CHONDROS MARIA CHAMILOTHORIS Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 09-3516-CIVIL TERM TO THE PROTHONOTARY: • ., Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP gy; ~~ ~ 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 Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorneys for Plaintiff Date: Ai~au~t 7, 2~~9 /lxh, Svc Dept. File# 206928 .~t~;, , }~"~ ' '~'~ , r ~~ as X05"3 . ~/ , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Aurora Loan Services, LLC Civil Division vs. No. 2009-3516 Serafeim Chondros Maria Chamilothoris ORDER AND NOW, this ~~~ day of ~ p~~~,,,~ ~,~ , 2009, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRAN'TF,D. It is fiurther ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendants, Serafeim Chondros and Maria Chamilothoris, by: 1. First class mail to Serafeim Chondros and Maria Chamilothoris at the last known address, 6 Hilltop Drive, Shippenburg, PA 17257, and the mortgaged premises located at 4 Hilltop Drive, Shippensburg, PA 17257-8001; and 2. Certified mail to Serafeim Chondros and Maria Chamilothoris at the last known address, 6 Hilltop Drive, Shippenburg, PA 17257 and the mortgaged premises located at 4 Hilltop Drive, Shippensburg, PA 17257-8001; and 2 3. Plaintiff is further directed to cause a true and correct copy of the Complaint to be posted on the mortgaged premises, 4 Hilltop Drive, Shippensburg, PA 17257-8001by the Sheriff or by a competent adult. 4. Publication in accordance with PA. R.C.P. 430. BY THE COURT: J. Cc: Serafeim Chondros Maria Chamilothoris 4 I~- illtop Drive, Shippensburg , PA 17257-8001 erafeim Chondros and Maria Chamilothoris 6 Hilltop Drive, Shippenburg, PA 17257 PHS# 206928 ~o ,~~~~L ir~.~d/~'`I _~ 3 Z~;Q4 ~~~~ 3Q ~~; I~~ ' i C _ , ~ ~,,, r - _, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~t~~n` nt .a~urrtl,~~j -~ d ~ FILED-E:;~r;vE ~. THE ~'~~~`~,-~^ ,~nTARY ,~.r.., Jody S Smith Chief Deputy Edward L Schorpp Solicitor 201Q J~a~~ 13 ~i~3 IQ~ 25 .;fit ,,re,~,''i,~; Aurora Loan Services, LLC vs. Serafeim Chondros Case Number 2009-3516 SHERIFF'S RETURN OF SERVICE 01/11/2010 05:48 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 11, 2010 at 1748 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Serafeim Chondros, pursuant to order of court by posting the premises located at 4 Hilltop Drive, Shippensburg, Cumberland County, Pennsylvania 17257 with a true and correct copy according to law. 01/11/2010 05:48 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 11, 2010 at 1748 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Maria Chamilothoris, pursuant to order of court by posting the premises located at 4 Hilltop Drive, Shippensburg, Cumberland County, Pennsylvania 17257 with a true and correct copy according to law. SHERIFF COST: $74.00 January 12, 2010 SO ANSWERS, O NY R ANDERSON, SHERIFF Deputy Sheriff .... ''f 'te oi't 1~7r, IN THE COURT OF COMMON PLEAS ~Y .1 ~ ~U~~ +~ M ~ CUMBERLAND COUNTY, PENNSYLVANIA AURORA LOAN SERVICES, LLC. Court of Common Pleas Plaintiff v. SERAFEIM CHONDROS MARIA CHAMILOTHORIS Defendants ORDER Civil Division CUMBERLAND County No. 09-3516-CIVIL TERM AND NOW, this ~ t~'~day of ~ " 0 , 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 tune as follows: Principal Balance $160,736.68 Interest Through June 2, 2010 $16,540.97 Per Diem $31.93 Late Charges $170.28 Legal fees $1,725.00 Cost of Suit and Title $1,913.70 Sheriffs Sale Costs $0.00 Property Inspections/ Property Preservation $12.00 Appraisal/Brokers Price Opinion $0.00 Mortgage Insurance Premium / $0.00 Private Mortgage Insurance Non Sufficient Funds Charge $0.00 Suspense/Misc. Credits ($0.00) Escrow Deficit $3,419.52 TOTAL $184,518.15 Plus interest from June 2, 2010 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriff s commission is not included in the above figure. `~ ~ ~_~ _ ~ ~~ ~z: - ~ ~o ~ }~ t ~~S rye ~ .dc ~. f ' J ~~ r i ~ ~`~ • r ~r~, •~~G~r ~ dJ h- r `~~ `; o U ~~~/~d ~~ BY THE COURT J. ~n~q~R d' s ~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson "' Sheriff ' Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~`~tr ~1 4urrtt~~,r~~~~~ :~ S=f' .;" - ~~' . _ a . _~ ~~_~ ., ._ ..`rr. ,,, Aurora Loan Services, LLC vs. Serafeim Chondros (et al.) Case Number 2009-3516 SHERIFF'S RETURN OF SERVICE 04/06/2010 02:07 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 a 1408 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 Serafeim Chondros and Maria Chamilothoris ,located at, 4 Hilltop Drive, Shippensburg, Cumberland County, Pennsylvania according to law. 04/12/2010 04:52 PM -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: Maria Chamilothoris, 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, Maria Chamilothoris, defendant is believed to living in Greece. 04/12/2010 04:52 PM -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: Serafeim Chondros, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Serafeim Chondros, defendant is believed to living in Greece. 06/03/2010 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 June 2, 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 Aurora Loan Services, LLC, 2617 College Park, Scottsbluff, NE, 69361, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 787.61 SHERIFF COST: $787.61 June 30, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF ~• DGl ~-~' ~~ -D~ ~.~ - C'v . S7~ LL pd ~,~ 7~ 9~y ~ ~~.~// ;c Coin..n<y5uito Shenfi. TelFOSOft. Inc. AURORA LOAN SERVICES, LLC. Pla=,~tiff ~ ~. 1~ SERAFEIM CHONDROS MARIA CHAMILOTHORIS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-3516-CIVIL TERM CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 AURORA LOAN SERVICES, LLC., 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 4 HILLTOP DRIVE„ SHIPPENSBURG, PA 17257-8001. 1. Name and address of Owner(s) or reputed Owner(s): Name SERAFEIM CHONDROS SERAFEIM CHONDROS MARIA CHAMILOTHORIS MARIA CHAMILOTHORIS 2'. ~ Name and address of Defendant(s) in the judgment: Address (if address cannot be reasonably ascertained, please so indicate) ' ' 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 6 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 4 HILLTOP DRIVE, SHiPPENSBURG, PA 17257-8001 6 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-5001. Name Address (if address cannot be reasonably ascertained, please so indicate) 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 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) Option One Mortgage Corporation, a California 3 Ada Corporation Irvine, CA 92618 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. ~ Natr~ and address of every other person who has any record interest in the property and whose interest may be affected by the same. , 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 4 HILLTOP DRIVE, SHIPPENSBURG, PA 17257-8001 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 United States Internal Revenue 13th Floor, Suite 1300 Special Procedures Branch 1001 Liberty Avenue Federated Investors Tower Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 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. March 9.2010 By: Attorney for Plaint'~'f - Phelan Hallinan &Schmieg, LLP ^ La ence T. Phelan, Esq., Id. No. 32227 ^ F ands 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 6 AURORA L0~4N SERVICES, LLC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. SERAFEIM CHONDROS MARIA CHAMILOTHORIS N0.09-3516-CIVIL TERM CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SERAFEIM CHONDROS SERAFEIM CHONDROS MARIA CHAMILOTHORIS MARIA CHAMILOTHORIS 4 HILLTOP DRIVE 6 HILLTOP DRIVE SHIPPENSBURG, PA 17257-8001 SHIPPENSBURG, PA 17257-8001 * *THIS FH2M I5 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 4 HILLTOP DRIVE„ SHIPPENSBURG, PA 17257-8001 is scheduled to be sold at the Sheriff's Sale on 06/02/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $176,422.88 obtained by AURORA LOAN SERVICES, LLC. (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 S T 1LL 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 b~ 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 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 N0.09-3516-CIVIL TERM AURORA LOAN SERVICES, LLC. vs. SERAFEIM CHONDROS MARIA CHAMILOTHORIS owner(s) of property situate in SOUTHAMPTON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 4 HILLTOP DRIVE„ SHIPPENSBURG, PA 17257-8001 Parcel No. 39-12-0318-053 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $176,422.88 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL that certain lot or tract of land situate in Southampton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point along the southern right of way line of Hilltop Drive along the dividing line between Lot 5 on the hereinbelow referenced plan and line of lands now or formerly of Thomas E. and Doris E. Shuman and line of lands now or formerly of Donald W. and Mildred M. Daihl; thence along said dividing line South 37 degrees 24 minutes 26 seconds West 327.64 feet to a point; thence along line of lands now or formerly of Robert D. and Yvonne M. Shoop, North 67 degrees 34 minutes 13 seconds West 211.88 feet to a point in the centerline of Newburg Road (SR 0696); thence along the dividing line between Lot 5 and Lot 6 on the hereinbelow referenced plan, North 52 degrees 55 minutes 49 minutes East 398.26 feet to a point; thence along the southern eight of way line of Hilltop Drive by a curve to the left having a radius of 175.00 feet and an arc length of 6.50 feet to a point; thence continuing along the southern right of way line of Hilltop Drive, South 51 degrees 52 minutes 55 seconds East 91.60 feet to a point, the place of BEGINNING. CONTAINING 52,417.29 square feet and being known ad Lot 5 as set forth on the Subdivision for Middlespring Estates, prepared by Fisher, Mowery, Rosendale and Associates, Inc., dated May 21, 1993, and recorded October 11, 1994, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 68, Page 124. TITLE TO SAID PREMISES IS VESTED IN Serafeim Chondros and Maria Chamilothris, h/w, by Deed from James E. Moseman, a/k/a James E. Moseman, a married man, dated 10/20/2005, recorded 10/28/2005 in Book 271, Page 3188. PREMISES BEING: 4 HII.LTOP DRIVE„ SIIIPPENSBURG, PA 17257-8001 PARCEL N0.39-12-0318-053. WRIT OF EXECUTION and/or ATTACHMENT . . . ~ . COMMONWEALTH OF PENNSYLVANIA) NO 09-3516 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC, Plaintiff (s) From SERAFEIM CHONDROS and MARIA CHAMILOTHORIS (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 $176,422.88 L.L.$.50 Interest from 2/21/10 to Date of Sale ($29.00 per diem) -- $2,958.00 Atty's Comm Atty Paid $449.00 Plaintiff Paid Date: 3/10/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs ~ ~ David D. Buell, Prothonotary By: Deputy Name: MICHELE M. BRADFORD, 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. 69849 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Known and numbered, 4 Hilltop Drive, Shippensburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 ~~-%~ Real Estate Coordinator ~J ~~ ~~ ~~ S?~ f~ 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: April 16, April 23, and Apri130, 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 No. aoo9-3s 16 civil Aurora Loan Services, LLC vs. Serafeim Chondros Maria Chamilothoris Atty: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-3516-CIVIL, AURORA LOAN SERVICES, LLC. vs. SERAFEIM CHONDROS, MARIA CHAMILO- THORIS, owners of property situate in SOUTHAMPTON TOWNSHIP, Cumberland County, Pennsylvania, being 4 HILLTOP DRIVE„ SHIPPENS- BURG, PA 17257-8001. Parcel No. 39-12-0318-053. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $176,422- .88. ~--- L' a Marie Coyne ditor SWORN TO AND SUBSCRIBED before me this 0 da of Aril 2010 i Notary NO_Ti-RI ~ SEAL DEBORAH A COLUNS Notary Public ARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 20th ,,;r ~ r ~. ~.. -. t ~, ~u9i: ~ '~i~f~ :ir~.. ~:2 r t )k?s.rns .. ~.> ~• -The Patriot-News Co. 2020 Techruology' Pkwy Suite 300` Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c'~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 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: 04/16110 VI-rK No. ~ CIvN 7irrm 04/23/10 ,i4un~re L.oan'~rvkxae,l.LC ~...-.. __ ... 04/30/10 <vs. ~., ,.. ,Choi. < wlerle ~hamilat~-orld I Atly: ~lel G ~d~.g ......... ... .................. . BY virtue of a Writ of Execwi~ NG, pQ-3516- t:1VB., T13RM ? AvRORALGAf~rsERVICES LLC of May, 2010 A.D. Sworn to an scribed before me this da , , vs. SEI~ApEiM CHONDROS ° '"" -~-c.-` 1~'"^. t`~ ` ' ~ MARL r41iAM(Lp~GRiS - ~_... ~'~ -- __ i~% ____ °"'°~s»rY~au;osO~N Notary Public Tow1~IS1•m?.L},mt,~~y Yid being. (,'~uuicipalitY) 4 I~dTOP DRIVE „ SI'~PE~ISBiiRG, PA" 17257-80(11 Parcel No. 39-12-0318-033(Acreage ;or etrebt COMMONWEpLTy OF PENNSYLVANIA Impravemorua ihereoa: 1tESIDENTIAL Notarial Seal Sherrie L Klsner, Notary Publk DWELLING JUDGMENT AMOUNT: 5176,422.88 Lower Paxton T1Mp,, pauphln County MY Commlaslon rss Nov, 26 2011 Member, PennsyNanla Assoctatlon t?f Notartea 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 AURORA LOAN SER LLC is the grantee the same having been sold to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 10TH day of MARCH, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 3516, at the suit of AURORA LOAN SERV against SERAFEIM CHONDROS & MARIA CHAMILOTHORIS is duly recorded as Instrument Number 201018175. IN TESTIMONY WHEREOF, I have hereunto set my hand ~~__. and~al of said office this ~ day of A.D.~ c rder of Deeds ~x~~ (aouMtr, t~rAsie, PN t~ty E~ires the First IAondery d Jen. 2014