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Home My WebLink About09-5848 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 207916 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff V. JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY 119 SOUTH STREET HARRISBURG, PA 17101 PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY, DECEASED 119 SOUTH STREET HARRISBURG, PA 17101 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Oa -5848 0'i v i ( ?h CUMBERLAND COUNTY File #: 207916 I- 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 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff VS. JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) : NO. 09-5848-CIVIL-TERM : CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE PHS #: 207916 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 Pjaintiff By: T Gam/ ? 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 [OAndrew C. Bramblett, Esq., Id. No. 208375 Date: 9-21-09 PHS #: 207916 VERIFICATION Jeffrey Stephan Limited Signing Ofd' hereby states that he/she is Jeffrey S10ptvtn of HOMECOMINGS FINANCIAL, LLC, servicing agent for Plaintiff 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 unworn falsification to authorities. Name: DATE: 2 a , 2U Stephan ning Offioet HOMECOMINGS FINANCIAL, File #: 207916 Seeton 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 ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff VS. JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) : NO. 09-5848-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: JOHNNA L. SEETON 119 SOUTH STREET HARRISBURG, PA 17101 PHS #: 207916 PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED 119 SOUTH STREET HARRISBURG, PA 17101 ANDREW C. SHEELY 127 SOUTH MARKET STREET, P.O. BOX 95 MECHANICSBURG, PA 17055 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 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 Date: 9-21-09 PHS #: 207916 FILED 2009 SIP 23 PH 2: L tl 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 #: 207916 Plaintiff is U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 1100 VIRGINIA DRIVE, P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY 119 SOUTH STREET HARRISBURG, PA 17101 PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY, DECEASED 119 SOUTH STREET HARRISBURG, PA 17101 who is/are the real owner(s) of the property hereinafter described. On 06/14/2005 FRACES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY made, executed and delivered a mortgage upon the premises hereinafter described to NEW CENTURY MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1914, Page 4225. By Assignment of Mortgage recorded 12/06/2005 the mortgage was assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED which Assignment is recorded in Assignment of Mortgage Book No. 723, Page 432. 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); File #: 207916 4. 5. 6. which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. The premises subject to said mortgage is described as attached. 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 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $84,021.92 Interest $3,343.55 01/01/2009 through 08/21/2009 (Per Diem $14.35) Attorney's Fees $1,300.00 Cumulative Late Charges $509.26 06/14/2005 to 08/21/2009 Property Inspections $22.50 Cost of Suit and Title Search 1,050-00 Subtotal $89,947.23 Escrow Credit $0.00 Deficit $3,271.13 Subtotal 271-1-1 $3 TOTAL , $93,218.36 7. 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. File #: 207916 8. Notice of Intention to Foreclose pursuant to Act 6 of 1974 is not required because the defendant(s) is/are not a "Residential Mortgage Debtor" as defined by the Act, having failed to provide Plaintiff notice of its acquisition of title. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not owner-occupied. 10. Mortgagor FRANCES JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY died on March 6, 2009, leaving a Will dated 12/2/98. Letters Testamentary were granted to JOHNNA L. SEETON on 3/13/09 in Cumberland County, No. 21-2009-248. Decedent's surviving heir at law is THE PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK. 11. Plaintiff does not hold the named Defendants, JOHNNA L. SEETON and THE PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendants in the aforesaid real estate only, and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). File #: 207916 WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $93,218.36, together with interest from 08/21/2009 at the rate of $14.35 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. HALLINAN & SCHMIEG, LLP L` _I Lawrence T. Phelan, Esq., IdTVo. 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 ? She al R. Shah-Jani, Esq., Id. No. 81760 ine R. Davey, Esq., Id. No. 87077 e ren 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 File #: 207916 r LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern side of Valley Street (50 feet wide) at corner of Lot No. 3 on the hereinafter mentioned Plan of Lots; thence by Valley Street North 68 degrees 01 minutes 00 seconds East a distance of 80 feet to a point at Lot No. 5 on said Plan; thence by Lot No. 5 South 21 degrees 59 minutes East a distance of 128.12 feet to a point at Lot No. 361 on the Plan of Louis Park; thence by Lot No. 361 and Lot No. 360 on the Plan of Louis Park South 58 degrees 04 minutes 00 seconds West a distance of 81.22 feet to a point at Lot No. 3 on the hereinafter mentioned Plan; thence by same North 21 degrees 59 minutes West a distance of 142.15 feet to a point, the Place of BEGINNING. Parcel Number: 09-12-2992-007D PROPERTY BEING: 752 VALLEY STREET File #: 207916 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 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 auth DATE: File #: 207916 Q FE c -,CE OF TH ? t ONOTARY 2009 AUG 25 PM 2: 1 GUi' k", )JNT Y F'&NNS`r LVAJNIA + 078.60 QQ AT" C'e mml wm?aaqq&3 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OFD-CF ')FTf-E c--RIFF E7 !CE F' ?T',?diJTY OF THE 2" A S -- 9 A& 11: ! f' tjA. ,'' I vFA 9 11Y U.S. Bank National Association I vs. Case Number Johnna L. Seeton 2009-5848 SHERIFF'S RETURN OF SERVICE 08/26/2009 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: Johnna L. Seeton, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 08/28/2009 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: Pennsylvania Legislative Animal Network, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 08/31/2009 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: Johnna L. Seeton, 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 Johnna L. Seeton. The Enola Postmaster has advised the defendant has moved and left no forwarding address. An exact address is not available. 09/02/2009 11:15 AM -Dauphin County Return: And now September 2, 2009 at 1115 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Johnna L. Seeton by making known unto herself personally, at 119 South Street Harrisburg, PA 17101 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/02/2009 11:15 AM -Dauphin County Return: And now September 2, 2009 at 1115 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Pennsylvania Legislative Animal Network, Inc. by making known unto Johnna Seeton, President at 119 South Street Harrisburg, PA 17101 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $71.50 September 04, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF t 0 f th e eriff Mary Jane SnyTyder Real Estate Depu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin U.S. BANK NATIONAL ASSOCIATION VS PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK INC. Sheriff s Return No. 2009-T-2358 OTHER COUNTY NO. 20095848 And now: SEPTEMBER 2, 2009 at 11:15:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon JOHNNA L SEETON by personally handing to JOHNNA L SEETON 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 119 SOUTH ST HARRISBURG PA 17101 Sworn and subscribed to before me this 3RD day of September, 2,009 A??4dAl NOTARIAL SEAL MARY MNE SNYDE,R, Notary Public Highspire, Dauphin County M Commission Expires Sept 1, 2010 So Answers, )CAIC- Sheriff of uphin o ty, 1 By Deputy Sheriff Deputy: R HOPKINS Sheriffs Costs: $60.5 9/1/2009 Mary Jane, Snder Real Estate epu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)780-6.590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin U.S. HANK NATIONAL ASSOCIATION VS PENNSYLVANIA LEGISLATJVE ANIMAL, NETWORK INC. Sheriffs Return No. 2009-T-2358 OTHER COUNTY NO. 20095848 And now: SEPTEMBER 2, 2009 at 11:15:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK INC. by personally handing to JOHNNA SEETON 1 true attested. copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 119 SOUTH STREET HARRISBURG PA 17101 PRESIDENT Sworn and subscribed to before me this 3RD day of September, 2009 llio?A/ NOTARIAL SEAL MARY JANE SNYDER, Notary Publi Highspire, Dauphin County, MY mmission Expires Set 1, 2010 So Answers, Sheriff of Da hin Co nt , P f Deputy Sheriff - - -- Deputy: R HOPKINS S'heSffs,Gc;,sts: $60.5 9/l/2009 In The Court of Common Pleas of Cumberland County, Pennsylvania U.S. Bank National Association vs. Johnna L. Seeton 119 South Street Harrisburg, PA 17101 Civil No. 2009-5848 Now, August 26, 2009, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sworn and subscribed before me this day of 20 Sheritf of COSTS SERVICE $ MILEAGE_ AFFIDAVIT County, PA 20 , at o'clock M, served the copy of the original In The Court of Common Pleas of Cumberland County, Pennsylvania U.S. Bank National Association vs. Pennsylvania Legislative Animal Network, Inc. 119 South Street Harrisburg, PA 17101 Civil No. 2009-5848 Now, August 28, 2009, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. epolagrmw"?. - Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sworn and subscribed before me this day of 120 copy of the original Sheriff of COSTS SERVICE $ MILEAGE_ AFFIDAVIT County, PA 20 , at o'clock M, served the SHERIFF'S RETURN OF SERVICE DAUPHIN Plaintiff(s) U.S. BANK NATIONAL ASSOCIATION,... Defendant(s) JOHNNA L. SEETON, ET AL PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INC., ET AL Serve At JOHNNA L. SEETON, ET AL 119 SOUTH STREET HARRISBURG, PA 17101 Special Instructions CIVIL ACTION NUMBER SHERIFF'S NUMBER COST MILEAGE DISTRICT Summons -xx- Complaint Other TYPE OF ACTION Mortgage Foreclosure TO BE COMPLETED BY SHERIFF Served and made known to , Defendant, on the - day of , 20_, at o'clock, _.m., at , County of , Commonwealth of Pennsylvania, in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is 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). Agent or person in charge of Defendant's office or usual place of business. and officer of said Defendant company. Other: SHERIFF By: , Deputy Sheriff On the day of , 20_, at o'clock, _.m., Defendant not found because: Moved _ Unknown _ No Answer -Vacant -Other SHERIFF By: , Deputy Sheriff DEPUTIZED SERVICE Now, this day of , 20 , I, Sheriff of County, Pennsylvania do hereby deputize the Sheriff of County to serve this Complaint and make return thereof and according to law. SHERIFF By: , Deputy Sheriff ATTORNEY FOR PLAINTIFF: TO BE COMPLETED BY PROTHONOTARY 1 awrence T. Phelan, Esq Td Nn 37727 Francis S Hallinan, Fc ; , id Nn 67695 ATTEST Daniel G. Schmieg, Fsy ,id Nn 62205 Michele M. Bradford, F_cn , id_ No 69949 Judith T_ Rnmann, F"s?l_, id_ Nn_ SR745 Pro Prothy Sheetal R Shah-lani, F q , 1d No 81760 lenine R Davey, Fsn id Nn -7077 1 auren R Tahm, Fc4 , id Nn 93337 Date Vivek Srivastava, FsqId_ No 202331 Jay R Ines, Fcn , id No 96657 Peter I. Mulcahy, Fsn , id. Nn_ 61791 Andrew 1. S nivack, Fcn , id Nn R4439 laime Merninness,F.an,T_ Id No 90114 Chrisnvalnnte P Fliakn5, Fc? id -1994620 lnshna i_ Gnldman, Fsn , 1d Nn 705047 Cnurtenay R_ Dunn?E , id Nn 20fi779 Andrew C. Rramhlett, Fsn , Id No 709375 1617 lFK Roulevard, Suite 1400 One Penn Center Playa Philadelphia, PA 19103 File #: 207916 ,t Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ,.,,Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 VS. JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY, DECEASED Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-5848-CIVIL-TERM 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 JOHNNA L. SEETON. IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY and PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY, DECEASED, 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 Plaintiff's damages as follows: As set forth in Complaint $93,218.36 Interest - 08/22/2009 to 10/08/2009 $688.80 TOTAL $93,907.16 I hereby certify that (1) the Defendants' last known address is 119 SOUTH STREET, with R ule 237.1, HARRISBURG, PA 17101, and (2) that notice has been given it?? copy attached. Lawren"e?Y. 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 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: io q D 2 , PHS # 207916 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 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 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION AS CUMBERLAND COUNTY TRUSTEE FOR RASC 2005KS8 VS. JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY, DECEASED : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-5848-CIVIL-TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she 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 JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY is over 18 years of age and resides at 119 SOUTH STREET, HARRISBURG, PA 17101. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. ? Lawrence T. P elan, 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 ? Ju 'th T. Romano, Esq., Id. No. 58745 ? eetal R. Shah-Jani, Esq., Id. No. 81760 ? enine 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 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 Plaintiff JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-5848-CIVIL-TERM CUMBERLAND COUNTY TO: PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED 119 SOUTH STREET HARRISBURG, PA 17101 DATE OF NOTICE: September 23, 2009 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 APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 207916 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. 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 --'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 She 1 R. Shah-Jani, Esq., Id. No. 81760 .Knine 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 207916 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 Plaintiff V. JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) TO: JOHNNA L. SEETON 119 SOUTH STREET HARRISBURG, PA 17101 DATE OF NOTICE: September 23, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-5848-CIVIL-TERM 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 APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 207916 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. 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 Ldwrence 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 207916 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 V. Plaintiff JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-5848-CIVIL-TERM CUMBERLAND COUNTY TO: JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED C/O ANDREW C. SHEELY 127 SOUTH MARKET STREET, P.O. BOX 95 MECHANICSBURG, PA 17055 DATE OF NOTICE: September 23, 2009 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. RYWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 207916 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. 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 _La*vrence 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 J me R. Davey, Esq., Id. No. 87077 uren 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 207916 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 Plaintiff v JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) TO: JOHNNA L. SEETON 752 VALLEY STREET ENOLA, PA 17025-1618 DATE OF NOTICE: September 23, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-5848-CIVIL-TERM 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 APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 207916 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street 1 Carlisle, PA 17013 l (717) 249-3166 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 Sh 1 R. Shah-Jani, Esq., Id. No. 81760 J ine R. Davey, Esq., Id. No. 87077 uren 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 207916 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 Plaintiff v JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-5848-CIVIL-TERM CUMBERLAND COUNTY TO: PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, INCORPORATED 752 VALLEY STREET ENOLA, PA 17025-1618 DATE OF NOTICE: September 23, 2009 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 APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. PHS # 207916 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street 1 Carlisle, PA 17013 J (717) 249-3166 /La,krence 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 eau e R. Davey, Esq., Id. No. 87077 n 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 207916 FILED- i UE OF THE ; ?S^`??TRY 2009 OCT -9 PH 12: 24 -+lccc> Po AT" e a31 (P15 , I (Rule of Civil Procedure No. 236) - Revised U.S. BANK NATIONAL ASSOCIATION AS CUMBERLAND COUNTY TRUSTEE FOR RASC 2005KS8 VS. COURT OF COMMON PLEAS JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/KIA FRANCES J. MCKEEFERY PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA MCKEEFERY, A/K/A FRANCES J. MCKEEFERY, DECEASED CIVIL DIVISION : No. 09-5848-CIVIL-TERM Notice is given that a Judgment in the above captioned matter has been entered against you on /o p By: $Er= If you have any questions concerning this made )please contact: I Lawren eEy.. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquir Jenne 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 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 ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINSTPROPERTY. ** AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 PHS # 207916 DEFENDANT SERVICE TEAM! iin JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL COURT NO.: 09-5848-CIVIL-TERM NETWORK, INCORPORATED SERVE JOHNNA L. SEETON AT: 119 SOUTH STREET HARRISBURG, PA 17101 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 06/02/2010 SERVED Served and made known to ~OFINNA L. S1rET~N Defendant on the ~`ilay of ~~, Zoe ~, at a : ~f~, o'clock -~ M., at 1tg 5eu~ CTS ISBJQi 1'~A , in the manner described below: ~ ~ ~ Defendant personally served. t-- -:~;~~ c~ _ Adult family member with whom Defendant(s) reside(s). . ~~ -, ~ ~ ~ Relationship is ~`~ ~~ i , ~ r~ci _ Adult in charge of Defendant's residence who refused to give name or relationship ~ ^ '.: rv -=~ `''' . { _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). N i ~ ~ ~,, c_z _ Agent or person in charge of Defendant's office or usual place of business. ` ~ ` :~ ~ -` _ an officer of said Defendant's company. _ x -~~- " ~ ~? ~~ a .- Other: • `=y _~ ~ Description: Age f'oD s Height ' '~ Weight 17 4 Race W Sex ~ Other ~ '~ - C l> ~~~ Vt_ , a competent adult, being duly sworn according 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 subsc 'bed before me this ~ day l~if~"I{ERLY CURTY of ~l/ , 20(~O , R _ _ N ~~~" `~'\ Y ST TE U AW 7~ERSEY ~atSS10N EXPiRE5 MARCH 7,1013 .. NOT SERVED On the o , 200_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) _ No Answer _ Service Refused Other: Sworn to and subscribed fore me this day ~~ of B y: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No, 32227 Francis S. HalBnan, Esq., Id. No. 62695 Dankl G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shcetal R Shah-Joni, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., {d. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Amlrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., id. No. 90134 ChrLsovalante P. Fliakos, Esq., Id. No.94620 Joshua I. Goklmaq Esq., Id. No. 205047 Courte~,ay R Dunn, Esq., Id. No. 206779 Andrew C. Bramblelt, Esq., ki. No. 208375 r ban 617 hn F K~ ed 6l m~ t 1 d 1 Jo t~ y v S ce 400 Philadelphia, PA 19103-]814 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY U.S. BANK NATIONAL ASSOCIATION A5 TRUSTEE FOR RASC 2005KS8 PHS # 207916 DEFENDANT SERVICE TEAM/_iin JOHNNA L. SEETON PENNSYLVANIA LEGISLATIVE ANIMAL COURT NO.: 09-5848-CIVIL-TERM NETWORK, INCORPORATED SERVE PENNSYLVANIA LEGISLATIVE ANIMAL TYPE OF ACTION NETWORK, INCORPORATED AT: XX Notice of Sheriff s Sale 119 SOUTH STREET SALE DATE: 06/02/2010 HARRISBURG, PA 17101 SERVED ~ ~ IMAI- h ~; PA- I,~Gtst~rtvE ~ ~' Served and made known to dE-rwe ~, tic . ,Defendant on the 2 day of ~ Vim. , _~,i~Od ~ at _ .~-i ~,Z, ~ ~(7, o'clock, M., at l14 Seaot! ~Ji'.~ lSBuAb~ Pk , in the manner described below: __ c~ "~ _ Defendant personally served. ` _ ~ =-:'? r~ , c-; _ Adult family member with whom Defendants} reside(s). - -1= _-r: Relationship is ~"'~ ~ , _ Adult in charge of Defendant's residence who refused to give name or relationship. `~; ~ ~ rn _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. ~TONNN~ SEEreN an officer of said ms's company. Other: Description: Age/{ reps Height_~'!~t_ Weight ~"1~ Race W Sex F Other I, ~J}-r,.d) `V~~ U.~ , a competent adult, being duly sworn according 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 i{1nr1BERLY CURTY s ~s()?ARY Pll9LlC before me this 2~ day STATE OF 1`~w ,FERSEY of ,, 20~ d . CH 7, 2013 1 L/n~ MY C~MN1tSSi0N 6X1'tRES MAR No By: ~-~j ~ G~~L% NOT SERVED On the of , 200_, at o'clock _. M., Defendant NOT FOUND because: Vacant Bad Address No Answer Service Refused Other: Sworn to and subscribed before me this day of ,~~ By: Notary: Moved _ Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lawmnce T. Phelan, Esq., Id. No. 32227 Francis S. HalBnan, Esq., Id. No. 62695 Dankl G. Schmleg, Esq., Id. No. 62205 Michde M. Bradford, Esq., Id. No. 69849 Judith T. Ran,ano, Esq., Id. No. 58745 Shcetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Ilavcy, Fsq., Id. Na 87077 Lauren R. Tabrs, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 66657 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 1. Goldman, Esq., id. No. ZOL5047 Courfenay R. Dunn, Fsq., Id. No. 206779 Andrew C. Brambldt, Fsq., Id. No. 20&;75 pnc Pmn Csvstcr ai Suburban Station SHERIF 'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson. '~ ~~ ~~°'~;~~ Sl1@/1~ 1"C TI } n Jody S Smith ~- '/~ Chief De ut ~~ ~- z ~ ~ A Y n u!>~ ~~ r"~,-~ ~ i~ }~~ ~' . Richard W Stewart ~ F .>~~ Solicitor I !QFFiC~C?FTt~sr£R~Fp ~~~~ -;_ - ;~:~;~;~r i'~ r rr: ~ ~r.,;~; U.S. Bank National Association vs. Case Number Johnna L. Seeon (et al.) 2009-5848 SHERIFF'S RETURN OF SERVICE 03/29/2010 Ronny R. Anderson ,S eriff who being duly sworn according to law, states that he made a diligent search and inquiry for the withi named defendant to wit: Joanna L. Seeton, but was unable to locate her in his bailiwick. He therefore eputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice of ale and Description according to law. 03/29/2010 Ronny R. Anderson ,S eriff who being duly sworn according to law, states that he made a diligent search and inquiry for the withi named defendant to wit: Pennsyvania Legislative Animal Network In Its Capacity as Devisee of the Estat of Frances Joanna McKeffrey, a/k/a Frances J. McKeffery, Decried, but was unable to locate them i his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Rea Estate Writ, Notice of Sale and Description according to law. 04/07/2010 12:59 PM -Michael Ba rick, Deputy Sheriff, who being duly sworn according to law, states that on4/7/10 a' 1259 hours, he posted true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, u on the property of Johnna L. Seeton and Pennsylvania Legislative Animal Network ,located at, 7 2 Valley Street, Enola, Cumberland County, Pennsylvania according to law. 04/23/2010 Dauphin County Retu and now the,21 st day of April 2010, at 1535 hrs, served the within Real Estate Writ, Notice of Sale an Description upon Pennsylvania Legislative Animal Network In Its Capacity as Devisee of the Estate o Frances Joanna McKeffrey, a/k/a Frances J. McKeffery, Decried the defendant, by making known unto ohnna L. Sefton, personally at Dauphin County Sheriffs Office, 101 Market St, Room 104, Harrisburg, ennsylvania its contents and at the same time handing to her a true and correct copy of the same. So A savers: Tina Francis, Deputy, Sheriff of Dauphin, County, Pennsylvania. 04/23/2010 Dauphin County Retur and now the,21st day of April 2010, at 1535 hrs, served the within Real Estate Writ, Notice of Sale an Description upon Johnna L. Sefton, in her capacity as Executrix of the Estate of Frances Joanna McKe frey, a/ka Frances J. McKeffrey, the defendant, by making known unto Johnna L. Sefton, personally at D uphin County Sheriffs Office, 101 Market St, Room 104, Harrisburg, Pennsylvania its contents and at the ame time handing to her a true and correct copy of the same. So Answers: Tina Francis, Deputy, Sheri of Dauphin, County, Pennsylvania. 06/02/2010 Ronny R. Anderson, Sh riff, who being duly sworn according to law, states that after due and legal notice had been given accordi g to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisl ,Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He sold the same for the s m of $78,100.00 to Horizon Residential Loan Servicing, 100 57th Street, Akron, PA 17501, being the bu er in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 2,805.16 07/09/2010 Deed Recorded 7/9/10. SHERIFF COST: $2,805.16 SO ANSWERS, July 14, 2010 RON R ANDERSON, SHERIFF ~-Dl~ R,l_ rte. a ~oo Pd` ~. (c~ CountySuite Sheriff. Teleosott, Inc. SCHEDULE OF DISTRIBUTION Date Filed: 6/23/10 Writ No. 2009-5848 ivil Term U.S. National Associ tion as Trustee for RASC 2005KS8 Vs Johnna L. Seeton, In er Capacity as Executrix of the Estate of Frances Joanna McKeffery, a Frances J. McKeffery Pennsylvania Legisl ive Animal Network, In Its Capacity as Devisee of The Estate of France Joanna McKeffery, a/k/a Frances J. McKeefery, Deceased 752 Valley Street Enola, PA 17025 Sale Date: June 2 2010 Buyer: James Smith, Dietterick & Connelly, LLP Bid Price: $ 78,1 0.00 Real Debt: '; $ 93,907.16 Interest: 3,709.05 Attorney Writ Costs: ~ 190.50 Total Due: $ i 97,806.71 DISTRIBUTION: Receipts: Cash o Account (02/09/2010): $ 1,500.00 Cash o Account (06/02/2010): 7,810.00 Cash o Account (06/18/2010): 75,025.56 Total Receipt: $ 84,335.56 Disbursements: Sheri s Costs Legal earch Trans r Tax State Trans r Tax Local East P sboro Township (Sewer/Water) Atto y Daniel Schmieg U.S. ational Association as Truste for RASC 2005I{S8 Total Disbur ements: Balance for istribution: So Answers: onny R. Anderson Sheriff } a~ :, d i ~ ~:i 2,505.16 300.00 1,436.78 1,436.78 1,707.50 1,500.00 75,449.34 ($84,335.56) 00.00 ~"~;~r° . t ~, SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cum RE: Sheriffs Sale, W held June 2, 201( EFFECTIVE DATE: J County No. 2009-5848 2, 2010 PREMISES: 752 Valle Street, East Pennsboro Township, Enola, Cumberland County, ennsylvania, Tax Parcel No. 09-12-2992-007D (the "Premises") RECITAL: Being the same premises which Robert C. Shultz, Jr. and Patricia A. Shultz, husband d wife by their Deed dated October 19, 1984 and recorded October 25, 1984 in a Office of the Recorder of Deeds in and for Cumberland County, Pennsylv is in Deed Book "Y", Volume 30, Page 451, granted and conveyed unto Fran es J. McKeefery with said Deed being re-recorded February 29, 1988 in Deed ook "F", Volume 33, Page 125. The Premises ide tified above and as more fully described in the legal description attached hereto and inco orated by reference herein as "Exhibit A" is subject to the below items and exceptions. All reco ding and docket locations identified are in the Office of the Recorder of Deeds of Cumberland C unty and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: 1. 2. 3. 4. 5. Claims and charg s for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. Possible unfiled The rights or cla Support arreara€ 1997, as amendE Any environmei Liens and municipal claims, charges and assessments. of any tenants or other parties in possession. of any owner or previous owner of the Premises pursuant to Act 58 of liens or claims filed or on record in the Federal District Court. + .~ 6. Payment of state d local real estate transfer tax, if applicable. 7. Any secured tran actions with respect to the Premises. 8. The area of the P emises is not certified. 9. Those matters w 'ch a view or inspection of the Premises would reveal. 10. The accuracy of a measurements and dimensions of the Premises or the rights or title of or through any p rson or persons in possession of same, conflicts with adjoining property, encroa hments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not o record at the Court House as of the effective date of this Title Report and subsequent t the date hereof. 13. Any tax increase ased on additional assessment made by reason of new construction or major improvem nts. 14. The absence or f ilure of proper and required notice being given to all owners and holders of liens d encumbrances intended to be divested by the Sheriff s sale and procedural defec by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriff s sale noted above. 15. Identity and leg competency of all parties at any closing or conveyance of the Premises should be establi hed. 16. Access to the Pre 17. Suitability or exi; certified. 18. ~al Estate taxes the Tax Claim Bi 19. ` ~l'Real Estate tc /taxes accruing on 20. Subject to the spc by public road or street is not certified. of sewer and water facilities on or available to the Premises is not the Premises due and payable but not turned over for collection to yes on the Premises assessed but not billed as well as those Real Estate and after January 1, 2010. usal rights, if any, of any spouse of Frances J. McKeefery. -2- - 21. Subject to the subject real es 22 23. 24. ~1 operation and effect of the absence of a legal description of the for purposes of the Sheriffs Sale. Subject to the lie of any inheritance tax or estate tax due the Commonwealth of Pennsylvania as result of the death of Frances J. McKeefery on Mazch 6, 2009. Subject to the ri is of any heirs or devisees under the Last Will and Testament of Frances J. McKe fery or as applicable under instate law. Subject to the li of any and all amounts due the Pennsylvania Department of Public Welfare, Estate ecovery Program. ~. Mortgage in the ount of $88,000.00 from Frances J. McKeefery to New Century Mortgage Co. da ed June 14, 2005 and recorded July 15, 2005 in Mortgage Book 1914, Page 4225, last signed July 1, 2009 in Instrument No. 200922474 to U.S. Bank, N.A. 26. Mortgage in the Authority of Cu Mortgage Book 201003233 to S~ 201012647 to tl~ `~ 27. Judgment again: \~`, Johnna L. Seeto Estate of France J. McKeefery, l; ~~2~09 to No. 200 mount of $20,000.00 from Frances J. McKeefery to Redevelopment iberland County dated May 20, 2005 and recorded June 10, 2005 in 910, Page 2225, assigned February 5, 2010 in Instrument No. wart Title Guazanty Co., subordinated May 18, 2010 in Instrument No. mortgage identified in item 25, above. Frances J. McKeefery in the amount of $93,907.16 and also against Executor or Executrix for the Estate of Frances Joanna McKeefery, the J. McKeefery, Pennsylvania Legislative Animal Network and Frances ceased, in favor of US Bank, National Association entered October 9, -5848 with respect to the Mortgage identified in item 25, above. 28. Judgment again Frances J. McKeefery in the amount of $1,970.47 entered July 12, 2006 in favor of Capi 1 One Bank to No. 2006-2950. 29. 30. 31. Judgment agains Frances J. McKeefery in the nature of a municipal lien in the amount of $1,168.50 entere December 3, 2008 in favor of East Pennsboro Township to No. 2008- 7079. Subject to all bui ding setback lines, easements, notes, conditions, restrictions and all other matters app aring on the Plan of Regent Construction Co. recorded in Plan Book 23, Page 20. Subject to the 25 foot sewer easement as shown on the Plan cited in Deed Book "N", Volume 25, Page 385. -3- ~ r ~ r 32. Subject to the rig~ts granted PPL in Misc. Book 192, Page 398. 33. Subject to the rig 286. 34. Subject to the rig adjoining Valley The undersigned other than the Sheriff of hts granted Riverton Consolidated Water Co. in Misc. Book 197, Page hts of others in and to that portion of the Premises lying within or Street. shall not be bound by this Title Report to any person, firm or entity Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -4- . . Writ No. 2009-5848 Civil U.S. Bank National Association as Trustee Successor in Interest to State Street Bank and Trust, as Trustee for Mortgage Pass-Through Certificates, 2001-MS1 vs. Johnny L. Seeton, Pennsylvania Legislative Animal Network In its Capacity as Devisee of the Estate of Frances Joanna McKeefery, a/k/a Frances J. McKeefery, Deceased Atty: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-5848-CIVIL-TERM, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 vs. JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA McKEEFERY A/K/A FRANCES J. McKEEFERY, PENNSYLVANIA LEG- ISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA McKEEFERY A/K/A FRANCES J. McKEEFERY, DECEASED, owners of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumber- land County, Pennsylvania, being 752 VALLEY STREET, ENOLA, PA 17025-1618. Parcel No. 09-12-2992-007D. improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $93,907- .16. EXHIBIT A .:. U.S. INK NATIONAL ASSO IATION AS TRUSTEE COURT OF COMMON PLEAS FOR SC 200SKS8 ... ~ , Plaintiff CIVIL DIVISION ~• N0.09-5848-CIVIL-TERM JOHNNA L. SEETON, IN HE CAPACITY AS EXECUTRIX CUMBERLAND COUNTY OF THE ESTATE OF FRANC S JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEF RY PENNSYLVANIA LEGISLAT VE ANIMAL NETWORK, IN ITS CAPACITY AS DEVIS E OF THE ESTATE OF FRANCES JOANNA MCKEE ERY A/K/A FRANCES J. MCKEEFERY, DECEASED. Defendant(s) 3 .U.S. BANK NATIONAL ASS Cl[ATION AS TRUSTEE FOR RASC 2005KS8, Plaintiff in the above action, by the undersigned attorney, sets forth as of the the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 752 VALLEYS ET, ENOLA, PA 17025-1618. 1. Name and address of Owner(s) o reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JOHNNA L. SEETON, IN H R CAPACITY AS 119 SOUTH STREET EXECUTRIX OF THE ESTA E OF FRANCES HARRISBURG, PA 17101 JOANNA MCKEEFERY A FRANCES J. MCKEEFERY PENNSYLVANIA LEGISLA IVE ANIMAL 119 SOUTH STREET NETWORK, ]IN ITS CAPAC AS DEVISEE HARRISBURG, PA 17101 OF THE ESTATE OF FRAN ES JOANNA MCKEEFERY A/K/A FRAN ES J. MCKEEFERY, DECEASED. 2. Name and address of Defendant( in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last Irnown address of very 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) CAPITAL ONE BANK 6851 JERICHO TURNPIKE; #190 SYOSSET, NY 11791 CAPITAL ONE BANK 436 SEVENTH AVENUE; SUITE 1400 C/O: JAMES C. WARMBRO T, ESQUIRE PITTSBURGH, PA 15219 4. Name and address of last recorde holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) REDEVELOPMENT AUTHO OF THE 114 NORTH HANOVER STREET COUNTY OF CUMBERLAND, A ODY CARLISLE, PA 17013 POLITIC AND CORPORATE A EXISTING UNDER THE LAWS OF THE CO ONEWELATH OF PENNSYLVANIA 5. 'Name and address of every Uth r person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 6. EAST PENNSBORO Name and address of every sale. Name None. 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 person who has any record interest in the property and whose interest may be affected by the Address (if address cannot be reasonably ascertained, please indicate) 7. _f Name and address of every be affected bx the sale`. Name TENANT/OCCUPANT Domestic Relations of Cumberland County -Commonwealth of Pennsyl Department of Welfare Commonwealth of Pennsyl Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program person of whom the plaintiff leas knowledge who has any interest in the property which may Address (if address cannot be reasonably ascertained, please indicate) 752 VALLEY STREET ENOLA, PA 17025-1618 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept 28061 Harrisburg, PA 17128 13TH Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 JOHNNA L. SEETON, IN ] AS EXECUTRYX OF THE FRANCS JOANNA MCK FRANCES J. MCKEEFER C/O: ANDREW C. SHEEL PENNSYLVANIA LEGISI NETWORK, IN ITS CAPA OF THE ESTATE OF FRA MCK:EEFERY A/K/A FRA MCKEEFERY, DECEASE C/O: ANDREW C. SHEEL I verify that the statement knowledge or information and be of 18 Pa. C.S.A. § 4904 relating December 17, 2009 . CAPACITY 'ATE OF 'ERY A/K/A ESQUIRE .TINE ANIMAL ITY AS DEVISEE CES JOANNA CES J. ESQUIRE 127 SOUTH MARKET STREET P.O. BOX 95 MECHANICSBURG, PA 17055 127 SOUTH MARKET STREET P.O. BOX 95 MECHANICSBURG, PA 17055 made in this affidavit are true and correct to the best of my personal ief. I understand that false statements herein are made subject to the penalties o unsworn falsification to authorities. By: rhela Hal nan & Schm' g, LLP ^ enc T. Phel sq., Id. No. 32227 ^ Francis S. ,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 ^ J ime McGuinness, Esq., Id. No. 90134 hrisovalante 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 U.S. BANK N~TIONA,L RASC 2005KS8 ' TION AS TRUSTEE'~'OR COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff N0.09-5848-CIVIL-TERM JOANNA L. SEETON, IN HER OF THE ESTATE OF FRANCI A/K/A FRANCES J. MCKEEFI PENNSYLVANIA LEGISLATI ITS CAPACITY AS DEVISEE ~ FRANCES JOANNA MCKEEF MCKEEFERY, DECEASED. APACITY AS EXECUTRIX JOANNA MCKEEFERY Y ANIMAL NETWORK, IN ~' THE ESTATE OF tY A/K/A FRANCES J. CUMBERLAND COUNTY Defendant(s) TO: JOHNNA L. SEETON, ] AS EXECUTRIX OF Tl FRANCES JOANNA M FRANCES J. MCKEEF 119 SOUTH STREET HARRISBURG, PA 171 HER CAPACITY PENNSYLVANIA LEGISLATIVE ANIMAL ESTATE OF NETWORK, IN ITS CAPACITY AS DEVISEE :EEFERY A/K/A OF THE ESTATE OF FRANCES JOANNA :Y MCKEEFERY A/K/A FRANCES J. MCKEEFERY, DECEASED. 119 SOUTH STREET HARRISBURG, PA 17101 * *THIS FIItM IS A DEBT COLLE OR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURP SE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD N BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENF RCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 7 2 VALLEY STREET, ENOLA, PA 17025-1618 is scheduled to be sold at the Sheriil's Sale on 06/02/2010 at 0:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the urt judgment of $93,907.16 obtained by U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE F R RASC 2005KS8 (the mortgagee) against you. In the event the sale is continued, an announcement will b made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be cancele~if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To nd out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop if the judgment was improperly ent~ 3. You may also be able to sale by filing a petition asking the Court to strike or open the judgment, .. You may also ask the Court to postpone the sale for good cause. stop the sale through other legal proceedings. You may need ~n attorney o assert your rights. The sooner you contact one, the more chance you will have of stopping the sale: ESee riot ce on page two on how to obtain an attorney.) MAY AKE 1. If the Sheriff s Sale is not stop ed, 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 th~ 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 i the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-5 3-7000. 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 ime, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share distribution of the money bid for ; the sale. The schedule shall be ke office. This schedule will state w with this schedule unless exceptia within ten (10) days after the filin 7. You may also have other rights after the sale. YOU SHOULD TAKE THIS P. LAWYER OR CANNOT AFF( TO FIND OUT WHERE YOU f the money which was paid for your house. A proposed schedule of cur house will be prepared by the Sheriff not later than thirty (30) days after ton file with the sheriff and will be made available for inspection in his ~ will be receiving that money. The money will be paid out in accordance s (reasons why the proposed distribution is wrong) are filed with the Sheriff of the proposed schedule. defenses, or ways of getting your home back, if you act immediately [t TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW GET LEGAL HELP. ND COUNTY BAR ASSOCIATION LAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 By virtue of a Writ of Exec U.S. BANK NATIONAL vs. JOHNNA L. SEETON, IN JOANNA MCKEEFERY ~ PENNSYLVANIA LEGIS] THE ESTATE OF FRANC DECEASED. SHORT DESCRIPTION x ion N0.09-5848-CIVIL-TERM SSOCIATION AS TRUSTEE FOR RASC 2005KS8 :R CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JA FRANCES J. MCKEEFERY TIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF ~ JOANNA MCKEEFERY A/K/A FRANCES J. MCKEEFERY, owner(s) of property situat in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, bei g (M icipality) P (Acs Improvements thereon: P JUDGMENT AMOUNT: Phelan Hallinan & Schmieg, Ll Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 or street address) )ENTIAL DWELLING ,907.16 i • ' ~ LEGAL DESCRIPTION ALL THAT CERTAIN pi a or parcel of land, situate in the East Pennsboro Township, Cumberland County, Pennsylvania, mo particulazly bounded and described as follows, to wit: BEGINNING at a point o the southern side of Valley Street (50 feet wide) at corner of Lot No. 3 on the hereinafter mentioned lan of Lots; thence by Valley Street North 68 degrees O 1 minutes 00 seconds East a distance of 80 feet to a point at Lot No. 5 on said Plan; thence by Lot No. 5 South 21 degrees 59 minutes East a istance of 128.12 feet to a point at Lot No. 361 on the Plan of Louis Pazk; thence by Lot No. 361 an Lot No. 360 on the Plan of Louis Pazk South 58 degrees 04 minutes 00 seconds West a distance o 81.22 feet to a point at Lot No. 3 on the hereinafter mentioned Plan; thence by same North 21 egrees 59 minutes West a distance of 142.15 feet to a point, the Place of BEGINNING. BEING Lot No. 4 on a Pl made by Gerrit J. Betz, R.S., Mechanicsburg, Pennsylvania, for Regent Constructions Company ted Apri128, 1972 and recorded in Cumberland County Plan Book 23, Page 20. CONTAINING 10, 810 sduare feet. HAVING THEREON ere~ted a dwelling house known and numbered as Valley Street. UNDER AND SUBJECT Ito a twenty-five foot minimum building setback line as shown on said Plan. UNDER AND SUBJECT ~to a twenty-five foot sewer easement as shown on said Plan. TITLE TO SAID PREMI ES IS VESTED IN Frances J. McKeefery, by Deed from Robert C. Schultz, Jr. and Patricia .Schultz, his wife, dated 10/19/1984, recorded 10/25/1984 in Book 33- F, Page 125. Note: Frances J. McKee ery has since departed this life. Estate info is listed below. PREMISES BEING: 752 GALLEY STREET, ENOLA, PA 17025-1618 PARCEL NO. i WRIT OF EXECUTION and/or ATTACHMENT . ~- i COMIktONW)ALTH O PENNSYLVANIA) N009-5848 Civil COUNTY OF CUMBE AND) CIVIL ACTION -LAW TO THE SHERIFF OF UMBERLAND COUNTY: To satisfy the debt, ' terest and costs due U.S BANK NATIONAL ASSOCIATION AS TRUSTEE FOR 205KS8 Plaintiff s) From JOHNNA L. S ETON, 1N HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA CKEEFERY A/K/A FRANCES J. MCKEEFERY,~PENNSYLVANIA LEGISLATIVE ANIM L NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA CKEEFERY A/K/A FRANCES J. MCKEEFERY, DECEASED. (1) You are directed to ry upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also direct to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as foil s: and to notify the garnish e(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for he account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposin thereof; (3) If property of the de endant(s) not levied upon an subject to attachment is found in the possession of anyone other than a n ed 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$93,907.16 L.L.$.50 Interest FROM 10/09/2 09 TO DATE OF SALE ($15.65 PER DIEM) - $3,709.05 Atty's Comm % Due Prothy $2.00 Atty Paid $190.50 Other Costs Plaintiff Paid Date: December 23, 200 ~ ~ K, Curtis R. L on g, Prothon o tary (Seal) ( ~ / ~ BY~ ,~C a„~.~- ~f- e~ Deputy REQUESTING PARTY: Name JOSHUA I. GOL MAN, ESQ. Address: PHELAN HAL INAN & SCHMIEG, LLP, 1617 JFK BOULEVARD, SUITE 1400, ONE PENN CENTER PLAZ ,PHILADELPHIA, PA 19103 Attorney for: PLAINTIF Telephone: 215-563-7000 Supreme Court ID No. 20 047 1 ~ • ~ ~ On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 752 Valley Street, Enola, more fully described on Exhibit "A" filed .with this writ and by this reference incorporated herein. Date: March 22, 2010 By: C Real Estate Coordinator h S .g d 8 Z X30 6001 ~.~1~3H~S 3y1~~-'~ ~ ;,' ~~l~f_~r- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL er Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH QF PENNSYLVANIA ss. COUNTY OF Lisa Marie Coy e, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being d y sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodic published in the Borough of Cazlisle in the County and State aforesaid, was established January , 1952, and designated by the local courts as the official legal periodical for the public tion of all legal notices, and has, since January 2, 1952, been regulazly issued weekly in the sai County, and that the printed notice or publication attached hereto is exactly the same as was Tinted in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, April 23, and Apri130, 2010 Aff~ant further Law Journal, a legal pf matter of the aforesaid statements as to time, that he is authorized to verify this statement by the Cumberland of general circulation, and that he is not interested in the subject ice or advertisement, and that all allegations in the foregoing and character of publication aze true. ,-- isa Marie Co ,Editor SWORN TO AND SUBSCRIBED before me this 30 da of Aril 2010 / Notary ~..~ NOTARIAL SEAL DEBORAH A COLLINS Notur Public CARLISLE BOROUGH, CUMSERLANO COUNTY AAI- Conlmh~ion Expins Apr 28.201 ~t M. fM~-NM CM U.$. Bank National Association as Trustee Successor in Interest to State Street Bank and Trust, as Trustee for Mortgage Pass-Through Certificates, 2001-MS1 vs. Johnna L. Seeton, Pennsylvania Legislative Animal Network In its Capacity as Devisee of the Estate of Frances Joanna McKeefery, a/k/a Frances J. McKeefery, Deceased Atty: Daniel G. Schmieg By virtue of a Writ of Execution NO. 09-5848-CIVIL-TERM, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RASC 2005KS8 va. JOHNNA L. SEETON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF FRANCES JOANNA McKEEFERY A/K/A FRANCES J. McKEEFERY, PENNSYLVANIA LEG- ISLATIVE ANIMAL NETWORK, IN ITS CAPACITY AS DEVISEE OF THE ESTATE OF FRANCES JOANNA McKEEFERY A/K/A FRANCES J. McKEEFERY, DECEASED, owners of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumber- land County, Pennsylvania, being 752 VALLEY STREET, ENOLA, PA 17025-1618. Parcel No. 09-12-2992-007D. Ei~e~: ~- TIAL DWELLItit}. JUDQ6tENT AI~UNT: X93,907- .16. ilk : t6i(YII1 ~ i7:t tJH k~ ;t;rt, 'i E ,~:t,' ~ i~ %i .C_ r~ ,r?A `: Viz: •~P ~ 9 ~'~G ::z't~etr~~rrti..,: ~r 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 c21~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: 04/16/10 04/23/10 ~jj~~•--~ ~ 04/30/10 /r, Sworn to and subscribed before me this 18'day f May, 2010 A.D. .~,~ ~ ~ ~ t ~, ~ , t ,` .. - _ Notary Public ~~`_ COMMONWEALTH OF PEWNSYLVANLA Nott-lel 5pl Sherrie L. Kfiner, Notary Punic Lower Paxton'R~vp,, DauAhkt County My Commisslpn Explnas Nov. 25, 2011 Member, PennslManla Association of Notaries Writ No. 2000~S9s8 ChrH Term us. 9.nk N Assoastlon ~ llruwe Suooasor In tntsrsst to State Steset Bank. and Must, as Trustee -for Mortgage Pass-Through Certlficattes, # 2001-MS1 vs. Johnna L. Seaton pennsyhranla Legislative Animal Network In its Capacity as Devisee of the Estate of Frances Joanna MciCestery, aAcM Francs J. McKeefarY, t)eosased Atty: tl~anlel G Schmleg By virtue of a Writ of Execution N0.09-5848- CIVIL-TERM U.S. BANK NATIONAL ASSOCIATION A5 TRUSTEE FOR RASC 2005KS8 vs. JOANNA L. SEETON, IN HER CAPACITY AS EJO:CITTRIX OF THE ESTATE OF FRANCES JOANNA MCKEEFERY A/K/A FRANCES- L MCKEEFERY PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK, IN -ITS CAPACITY AS DEVISEE OF THE ESTATE OE FRANCES JOANNA MCKEEFERY A!K/A FRANCES J. MCKEEFERY, DECEASID. owner(s) of property situate in the TOWNSHIP OF EAST pFSINSBORO, Cumberland County, Pennsylvania,being(Municipaiity) 752VALLEY STREET, ENOLA, PA 17025-1618 Parcel No. 09-12-2992-0(17D (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: 593,907.16 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 HORIZON RESIDENTIAL 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 23RD day of DEC, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 5848, at the suit of RASC 2005KS8 TR against FRANCES JOANNA MCKEEFERY AKA FRANCES J EXTRIX & PENNSYLVANIA LEGISLATIVE ANIMAL NETWORK is duly recorded as Instrument Number 201018495. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this y day of of Deeds