HomeMy WebLinkAbout09-666510 AMH:LFG 524569.1 (00308.061 ) 10/5/09
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. CR-to(0(05 0,-Iyil Iex+k
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
TO THE WITHIN DEFENDANTS:
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 defense 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.
AMH:LFG 524569.1 ( 00308.061 ) 10/5/09
Cumberland County Bar Association
Lawyer Referral Service
32 S. Bedford Street
Carlisle, PA 17013
Telephone:
Date: i o u f
(717) 249-3166
(800) 990-9108
n
J
Angela 4 olt, Esquire
Attorneys for Plaintiff
2
AMH:LFG 524569.1 ( 00308.061 ) 10/5/09
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. 0 9 G 66 -5 ( 7
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
Plaintiff, Stonemill Property Management, by and through its counsel, Angela M. Holt,
Esquire and Blakinger, Byler & Thomas, P.C., hereby files this Complaint, and in support thereof,
avers as follows:
1. Plaintiff is Stonemill Property Management, a registered fictitious name with an
address of P.O. Box 506, Elizabethtown, Pennsylvania 17022.
2. Defendant Lori Shumberger is an adult individual with a last known address of
Trindle Mobile Home Park, 19 Lois Lane, Mechanicsburg, Pennsylvania 17050.
3. Defendant Alan Shumberger is an adult individual with a last known address of
Trindle Mobile Home Park, 19 Lois Lane, Mechanicsburg, Pennsylvania 17050.
4. Upon information and belief, Defendants Shumberger are the current titleholders of
a 1983 Skyline mobile home unit, Model Number 0 11102995, located in the Trindle Mobile Home
AMH:LFG 524569.1 ( 00308.061 ) 10/5/09
Park, 19 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania (the "Property"). A true and
correct copy of the Pennsylvania Department of Transportation Vehicle Record Abstract for the
Property is attached hereto and incorporated herein as Exhibit "A".
5. In 2003, Defendants Shumberger failed to pay real estate taxes on the Property. A
true and correct copy of the Tax Claim Inquiry issued by the Cumberland County Tax Claim Bureau
is attached hereto and incorporated herein as Exhibit "B".
6. In 2004, Defendants Shumberger failed to pay real estate taxes on the Property. A
true and correct copy of the Tax Claim Inquiry issued by the Cumberland County Tax Claim Bureau
is attached hereto and incorporated herein as Exhibit "B".
7. In or about late 2004, Defendants Shumberger abandoned the Property.
8. As of June 3, 2005, Defendants Shumberger had an outstanding tax claim of $335.44.
9. On or about June 2, 2005, Stonemill Property Management paid Defendant
Shumbergers' outstanding tax balance for the year 2003 in the amount of $176.07.
10. On or about June 2, 2007, Stonemill Property Management paid Defendant
Shumbergers' outstanding tax balance for the year 2004 in the amount of $159.37.
11. On May 18, 2005, Stonemill Property Management sent a letter to Defendant Alan
Shumberger seeking release of the Property and requesting that Defendant forward the signed and
notarized title for the mobile home unit. A true and correct copy of the May 18, 2005 letter is
attached hereto and incorporated herein as Exhibit "C".
12. Defendant Alan Shumberger failed to respond to the May 18, 2005 correspondence.
13. As evidenced by the Vehicle Record Abstract, John Hanson Savings Bank FSB
("John Hanson") is a lienholder of record against the Property.
2
AMH:LFG 524569.1 ( 00308.061) 10/5/09
14. Upon information and belief, as of April 26, 1991, John Hanson is no longer in
existence or conducting business. A copy of the FDIC Institution Directory Report for John Hanson
is attached hereto and incorporated herein as Exhibit "D".
15. As evidenced by the FDIC Institution Directory Report, John Hanson went into
receivership. The Federal Deposit Insurance Corporation was appointed as receiver.
16. On August 27, 2009, counsel for Stonemill Property Management sent a facsimile
to the FDIC Division of Resolutions and Receiverships requesting a release of the lien against the
property. A copy of the August 27, 2009 facsimile is attached hereto and incorporated herein as
Exhibit "E".
17. On September 9, 2009, the FDIC Division of Resolutions and Receiverships sent an
Affidavit of Lien Release to counsel for Stonemill Property Management releasing and discharging
all liens and encumbrances on the Property. A copy of the Affidavit of Lien Release is attached
hereto and incorporated herein as Exhibit "F".
18. Despite the Affidavit of Lien release, the lien remains of record with the Department
of Transportation.
19. Pursuant to § 505 of the Mobile Home Park Rights Act, the Property has since been
relocated to the National Village Mobile Home Park, Union County, Pennsylvania.
WHEREFORE, Plaintiff Stonemill Property Management respectfully requests that this
Court, pursuant to Pennsylvania Rule of Civil Procedure 1066, order as follows:
a. that the lien held by John Hanson Savings Bank be decreed satisfied and discharged;
3
AMH:LFG 524569.1 ( 00308.061 ) 10/5/09
b. that after reasonable notice and opportunity for hearing having been provided to all
interested parties, ownership of one 1983 Skyline mobile home bearing Model
Number 011102995, be awarded to Stonemill Property Management;
C. that the Defendants and any person claiming through the Defendants be forever
barred from asserting any right, lien, title or interest in the property inconsistent with
the interest or claim of Plaintiff Stonemill Property Management;
d. that, absent the filing of an Answer or Objection, the Prothonotary shall be authorized
to enter final judgment in favor of Plaintiff Stonemill Property Management upon the
Plaintiff's filing of a Praecipe so requesting;
e. directing that the Department of Transportation may accept this Order as evidence
of ownership in lieu of a Certificate of Title;
f. directing Plaintiff Stonemill Property Management to submit the appropriate forms,
taxes and fees and comply with any other procedures of the Department of
Transportation in order to receive the appropriate Certificate of Title for the property.
BLAKINGER, BYLER & THOMAS, P.C.
Date: S By; i QJ9L kt, ' L
M. Holt, sq 're
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for the Plaintiffs
4
AR/3
VERIFICATION
I, IRVIN H. PEIFER, verify that I am a p do W in Stonemill Property hem, owner
and operator of Tnndle Mobile Hone Park, and, as such, I am authorized to make this verification
on behalf of the proprietorship and that the staffs made in the foregoing Complaint are true and
correct. I understand that false statements made herein are subject to the penalties of 18 Pe.C.S.A.
§ 4904, felating to unswmn hIsi6catim to authorities.
. Peifer
Dated: -67h A _, 2009
i
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
7/21/09 13:56
PAGE 1
OWNER LORI A SHUMBERGER
19 LUIS LANE
TRINDLE MHP
MECHANICSBURG PA 17055
TITLE NUMBER 34793834
TAG NUMBER
VIN 01110299S
MAKE SKYLINE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS YES
STOPS NO
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
LIEN INFORMATION
LIEN HOLDER NO. 1
NAME : JOHN HANSON SAVING BANK
ADDRESS: P 0 BOX 15170
KNOXVILLE TN 37901
NO 2ND OR 3RD LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
092020277000380 002
LESSEE NONE
TITLE DATE : 11/22/82
REGISTRATION EXPIRY DATE:
BODY TYPE MH
ODOMETER READING
*ACTUAL MILEAGE
DUPLICATE TITLE COUNT 1
VEHICLE YEAR 1983
STOLEN DATE
EXPIRATION DATE: 09/26/21
ABA NO :
ELT IND:
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TDD IN STATE 1-800-228-0676
TDD OUT-OF-STATE 717-412-5380
WWW.DOT.STATE.PA.US
L.L.P7SS 1..^17 Y t iai L?LH-?
/03/252)5 09:25
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C3A8;J-tI A:iD CO Lugr"- 'SAX C"XiM =Rm?u
,91949050]2005 am COUR17i0C38 S74AP-M
CL?1656 717 240-5354
PWNS
5/0312005 CARLZSL-, PA 17013 FAX
FAQ( 717 290-6354
TAX CLAIM IXQUIRY
•..»••+» DIET/CTL SO 6490 R 3 H A R K S
SHUMSLR=, ALAN ST -19 LOIS LANE 1l
19 LOTS LAN3
l4SCl3P1CICSBURO PA 17050 - MoBILB HOME PARK
DUSC -LOT 19
.Mobile Hama - 240 Land
C=RT WL-R/C
495105
1D-IMPDSN TOMNSHIP
160-CUH93ALAW VALLEY S.D. BOOK/PACE CELT MAIL-SALE 1501904
MAp NO 10-22-0525-021 TR09304
21 LANG USE T
STATUS C % = E 9,610 VALUE C&G 2,210
RU A= INT ADDSD
RL-_zIYY
TAX FVMLTY 2V TERM Cygs PAY1tEM'!8 DUE Emm MO
15
0 3 CODE M SCRIPTION NO
' 14.65 1.97 2.55 14.18 .01
1
01/21/04 200 CTY-NAMPM
.
99 .10 .17 1.26 .01
01121/04 250 743- ? T°'P 92 .19 .17
1 2.25 n .99
01121/04 300 MUR-IDJOTM T
00 8C1-CM0MX?wM V311Y .
11,22
69.30 8.83 ... 106.35
......
1
01/22/04 4
2003 TAX TOTAL 136.07 / (
15.00
01/21/04 201 Y1LMIG FEE 5.00
02/23/04 202 POSTAGE RST & CLAIM 20.00
04/20/04 204 POSTIIgG RE t"/CLAIM -- -------
2003 FEE TOTAL 40.00
(2002 Ym TCTALS # SALANCE
SD--RFALAxcr DUE NEXT NO11T4i
t,* .00
176.07 176.07,/ .33
176.90
- - - - - -
EST
,
_ - - - - - - - - - - - - - - - .75
• •01/19/05 200 C7Y-HAMPO= T" 20.95 2 - - - - - - - - - -
23-. 47
2.20 - -
.15
.01
01113105 250 LIB-HAWORS WP .20
1
95 .1D .05
92 .19 .OS
1
2.16 .01
i4
01/19/DS 300 MON-HAMPDER T" .
.
04 9.80 3.70
98
111.54
01130105 400 SQ1-CUMB Va11Y --
. -
2004 TAX TOTAL 139.37
15.00
01/19/05 201 FILING r= S.00
02/03/05 202 POSTAGS RXT a CLAIM
05/05/05 204 POSTING F3TURN/CLAIM - --------
2006 FS8 TOTAL 20.00
91
?
' 2004 TOTALS & BALANCE
g • *DUB NEXT MOM 159.37 .00 .
159.37
- - -
iso?2a
. _ - - - - - - - - - - - - - - - - 'CLAIM TOTALS - - - - - - - - - -
-335 44 .00 - - -
335.49 1.74
Zs,rIMATBD TOTAL DUE NEXT MOS4TH -
- - - - - - - - - - - - - - - - -' - - -
MISC RECITPTS - - - - - - - - - - - - - - - - - - -
Stonemill Property Management
P.O. Box 505, Eliz;lbethtuwn, PA 17022-0506
Phone: (717) 367-5109 a Fax: (717) 361-7425
May 18, 2005
Alan Shumberger
Trindle MHP
i.
19 Lois Lane j s
Mechanicsburg, PA] 17050
Dear Mr. Shumberger:
RE: 1983 Skyline Model #011102995, Lot 19 Lois Lane, Trindle Mobile Home Park
I am writing to confirm that you, Alan Shumberger, no longer have any interest in
the mobile home referred to above and that you are hereby releasing the mobile home to
Stonemill Property Management. 11' you receive this letter and agree that this is a true
statement, please acknowledge by sending the signed and notarized title to Stonemill
Property Management at the address shown above.
Sinccrely.
STONEN.a. 1, PROPERTY MANAGEMENT
Irvin H. Peifer,
Owner
.. IHPLiaa
Complete items 1, 2, and 3. Also complete
it•`m 4 if Restricted Delivery is desired.
t int your name and address on the reverse
s that we can return the card to you.
1 ach this card to the back of the mailpiece,
or on the front if space permits.
Article Addressed to:
?V L'VCOCA -
A. Signature
X 4;'4e' ? Agent
? Adore
B. Received by (Printed Name) D. Date of Dell
D. Is delivery address different from item 17 ? Ye:
If YES, enter delivery address below: ? No
3. Semite T pe
1 n ?{ rw f n r+7 Express Mail
! ! i ! ? ?°t L] Return Receipt for Merchandise
--Z-Insured M4V ' -f7.?0:D...._. --
4, Restricted Delivery? (axtra Fee) ? Yes
Number
4193'
^s.'er from service labeo 7003 3110 0000 0703
=cm 881 / Ugujt ?QDI it' i i i Damgsiic Returtt i l i l r i r i Receipt i
102595-02-M-1540
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Blakingei?Bylff&=S, P.C. F A C S I M I L E
To: FDIC Division of Resolutions and Receiverships
Fax: 703-812-1082
From: Angela M. Holt
Date: August 27, 2009
Pages: 1
File: 00308.064
Please be advised that this office represents Stonemill Property Management in matters relating to the
transfer of title for a mobile home unit that has been abandoned. Attached please find documents relating
to a 1983 Skyline Mobile Home Unit bearing VIN # 01110299S that was financed through John Hanson
Savings Bank, located in Knoxville, Tennessee. The mobile home was abandoned in 2004 by the prior
owner, Lori Shumberger. As I understand, John Hanson Savings Bank was closed in 1991. As reflected
on the attached Vehicle Record Abstract, John Hanson Savings Bank remains listed as a lienholder of record
against the title to the mobile home.
Please consider this fax a written request for a Release of Lien. Additionally, please provide any information
regarding the financial institution which currently holds this lien and how I may obtain title to the unit. I
can be reached by telephone at 717-509-7283 or email at amh@,bbt-law.com.
Thank you for your anticipated cooperation in this matter. I look forward to hearing from you.
Since KM.Hovl?
Angela AMH/lfg
CONFIDENTIAL
The information contained in this facsimile message is attorney
privileged and confidential information intended only for the use of
the individual or entity named above. If the reader of this message
is not the intended recipient, you are hereby notified that any
dissemination, distribution, or copy of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify us by telephone and return the original message
to us at the above address via the U.S. Postal Service. Thank you.
From the Desk Of...
Angela M. Holt
Blakinger, Byler & Thomas, P.C.
28 Penn Square
Lancaster, PA 17603
http://www.bbt-law.com
Phone: (717) 509-7283
Fax: (717) 299-9529
Email: amh@bbt-law.com
PE. tiIiSY' VANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
7/21/09 13:56
PAGE 1
092020277000380 002
OWNER LORI A SHUMBERGER LESSEE NONE
19 LUIS LANE
TRINDLE MHP
MECHANICSBURG PA 17055
TITLE NUMBER 34793834
TAG NUMBER
VIN 01110299S
MAKE SKYLINE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS YES
STOPS NO
TITLE DATE : 11/22/82
REGISTRATION EXPIRY DATE:
BODY TYPE MH
ODOMETER READING
*ACTUAL MILEAGE
DUPLICATE TITLE COUNT 1
VEHICLE YEAR 1983
STOLEN DATE
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
LIEN INFORMATION
LIEN HOLDER. NO. 1
NAME : JOHN HANSON SAVING BANK
ADDRESS: P 0 BOX 15170
KNOXVILLE TN 37901
NO 2ND OR 3RD LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
EXPIRATION DATE: 09/26/21
ABA NO :
ELT IND:
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TDD IN STATE 1-800-228-0676
TOO OUT-OF-STATE 717-412-5380
k''WW.DOT.STATE.PA.US
08/27/2009 16:04 FAX 7175091870 BLARINGER,BYLER&THOMAS
[a 001
s TX REPORTS
TRANSMISSION OR
TX/RX NO
RECIPIENT ADDRESS
DESTINATION ID
ST. TIME
TIME USE
PAGES SENT
RESULT
0740
17038121082
08/27 16:04
00'33
2
OR
BsykraTh=LW P.C. FACSIMILE
To: FDIC Division of Resolutions and Receiverships
Fax: 703-812-1082
From: Angela M. Holt
Date: August 27, 2009
Pages: 1
File: 00308.064
Please be advised that this office represents Stonemill Property Management in matters relating to the
transfer of title for a mobile home unit that has been abandoned. Attached please find documents relating
to a 1983 Skyline Mobile Home Unit bearing VIN # 0111 0299S that was financed through John Hanson
Savings Bank, located in Knoxville, Tennessee. The mobile home was abandoned in 2004 by the prior
owner, Lori Shumberger. As I understand, John Hanson Savings Bank was closed in 1991. As reflected
on the attached Vehicle Record Abstract, John Hanson Savings Bank remains listed as a lienholder of record
against the title to the mobile home.
Please consider this fax a written request for a Release of Lien. Additionally, please provide any information
regarding the financial institution which currently holds this lien and how I may obtain title to the unit. I
can be reached by telephone at 717-509-7283 or email at amh(a,bbt-law.com.
Thank you for your anticipated cooperation in this matter. I look forward to hearing from you.
Since ly
Angela M. Hol
AMH/lfg
?VJ [_C
Federal Deposit Insurance Corporation Division of Resolutions and Receivership
1601 Bryan Street, Dallas, TX 75201 Customer Service Department
((888) 206-4662 email: cservicefdicdalfa.fdic.gov
09/09/2009
Blakiner, Byler & Thomas (BB&T)
Attn: Angela M. Holt
28 Penn Square
Lancaster, PA 17603
RECEIVED
SEP 1 4 2009
SUBJECT: FIN# - 1286 -JOHN HANSON FSB
Request Number: 2005962900
Your Reference: 2005962900
Subject: Stonemill Property Management
Blakinger, Byler &
Thomas, P.C.
Dear Angela M. Holt:
Enclosed please find the following original documents pertaining to the above-described asset:
AFFIDAVIT OF LIEN RELEASE
INVOICE
Receipt of this document will not effectuate the release/transfer of the property until the document is filed with the
appropriate Recording Official. The attached document should be filed with the Department of Motor Vehicles.
Please see that this document is properly filed. Duplicate requests for documents will incur a charge of $25.00.
If you have any questions, please call the Customer Service Center toll-free at 888-206-4662. Otherwise, you may
inquire via e-mail, cservicefdicdal(Wdic.gov, please reference your request number. You may also send any future
inquiries to "Customer Service" at the address above.
Sincerely,
Enclosure(s)
(ivy t `` -•-' ?,'t ? `V `_'6,? ?./
Sheila Umeh
FDIC Customer Service
Revised 3/04/03 by K. Willingham
FDICe
Federal Deposit Insurance Corporation
1910 Pacific Avenue, Dallas, TX 75201
(972) 448-6000 (888) 206-4662
Dallas Field Office - Division of Resolutions and Receivership
Customer Service Deaartment
FAX (703) 812-1082 email: CServicedal@fdic.gov
AFFIDAVIT OF LIEN RELEASE
Date: September 9, 2009
State: Pennsylvania Certificate of Title Number: 34793834
On a (Make - Body) SKYLINE - MH Year: 1983 VIN Number: 01110299S
Registered Owner(s): LORI A SHUMBERGER
I, Priscilla Catapat, Authorized Agent, on behalf of the FEDERAL DEPOSIT INSURANCE CORPORATION,
whose address is 1601 Bryan Street, Dallas, Texas 75201, upon Oath, Depose and Say:
The undersigned holder of a lien on the motor vehicle described herein does
hereby state that the lien and encumbrance described in this Affidavit of Lien
Release is released and discharged.
FEDERAL DEPOSIT INSURANCE CORPORATION FEDERAL
DEPOSIT INSURANCE CORPORATION which pursuant to 12
USC Section 1441a (m) (l), succeeded the Resolution Trust
Corporation as Receiver for JOHN HANSON SAVINGS BANK,
FSB, BELTSVILLE, MD ("FDIC").
By: ZS
Name: iscilla Catapat
Title: Authorized Agent
STATE OF TEXAS
COUNTY OF DALLAS
SUBSCRIBED AND SWORN to before me on this September 9, 2009.
SHEBA A. l1MEH
MY COMMISSION EXPIRES
fix AUDW 4, 2012
kc? (ty,
Name: Sheila A. Umeh
Notary Public
Revised 3/02 (Pennsylvania) Affidavit of Lien Release - Vehicle
0
CF ?N r JI-I v TAF?Y
2009 OCT -6 PH 1: 51
CUtylr L- L , y
r %4 --y
:V
*78.50 P.0 AV't
Ce 4-TI O'S
e a.31s31
lk
AMH:LFG 532628.1 (00308.061) 10/12/09
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. 09-6665 Civil Term
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
PLAINTIFF'S MOTION FOR SPECIAL ORDER
DIRECTING SERVICE BY PUBLICATION
Plaintiff Stonemill Property Management, by and through its attorneys Angela M. Holt,
Esquire, and Blakinger, Byler & Thomas, P.C., hereby files this Motion for Special Order Directing
Service by Publication pursuant to Pa.R.C.P. 430(a), stating as follows:
1. Plaintiff brings this Quiet Title Action concerning a 1983 Skyline mobile home unit,
Model Number 011102995, located in the Trindle Mobile Home Park, 19 Lois Lane, Mechanicsburg,
Cumberland County, Pennsylvania. A true and correct copy of Plaintiff's Complaint is attached
hereto and incorporated herein as Exhibit "A".
2. This motion concerns service of Plaintiffs Complaint upon Defendants Lori
Shumberger and Alan Shumberger.
3. The undersigned has attempted to locate the whereabouts of Defendants for purposes
of serving them with a copy of the Complaint. Between August 13, 2009 and September 8, 2009,
AMH:LFG 532628.1 ( 00308.061 ) 10/12/09
the undersigned attempted to determine the whereabouts of the Defendants as set forth in the
Affidavit attached hereto and incorporated herein as Exhibit "B".
4. The undersigned has failed to locate the Defendants or any existing legal
representative of these individuals.
5. Accordingly, service cannot be made pursuant to Pa.R.C.P. 400(a) relating to service
of original process.
6. Under all of the circumstances set forth in Exhibit "B", Plaintiff proposes to serve
Defendants Lori Shumberger and Alan Shumberger by publication under Pa.R.C.P. 430(b)(1). The
publication shall run once in the Cumberland Law Journal and once in The Sentinel.
7. Plaintiff believes that service in such manner will constitute proper and sufficient
service under Pa.R.C.P. 430 and other rules governing service as set forth in the Pennsylvania Rules
of Civil Procedure.
8. No judge has ruled upon any other issue in this matter.
WHEREFORE, Plaintiff respectfully requests that this court enter an order granting Plaintiff
leave to make service of the Complaint on Defendant Lori Shumberger and Defendant Alan
Shumberger pursuant to Pa.R.C.P. 430(a) by publication once in the Cumberland Law Journal and
once in The Sentinel.
BLAMNGER, BYLER & THOMAS, P.C.
Date: B
Angela . Holt, squire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
2
AMH:LFG 524569.1 (00308.061 ) 10/5/09
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
4001
E
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. Cq - tPLA05 0+vit`&1k
v.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
TO THE WITHIN DEFENDANTS:
rr-
CJ
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 defense 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.
AMH:LFG 524569.1 ( 00308.061 ) 1015!09
Cumberland County Bar Association
Lawyer Referral Service
32 S. Bedford Street
Carlisle, PA 17013
Telephone:
Date: 16':? uq
(717) 249-3166
(800) 990-9108
r
-
Cj k-
Angela M. olt, Esquire
Attorneys for Plaintiff
2
AMH:LFG 524569.1 (00308.061 ) 10/5/09
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No.
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
Plaintiff, Stonemill Property Management, by and through its counsel, Angela M. Holt,
Esquire and Blakinger, Byler & Thomas, P.C., hereby files this Complaint, and in support thereof,
avers as follows:
1. Plaintiff is Stonemill Property Management, a registered fictitious name with an
address of P.O. Box 506, Elizabethtown, Pennsylvania 17022.
2. Defendant Lori Shumberger is an adult individual with a last known address of
Trindle Mobile Home Park, 19 Lois Lane, Mechanicsburg, Pennsylvania 17050.
3. Defendant Alan Shumberger is an adult individual with a last known address of
Trindle Mobile Home Park, 19 Lois Lane, Mechanicsburg, Pennsylvania 17050.
4. Upon information and belief, Defendants Shumberger are the current titleholders of
a 1983 Skyline mobile home unit, Model Number 011102995, located in the Trindle Mobile Home
AMH:LFG 524569.1 ( 00308.061) 10/5109
Park, 19 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania (the "Property"). A true and
correct copy of the Pennsylvania Department of Transportation Vehicle Record Abstract for the
Property is attached hereto and incorporated herein as Exhibit "A".
5. In 2003, Defendants Shumberger failed to pay real estate taxes on the Property. A
true and correct copy of the Tax Claim Inquiry issued by the Cumberland County Tax Claim Bureau
is attached hereto and incorporated herein as Exhibit "B".
6. In 2004, Defendants Shumberger failed to pay real estate taxes on the Property. A
true and correct copy of the Tax Claim Inquiry issued by the Cumberland County Tax Claim Bureau
is attached hereto and incorporated herein as Exhibit "B".
7. In or about late 2004, Defendants Shumberger abandoned the Property.
8. As of June 3, 2005, Defendants Shumberger had an outstanding tax claim of $335.44.
9. On or about June 2, 2005, Stonemill Property Management paid Defendant
Shumbergers' outstanding tax balance for the year 2003 in the amount of $176.07.
10. On or about June 2, 2007, Stonemill Property Management paid Defendant
Shumbergers' outstanding tax balance for the year 2004 in the amount of $159.37.
11. On May 18, 2005, Stonemill Property Management sent a letter to Defendant Alan
Shumberger seeking release of the Property and requesting that Defendant forward the signed and
notarized title for the mobile home unit. A true and correct copy of the May 18, 2005 letter is
attached hereto and incorporated herein as Exhibit "C".
12. Defendant Alan Shumberger failed to respond to the May 18, 2005 correspondence.
13. As evidenced by the Vehicle Record Abstract, John Hanson Savings Bank FSB
("John Hanson") is a lienholder of record against the Property.
2
AMH:LFG 524569.1 (00308.061 ) 10/5109
14. Upon information and belief, as of April 26, 1991, John Hanson is no longer in
existence or conducting business. A copy of the FDIC Institution Directory Report for John Hanson
is attached hereto and incorporated herein as Exhibit "D".
15. As evidenced by the FDIC Institution Directory Report, John Hanson went into
receivership. The Federal Deposit Insurance Corporation was appointed as receiver.
16. On August 27, 2009, counsel for Stonemill Property Management sent a facsimile
to the FDIC Division of Resolutions and Receiverships requesting a release of the lien against the
property. A copy of the August 27, 2009 facsimile is attached hereto and incorporated herein as
Exhibit "E".
17. On September 9, 2009, the FDIC Division of Resolutions and Receiverships sent an
Affidavit of Lien Release to counsel for Stonemill Property Management releasing and discharging
all liens and encumbrances on the Property. A copy of the Affidavit of Lien Release is attached
hereto and incorporated herein as Exhibit "F".
18. Despite the Affidavit of Lien release, the lien remains of record with the Department
of Transportation.
19. Pursuant to § 505 of the Mobile Home Park Rights Act, the Property has since been
relocated to the National Village Mobile Home Park, Union County, Pennsylvania.
WHEREFORE, Plaintiff Stonemill Property Management respectfully requests that this
Court, pursuant to Pennsylvania Rule of Civil Procedure 1066, order as follows:
a. that the lien held by John Hanson Savings Bank be decreed satisfied and discharged;
3
AMH:LFG 524569.1 ( 00308.061 ) 10/5109
b. that after reasonable notice and opportunity for hearing having been provided to all
interested parties, ownership of one 1983 Skyline mobile home bearing Model
Number 011102995, be awarded to Stonemill Property Management;
C. that the Defendants and any person claiming through the Defendants be forever
barred from asserting any right, lien, title or interest in the property inconsistent with
the interest or claim of Plaintiff Stonemill Property Management;
d. that, absent the filing of an Answer or Objection, the Prothonotary shall be authorized
to enter final judgment in favor of Plaintiff Stonemill Property Management upon the
Plaintiff's filing of a Praecipe so requesting;
e. directing that the Department of Transportation may accept this Order as evidence
of ownership in lieu of a Certificate of Title;
f. directing Plaintiff Stonemill Property Management to submit the appropriate forms,
taxes and fees and comply with any other procedures of the Department of
Transportation in order to receive the appropriate Certificate of Title for the property.
BLAKINGER, BYLER & THOMAS, AC.
Date: 5
By: i C? LI k' k 4
gela M. Holt, Esquire
Attorney I.D. #209333
28 Perin Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for the Plaintiffs
4
BLAHF.NGER.BYLER&THOKAS
VERIFICATION
1900
I, IRVIN H. PEWER, verify that I am a principal in Stonemill Property Management, owner
and operator of Trindle Mobile Home Park, and, as such, I am authorized to make this verification
on behalf of the proprietorship and that the statements made in the foregoing Complaint are true and
correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A.
§ 4904, relating to unswom falsification to authorities.
Irv . Peifer "-/
Dated: _ 2009
EXHIBIT A
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
7/21/09 13:56
PAGE 1
OWNER LORI A SHUMBERGER
19 LUIS LANE
TRINDLE MHP
MECHANICSBURG PA 17055
092020277000380 002
LESSEE NONE
TITLE NUMBER 34793834
TAG NUMBER
VIN 01110299S
MAKE SKYLINE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS : YES
STOPS : NO
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
LIEN INFORMATION
LIEN HOLDER NO. 1
NAME : JOHN HANSON SAVING BANK
ADDRESS: P 0 BOX 15170
KNOXVILLE TN 37901
NO 2ND OR- 3RD LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
TITLE DATE : 11/22/82
REGISTRATION EXPIRY DATE:
BODY TYPE MH
ODOMETER READING
*ACTUAL MILEAGE
DUPLICATE TITLE COUNT 1
VEHICLE YEAR 1983
STOLEN DATE
EXPIRATION DATE: 09/26/21
ABA NO :
ELT IND:
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TDD IN STATE 1-800-228-0676
TDD OUT-OF-STATE 717-412-5380
WWW.DOT.STATE.PA.US
EXHIBIT B
J:Z4111t5:35 t.:in'+?.SS 1„117 IPIN LL 1:T C. u:I
' i r'M-121X D COtZTS': TAX C: x 21 B_1RZ .
?AGa 1
.91o4y0SW2005 ORE COURI7cmR SgeJ%P
CI,7a656
6/0312005 CARLISL'a PA 17013 PHONE 717 340-6366
FAX 711 240-6354
TAX CLAIM INQUIRY
.....?+. DIET/CTL 10 8490 .. ... R g M A A K S
SHOMBER=, ALAN 42 -19 J LOIS LANE }J
'
19 LOTS LANE -`
MECIMICSBURO P31 17050 PA0022 _ NOSILY xCMS PARR
Do= -LOT 19
-Mobile Rcmfe - No Land
CLRT MAIL-R/C 495105
10-mammBN TOWNSHIP
P
E
B CERT MAIL-SALE 1501904
21160-CO01f88RLAND VALLEY S.D. AG
AD MAP NO 10-22-052 5-021 TRO9304
D
T
STATUS C ACR=Z
VALUE 9,610 VALOR C&G
2,210
BUA= IRT ADDED
RECEIPT
NO TAX PENAT.TS 2vTFRm C S'9-M PAY77ERTS DOE BACK MO
DATE CODE D83CRIPTIcw
65 1.97 2.55
19
24.18 .15
01/21/04 200 CTY-HKMPM %W .
99 .10 .17 1.26 .01
01/21/04 250 1x8-NAMPM TNP .
17 28
2 .01
01/21/04 300 MUR-HA_"pww TWP
01/22/04 40D 8CH-CSA488SlLA1ID vally 1.92 .19 .
---
69.30 6.83 11.22 .
106.35 // 5 66
2003 TAX TOTAL 135.07
15
00
01/21/04 201 PILING PES, .
5100
02/23/04 202 POSTAGE RST & CLAIM
04120/04 204 P08TIN0 Rs-':LiRM/CLAIM .- --20.00
7003 FE*_ TOTAL 40.00
2003 Y= TCTALS # BALANCE 176.07 .00 176.0 7 .33
ESTt1Lk D-';ALARCE DUE NSXT NONM
- - _ - - - - - 176.90
-
• •01/19/05 200 CTY-iWMPOES TWP - - - - - 20.55 - - - - 2.07 _ - - - .75 _ _ 23.47 .15
01
Ol/19/aS 250 LIB-HAbWDEN TWP 1.95 .20 as 2.20 .
01
01119/05 300 MIlQ-HAM D= 'wF 1.92 .19 .05 2.16 .
74
01/20105 400 SCR-COM ORLAZM Vally 98.04 9.80 3.70 111.54 .
2004 TAX TOTAL 139.37
01/19/05 201 PILING M 15.00
02103/05 202 P05TAGS R3:T & CLAIM S.00
05/05/05 204 POSTING RXT^VtN/CLAIM
2004 PER TOTAL 20.00
'
'
CZAR TOTALS & SAIMCE
t00 159.37 .00 159.37 .91
11SfiIA+"?'_7?5[g DUE N--.'T MONTH 160.29
- - - - - - - - - - - - - - - - - - - - -CLAIM TOTALS - - - 335.44 - - - - .00 _335.44 1.74
ESTIMATED TOTAL DUE V= MMM
MISC RECXIFTS - • - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
EXHIBIT C
Sto nemill Property 1Vlanaaement
P.O. Box 505, Elizabethtown, PA 17022-0506
Phone: (717) 367-5109 • Fax: (717) 361-7425
May 18, 2005
Alan Shumberger
Trindle MHP
19 Lois Lane j.
Mechanicsburg, PA f17050 i i
Dear Mr. Shumberger:
RE: 1983 Skyline Model #011102995, Lot 19 Lois Lane, Trindle Mobile Home Park
I am writing to confirm that you, Alan Shumberger, no longer have any interest in
the mobile home referred to above and that you are hereby releasing the mobile home to
Stonemill Property Management. It you receive this letter and agree that this is a true
statement, please acknowledge by sending the signed and notarized title to Stonemill
Property Management at the address shown above.
Sincerely.
STONEMiLL PROPERTY MANAGEMENT
Irvin H. Peifer,
Owner
.. IHPLiaQ
i Complete items 1, 2, and 3. Also complete
it4m 4 if Restricted Delivery is desired.
lach nt your name and address on the reverse
that we can return the card to you.
this card to the back of the maitpiece,
or on thw frnnr ii
V
i -z ster from service label) 7003 3110 0 0 0 0 0 7 0 3 419 3'
?C,m $811 p 9t go pi . i - ._ .. - - - - r- ---r- -'--- --.._-; m ° _ ° d c .:
E ' ' Iuu y, gi, t 1 139mestic Return Retei t i ? i ; .. a° g
f t t P
102595-02-M-1540
• I ti
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EXHIBIT E
B1aldngezByk-x&T'hoxnas, P.C.
FACSIMILE
To: FDIC Division of Resolutions and Receiverships
Fax: 703-812-1082
From: Angela M. Holt
Date: August 27, 2009
Pages: 1
File: 00308.064
Please be advised that this office represents Stonemill Property Management in matters relating to the
transfer of title for a mobile home unit that has been abandoned. Attached please find documents relating
to a 1983 Skyline Mobile Home Unit bearing VIN # 01110299S that was financed through John Hanson
Savings Bank, located in Knoxville, Tennessee. The mobile home was abandoned in 2004 by the prior
owner, Lori Shumberger. As I understand, John Hanson Savings Bank was closed in 1991. As reflected
on the attached Vehicle Record Abstract, John Hanson Savings Bank remains listed as a lienholder of record
against the title to the mobile home.
Please consider this fax a written request for a Release of Lien. Additionally, please provide any information
regarding the financial institution which currently holds this lien and how I may obtain title to the unit. I
can be reached by telephone at 717-509-7283 or email at amh&bbt-law.com.
Thank you for your anticipated cooperation in this matter. I look forward to hearing from you.
g ly
M. Hol
AMH/lfg
CONFIDENTIAL
The information contained in this facsimile message is attorney
privileged and confidential information intended only for the use of
the individual or entity named above. If the reader of this message
is not the intended recipient, you are hereby notified that any
dissemination, distribution, or copy of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify us by telephone and return the original message
to us at the above address via the U.S. Postal Service. Thank you.
From the Desk Of...
Angela M. Holt
Blakinger, Byler & Thomas, P.C.
28 Penn Square
Lancaster, PA 17603
http://www.bbt-law.com
Phone: (717) 509-7283
Fax: (717) 299-9529
Email: amh@bbt-law.com
PE y^iSYLVANIA DEPARTMENT OF TRANSPORT-.', iON
VEHICLE RECORD ABSTRACT
7/21/09 13:56
PAGE 1
092020277000380 002
OWNER LORI A SHUMBERGER LESSEE NONE
19 LUIS LANE
TRINDLE MHP
MECHANICSBURG PA 17055
TITLE NUMBER 34793834
TAG NUMBER
VIN 01110299S
MAKE SKYLINE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS YES
STOPS NO
TITLE DATE : 11/22/82
REGISTRATION EXPIRY DATE:
BODY TYPE MH
ODOMETER READING
)EACTUAL MILEAGE
DUPLICATE TITLE COUNT 1
VEHICLE YEAR 1983
STOLEN DATE
TITLE BRAND INFORMATION
NO TITLE BRANDS EXIST FOR THIS TITLE
LIEN INFORMATION
LIEN HOLDER, NO. 1
NAME : JOHN HANSON SAVING BANK
ADDRESS: P 0 BOX 15170
KNOXVILLE TN 37901
NO 2ND OR 3RD LIENS EXIST FOR THIS TITLE
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
HARRISBURG, PA 17106-8691
EXPIRATION DATE: 09/26/21
ABA NO :
ELT IND:
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TDD IN STATE 1-800-228-0676
TDD OUT-OF-STATE 717-412-5380
WWW.DOT.STATE.PA.US
08/27/2009 16:04 TAX. 7175091870 BLAKINGER,BYLER&THOMAS 0001
*** TX REPORT **?e
TRANSMISSION OK
TX/RX NO 0740
RECIPIENT ADDRESS 17038121082
DESTINATION ID
ST. TIME 08/27 16:04
TIME USE 00,33
PAGES SENT 2
RESULT OK
H BYW&nWM3M P.C. FACSIMILE
To: FDIC Division of Resolutions and Receiverships
Fax: 703-812-1082
From: Angela M. Holt
Date: August 27, 2009
Pages: 1
File: 00308.064
Please be advised that this office represents Stonemill Property Management in matters relating to the
transfer of title for a mobile home unit that has been abandoned. Attached please find documents relating
to a 1983 Skyline Mobile Home Unit bearing VIN # 01110299S that was financed through John Hanson
Savings Bank, located in Knoxville, Tennessee. The mobile home was abandoned in 2004 by the prior
owner, Lori Shumberger. As I understand, John Hanson Savings Bank was closed in 1991. As reflected
on the attached Vehicle Record Abstract, John Hanson Savings Bank remains listed as a lienholder of record
against the title to the mobile home.
Please consider this fax a written request for a Release of Lien. Additionally, please provide any information
regarding the financial institution which currently holds this lien and how I may obtain title to the unit. I
can be reached by telephone at 717-509-7283 or email at amhna.bbt-law.com.
Thank you for your anticipated cooperation in this matter. I look forward to hearing from you.
Since ly
Angela M. Hol
AMRUg
EXHIBIT F
FDIC
Federal Deposit Insurance Corporation Division of Resolutions and Receivership
1601 Bryan Street, Dallas, TX 75201 Customer Service Department
((888) 206-4662 email: cservicefdicdal@fdic.aov
09/09/2009
Blalciner, Byler & Thomas (BB&T)
Attn: Angela M. Holt
28 Penn Square
Lancaster, PA 17603
RECEIVED
SEP 1 4 2009
SUBJECT: FIN# - 1286 -JOHN HANSON FSB
Request Number: 2005962900
Your Reference: 2005962900
Subject: Stonemill Property Management
Blakinger, Byler &
Thomas, P.C.
Dear Angela M. Holt:
Enclosed please find the following original documents pertaining to the above-described asset:
AFFIDAVIT OF LIEN RELEASE
INVOICE
Receipt of this document will not effectuate the release/transfer of the property until the document is filed with the
appropriate Recording Official. The attached document should be filed with the Department of Motor Vehicles.
Please see that this document is properly fded. Duplicate requests for documents will incur a charge of $25.00.
If you have any questions, please call the Customer Service Center toll-free at 888-206-4662. Otherwise, you may
inquire via e-mail, eservicefdicdal(@fdic.gov, please reference your request number. You may also send any future
inquiries to "Customer Service" at the address above.
Sincerely,
Enclosure(s)
?- y
Sheila Umeh
FDIC Customer Service
Revised 3/04103 by K Willingham
11 ? 01 ?q
Federal Deposit Insurance Corporation
1910 Pacific Avenue, Dallas, TX 75201
(972) 448-6000 (888) 206-4662
Dallas Field Office - Division of Resolutions and Receivership
Customer Service Deaartment
FAX (703) 812-1082 email: CServicedal@fdic.gov
AFFIDAVIT OF LIEN RELEASE
Date: September 9, 2009
State: Pennsylvania Certificate of Title Number: 34793834
On a (Make - Body) SKYLINE - MH Year: 1983 VIN Number: 011102995
Registered Owner(s): LORI A SHUM 3ERGER
I, Priscilla Catapat, Authorized Agent, on behalf of the FEDERAL DEPOSIT INSURANCE CORPORATION,
whose address is 1601 Bryan Street, Dallas, Texas 75201, upon Oath, Depose and Say:
The undersigned holder of a lien on the motor vehicle described herein does
hereby state that the lien and encumbrance described in this Affidavit of Lien
Release is released and discharged.
FEDERAL DEPOSIT INSURANCE CORPORATION FEDERAL
DEPOSIT INSURANCE CORPORATION which pursuant to 12
USC Section 1441a (m) (I), succeeded the Resolution Trust
Corporation as Receiver for JOHN HANSON SAVINGS BANK,
FSB, BELTSVILLE, MD ("FDIC").
By:tt.u?" Z
Name: scilla Catapat
Title: Authorized Agent
STATE OF TEXAS
COUNTY OF DALLAS
SUBSCRIBED AND SWORN to before me on this September 9, 2009.
3NElLA A. U EH
MY COMMISSION EXPIRES
- AtgW 4, 2012
Name: Sheila A. Umeh
Notary Public
Revised 3/02 (Pennsylvania) Affidavit of Lien Release - Vehicle
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. 09-6665 Civil Term
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
AFFIDAVIT OF ANGELA M. HOLT CONCERNING THE WHEREABOUTS OF
DEFENDANT LORI SHUMBERGER AND DEFENDANT ALAN SHUMBERGER
The undersigned, being duly affirmed according to law, deposes and says that:
I am an attorney representing Stonemill Property Management, Plaintiff in the above
captioned Quiet Title Action.
2. A Complaint was filed against the Defendants on October 6, 2009.
3. The last known address of Defendant Lori Shumberger is Trindle Mobile Home Park,
19 Lois Lane, Mechanicsburg, Pennsylvania 17050. Defendant Lori Shumberger no longer resides
at this address.
4. Pursuant to Pa.R.C.P. 430, Plaintiff made a good faith effort to locate Defendant Lori
Shumberger by submitting to the United States Postal Service on August 13, 2009 a Request for
Change of Address or Boxholder Information Needed for Service of Legal Process, which yielded
no forwarding address. A copy of the Request for Change of Address or Boxholder Information
Needed for Service of Legal Process, with the Post Office's response indicated thereon, is attached
hereto and incorporated herein as Exhibit "I".
AMH:LFG 532628.1 ( 00308.061 ) 10/12/09
5. Pursuant to Pa.R. C.P. 430, Plaintiff made a good faith effort to locate Defendant Lori
Shumberger by submitting to Cumberland County Voter Registration on September 8, 2009 a letter
requesting the current address on file with Voter Registration for Defendant Lori Shumberger, which
yielded no forwarding address. A copy of the letter with Cumberland County Voter Registration's
response handwritten thereon, is attached hereto and incorporated herein as Exhibit "2".
6. An internet and phone record search has not revealed any information concerning
Defendant Lori Shumberger.
7. The last known address of Defendant Alan Shumberger is Trindle Mobile Home Park,
19 Lois Lane, Mechanicsburg, Pennsylvania 17050. Defendant Alan Shumberger no longer resides
at this address.
Pursuant to Pa.R.C.P. 430, Plaintiff made a good faith effort to locate Defendant Alan
Shumberger by submitting to the United States Postal Service on August 13, 2009 a Request for
Change of Address or Boxholder Information Needed for Service of Legal Process, which yielded
no forwarding address. A copy of the Request for Change of Address or Boxholder Information
Needed for Service of Legal Process, with the Post Office's response indicated thereon, is attached
hereto and incorporated herein as Exhibit "3".
9. Pursuant to Pa.R.C.P. 430, Plaintiff made a good faith effort to locate Defendant Alan
Shumberger by submitting to Cumberland County Voter Registration on September 8, 2009 a letter
requesting the current address on file with Voter Registration for Defendant Alan Shumberger, which
yielded no forwarding address. A copy of the letter with Cumberland County Voter Registration's
response handwritten thereon, is attached hereto and incorporated herein as Exhibit "2".
2
AMH:LFG 532628.1 ( 00308.061) 10/12/09
10. An internet and phone record search has not revealed any information concerning
Defendant Alan Shumberger.
Angela M. olt, E uire
Attorney for Plaintiff Stonemill Property Management
Sworn to before me this the B
day of _,2009.
i
4otaryPublic
COMMONWEALTH OF PENNSYLVANL4
Nohrhl Seal
Use F. Gorgon, Notary Public
c
y of lancestor County
MYC
Member, p 2012
Associatlon of Notaries
3
August 13, 2009
Postmaster
Mechanicsburg, PA 17050
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER
INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if boxholder) for the following:
Name: Lori Shumberger Address: 19 Lois Lane. Mechanicsburg. PA 17050
(NOTE: Only one request may be made per completed form. The name and last known address are required for change of address information.
The name, if known, and Post Office box address are required for boxholder information. The following information is provided in accordance with
39 CFR 265.6(d)(4)(ii). There is no fee charged for change of address or boxholder information.
1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation acting pro se must cite statute):
3. The names of all known parties to the litigation: Stonemill Property Management v. Lori Shumberger; Alan
Shumberger and John Hanson Saving Bank
4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County,
Pennsylvania
5. The docket of other identifying number if one has been issued: Not yet filed
6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant
"WARNING"
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR
IMPRISONMENT OF NOT MORE THAN FIVE (5) YEARS OR BOTH (TITLE 18 U.S.C. § 1001).
1 certify that the above information is true and that the address information is needed and will be used solely for service
of legal process in connection with actual or prospective litigation.
Blakinger, Byler & Thomas, P.C.
28 Penn Square
An ela M" Holt, E uir Lancaster, PA 17603
FOR POST OFFICE USE ONLY
No change of address order on file
Not known at address given
Moved, left no forwarding address
No such address
AMH:LFG 526825.1 (00308.064) 8113/09
x*&'%
NEW ADDRESS OR BOXHOLDER'S
NAME AND STREET ADDRESS A.
`?ua? p.4 -
m
AM 2 4 2009
anon
Blakinger,Byler&Thomas, P.C.
Attorneys at Law
James H. Thomas
Frank P Mincarelli
Stephen M. Kraybill
Dan A. Blakinger
Barry A. Solodky
Susan E. Grosh
Frank J. Vargish, III
George T. Cook
Jesse C. Robinson
Kim Caner Paterson
Theresa A. Mongiovi
Richard B. Posey
Edward L. Miller
Aaron S. Marines
Susan P Peipher
Aaron D. Hollis*
Jonathan R. Hofstetter
Randall M. Justice
Brian R. Wilson
Angela M Holt
N
*LL.M. in Taxation
M
Retired
Richard J. Blakinger
Michael D. Bull
M
28 Penn Square
Lancaster, PA 17603
717-299-1100
Fax 717-299-9529
http://www.bbt-law.com
September 8, 2009
Cumberland County Voter Registration
310 Allen Road, Suite 101
Carlisle, PA 17013
Re: Request for voter registration records
Dear Sir or Madam:
Writer's Direct Dial Number:
(717) 509-7283
E-MAIL: amh@bbt-law.com
Pursuant to Rule 430 of the Pennsylvania Rules of Court, I am required to exhaust all
good faith efforts to locate a defendant in a civil action before I can serve that defendant
by publication, including "examinations of local telephone directories, voter
registration records, ...." Please provide the current address that is on file with the
Cumberland County Voter Registration for the following individuals:
Lori Shumberger
Alan Shumberger
Charles B. Grove, Jr.
(1958-1985) I have enclosed a return envelope for your use in providing me with copies of any
Samuel S. Wenger current address information you may have for these individuals, or your statement that
(1938-1989) no address is on record if that is the case.
M. Elvin Byler
(1965-1992)
I appreciate you assistance in this matter. Please do not hesitate to contact me if you
have any questions or need any further information.
dSincerel ,
Angela M. Holt
AMH:Ifg
cc: Stonemill Property Management
#528821.1/00308.064
C cs
_ A,- n i LkA
August 13, 2009
Postmaster
Mechanicsburg, PA 17050
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER
INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if boxholder) for the following:
Name: Alan Shumberger Address: 19 Lois Lane. Mechanicsburg, PA 17050
(NOTE: Only one request may be made per completed form. The name and last known address are required for change of address information.
The name, if known, and Post Office box address are required for boxhokter information. The following information is provided in accordance with
39 CFR 265.6(d)(4)(ii). There is no fee charged for change of address or boxholder information.
1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party
acting pro se - except a corporation acting pro se must cite statute):
3. The names of all known parties to the litigation: Stonemill Property Management v. Lori Shumberger, Alan
Shumberger and John Hanson Saving Bank
4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland County,
Pennsylvania
5. The docket of other identifying number if one has been issued: Not yet filed
6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant
"WARNING"
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR
IMPRISONMENT OF NOT MORE THAN FIVE (5) YEARS OR BOTH (TITLE 18 U.S.C. § 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service
of legal process in connection with actual or prospective litigation.
Blakinger, Byler & Thomas, P.C.
' 28 Penn Square
Angela M. Holt, E qu Lancaster, PA 17603
FOR POST OFFICE USE ONLY
No change of address order on file NEW ADDRESS OR BOXHOLDER'S D6URG Pq I,
Not known at address given NAME AND STREET ADDRESS os
Moved, left no forwarding address zo
No such address Itllf; 9 A WM °"R
AMH:LFG 526824.1 (00308.064) 8113/09
LEE,
nr t F Z I Y
200 OCT 15 P,G' G. 2
CUM,
PENN S7'L`f'ir'! `\If I
OCT 16 2009(
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
No. 09-6665 Civil Term
ORDER
And now, this It* day of 0 Z;? , 2009, upon consideration of the
Plaintiff s Motion for Special Order Directing Service by Publication pursuant to Pa.R.C.P. 430(a),
and it appearing to the Court that Plaintiff has made a good faith effort to locate Defendants Lori
Shumberger and Alan Shumberger, Plaintiff's motion is granted.
IT IS HEREBY ORDERED that Plaintiff shall make service of the Complaint on Defendant
Lori Shumberger and Defendant Alan Shumberger by publication pursuant to Pa.R.C.P. 430(b)(1).
The publication shall run once in the Cumberland Law Journal and once in The Sentinel. Counsel
for Stonemill Property Management shall provide proof ice of s h service by publication.
J.
t EO....,'..:i 4 iv.:l
-F THE X0 99 6C'T 19 y d 2° ; 8
AMH:LFG 535109.1 ( 00308.061 ) 1113/09
.. GTNAL
BLAKINGER, BYLER & THOMAS, P.C.
By: Angela M. Holt, Esquire
Attorney I.D. #209333
28 Penn Square
Lancaster, PA 17603
(717) 299-1100
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - QUIET TITLE
STONEMILL PROPERTY
MANAGEMENT
Plaintiff
No. 09-6665 Civil Term
V.
LORI SHUMBERGER and ALAN
SHUMBERGER
Defendants
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-captioned matter.
BLAKINGER, B ER & THOMAS, P. C.
Date: 3 /bq B
ngela Holt, squire
Attorney I.D. #209333
AMH:LFG 535109.1 ( 00308.064) 11/3/09
0
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OF THIE F""WTARY
2009 NOV -5 PM 12: 44
CUME? t?IjtJNTY
N SYL1iANLA
$1 o. oo !Pb A-ri"
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U* .133043
FILED-OFFICE
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC '' 'HIE PROTHONOTAR
By: Angela H. Sanders, Esquire 2913 SEP 24 AM 9: 18
Attorney I.D. No. 209333
480 New Holland Ave, Suite 6205 CUMBERLAND COUNTY
Lancaster, PA 17602 PENNSYLVANIA
717/945-5745(Phone)/717/945-5764(Fax) Attorneys for Plaintiff
AngelaS @bcgl-law.com
STONEMILL PROPERTY IN THE COURT OF COMMON PLEAS
MANAGEMENT OF CUMBERLAND COUNTY,
Plaintiff PENNSYLVANIA
V.
No. 09-6665
LORI SHUMBERGER and ALAN Civil Term — QUIET TITLE
SHUMBERGER
Defendants
PRAECIPE
TO THE PROTHONOTARY:
As no Answer or Objection has been filed to the Court's Order of February 2,
2010, please enter final judgment in favor of Plaintiff Stonemill Property
Management pursuant to Pa.R.C.P. 1066(b)(1).
BRUBAKER CONNAUGHTON GOSS &
LUCARELLI LLC
Date: 3 I? By:�3"
Ange H. San ers, uire
Attorney I.D. #209333
480 New Hollan venue, Suite 6205
Lancaster, PA 17602
Phone: 717-945-5745
Fax: 717-945-5764
Email: AngelaS @bcgl-law.com
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