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Home My WebLink About09-6753Phelan 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 ,-?ndrew 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHII MORTGAGE CORPORATION 2001 BISHOP'S GATE BLVD MOUNT LAUREL, NJ 08054 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff v. SARATOGA OCEAN MIKHAIL OCEAN 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA 1164 FEDERAL BUILDING, 228 WALNUT STREET HARRISBURG, PA 17101 Defendants TERM OA- NO. 04 - &'753 vil (erwt CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE Wl he ti'' F r"eF, tFht!'' F? H CJ Correct copy of 1,v File #: 218615 fire 1 218615 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 4: 218615 Plaintiff is PHH MORTGAGE CORPORATION 2001 BISHOP'S GATE BLVD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: SARATOGA OCEAN MIKHAIL OCEAN 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA 1164 FEDERAL BUILDING, 228 WALNUT STREET HARRISBURG, PA 17101 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 09/30/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR ERA MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200836834. By Assignment of Mortgage recorded 05/07/2008 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 200815003. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 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 File #: 218615 of said mortgage, upon failure of mortgagor to make such payments after a date specified 6 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 $321,268.40 Interest $18,838.24 01/01/2009 through 10/08/2009 (Per Diem $67.04) Attorney's Fees $1,300.00 Cumulative Late Charges $910.56 09/29/2008 to 10/08/2009 Property Inspections $66.25 Cost of Suit and Title Search 750.00 Subtotal $343,133.45 Escrow Credit $0.00 Deficit $2,024.55 Subtotal $2,024.55 TOTAL $345,158.00 7 8 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability File #: 218615 discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. IL . The United States of America is made a Defendant herein pursuant to 28 U.S.C. 2410, because of federal tax liens that have been filed with the Prothonotary of CUMBERLAND County in the Judgment Index Unit as follows: (a) United States vs. MIKHAIL OCEAN ; IRS Docket No. 2007-4853 . filed 8/15/2007 ; in the amount of $17003.48 . File #: 218615 WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $345,158.00, together with interest from 10/08/2009 at the rate of $67.04 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.. By: File #: 218615 LJ Francis S. Hallman; Esq., Id. No. 0209J ? 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 J. Mulcahy, Esq., Id. No. 61791 ? er Andrew w 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 LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right-of-way line of Stonehedge Drive, a sixty foot wide right-of-way, said point also being the southwest corner of Lot No. 34; thence along the western right-of-way line of Stonehedge Drive, South twenty-one (21) degrees fifty (50) minutes zero (00) seconds West a distance of forty-three and sixty-four hundredths (43.64) feet to a point; thence along the same and a curve to the right having a radius of two hundred seventy and zero hundredths (270.00) feet and an arc distance of one hundred and zero hundredths (100.00) feet, said arc being subtended by a chord of South 32 degrees 26 minutes 37 seconds West, a chord distance of ninety-nine and forty-three hundredths (99.43) feet to a point at the corner of Lot No. 32 of the Stonehedge PRD Stage 3A also being in the center of a 40 foot wide drainage swale; thence along Lot No. 32 and the center of said swale, North forty-four (44) degrees fifty-nine (59) minutes thirty-eight (38) seconds West a distance of one hundred forty- three and twenty-five hundredths (143.25) feet to a point in the center of the aforesaid 40 foot wide drainage swale at lands now or formerly of Stonehedge Developers, Inc.; thence along said land of Stonehedge Developers, Inc. and the center of said swale, North twenty-one (21) degrees fifty (50) minutes zero (00) seconds East a distance of eighty-five and zero hundredths (85.00) feet to a point at the corner of Lot No. 34; thence along Lot No. 34, South sixty-eight (68) degrees ten (10) minutes zero (00) seconds East, a distance of one hundred fifty and zero hundredths (150.00) feet to a point, the point of beginning. File #: 218615 SUBJECT TO a twenty, (20) foot wide drainage easement along its southern property line common with Lot No. 32, and a twenty (20) foot wide drainage easement along its western property line with other lands of Stonehedge Developers, Inc. CONTAINING 0.39 acres, more or less, and identified as Lot No. 33 of Stonehedge PRD Stage 3A, recorded in Plan Book 69, Page 13 in Cumberland County Recorder of Deeds Office, Carlisle, Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 311, Page 42, and subject to a Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 503, Page 404, and further subject to the Bylaws of the Stonehedge Home Owners Association as recorded in Cumberland County Miscellaneous Book 311, Page 511. PARCEL NO: 40-23-0602-204 PREMISES: 118 STONEHEDGE DRIVE File #: 218615 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: f o 1 S (0 5 File #: 218615 0 FILFr-:)i F CE OF THE 2-09 OCT -9 Pki 12: 26 -*Z'f3 , 50 Pb ATM ? 86tRt3 ?,3((vr18 Sheriffs Office of Cumberland County ? e}? FILED-OF 'vE R Thomas Kline C THE ?, u, I?'?eT Sheriff 6tt?1LV ?t CuiriGr,?l? t! Ronny R Anderson " +? 2009 OCT i GS AM Q; 43 Chief Deputy Jody S Smith CUN:". Civil Process Sergeant !P'C:.Nt"tiiS'(LANA Edward L Schorpp Solicitor PHH Mortgage Corporation vs. Saratoga Ocean Case Number 2009-6753 SHERIFF'S RETURN OF SERVICE 10/27/2009 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: Saratoga Ocean, 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 Saratoga Ocean. Request for service at 118 Stonehedge Drive Carlisle, PA 17015 is vacant. The Carlisle Postmaster has advised the defendant has forwarded their mail to P.O. BOX 22247 Santa Fe, NM 87502. 10/27/2009 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: Mikhail Ocean, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Mikhail Ocean. Request for service at 118 Stonehedge Drive Carlisle, PA 17015 is vacant. The Carlisle Postmaster has advised the defendant has forwarded their mail to P.O. BOX 22247 Santa Fe, NM 87502. SHERIFF COST: $59.40 October 27. 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 t,,,?cndrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHH MORTGAGE CORPORATION Plaintiff VS. ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-6753-CIVIL TERM SARATOGA OCEAN CUMBERLAND COUNTY MIKHAIL OCEAN Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 218615 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Pla?Utiff _ 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 1. Goldman, Esq., Id. No. 205047 ? ourtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Date: 11-3-09 PHS #: 218615 VERIFICATION fy?VC_ 7T O\A kAe hereby states that he/she is V \ CP (? ?f S l &,e n? of PHH MORTGAGE CORPORATION, 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 unsworn falsification to authorities. ? /1.1 ) Name: ,(na rc TN k0 Kke DATE: S Wx( 12,200 1 Title:VlCQ pf-eS(44 Company: PHH MORTGAGE CORPORATION File #: 218615 Ocean 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 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHH MORTGAGE CORPORATION Plaintiff VS. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-6753-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: SARATOGA OCEAN 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 PHS #: 218615 MIKHAIL OCEAN 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 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 1. Goldman, Esq., Id. No. 205047 ? Qeurtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Date: 11-3-09 PHS #: 218615 RLEu r E- ?pv rPr t1t? 1; -J•.1 APi 2069 NOY -5 Ff 1 1,58 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY PHH MORTGAGE CORPORATION PHS # 218615 DEFENDANT SERVICE TEAM/ sam SARATOGA OCEAN COURT NO.: 09-6753-CIVIL TERM MIKHAIL OCEAN THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE THE UNITED STATES OF TYPE OF ACTION AMERICA C/O THE UNITED STATES XX Mortgage Foreclosure ATTORNEY FOR THE MIDDLE XX Civil Action DISTRICT OF PA AT: MAIN JUSTICE BUILDING 950 PENNSYLVANIA AVENUE, N.W. WASHINGTON, DC 20530 SERVED Served and made known to f ~~~tt~j~lit~•A+t,.c Defendant on the 12~'`day of ~,~p-t~„~ 20OC] , at ~~, o'clock ~. M., at ~,'i-n~ ,,a--, r4P~nv ~ , in the manner described below: Defendant personally served. Adult family member with whom 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. an officer of said Defendant's company. Other: Description: Age ~~~t Height _~'~;4 Weight C~~i Race~Sex /~L Other h~vt~ L_ l-f-i~rc~, ,, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Com laint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated aptg`fer, Sworn to and subscribed ~~~~~P, L;,,Lr:'~~~ before me this _ l~`"day `~,`~`. werpNwr,~ .,.'~ of N~yr•t, 2009. ~:'a~ ~. ~L' ; U Notary: By: ,--r : ~c~~HES1z3, ~~': • ,Y ; ~'~j,~ !i, _ NOT SERVED '~ ~ .~'••' n the d~f , 200_, at o'clock . M., DefeiSQgyti~~~'tjUND because: - Vacant ~~d Address _ Moved _ Does Not Reside (Not Vacant) No Answer ~! Service Refused Other: Sworn to and subscribed before me this day of ~~ By: FlLE:~-~,r:1;:;F 2Q~9 F~~'~ 30 ~9-~ :~~ 5 i Cl.~i~~_ _ . , ~~v;~~ ~, AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY PHH MORTGAGE CORPORATION PHS # 218615 DEFENDANT SERVICE TEAM/ iil SARATOGA OCEAN COURT NO.: 09-6753-CIVIL TERM MIKHAIL OCEAN THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE MIKHAIL OCEAN AT: 14 DESCANSO ROAD SANTA FE, NM 87508-9125 By: Served and made known to ~ ' /~j1Bi~~ Oc.-24N Defendant on the day of ~_, 201 !~ , t ~ ~' , o'clock ~: M., at __[~f ,(,~S[.~N,L~'U ~ , in the manner described below: _~~',. Defendant personally served. ca _ Adult family member with whom 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). r _ Agent or person in charge of Defendant's office or usual place of business. 3 - an officer of said Defendant's company. N _ Other: w iG~1 Description: Age (~ Height ~~ ~ Weight f ~fo Race ~ Sex,~_Other I, / tee' ~l .ri~,.~competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Comylaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of , 20_. Notary: On the day of , 20_, at Vacant Bad Address No Answer _ Service Refused Other: Sworn to and su cribed bef ~n e this ay of !a-hlhf~l. , Notary: TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVED NOT SERVED o'clock _. M., Defendant NOT FOUND because: _ Moved _ Does Not Reside (Not Vacant) By: e OFFICIAL SEAL MICHAEL A. SISNEROS Notary Public State of N w e 'c My Commission Expires ~ ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Frwncts S. HalYnan, Fsq., Id. Na 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 Janine R Davey, Esq., Id. No. 87077 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 20233] 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. FBakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205pg7 Caurterray R Dunn, Esq., Id. No. 206779 Andrew C. BrambkYt, Esq., W. No. 208375 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY PHH MORTGAGE CORPORATION PHS # 218615 DEFENDANT SARATOGA OCEAN MIKHAIL OCEAN THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVICE TEAMJ.iil COURT NO.: 09-6753-CIVIL TERM SERVE SARATOGA OCEAN AT: TYPE OF ACTION 14 DESCANSO ROAD XX Mortgage Foreclosure _ SANTA FE, NM 87508-9125 XX Civil Action ~3 SERVED Served and made known to Defendant on the~~ y of __~, 2010 X00 , o'clock ~. M., at l~~L ~NSd Kc~ , in the manner described below: 7~Defendant personally served. _ Adult family member with whom 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. _ an officer of said Defendant's company. Other: 0 t Description: Age ~{U-~!?Height " Weight / SD Race 1~ Sex ~ Other I, competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of , 20_. Notary: By: On the day of _,.S~at _ Vacant -Bad Address No Answer Service Refused Other: NOT SERVED o'clock _. M., Defendant NOT FOUND because: _ Moved _ Does Not Reside (Not Vacant) Sworn to ands scribed bef e me this "~ day ~ / ,/~ of ~. By: rte"{` Notary: ATTORNEY FOR PLAINTIFF oF>:ici;~~ s~At_ MICHAEL 6~. SISNEROS Notasy Pubtic State of N w e ° 1Ig3 ~ M Commission Exp Lawrenw T. Phelan, Esq., Id. No. 32227 Francis S. HalBnan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq. Id. No. 69849 Judith T. Romano, Esq., Id. Na 58745 Sheetal R Shah-Jani, Esq., Id. Na 81760 Janine R. Davey, Esq., Id. No. 8707'1 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq Id. No. 202331 Jay B. Jones, Esq., Id. Na 86657 Peter J. Muks,hy, Esq., Id. Na 61791 Andrew L Spivack. Esq., Id. Na 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. GoHmaq Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew G Bramblct4 Esq., ld. Na 208375 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PHH MORTGAGE CORPORATION Plaintiff COURT OF COMMON PLEAS v SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 03/30/2010 to Date of Sale ($59.45 per diem) TQTAL s ~a~4.op PD A~ 5q.4D C6F 7$ • SO fa.po 10.0 ' 1~}, pp a.so ~~ ~ IQ$.~D -Po Am/ Note: Please attach description of property. PHS # 218615 ~a. a, ~(~ so u. e~~" q ~a~a5 ~~ a~ 1 ~f5$ cQ CIVIL DIVISION N0.09-6753-CIVIL TERM CUMBERLAND COUNTY C~ $356,688.88 -- -~ , 9 690.35 $366,379.23 '~ =-~ C /y~.,c ~ /! ti-t Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ P ter J. Mulcahy, Esq., Id. No. 61791 ^~ndrew L. Spivack, Esq., Id. No. 84439 ((~~"" Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 i1 c.~: ;~~ _ cam, ~: -~ i ,zm ~,_~ ;.~ ~.~ b ° .~ ~ N ~ N O~ O~ ~ N Q oo o ¢ A o0 0 ¢ y ~ ¢ r U ~ oo r ¢ ~ 00 U~ ~~ ° z ¢z U oz 3 ~¢w ~¢w a~'i WE-~ ~ ~WE-~ Q~ A~ ¢ ~ ~ ~ ~ ~ '^ a a` a, ~ ~ a~ OV M N o~~~~ M N ~~ O z O N N ~, F ; ] ~O ~O p o0 p c.l n O~ N O W ~Fjyj jW~ a a, ° o ozv'zo~ornc°~~~ o ob o oz 0 O a ~. ~~ O W ~ r a.ti-Zo-Zo'`°zbzzz~ °~z ~zb~ ~ Pti O o ~ „ ..~ ~..~ .b °° z ,~ b w b CYi ° °~ O~ O ~ ~ Ew a,cw o:,Wb-dbzb °'Q'o o:a"w U "~ fJ" " ~ ~ ap o w .~ ~ a+W b W ~ W :d W w a~i .-. O~ W W ~ w~~ ~ °w c ~ww ° ~w ~ ~~ C7 OVW Via' O Q ~~ >,x~•~6'.~~~°~'+~xGtj~°'~°~~~I.~ x ~ O ~V a > v~~ a w ¢a^^^^^^^^^^^ ^^^^ Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 ~~;~~ __,,. , .,: __ ~ ..;r ~- One Penn Center Plaza 1.,_,:_ - . _ , ~, Philadelphia, PA 19103 ' ` 215-563-7000 Z~I~Ji"~~~'~' -3 1~!` ~~~ ~~ ~,;~. PHH MORTGAGE CORPORATION ~t'':~:- .- _ _ ,.-~,1~ ~e, Plaintiff , , v. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION N0.09-6753-CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ J y B. Jones, Esq., Id. No. 86657 ^ eter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 PHH MORTGAGE CORPORATION Plaintiff v. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-6753-CIVIL TERM CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 PHH MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116. Name and address of Owner(s) or reputed Owner(s): Name SARATOGA OCEAN MIKHAIL OCEAN n ^' - r~ ~~' r~ _ Address (if address cannot be reasonably , ~ - _ __~ ascertained, please so indicate) - /=~ ; ; t ~' -t: 14 DESCANSO ROAD c,3 `- SANTA FE, NM 87508-9125 _ ~, 14 DESCANSO ROAD ~ ~=~ -.;' SANTA FE, NM 87508-9125 ~;~ ~, 'x c~ --~c 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) MID PENN BANK MARKET SQUARE PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17101 MID PENN BANK MARKET SQUARE PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17103 MID PENN BANK C/O 2320 NORTH 2ND STREET, P.O. BOX 60457 KELLY M. KNIGHT, ESQUIRE HARRISBURG, PA 17106-0457 GRAYSTONE BANK 112 MARKET STREET HARRISBURG, PA 17101-2043 GRAYSTONE BANK C/O 240 NORTH 3RD STREET, 7~ FLOOR MICHAEL L. SOLOMON, ESQUIRE HARRISBURG, PA 17101-1503 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Narrte Add 'f dd b None. ress (i a ress cannot e reasonably ascertained, please indicate) Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare UNITED STATES INTERNAL REVENUE SPECIAL PROCEDURES BRANCH FEDERATED INVESTORS TOWER U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 FEDERAL BUILDING, P.O. BOX 11754 228 WALNUT STREET HARRISBURG, PA 17108 STONEHEDGE HOMEOWNERS ASSOCIATION INCORPORATED STONEHEDGE HOMEOWNERS ASSOCIATION, INC. STONEHEDGE HOMEOWNERS ASSOCIATION, INC. 39 GARLAND COURT #2 CARLISLE, PA 17013-4409 4101 NORTH 6TH STREET, # 2057 HARRISBURG, PA 17110-1610 P.O. BOX 2057 HARRISBURG, PA 17105-2057 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Apri126, 2010 By: Attorney for Pla ntiff Phelan Hallman &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallman, 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 .~ PHH MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. SARATOGA OCEAN MIKHAIL OCEAN N0.09-6753-CIVIL TERM CUMBERLAND COUNTY Defendant(s) N NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~ ~ -Q -, ~. ~ ; .' ,7 TO: SARATOGA OCEAN ~ ~~ ~'i' c.~ MIKHAIL OCEAN ' .~-, 14 DESCANSO ROAD =_ SANTA FE, NM 87508-9125 j ` ~ ~' p = " * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116 is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8, ZO10 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $356,688.88 obtained by PHH MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 1 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. S. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution N0.09-6753-CIVIL TERM PHH MORTGAGE CORPORATION vs. SARATOGA OCEAN MIKHAIL OCEAN owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, (Municipality) Pennsylvania, being 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116 (Acreage or street address) Parcel No. 40-23-0602-204 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $356,688.88 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land and the improvements thereon, situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right-of--way line of Stonehedge Drive, a sixty foot wide right-of--way, said point also being the southwest corner of Lot No. 34; thence along the western right-of--way line of Stonehedge Drive, South twenty-one (21) degrees fifty (50) minutes zero (00} seconds West a distance of forty-three and sixty-four hundredths (43.64) feet to a point; thence along the same and a curve to the right having a radius of two hundred seventy and zero hundredths (270.00) feet and an arc distance of one hundred and zero hundredths (100.00) feet, said arc being subtended by a chord of South 32 degrees 26 minutes 37 seconds West, a chord distance of ninety-nine and forty-three hundredths (99.43) feet to a point at the corner of Lot No. 32 of the Stonehedge PRD Stage 3A also being in the center of a 40 foot wide drainage swale; thence along Lot No. 32 and the center of said swale, North forty-four (44) degrees fifty-nine (59) minutes thirty-eight (38) seconds West a distance of one hundred forty-three and twenty- five hundredths (143.25) feet to a point in the center of the aforesaid 40 foot wide drainage swale at lands now or formerly of Stonehedge Developers, Inc.; thence along said land of Stonehedge Developers, Inc. and the center of said Swale, North twenty-one (21) degrees fifty (50) minutes zero (00) seconds East a distance of eighty-five and zero hundredths (85.00) feet to a point at the corner of Lot No. 34; thence along Lot No. 34, South sixty-eight (68) degrees ten (10) minutes zero (00) seconds East, a distance of one hundred fifty and zero hundredths (150.00) feet to a point, the point of beginning. SUBJECT TO a twenty (20) foot wide drainage easement along its southern property line common with Lot No. 32, and a twenty (20) foot wide drainage easement along its western property line with other lands of Stonehedge Developers, Inc. CONTAINING 0.39 acres, more or less, and identified as Lot No. 33 of Stonehedge PRD Stage 3A, recorded in Plan Book 69, Page 13 in Cumberland County Recorder of Deeds Office, Carlisle, Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 311, Page 42, and subject to a Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 503, Page 404, and further subject to the Bylaws of the Stonehedge Home Owners Association as recorded in Cumberland County Miscellaneous Book 311, Page 511. TITLE TO SAID PREMISES IS VESTED IN Mikhail Ocean and Saratoga Ocean, h/w, by Deed from Vallery Clouse, single woman, dated 09/30/2005, recorded 10/03/2005 in Book 271, Page 1225. PREMISES BEING: 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116 PARCEL N0.40-23-0602-204 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6753 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PHH MORTGAGE CORPORATION Plaintiff (s) From SARATOGA OCEAN and MIKHAIL OCEAN (l) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $356,688.88 L.L.$.50 Interest from 3/30/10 to Date of Sale ($59.45 per diem) -- $9,690.35 Atty's Comm Due Prothy $2.00 Atty Paid $]98.40 Other Costs Plaintiff Paid Date: 5/3/l 0 David D. Buell, Proth notary (Seal) By: Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Te I ephone: 215-563-7000 Supreme Court ID No. 90134 PHH MORTGAGE CORPOI PLAINTIFF V. SARATOGA OCEAN, MIKHAIL OCEAN, DEFE ,TION IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6753 CIVIL ORDER OF COURT AND NOW, this 1 ~`~ day of July, 2010, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY Ot~DERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendan~,s will file an answer on or before August 10, 2010; 3. If no answer to~the Rule to Show cause is filed by the required date, the relief requested by Petitioner sfhall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendants file an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothon is directed to forward said Answer to this Court. By the Court, /Jenine R. Davey, Esquire Attorney for Plaintiff ~ratoga Ocean ,/Mikhail Ocean Defendants bas l Q.S ryL~ '7 l4~1~ l ~~, M. L. Ebert, Jr., J. r~ ~ , r- ,~ =°~, -n e :' ~ ;~ t r r f? ~ "~'; " ~ .~ r ` J~ ~ • N V1J I , = ~; ~' ~ ~'C1 _ E.i c~ f -~ i +~ r~ 'T, ~I~.~-t i r~ ,h ~f. 2C4~ ~,' ~~ ~,~.~ ,. ~'~: (~ .~u (~ 3 PMa K : ~~ l'+ Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PHH MORTGAGE CORPORATION Court of Common Pleas Plaintiff . Civil Division v. . CUMBERLAND County SARATOGA OCEAN MIKHAIL OCEAN No. 09-6753-CIVIL TERM Defendants CERTIFICATION OF SERVICE 218615 I hereby certify that a true and correct copy of the Rule Returnable noting a Rule Return date of August 10, 2010 was sent to the following individual on the date indicated below. SARATOGA OCEAN MIKHAIL OCEAN 14 DESCANSO ROAD SANTA FE, NM 87508-9125 SARATOGA OCEAN MIKHAIL OCEAN 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 SARATOGA OCEAN MIKHAIL OCEAN 19 ESTRADA REDONDA SANTA FE, NM 87506 SARATOGA OCEAN MIKHAIL OCEAN PO BOX 22247 SANTA FE, NM 87502-2247 Phelan Hallinan & Schmieg, LLP DATE: ~l Z (~ O By: I_j Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ATTORNEY FOR PLAINTIFF 218615 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY PHH MORTGAGE CORPORATION PHS # 218615 DEFENDANT SERVICE TEAMI spl SARATOGA OCEAN MIKHAIL OCEAN COURT NO.: 09-6753-CIVIL TERM THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE MIKHAIL OCEAN AT: 14 DESCANSO ROAD SANTA FE, NM 87508-9125 TYPE OF ACTION XX Notice of Sheriff s Sale SALE DATE: 09!08/2010 U SERVED Served and made known to 1-1~~, O~Al~ ~ Pendant on the ~t~ day of ~~, 20 ~Q, at 1,50 ,o'clock'. M., at~~1~S('Ar1hb~. Jilt~1~0-~ 111'1 , in the manner described below: Defendant personally served. _ Adult family member with whom 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. an officer of said Defendant's company. _ Other: q Description: Age ~~ Height ~! Weight ~ (D~J Race CAN Sex ~ Other I, , a competent adult, being duly sworn according to law, depose and state that I pers n 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. •~ ~ ~ ~ ~ `Sv,~orn tti.and subscribed ~ •'- before me this ~_ day ~~~ ~RfThla M. Bovvetf of , 20~Q wa.~arii. of By: NOT SERVED On the day of , 20_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Bad Address No Answer Service Refused Other: Sworn to and subscribed obeffore me this ,~~ day Notary: By: _ Moved _ Dces Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lasrrena T. PAdne, Esq., Id. No. 32227 Francis S. IlaBinwy Esq., Id No. 62695 Dade! G. Schmiey Esq., Id. No. 62205 Midrde M. Bedford, Esq., id. No. 69049 Jud11A T. Roeaao, Esq.., Id. No. 58745 Sheeld R Shah-Jam Feq., Id. Nw 81760 Je~hK R Davey, Esq., ld. No. 87077 Laaea~ R Tahas, Esq., id. No.43337 Vivdc SNvselava, Esq., Id. Nw 207331 Jay B. Jone+. Esq., Id. No. 86657 Peter J. Mnkahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., b. No. 84439 Jahne McGahu~, Esq., Id. No. 90134 (;htfsovahmie P. F6kas, Esq., Id. No.94620 3o~ea L GoHea0. Esq., Id. No. 205047 Consienay R Dnp0. Esq., Id No. 286279 ,~,~, ~. ~, u,~6 ~ a: 3SP/`7 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY PHH 11^IORTGAGE CORPORATION PHS # 218615 DEFENDANT SERVICE TEAM/ snl SARATOGA OCEAN MIKHAIL OCEAN COURT NO.: 09-6753-CIVIL TERM THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE SARATOGA OCEAN AT: 14 DESCANSO ROAD SANTA FE, NM 87508-9125 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 09!08/2010 SERVED Served and made known to'p, ,Defendant on the ~ day of 201.~,,at ..~ ~l :~, o'cloekQ . M., at i`I w ~~` , in the manner descri d below: r_ `~' 1 ~~ + i _ Defendant personally served. ~_, ~ -= ~ _.~ X Adult family mem r with whom Defendant(s) reside(s). ~~' . ~~? Relationship is M;~~~d ~ ~ _ ~~. C to ~ ; -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. 3 _ an officer of said Defendant's company. ~: _ Other: :--, w - : t ~p ~ De cription: Age ~~ Height ~ 1 Weight ~. Race (~l~ Sex ~ Other I, , a competent adult, being duly sworn according to law, depose and state that I perso handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case orr the date and at the address indicated. above. • • ~ ~ Sworn to and• subscribed • ~ ~ ~ - • • before me this !~ day ~ a~~w, of ~ , 20/O ~~ ~• + Ilan e•wsl>F r~ loo tary: By: rra.~wenw u --`°`-- NOT SERVED On the day of , 20 , 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 before me this day of -~_. By: Notary: ATTORNEY FOR PLAINTIFF lawsenoe T. Phew, Esq., Id. Nw 322'27 F'aocis S. PLi8lnao, Esq., Id. Nw 62695 Dank! G. Srhmie8, Esq., Id. Nw 62265 MkMk M. Bsadfmd, Esq., b. Nw 69849 Judith T. Ramanq Esq., ld. Nw 58744 Shedai R Shah•Jaai, Esq., ld. Nw 81760 ]mine R Davey, Esq, Id. No.87077 Isw~en R Tshas, Esq., Id. Nw 93337 Vivdc Srivaswra, Esq., Id.. Nw 202331 Jay B. Joaea, Esq,/d. No. 86667 - Prier J. Mekehy, Esq., Id. Nw 61'791 Andrew L Spivack, Esq., hl. No. 84434 Jahne McGuinness, Esq., id. Nw 90134 Chrisovalante P. FBakas, Esq., Id. Nw 94620 Joshua i. Coldnum, Fsq, Id. Nw 206047 Cou~Ynwy R Duau, Feq., Id. Nw 206779 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PHH MORTGAGE CORPORATION Plaintiff, v. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) CUMBERLAND COUNTY COURT OF COMMON P~.,EAS CIVIL DIVISION No. 09-6753-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.I COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". ^"~ ^ L rence T. Phelan, Esq., Id. No. 32 ~ ~' o _.r ^ Francis S. Hallinan, Esq., Id. No. 62b9~ '~ ~ ^ Daniel G. Schmieg, Esq., Id. No. 62205. ^ Michele M. Bradford, Esq., Id. No~49~ C~ : ,~ ~ ~_ ^ Judith T. Romano, Esq., Id. No. 585' c ~ ^ Sheetal R. Shah-Jani, Esq., Id. No.~1760 _ ~ ^ Jenine R. Davey, Esq., Id. No. 870~;~ ~' ~ ^ Lauren R. Tabas, Esq., Id. No. 933~37~:;- (,p~ ^ Vivek Srivastava, Esq., Id. No. 20233~~ ~ ^ Jay B. Jones, Esq., Id. No. 86657 J ^ Peter J. Mulcahy, Esq., Id. 1\Tc. 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 Date: ~ ~ ((~ IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the alaintiff at the Sheriff s Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 218615 ~'HH 1tSIORTGAGE CORPORATION Plaintiff v. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-6753-CIVIL TERM CUMBERLAND COUNTY AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 PHH MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1 I8 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) SARATOGA OCEAN MIKHAIL OCEAN Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 14 DESCANSO ROAD SANTA FE, NM 87508-9125 14 DESCANSO ROAD SANTA FE, NM 87508-9125 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) MID PENN BANK MID PENN BANK MID PENN BANK C/O KELLY M. KNIGHT, ESQUIRE GRAYSTONE BANK GRAYSTONE BANK C/O MICHAEL L. SOLOMON, ESQUIRE MARKET SQUARE PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17101 MARKET SQUARE. PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17103 2320 NORTH 2ND STREET, P.O. BOX 60457 HARRISBURG, PA 17106-0457 112 MARKET STREET HARRISBURG, PA 17101-2043 240 NORTH 3RD STREET, 7~ FLOOR HARRISBURG, PA 17101-1503 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY SNELBAKER & BRENNEMAN PC C/O RICHARD C. SNELBAKER, ESQUIRE 44 WEST MAIN STREET MECHANICSBURG, PA 17055-6249 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare UNITED STATES INTERNAL REVENUE SPECIAL PROCEDURES BRANCH FEDERATED INVESTORS TOWER U.S. DEPARTMENT OF NSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA 118 STONEHEDGE DRIVE CARLISLE, PA 1.7015-9116 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 FEDERAL BUILDING, P.O. BOX 11754 228 WALNUT STREET HARRISBURG, PA 17108 STONEHEDGE HOMEOWNERS ASSOCIATION INCORPORATED STONEHEDGE HOMEOWNERS ASSOCIATION, INC. STONEHEDGE HOMEOWNERS ASSOCIATION, INC. 39 GARLAND COURT #2 CARLISLE, PA 17013-4409 4101 NORTH Ern STREET, # 2057 HARRISBURG, PA 17110-1610 P.O. BOX 2057 HARRISBURG, PA 17105-2057 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date ~ ~~4~(~ By: ~ r Attorn or Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Name and Plan 8c LLP :_ & Address ~ 1617 JFK'Bqul4vard, Suite 1400 Of Sender bne Penti~Ceate~r Plaza PA 19303 JOT/i'NW - SEPTEMBER 2010 SALE Line Article Number Name and Past O1~xx Addrep p~ 1 •iAR y~ lf3G'C[lPANf ~ d1i: ~ E DR1VE k17015-9116 ._. _ ._... 2 •"•« Don Retatioa~ of Crmt+s~Ia1~d Coaaty o m 13NorN Rauo~ler Street ` ~ n a ~ ~ o PA~17013 ~ 1 g •«w,r Gonmodwealtli.otPwo~ylvaala 1 ~ ~ Dspartaiaat of Welhre ~ ~ P:O:1Aoi 2673 M - P17105 4 •a~Fk yam V~ aa 'Y I STiA~1Z$lN1XRlYALREVFN[lE ~ I umi~ . p ~ ~ ~ ~ .I;PLCIAI. PROCEDURES BRANCH ', ~ LL ` FEDERATED gVYE8TOR9 TOWER ~ .,~. ~ o 13TS Ff.OpR, 8011'& 1300 1041. LIBERTY AVENUE o o iii Q~Mf~ N O.~ P `PA. .• •~ 5 "*** i1.8. AR~'MLYVTOFJUSTICE U.S. ATTOIll~IEY FOR THE MIDDLE DL?fRICT OF PA ilL~~ ~~P.O: BOX 11754 PA 17108 6 PJ1NN MAR1~T.l~j uA$E ~ _ .. ' 17 N08Tf~~ ,t'(~hID ET ..... JEA 17101 7 110D MABLICBT Bt~UARE PI.A7d 14 NO1M}'H:$NDSTRY.ET "16i-17103 8 MD} . (70 ~ IQi.L1FM,:f3H7', ESQUIRE . 23]0 NOR1'HZaO'STREET, P.O. BOX 60457 Pi- 1710b-0157 9 `(BLt 11i~MAIE~I'dCdi11LET . .147101-3043 1' 10 GRA GO ~ MICHAEL I8tO1GOMON, ESQUIRE ~ t401YO~H:E~°'STRESf, 7~ FLOOR PA 17101-ISOti t1 ~ 15 RE: SARk'1'OGA OCEAN CUMH TEAM 3 Pffip 218615 ra~rn~e.ror n~.t.~.uabysenmr radNmb.ratri.or ra~et. re.mu. dwhnknq~tlda .a.a~ruotnd...aau.'iLs a.ahaaasowoIDo. Reomvha to.tlrnoo.mwiooor doao.oa.arB~W..btmdoamrotnoerueoUo~lo~.~e.asw.OWp~rt ~ p~ >~ atillakd vro~~.w.'13~eedsoaew~ypwa.a.m~...ewmr~.etst.ssoo. 're. 5a . s , . r. r usooo sK ~.d~cva.o~a...s.~u aaaW.i tee, sa nom rri . a9oos91]~odav~iffr daow~e. L Name and PhbluiI~Ulinan dt 3chmieg, LLP Address Ibl'7 JFR ~ouievud, Suite 1400 Of Sender Qrti"ry`~~,` Center Pla3a 13hi1w~Aia PA 1 Ol Al rnTTwiev eaea~ra~rntrn e ~ . r zA Lme Article Number Nsui~ alai PosE ORke Addt+da P Fee 1 •••• HOMEOWNERS ASSOCIATIbN INCORPORATED 3! G9~,1.;AND~COURT 1a'Z PA 17013-~W09 0 0 2 •••• DGE HOMEOWNERS ASSOCIATION, nvc. ~R ~ 4101;~' IQRTH 6~ STREET # 2057 I` , , G PA 17110-1610 et"" 3 •"*+ DGE HOMEOWNERS ASSOCIATION, INC. ~ ~~ P.Of $O~X,.2057 R1 HARRI$1¢URG PA 17105.2057 I w q •ara ~ 1 ~ 5 •••a ~ q 6 ...• ~ ~ ~v'J` 7 •R•a No~ ~lMfl 0 0 8 a•w• g raw• 10 awRa 11 •aRa 13 •••. , 14 •••• 15 *••* RE: SARATOGA OCEAN CUMBERLAND TEAM 3 . P1~31M 218615 row Num Pisrot Li ber of ra.i Nubx otPbme Yeeimn~r, Per P~ or ~ ILe .otvame i rpied m as sa. 13s minim tad ned by Seodar Rewied et gar Offiee R.adviuf ) - lbrtlm remaerwtfeadoomrae~hle dowwo4~ 0mnaoe u emehy 9are~ 530,000 pr h iw R ~ ' m lodmeiU'PRYebM b 7 east Damrtio A,LiI A4nwl 8900 X13 sod 5931 Pon lfmite6aoeat 'L' .. . ~~ {~ a m N 'O G ~~ ~~d ~. ~ ~o '^ 0 rv Sti ~. 0 ~y s: ~ ~n ab ~; ~~ ~~ 'II ~ A y 8 y A ~_°~.~~ a "'FRB A a~ o N_ R 'w ~ ~. O_~ M 3~~ ~ ~, O y~y.~ "~'~ N (f U ~ ~ m p (Ai ~ O F ~ ~ 4 B ~ ~. ~ „ n ~~ ~. g~9a H r~ ~~y~ s E a =~ -~° a= ~~~~. a~ ~ ~ ~~ F~~~~ ~x?.~ 9s~ yn=a R"='~ 8~~~~ n ~ ~n n'~ y'c ~~H " 3 ~` 8 ~y~~~ ~ ~ ~ w -o Q o rn ~IAIWINI~IoI~I~I~I~I~IAIWIN ~F ~F ~F 7F ~F 4 ~F 7F ~F 7F ~F ~F I IF I 7F ~F IF 7F ~F ~F k- ~F 7F ~F 7F ~F ~F ~F ~F ~F 7F ~F 7F ~F if * ~ * * * ~F ~F t ~F ~F ~F ~F ~F ~F ~F ~F 7F M~ 7F ~F 7F ~F a O z 7~ F~+1 11.1 V N Y y Q '~+S ~3T~~~® • ~~r® r ., ® PITNEY BpyYES ~1.26~ ` 02 1M 0004277256 JUL 27 2010 MAILED FROM ZIP CODE 1 9103 r oaz ~' -*~ a w ~ ~ p- ~ c~ co =; a ~ ~~~ A ~F N f~D ~, w ~ o -n Y,.~nY '"~,~ x~ f~~Yt~~a~' ~ o ~' gznR°r"y _m R' b~~zz°;~~~~ ~~~~~m ~~ o ~~~ or tail t~i7 !~~, ~ °~ ° b 'v ~nb~ O ~ C "-~"~ ~ ~ ~ ~ Q ~~..y r y ~/ !1a 1 OO ': ' / ° H P . t ~ t ~ ~ ~ . ~ 1 ~ ~ P OOf . "r7 r My I N SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,~. Ronny R Anderson s Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~„tr of ~sfi~n~r~~r~~ ~ Yeas Y1~~~. QF>=:GE C?F TrtE ..cRiFf FILED-QFFICE ~I"" T~rE PPOTNONOTAPY 2010 OCT 20 ~ 9~ 45 ~lM~ERLAh~U COUNTY PEhEdSYLVANIA PHH Mortgage Corporation Case Number vs. Saratoga Ocean (et al.) 2009-6753 SHERIFF'S RETURN OF SERVICE 05/12/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice of Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant to wit: Saratoga ocean to her last known address of, 14 Descano Road, Sante Fe, New Mexico, 87508 The return receipt card was signed by, Michail Ocean, on 7/13/10 and returned to the Cumberland County Sheriff's Office. 06/26/2010 08:06 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-2010 at 0806 hours, he posted a true copy of he within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Saratoga & Mikhail Ocean, located at, 118 Stonehedge Drive, Carlisle, Cumberland County, Pennsylvania according to law. 07/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice of Sale and Description in the following manner: The Sheriff mailed a notice of the action by certified mail, return receipt requested to the within named defendant to wit: Mikhail Ocean, to his last known address of, 14 Descano Road, Sante Fe, New Mexico, 87508. The item was returned "unclaimed, unable to forward", however, Mikhail Ocean, signed the return receipt for Saratoga Ocean at this same address on, 7/13/10. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg on behalf of Fannie Mae, P.O. Box 650043, Dallas, TX 75265, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 763.92 SHERIFF COST: $763.92 October 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF a-E~ Pdr C~. ~ ~~. ~h~ ~~~i~ a~~' ~~3 (ci CounfySuit~: ShenfT. Teleosoft. Inc. PHH MORTGAGE CORPORATION Plaintiff ~ , v. SARATOGA OCEAN MIKHAIL OCEAN Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 COURT OF COMMON PLEAS CIVIL DIVISION NO.09-6753-CIVIL TERM CUMBERLAND COUNTY PHH MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116. 1. 2. Name and address of Owner(s) or reputed Owner(s): Name SARATOGA OCEAN MIKHAIL OCEAN Name and address of Defendants} in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 5. SAME AS ABOVE 14 DESCANSO ROAD SANTA FE, NM 87508-9125 14 DESCANSO ROAD SANTA FE, NM 87508-9125 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) MID PENN BANK MID PENN BANK MID PENN BANK C/O KELLY M. KNIGHT, ESQUIRE GRAYSTONE BANK GRAYSTONE BANK C/O MICHAEL L. SOLOMON, ESQUIRE MARKET SQUARE PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17101 MARKET SQUARE PLAZA 17 NORTH SECOND STREET HARRISBURG, PA 17103 2320 NORTH 2ND STREET, P.O. BOX 60457 HARRISBURG, PA 17106-0457 112 MARKET STREET HARRISBURG, PA 17101-2043 240 NORTH 3RD STREET, 7~ FLOOR HARRISBURG, PA 17101-1503 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. , Name ~ ~ ' Address (if address cannot be ' reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare UNITED STATES INTERNAL REVENUE SPECIAL PROCEDURES BRANCH FEDERATED INVESTORS TOWER U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA 118 STONEHEDGE DRIVE CARLISLE, PA 17015-9116 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 FEDERAL BUILDING, P.O. BOX 11754 228 WALNUT STREET HARRISBURG, PA 17108 STONEHEDGE HOMEOWNERS ASSOCIATION INCORPORATED STONEHEDGE HOMEOWNERS ASSOCIATION, INC. STONEHEDGE HOMEOWNERS ASSOCIATION, INC. 39 GARLAND COURT #2 CARLISLE, PA 17013-4409 4101 NORTH 6'$ STREET, # 2057 HARRISBURG, PA 17110-1610 P.O. BOX 2057 HARRISBURG, PA 17105-2057 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. April 26, 2010 By: Attorney for Pl tiff 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 PHH MORTGAGE CORI50RATION Plaintiff COURT OF COMMON PLEAS vs. SARATOGA OCEAN MIKHAIL OCEAN CIVIL DIVISION N0.09-6753-CIVIL TERM CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SARATOGA OCEAN MIKHAIL OCEAN 14 DESCANSO ROAD SANTA FE, NM 87508-9125 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY ** Your house (real estate) at 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116 is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 8, 2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $356,688.88 obtained by PHH MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 a1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7004. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution N0.49-6753-CIVIL TERM PHH MORTGAGE CORPORATION vs. SARATOGA OCEAN MIKHAIL OCEAN owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, (Municipality) Pennsylvania, being 118 5TONEHEDGE DRIVE. CARLISLE, PA 17015-9116 (Acreage or street address) Parcel No. 40-23-0602-204 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $356,688.88 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or parcel of land and the improvements thereon, situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right-of--way line of Stonehedge Drive, a sixty foot wide right-of--way, said point also being the southwest corner of Lot No. 34; thence along the western right-of--way line of Stonehedge Drive, South twenty-one (21) degrees fifty (50) minutes zero (00) seconds West a distance of forty-three and sixty-four hundredths (43.64) feet to a point; thence along the same and a curve to the right having a radius of two hundred seventy and zero hundredths (270.00) feet and an arc distance of one hundred and zero hundredths (100.00) feet, said arc being subtended by a chord of South 32 degrees 26 minutes 37 seconds West, a chord distance of ninety-nine and forty-three hundredths (99.43) feet to a point at the corner of Lot No. 32 of the Stonehedge PRD Stage 3A also being in the center of a 40 foot wide drainage swale; thence along Lot No. 32 and the center of said swale, North forty-four (44) degrees fifty-nine (59) minutes thirty-eight (38) seconds West a distance of one hundred forty-three and twenty- five hundredths (143.25) feet to a point in the center of the aforesaid 40 foot wide drainage swale at lands now or formerly of Stonehedge Developers, Inc.; thence along said land of Stonehedge Developers, Inc. and the center of said swale, North twenty-one (21) degrees fifty (50) minutes zero (00) seconds East a distance of eighty-five and zero hundredths (85.00) feet to a point at the corner of Lot No. 34; thence along Lot No. 34, South sixty-eight (68) degrees ten (10) minutes zero (00) seconds East, a distance of one hundred fifty and zero hundredths (150.00) feet to a point, the point of beginning. SUBJECT TO a twenty (20) foot wide drainage easement along its southern property line common with Lot No. 32, and a twenty (20) foot wide drainage easement along its western property line with other lands of Stonehedge Developers, Inc. CONTAINING 0.39 acres, more or less, and identified as Lot No. 33 of Stonehedge PRD Stage 3A, recorded in Plan Book 69, Page 13 in Cumberland County Recorder of Deeds Office, Carlisle, Pennsylvania. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 311, Page 42, and subject to a Supplemental Declaration of Covenants and Restrictions recorded in Cumberland County Miscellaneous Book 503, Page 404, and further subject to the Bylaws of the Stonehedge Home Owners Association as recorded in Cumberland County Miscellaneous Book 311, Page 511. TITLE TO SAID PREMISES IS VESTED IN Mikhail Ocean and Saratoga Ocean, h/w, by Deed from Vallery Clouse, single woman, dated 09/30/2005, recorded 10/03/2005 in Book 271, Page 1225. PREMISES BEING: 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116 PARCEL N0.40-23-0602-204 WRIT OF EXECUTION and/or ATTACHMENT .- , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6753 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PHH MORTGAGE CORPORATION Plaintiff (s) From SARATOGA OCEAN and MIKHAIL OCEAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $356,688.88 L.L.$.50 Interest from 3/30/10 to Date of Sale ($59.45 per diem) -- $9,690.35 Atty's Comm Atty Paid $198.40 Plaintiff Paid Date: 5/3/10 (Seal) Due Prothy $2.00 Other Costs i David D. Buell, Prothono By: Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 ll~ On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 118 Stonehedge Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 B: c~~. ~~~.~~~~ Real Estate Coordinator _ ~ -~ ~; ~ ~~{ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal; a-legal periodical published in the Borough of Carlisle in the County and.State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication aze true. wnt fro. ~-spas ci.a PHH Mortgage Corporation vs. Saratoga Ocean Mikhail Ocean Atty.: Daniel Schmieg By Virtue of a Writ of Execu- tion NO. 09-6753-CIVIL TERM, PHH MORTGAGE CORPORATION vs. SARATOGA OCEAN, MIKHAIL OCEAN, owners of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, Pennsylvania, being 118 STONEHEDGE DRIVE, CARLISLE, PA 17015-9116. Parcel No. 40-23-0602-204. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: X356,688- .88. 'sa Mane Coyne, E itor SWORN TO AND SUBSCRIBED before me this 30 da of Jul 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY Mp Commbsion Explns Apr Z8, 2014 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 Sheriffl s Deed in which Fannie Mae is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 3rd day of May, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 6753, at the suit of PHH Mortgage Com against Saratoga & Mikhail Ocean is duly recorded as Instrument Number 201030009. IN TESTIMONY WHEREOF, I haveto set my hand and seal of said office this ~ day of The Patriot-News Co. 20x0 Technology Pkwy Suite 3Q0 -- Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the ~Jatriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 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: Writ No. 2009-6753 Civil Tenn 07/09/10 ° PHH Mortgage Corporation vs 07/16/10 Saratoga Ocean 07/23/10 .. Mikhail Ocean 1 Atty: Daniel Schmieg ( ~ 1 " By Virtue of a Writ of Execution N0.09-6753- _~-"}` -~J` CIViL TERM PHH MORTGAGE CORPORATION / ' _ sARAT(X;AOCEAN 1 Sworn t~d subscribed before ,#fii 5of August, 2010 A.D. - Fi , MIIQ3t1IL OCEAN ' \ ~ r ~ ,,~ ~< i ~' owner(s) of property situate in SOUTH ,~1 ~~ ~, ~ ; : f ; ~ ~+~ ~ ~~',_ MIDDLETON TOWNSHIP, Cumberland `'-. l ~ ~---- - -- -. _ ._ connty, Notary Public _rv _-..___ (Municipality) Pennsylvania, being 118 3TONEHEDGE DRNE, CARLISLE, PA 17015-9116 COP~iNiOdWWEALT'ii uw ~Ei'~lVSYi;~~IUU~ (Acreage or street address) _ Notarial Sea; -l-_---~-° ~ Pazcel No. 40-23-0602-204 Sherrie L Kisner, .Nara ' Improvements thereon: RESIDENTIAL I ry Ftrh(i; + Lower Parton Twp., Dauphin Co~nt',~ j DWELLING ~ IWy Camm[ss[on Expires Nov, 26, 2011 NDGMENTAMOUNT: $356,688.88 b'!emher, Pennsylvania Ass~~ ocfagfofi oa"- yo?apf;~-`I