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HomeMy WebLinkAbout09-7963Phelan 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 o,'<heetal 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 221137 CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 V. Plaintiff FRANCIS J. LAFFERTY, IV 3211 NORTH FRONT STREET HARRISBURG, PA 17110 JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. OQ -'M-3 010-tC-l 'W n CUMBERLAND COUNTY File #: 221137 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 #: 221137 1. Plaintiff is CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: FRANCIS J. LAFFERTY, IV 3211 NORTH FRONT STREET HARRISBURG, PA 17110 JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/04/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR COMMERCE BANK/HARRISBURG, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1937, Page 0126. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 221137 6 The following amounts are due on the mortgage: Principal Balance $202,966.60 Interest $5,849.25 06/01/2009 through 11/12/2009 (Per Diem $35.45) Attorney's Fees $1,300.00 Cumulative Late Charges $330.65 01/04/2006 to 11/12/2009 Cost of Suit and Title Search %5-50L00 Subtotal $210,996.50 Escrow Credit $0.00 Deficit $199.25 Subtotal $199-2-5 TOTAL $211,195.75 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 Sheriff s Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is nat seeking a judgment of personal liability (or an in ners? onam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 221137 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $211,195.75, together with interest from 11/12/2009 at the rate of $35.45 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By- El Lawrence T. Phel , 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 ? J ith T. Romano, Esq., Id. No. 58745 L'J Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 221137 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of West Maplewood Avenue at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along the northern side of West Maplewood Avenue, South 68 degrees 52 minutes 10 seconds West, a distance of one hundred two and forty-nine hundredths (102.49) feet to the eastern side of South Frederick Street; thence along the eastern side of South Frederick Street, North 14 degrees West, a distance of one hundred sixteen (116) feet to a point; thence North 66 degrees 59 minutes 30 seconds East, a distance of eighty-eight and fourteen hundredths (88.14) feet to the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan; thence along said dividing line, South 21 degrees 7 minutes 50 seconds East, a distance of one hundred seventeen and ninety-nine hundredths (117.99) feet to a point on the northern side of West Maplewood Avenue, at the point or place of Beginning. CONTAINING 11,095 square feet and being Lot No. 1 on the final subdivision plan for Harson, Inc., as recorded in the Cumberland County Recorder's Office in Plan Book 50, at Page 74, and being 24 West Maplewood Avenue, Mechanicsburg, Pennsylvania. Parcel No.: 16-24-0787-135 PREMISES: 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428 File #: 221137 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: 4 Attorney for Plaintiff File #: 221137 S ZG9y ?`? F,r1 ?7e.so CK-4- 81L54$ r2?-a33?i/ SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Chase Home Finance LLC vs. Jennifer E. Lafferty ~~~~~tii~, of ~u:,~(~,~p~~~~ - -.~: ~~ _~ ~ ~' 20~~ CAL - I ~ ~ ~ 2~ ~ 3 Case Number 2009-7963 SHERIFF'S RETURN OF SERVICE 11/17/2009 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: Francis J. Lafferty IV, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 11!20/2009 09:38 AM -Dauphin County Return: And now November 20, 2009 at 0938 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Francis J. Lafferty IV by making known unto Barbara Moyer, Receptionist at 3211 North Front Street, Harrisburg, PA 17110 its contents and at the same time handing to her personally the said true and correct copy of the same. 11/23/2009 08:42 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2009 at 2042 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Francis J. Lafferty IV, by making known unto himself personally, at 24 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. 11/23/2009 09:50 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2009 at 2150 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer E. Lafferty, by making known unto herself personally, at 251 N. Saint Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 11/30/2009 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: Jennifer E. Lafferty, 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 Jennifer E. Lafferty. Request for service at 24 West Maplewood Avenue, Mechanicsburg, PA 17055 is occupied by Francis J. Lafferty IV. SHERIFF COST: $100.00 SO ANSWERS, T .i~~~~/IC ,,.+1 November 30, 2009 R THO~~KLI E, HERIFF BY ty Sher ;c ~., ~ - i ~ 'f ~~s;~fl hu. Mary Jane Snyder Real Estate Depu William. T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles, E. Sheaffer Chef Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin CHASE HOME FINANCE LLC VS FRANCIS J LAFFERTY, IV Sheriff s Return No. 2009-T-2957 OTHER COUNTY NO. 20097963 And now: NOVEMBER 20, 2009 at 9:38:00 AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon FRANCIS J LAFFERTY, IV by personally handing to BARBARA MOYER 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 3211 NORTH FRONT STREET HARRISBURG PA 17110 RECEPTIONIST Sworn and subscribed to before me this 20TH day of November, 2009 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County M Commission F,x fires Se i i, 2010 So Answers, Sheriff of Dauphi Co nty,~P , ,~ ~ By • ~. u., c~` Deputy Sheriff - Deputy: KEVIN MARTIN Sheriffs Costs: $47.25 11/19/2009 F, PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CHASE HOME FINANCE LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. N0.09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY CUMBERLAND COUNTY Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 06/09/2010 to Date of Sale ($35.93 per diem) TOTAL 8'~.y.do o~ ~k~ 9~s3~i: ~-''~ ~S3 8'd ~7Q:,SD E~~FS ~ F ~ ,~ i~ ~~,o a ~-~., s'a P'~' `may ~/ o b, a D co s-~ B F ~~1 1 •~~ p~ ~~ Se2.,dd ~~.LCo ~'~ ~f~ ~~tC J-L c~ $218,569.35 .,~ ~ +~ r 7-; ~ ~ 6 575.19 . ,. =r' ~ ~ ~:.:~ , _ ~_ ,v ~_.. ~Y .. : -cr ~`= $225,144.54 c. _ ~ ~`-' -~ ~- C'',. Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ La ence T. Phelan, Esq., Id. No. 32227 rancis 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 rv _~ Q t... r-- v, -~ 7~ xj ~' ~-, '~~: ,,} ~w :~ --G Note: Please attach description of property. PHS # 221137 w I~ Oa ~H U~ O~ ~~ O~ ~~ ~U U a zW d w o .~ Wa H a w~~ a~ awl ~W ,,.., ~ A U w ~' w~ Oo w O~ w ~° ~~ W 'u a~ H f~ a a °~' 3 b Q 1 F~ `-r O ~ ~ ~ H .... w~a ¢w~ ~O~ ~z~ ~~¢¢ wMx y, w wAo wzNz~ aoa ai ~+ ..~ Q a ~~~ ti N U 0 N y~ O N ~ ~ ~ ~ ,.., ~ d' ~ ~ ~ OMO Q~ O v1 ~ M ~ [~ N~ON~~t'O~Ol~l~cM+~ ^-~~~ ON~pN M b~ ~ O M N ~ pp ~ ~" O N O p,,z o oz o,Z~o~o~N„ o 0 0~ o oz b ~w..~ ~~ W ~ ~ ~W " " ~, y"y o °" y y :~ w ~wo"now~~www'~w.~ y ~ v H W ~ a•d ~ ~~x A ~ a o,a ~ ~~ ~ci w s ~ y~ E"~p4~'v~ °~ 3~~ a 3 ¢a^ ^^^0~^^~^~~0^0^ LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more pazticulazly bounded and described as follows, to wit: BEGINNING at a point on the northern side of West Maplewood Avenue at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along the northern side of West Maplewood Avenue, South 68 degrees 52 minutes 10 seconds West, a distance of one hundred two and forty-nine hundredths (102.49) feet to the eastern side of South Frederick Street; thence along the eastern side of South Frederick Street, North 14 degrees West, a distance of one hundred sixteen (116) feet to a point; thence North 66 degrees 59 minutes 30 seconds East, a distance of eighty-eight and fourteen hundredths (88.14) feet to the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan; thence along said dividing line, South 21 degrees 7 minutes 50 seconds East, a distance of one hundred seventeen and ninety-nine hundredths (117.99) feet to a point on the northern side of West Maplewood Avenue, at the point or place of Beginning. CONTAINING 11,095 square feet and being Lot No. 1 on the final subdivision plan for Harson, Inc., as recorded in the Cumberland County Recorder's Office in Plan Book 50, at Page 74, and being 24 West Maplewood Avenue, Mechanicsburg, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Francis J. Lafferty, IV and Jennifer E. Lafferty, h/w, by Deed from Stewart C. Taylor, married man, dated O 1 /04/2006, recorded O 1 / 10/2006 in Book 272, Page 3531. PREMISES BEING: 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428 PARCEL NO. 16-24-0787-135. Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff v. FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) FlLE~a ~ r {.:'~~ Attorneys for Plaintiff 201Q J~}L 16 PSI ~~ COURT OF COMMON PLEAS CIVIL DIVISION CERTIFICATION NO.09-7963 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 ^ L ence T. Phelan, Esq., Id. No. 32227 rancis 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 CH~SE HOME FINANCE LLC ^~ Plaintiff V. FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) 2Qi0 J~~ 1 ~ PPi 3~ U ~;~ :. CU~~~~.:- - ~ :{~uI~1~Y COURT OF COMMON PLEAS CIVIL DIVISION N0.09-7963 CIVIL TERM CUMBERLAND COUNTY PHS # 221137 AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428. Name and address of Owner(s) or reputed Owner(s): Name FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 3211 NORTH FRONT STREET HARRISBURG, PA 17110 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 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) None. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) COMMERCE BANIC/HARRISBURG, N.A. 100 SENATE AVENUE CAMP HILL, PA 17011 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. v .~ 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 JENNIFER E. LAFFERTY C/O MICHAEL SCHERER, ESQUIRE 24 WEST MAPLEWOOD AVENUE MECHANICSBURG, PA 17055-6428 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 19 W SOUTH STREET CARLISLE, PA 17013-3444 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. July 12, 2010 Bv: Attorney for Plaintiff Phelan Haltinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 [a'):rancis 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 i~ ..' CHASE HOME FINANCE LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. N0.09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV CUMBERLAND COUNTY JENNIFER E. LAFFERTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY _ ~ ° --n TO: FRANCIS J. LAFFERTY, IV ~ ° ~~i ~~ 3211 NORTH FRONT STREET ~ Tf ~ ~ t HARRISBURG, PA 17110 X~r; ` r - -° r c~ JENNIFER E. LAFFERTY ~ T 4 r _ `' ~' .~- 251 SAINT JOHNS DRIVE -~' ~=~ c,~~ i _t. ` `'~`~' CAMP HILL, PA 17011 ~ ~• * *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 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055- , 6428 is scheduled to be sold at the Sheriff s Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $218,569.35 obtained by CHASE HOME FINANCE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 21230. 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.) a a 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 Sheriffis 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 compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shaze 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 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of West Maplewood Avenue at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along the northern side of West Maplewood Avenue, South 68 degrees 52 minutes 10 seconds West, a distance of one hundred two and forty-nine hundredths (102.49) feet to the eastern side of South Frederick Street; thence along the eastern side of South Frederick Street, North 14 degrees West, a distance of one hundred sixteen (116) feet to a point; thence North 66 degrees 59 minutes 30 seconds East, a distance of eighty-eight and fourteen hundredths (88.14) feet to the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan; thence along said dividing line, South 21 degrees 7 minutes 50 seconds East, a distance of one hundred seventeen and ninety-nine hundredths (117.99) feet to a point on the northern side of West Maplewood Avenue, at the point or place of Beginning. CONTAINING 11,095 square feet and being Lot No. 1 on the final subdivision plan for Harson, Inc., as recorded in the Cumberland County Recorder's Office in Plan Book 50, at Page 74, and being 24 West Maplewood Avenue, Mechanicsburg, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Francis J. Lafferty, IV and Jennifer E. Lafferty, h/w, by Deed from Stewart C. Taylor, married man, dated 01/04/2006, recorded 01/10/2006 in Book 272, Page 3531. PREMISES BEING: 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17056428 PARCEL NO. 16-24-0787-135. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-7963 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC Plaintiff (s) From FRANCIS J. LAFFERTY, IV AND JENNIFER E. LAFFERTY (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$218,569.35 L.L.$.50 Interest INTEREST FROM 06/09/2010 TO DATE OF SALE ($35.93 PER DIEM) - $ 6,575.19 Atty's Comm % Due Prothy $2.00 Atty Paid $219.00 Other Costs Plaintiff Paid Date: JULY 16, 2010 Da ' .Buell, Pr thonotary (Seal) By: Deputy REQUESTING PARTY: Name FRANCIS S. HALLINAN, 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. 62695 PLAINTIFF CHASE HOME FINANCE LLC DEFENDANT FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY AFFIDAVIT OF SERVICE (FNMA) CUMBERLAND COUNTY n C SERVE FRANCIS J. LAFFERTY, IV AT: 3211 NORTH FRONT STREET HARRISBURG, PA 17110 **DIVORCED- ONE CANNOT ACCEPT SERVICE FOR OTHER** SERVED PHS # 221137 K .0 n-1 r_ t SERVICE TEAM/ kxc ti COURT NO.: 09-7963 CIVIL, TEId fir - . -„ TYPE OF ACTION ' c XX Notice of Sheriff's Sale SALE DATE: 12/08/2010 c?a -rt t ,? rT1 .. .ern fV -G t-l Served and made known to FRANCIS J. LAFFERTY, IV, Defendant on the 20 day of , 20 IP, at 4_ , o'clock ]?. M., at tit Gtf?+v?t 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, eoe- !9 el; r -, w f le ,r>L an officer of said Defendant's corn any. Other: 1'?+dC• 2fcjJ 'r l- ?.: /1 k? X1;1' ?'?e'C T i 0• Description: Age _ 35' Height S C - Weight _? - Race W Sex A4 Other I,? -+i?e L?th+i? I?•?irr , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of7LZ-- NotaBy: t NOT S ERVED On the day of , 20_, at o'clock M., Defendant NOT FOUND because: - Vacant Bad Address - Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of 20__ By: Notary: ATTORNEY FOR PLAINTIFF _ Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Sel mieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69549 .Iudilh T. Romano, Esq., Id. No. 55745 Sheelal R Shah-Jani, Esq., Id. No. 51760 .Lenin R. Davey, Esq., Id. No. 87077 NOTARIAL SEAL Lauren R. Tabas, Esq., Jr. No. 93337 Vi k S i E I N 0 JAMES E OSBORNE ve vastava, r sq., d. o. 2 2331 Jay B.Jo-,Fsq,Id.No.M657 Notary Y Public Peter J. Mulcahy, Esq., Id. No. 61791 A d 1 S WEISSPORT BORO n rew .. pivack, Esq., Id. No. 84439 JaimeMccumncs Es Id N 90134 ., CARBON COUNTY W C , q, . o. Chrsovalanl P Fli k F N Id 9462 y ommission Expir . e a os, sq., . o. 0 es Apr pg 2013 Joshua l• Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Fsq, Id. No, 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 l '. ACCEPTANCE OF SERVICE I accept service of the o a ?-c (Name of Document Being Accepted) on behalf of iLf t and certify that (Name of Defendant) I am authorized to do so. Date: 0.Z?? Signature: ?Z /* ?, (Defendant o uthorized A it, i tune) a ?x ?5 (MG??i?g, Ad ? ssZ, C, tc, cA a, ,r County (County of Proceeding) No. 0G1 ` -7 S L I (File or Docket Number) PLAINTIFF SUNTRUST MORTGAGE INC. AFFIDAVIT OF SERVICE (FNMA) CUMBERLAND COUNTY PHS # 236196 DEFENDANT DANIEL K. KULIG SERVE DANIEL K. KULIG AT: 980 BEECH AVENUE HERSHEY, PA 17033-2205 SERVICE TEAM/ kxc COURT NO.: 10-2676-CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/08/2010 SERVED Served and made known to DANIEL K, KULIG , Defendant on the ?Wday of 5T , 20 /U, at ,?IoclockP. M., at the aSo-,e in the manner described below: ADefendant 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: r< Description: Age 4d1?- Height Weight 2W Race W _ Sex _M Other I,L4.?jr DfHK-?/ a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this,?-3 day of -`7",-jr 20(p. Notary: By: NOTSERVED On the day of _ , 20_, at __ o'clock _. M., Defendant NOT FOUND because: Vacant _ Bad Address - Moved - Does Not Reside (Not Vacant) No Answer on Service Refused Other: Sworn to and subscribed before me this day of , 20_ By: Notary: at at rrr NOTARIAL SEAL JAMES EOSBORNE Notary Public WEISSPORT BORO., CARBON COUNTY My Commission Expires Apr 29, 2013 ATTORNEY FOR PLAINTIFF 1,awrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel C. Sehmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shectal R. Shah-Jani, Esq., Id. No, 8060 Jevrtne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id- No. 93337 Vivek Srivastava, Esq., Id. No. 202331 .lay B. Jones, Fu1., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivock, Esq., Id. No. 84439 Jaime McCuinnas% Esq., Id, No. 901:60 Chrisovalanle P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id, No. 205147 Courtemy R. Dunn, Esq., Id. No. 206779 Andrew C. BramblMt, Esq., Id. No. 21)3375 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1410 Philadelphia, PA 19103-1814 1215) 563-7000 PLAINTIFF SUNTRUST MORTGAGE, INC. AFFIDAVIT OF SERVICE (FNMA) CUMBERLAND COUNTY PHS # 217386 DEFENDANT DANIEL J. PAJSKI RANDY L. SHULTZ SERVE DANIEL J. PAJSKI AT: 2200 VINE STREET MIDDLETOWN, PA 17057 SERVICE TEAM/ kxc COURT NO.: 10-2809 CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/08/2010 SERVED Served and made known to DANIEL J. PAJSKI , Defendant on the 2C day of 20 !!? , at 1 5-0, o'clock C. M., at tkt u!x-..G in the manner described below: .KDefendant 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 .3S± Height Weight 170! Race k..? Sex M _ Other I, br-,)-lrs t}tJk)" , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this ;t? day of v'' - , 201x? Notary: By: I NOT SERVED On t e day of _ 20_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant , Bad Address - Moved - Does Not Reside (Not Vacant) _ No Answer on at at Serv ice Refused Other: Sworn to and subscribed before me this day of-2U-_. By: Notary' ATTORNEY FOR PLAINTIFF Utwrenrc T. Phelan, Esq., Id. No. 32227 Francis S. Haiti.^ Esq., Id. No. 62695 Daniel G. Schmicg, Esq. Id. No. 62205 Michele M. Bradford, Esq, Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheelal R Shah-Joni, Esq., Id. No. 81760 NOTARIAL SEAL r? Jenine R. Davey, Esq., ld. No. 87077 I.a=n R. Tabas, Esq., Id. No. 93337 JAMES E OSBORNE Vivck Srivastava, Esq., ld. No. 202331 B F Id N 86657 J J Notary Public . ones, sq., o. ay . Peter J. Mulwhy, Fsq, Id. No. 61791 WEISSPORTBORO., CARBON COUNTY Andrew Spivack,F_sq,Id.No. 39 N. 9010134 Jaime Ms cGuinness Fs Id My Commission Expires Apr 29 2Q?S , . g, Chrisovalante P. Fliakos, Esq., Id. No. 94620 , Joshua I. Goldman, Fsq, Id. No. 205047 Courtenay IL Dunn, Esq, Id. No. 206779 Andrew C. Bramblelt, Esq., Id. No. 208375 One Penn Center at Suburrh?,au Station 1617 John F. Kennedy Blvd, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-701)47 PLAINTIFF SUNTRUST MORTGAGE, INC. AFFIDAVI"f OF SERVICE (FNMA) CUMBERLAND COUNTY PHS # 217386 DEFENDANT DANIEL J. PAJSKI RANDY L. SHULTZ SERVE RANDY L. SHULTZ AT: 2200 VINE STREET MIDDLETOWN, PA 17057 SERVICE TEAM/ kxc COURT NO.: 10-2809 CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/08/2010 SERVED Served and made known to RANDY L. SHULTZ , Defendant on the 24day of AtAj-i,?- 20 10, at o'clock p. M., at 4-4e cj nc--e in the manner described elow: Y 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: T Description: Age t` Height .S?,? r Weight ! 0 -Race _W _ Sex 44 Other I,ajs4,1Ac , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 2--'7 day of a-?2W o. Notar? By: '?- t' 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 on at at Service Refused Other: Sworn to and subscribed before me this day of 2 - By: Notar : ATTORNEY FOR PLAINTIFF y I.awrence T. Phelan, Fsq, Id. No. -32227 Francis S. Halfinan, Fsq., Id. No. 62695 Daniel G. Schmi,%, Ful., Id. No. 62205 Michele M. Bradford, -sq., Id. No. 69849 Jndith T. Romano, Esq., Id. No. 58745 Shmul R. Shah-Jani, Esq., Id. No. 81760 Jenin , R. Davcy, Esq., Id. No. 87077 NOTARIAL SEAL Lauren R. Tabas, Esq., Id. No. 93337 JAMES E flSBORNE VW k Sriveslava, Esq. Id. No. 202331 .ray B. Jones, Fsq, Id. No. 86657 Notary Public Peter J. Mulcahy, Esq., Id. No. 61791 WEISSPOR7 8080., CARSON COUNTY Andrew L. Spivack, Fsq, Id. No. 64439 JaimeWG.inness,Esq.,Id.N°'90134 My Commissi E 94620 d P. F . l Id No. , Chsovalante on xpires Apr 29. 2013 No, shhua ua 1 I. . Gol Goic jo 2005050 dman, Esq Esq 47 , Id. . No . Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 One Penn Center at Suburban Station 1617 Juhn F. Kennedy Blvd, Suite 1400 Philadelphia, PA 19103-1814 Q15) 563-7000 AFFIDAVIT OF SERVICE PLAINTIFF METLIFF HOME LOANS A DIVISION OF METLIFE BANK NA DEFENDANT CARLOS F. ORELLANA ENRIQUE, TA E. ORELLANA SERVE CARI.OS F. ORELLANA AT: 209 NORMAN ROAD, CAMP HILL, PA 17011-6127 CUMBERLAND COUNTY PUS It 215902 SERVICE TEAM/ kxc COURT NO.: 09-6166-CIVIL, TERM TYPE OF ACTION XX Notice of SLerifr s Sale SALE DATE: 12/08/2010 SERVED Served and made known to CARLOS F. ORELLANA Defendant on the M' day of Av& us-r , 20 10, at 1: 0 1 , o'cloc k. M., at a tS9 NoFMM+ Ra+C.¢ik P lit A , in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is W I FE _ 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 4Q5_ Height '-) '1/0" Weight Z O Race K Sex F - Other 1, ) /f,+ 1j ki t-L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subsc 'bed ;?- -- before me this day KIMBERLY CURTY - -?? of,G(? , 20. to l?- NOTARY PUBLIC STATE OF NEW JERSEY Nut '?lY COMMISSION FXr'IRFS MARCH 7, 2013 ERVED NOT S On ay of 20 at ^ o'clock M., Defendant NOT FOUND because ?Wacarrr Bad Address -Moved _ Does Not Reside (Not Vacant) _ No Answer on _ at _at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF Lawrma T. Phelan, Fs " Id N. 32227 Finaous S. Hanoto % Esq., Id. N. 62695 Daniel G. Sdumie8, Esq., Id. No. 62205 Michele M. BrAdford, Esq., Id. No. 69849 Judith T. Romano, N., Id. Na.58745 Shertal R. Shah-Dank Esq., Id. N(. 81760 Jeoine R Davey, Esq-, M No. 87077 Laur n R. Tabas Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 866.57 Peter J. Muk-Ay, Esq., Id. No. 61791 Andrew L Spivak, F.cq., Id. No 84039 Jaime McGui ness, Fsq., Id. No. 90134 Chrisuvalamie P. FSakos, Esq, Id. No. 9/620 Joshua L Goldman, Fsq., Id. No. 205047 Couttmay R Dorm, Esq., Id. \o. 206779 Andrew C. Brambiett, Fsa Id. No. ZNW5 Ooe Peon Cemer at Suburban Statiah 1617 Jo7o F. Kennedy Blvd., Suite 1400 Philadelphia, PA 191031814 (215)56370M AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA PHS # 215902 DEFENDANT SERVICE 'T'EAM/ kxc CARLOS F. ORELLANA COURT NO.: 09-6166-CIVIL TERM ENRIQUETA i:. ORELLANA SERVF. ENRIQUETA E. ORELLANA AT: 209 NORMAN ROAD, CAMP HILL, PA 17011-6127 TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 12108/2010 SERVED Served and made known to ENRI UETA E. ORELLANA , Defendant on the _I of day of GttS"T, 20 l 0 , at D7o'clock]? M., at 2U 1 1yo tot wQT1,0A,hP iLt , P?A , in the manner described below: -7Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship iv 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: 1 " De:%Iv&b n: Age 4QS _ Height ?{Z Weight a Race 4 Sex Other I, L{ a competent adult, being duly swom according to law, depose and state that t personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date' and at the address indicated above. Sworn to and subsc bed before ?q e this day KIMBERLY ('!'RTY of 20, NOTARY PUBLIC Not % By: P6.1X4 .il"ATE OF NEW JERSEY NOT SERVED i kI!' COMMISSION EXPIRES MARCH 7.2013 On the da f 20at ^ o'clock M., Defendant NOT FOiecause: - avant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of 20_. By: Notary: ATTORNEY FOR PLAINTIFF' tawreace T. Phelea, Fsq, Id. No. 32271 Francis S. H-Uh aq FA, Id. Na 62695 DaWd G. Sdhrdes, Esq., Id. Na 62205 Mkhde M. Bradford, Esq., Id. No. 69849 Judith T. Romans, Esq., Id. No. 58745 Sheelal R Shah•Jard, Fsq., Id. Ne. 81760 Jndne R Davey, Fsq, Id. No. 87077 laureo R Tabus, Esq., Id. No. 93337 Vivek Srivastava, Esq, Id. Na 202331 Jay B. Jones, Fsq., Id. No. 86657 Peter J. Mulnhy, Esq, Id. No. 61791 Andrew L Spirant, Fsq, Id. Na 84439 Jaime McGu6eeas, Etq, Id. No. 90134 Chrisovalaute P. }tiakos, Fsq, Id. Na. 91620 Joshua L Goldrm, Fsq., Id. No. 205047 Courimay R Dow, Fsq., Id. No. 206779 Andrew C. Branblell, Esq Id. Na 209775 Our Penn Cnaer at Sam b'an slatioe 1617 Jobe F. Kennedy Bhd, Site 1400 Philadelphia, PA 19103.1814 (215) 5637000 ;AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CMLTI 2007-0 PHS # 236832 DEFENDANT SERVICE TEAM/ kxc MAGED A. ABDELMALIK A/K/A MAGED ABDELMALIK COURT NO.: 10-2610-CIVIL TERM HANAN M.AWADALLA SERVE HANAN M. AWADALLA AT: TYPE OF ACTION 5001 PELLINGHAM CIRCLE XX Notice of Sheriff's Sale ENOLA, PA 17025-1292 SALE DATE: 12/08/2010 SERVED Served and made known to HANAN M. AWADALLA , Defendant on the 154Lday of 20 at 5'.377, o'clock t. M., at 5MI PEU.Inr 614"64, bNoLA Dq, in the manner described below: Defendant personally served. ?Adult family member with whom Defendant(s) reside(s). Relationship is Sg? - 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 _-_Q__ Height `4 ` Weight it &0 Race - Sex A Other f, Pd14 D A6 L4- , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day r of KIMBERLY C(JRTY Notary: / - By: P0" -?*4 s NOTARY PUBLIC NOT SERVED STATE OF 1titE4 JERSEY On a 20 at o'clock M. Defendant MY COMMISSION tXPIRES MARCH 7, 2013 Y NOT FOUND because _-- -- mac' _ Bad Address _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at - Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF I.awrenm T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Fsq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. Nu. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Roman, Esq., Id. No. 58745 Sheetat R. Shah-.rani, Esq., Id. No. 81760 Jenine R, Davev, Esq., Id. No. 871177 Iauren R. Tabas, E.sq- Id. No. 93337 Vivek Srivastava, Exl., Id. No. 202331 Jay B. Jonas, Fsq., Id. No. 86657 Peter J. Mukahy, Fsq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. "149 Jaime McGuinness, Esq., Id. N. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Brambiell, Fsq., Id. No. 208375 one Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 14W Philadelphia, PA 19103-1814 (215) 56.4-711181 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CMLTI 2007-0 PHS # 236832 DEFENDANT SERVICE TEAM/ kxc MAGED A. ABDELMALIK A/K/A MAGED ABDELMALIK COURT NO.: 10-2610-CIVIL TERM HANAN M. AWADALLA SERVE MAGED A. ABDELMALIK A/K/A MAGED ABDELMALIK TYPE OF ACTION AT: XX Notice of Sheriff's Sale 5001 PELLINGHAM CIRCLE SALE DATE: 12/08/2010 ENOLA, PA 17025-1292 SERVED Served and made known to MAGED A. ABDELMALIK , Defendant on the V?tly of U" T , 20 10 , at j:3'1, o'clock -PM., at 5W I PE WOU4k lMm 60, trioth-,P4 , 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/(_?QHeight Weight a00 Race T Sex &I -Other I, P,NA-t,e 440" , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed KIMBERLY ??URTY before me this ]?•? day NOTARY PUBLIC of 6,20(o STATE GF' NSW JERSEY MY COMMISSION 1 XPIRES MARCH 7, 2013 Nota NOT SERVED On the _ ay o 20_, at _ o'clock M., Defendant NOT FOUND because: ---)V an-[ Bad Address _ Moved _ Does Not Reside (Not Vacant) _ No Answer.on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF 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 Shectal R. Shah-JAM, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabors, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202-131 .Jay B. Jones, Esq., Id. No. 86657 Peter J. Muleahp, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovolante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courienay R. Dunn, Esq., Id. No. 206779 Andrew C. Brambk%1, Esq., Id. No. 208375 One Penn Ccnter at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7001) PLAINTIFF NATIONSTAR MORTGAGE, LLC, F/K/A CENTEX HOME EQUITY COMPANY, LLC DEFENDANT DAVID M. HARNER SERVE, DAVID M. HARNER AT: 98 FRONT STREET ENOLA, PA 17025-3211 PHS # 236006 SERVICE TEAM/ kxc COURT NO.: 10-2576-CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/08/2010 SERVED Served and made known to DAVID M. HARNER , Defendant on the j?day of A96UST , 20 (0, at 1 0, o'clock g. M., at qk FRONT S-r? dTI Fjgg(A Ah, in the manner described below: V 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: r t• Dese1= ti( n- Age .46S Height Weight a[O Race w Sex Other NI (.,D Ou- _,a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subs'c> ibed before we this l S' day of J, ' 20 t KIMBERLY CL'RTY I NOTARY PUBLIC By: STATE Of NEW JERSEY Notary: An NOT SRVED MY COMMISSION EX; IRES MARCH 7, 2013 On the 20_, at o'clock _. M., Defendant NO V_ Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of _, 20__. By: Notary: AFFIDAVI'T' OF SERVICE CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq_, Id. No. 32227 Francis S. Haltimm, Esq., M. No. 62695 Daniel G. Schmieg, Fsq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Shectal R. Shah-Jana, Esq., Id. No. 8170) Jenine R. Davey, Esq., Id. No. 87077 Lauren R, Tabas, Esq., Id. No. 93337 Vivck Srivastava, Esq., Id. No. 202331 Jay W Jom s, F_sq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew I.. Spi-k, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chriso-tmoc P. Fliakas, Fs p, Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, F_sq., Id. No. 206779 Andrew C. Bramblelt, Essqq Id. No. 208375 One Penn Cc" ter at Suburilan Station 1617 John F. Kennedy Blsd., Suite 14W Philadelphia, PA 19103.1814 (215) 563-71111 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. PHS # 192838 DEFENDANT SERVICE TEAM/ kxc ALLISON A. LEFAIVRE AIK/A ALLISON ANNE LEFAIVRE COURT NO.: CIVIL-09-2922 ANTHONY L. FLYTHE SERVE ALLISON A. LEFAIVRE A/K/A ALLISON ANNE TYPE OF ACTION LEFAIVRE AT: XX Notice of Sheriff's Sale 370 CHANNING DR SALE DATE: 12/08/2010 CHAMBERSBURG, PA 17201-3201 SERVED r54 Served and made known to ALLISON NE LEFAIVRE , Defendant on thIVI-1 day of /?7V? y o 20 LD, at 10 o clock _ M., at --?My O-N N i ?I q Qj , in th manner describ 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: Desc iption: Age ,3,5 Height, $1 _ Weight/ Race (04 Sex Other PC) S ° S I, et k. & ?Ico?mppc ent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and sub?i?e? befo me this oday FLETTERKENNY TARIAL SEAL of 20L LLE H. CARTY tary Public WP, FRANKLIN COUNTY '?( NOTSERV Expires Nov 10, 201 1 n the clay o _ 20_, at o'clock _. M., De endant NOT FO ecau., . Does Not Reside (Not Vacant) Service Refused Other: Sworn to and subscribed before me this day of 20 . Notary: By: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 F antis S. Nallinan, Esq., Id. No. 62695 Daniel G. Schmieg, F_sy., Id. No. 6220, Michele M. Badl'ord, F_sq„ Id. No. 69839 Judith T. Romano, Esq., Id. No. 55745 Shechd R. Shah-Jani, Esq., Id. No. 817641 Jenine R. Davey, Fap, Id. No. 87077 Lauren R. Tabas Emr, Id. No. 93337 Pivek Sdvas(a-, Esq., Id. No. 202431 Jay B. Junes, F_stl., Id. No. 56657 Peter J. Mulcahy, Esq., Id. No. 61791 Ami mw L. Spivack, Esq., Id. No. 54439 Jaime McGuinness, Esq., Id. No. 90134 Chd%vetante P. Fliakm Esq., Id. No. 94620 Jushua L Goldman, Fsy., Id. No. 205047 Cou"emy R. Dunn, Fsq., Id. No. 21)6779 A.I. C. Brdnthk4t, Esq., Id. No. 205375 one Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (2151 WV70W No Answer on at 9 PLAINTIFF CITIMORTGAGE, INCORPORATED, S/B/M TO FIRST NATIONWIDE MORTGAGE CORPORATION DEFENDANT ANDREW W. FRANGE SERVE ANDREW W. FRANGE AT: 131 BRIAN DRIVE ENOLA, PA 17025-1565 PHS # 228996 SERVICE TEAM) kxc COURT NO.: 10-995 CUM TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 12/0&12010 SERVED Served and made known to ANDREW W. FRANGE . Defendant on the 1!Nay of 20 1a , at 4-.oo, o'clock jP. M., at 1901 STATE 9-OA 9 in the manner described below: V Defendant personally served. M*A q S ?l &L.ts , Q 1 _ 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. t. Other: Description: Age '?O S Height Weight 1 0 Race W Sex /44 Other 1, b 001.0 "t-L a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. j A F:j-*"u 4 V4w,? /Jl/ d FS J' (a,wfj ESL CdS i?J Sworn to and subsc bed t ( 7 wf,"Ww P."A bE6 (o .16( 3T*f-12b , P r ,.4- before ipe thisM?x da J?/.(ShcGl-E ?/?. of-,2014 N y: NOTSERVED On the o 20_, at ^ o'clock M., Defendant NOT FOUND because: Vac J Bad Address _ Moved _ Does Not Reside (Not Vacant) o Answer on at at Service Refused KIMBERLY CORTY NOTARY KiBLIC Other. ' STATE OF NEW'1ERSEY Sworn me and this subscribed MY COMMISSION EXPIRES MARCH 7, 2013 offore m , day By: L N.3 Notary: ATIrORNEY T. 4 JIM_h l'fl ¦ =& s. dam, Bsq., LL Ne. am DaalelG. Schmk& Seri., 1d. Na. 62215 Michele M. BtNO" rtq, rd. Ns. 6909 JadNkT. Nagy Faq., 1d. No. 9745 Skaed N.901?Jsal, N K Ne. 8170 Jedw N. prey. &qµ, rd. Ne. 87'177 Lame R Tabu, Esq., LL Na 93337 Vivek Sduaffa. Esq., Id. No. 212331 Jay B. Jem. Faq, it No, 86657 Peter J. Mulcahy, Esq., 1d. Na.41791 Aedns L 80rsek: Faq.. M. N. %439 Jakssr 16ec Pq, u We. 98134 C21 chewkm4 P. F4ka%But, rd. Na 946M Jaebr L Gsldw4y pari., rd. No. 2858% C4sa40q N. Derma, Nq. 8d. W 28 M Andrew G am t No. 287 6117 Jam F.F. Keaaedy llkaj, sa8e 1480 PhBrlellabia, PA 19183.1814 (21.5) 563-70100 -r'nDAITT OF SERVICE CUMBERLAND COUNTY AFFIDAVIT 6F SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY CHASE HOME FINANCE LLC PHS # 221137 DEFENDANT SERVICE TEAM/ kxc FRANCIS J. LAFFERTY, IV COURT NO.: 09-7%3 CIVIL TERM JENNIFER E. LAFFERTY SERVE FRANCIS J. LAFFERTY, IV AT: TYPE OF ACTION 24 WEST MAPLEWOOD AVENUE XX Notice of Sheriffs Sale MECHANICSBURG, PA 17055-6428 SALE DATE: 12/08/2010 **DIVORCED- ONE CANNOT ACCEPT SERVICE FOR OTHER** SERVED Ua&d3If fo(0, ,g.$ Served and made known to FRANCIS J. LAFFERTY, IV , Defendant on the P*day of /, 20 t4 -at- , o'clock?. M., at 4 W whoa 040e ? in the manner described below: ? Defendant personally served. ?A) - 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 4-0 Height ?of?a Weight 460 Race W Sex _P Other I, J?6/-441-D Zt_ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. if1 [>LRLY CURTY Sworn to and su^b's,cf ibed before me this oq?h day - y a l ,k') t'L i3 W of 4Lkfi:, 201 a t) N;IF ERSEA ?My C0ly M1SS'.(!:v ?':r9it S MARCH 7, 2013 Nota y: NOT SERVED a On t6 20at o'clock M., Defendant NOT FOUND because: _ _ 5cant Bad Address _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of M_. By: Notary: ATTORNEY FOR PLAINTIFF rv C> T. Phelan, Esq., Id. No. 32227 Lawrence Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Sdmieg, Esq., Id. No. 62285 ,- Michele M. Bradford, Esq., Id. No. 69849 ...; rn 1-YI .?. Judith T. Romano, Esq, Id. No. 58745 Shectal R Shah-Jank Es Id 81760 No - . . q, . . i R D E Id N 87077 J r :-vy an ne . avey, sq., . o. > Lauren R. Tubas, Esq, Id. No. 93337 _ Vivek Srivastava, Esq, Id. No. 202331 Jay B. Jones, Esq, Id. No. 86657 ..? Peter J. Mulcahy, Esq., Id. No. 61791 C:) Andrew L. Spivack, Esq, Id. No. 84439 ' - - Ch i l t P FN k E Id 94620 ., N 6 C ) 7 r so a an e . e os, . sq, o .. ? .. r s Joshua 1. Goldman, Esq., Id. No. 205047 ?-- Courteney R. Dunn, Fsq., Id. No. 206779 Andrew C Bramblett, Esq? b. No. 20&375 ., ? One Penn Center at Suburban Station 1617 John F. Kennedy Blvd, Suite 1400 Philadelphia, PA 191034814 (215) 5637000 ?? 0 :40 AFFIDAVIT OF SERVICE (FNMA) t 1 IINTIFF CUMBERLAND COUNTY i %SE HOME FINANCE LLC PHS # 221137 DEFENDANT SERVICE TEAM/ kxc FRANCIS J. LAFFERTY, IV COURT NO.: 09-7%3 CIVIL TERM JENNIFER E. LAFFERTY SERVE JENNIFER E. LAFFERTY AT: TYPE OF ACTION 251 SAINT JOHNS DRIVE XX Notice of Sheriffs Sale CAMP HILL, PA 17011 SALE DATE: 12108/2010 "DIVORCED- ONE CANNOT ACCEPT SERVICE FOR OTHER" SERVED I and made known to JENNIFER E. LAFFERTY , Defendant on the284'day of KCrKS'T, 20 (O , at 3a , o'clock A. M., at !25( V T61+0 bR,' np(f% DA , in the manner described below: )efendant 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). 1.+,1ent or person in charge of Defendant's office or usual place of business. ___ an officer of said Defendant's company. Age ¢?S Height Weight 13o Race Sex F Other ?,rjr?t r ?yj /VA-LL , a competent adult, being duly sworn according to law, depose and state that I personally uc and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned !ate and at the address indicated above. -? KREE(ii[ Y C(!RTY .t Gild subscribed Nt)IAR E* I'iAil,IC r e this day C!?iviMISi1CiN 1 ' 11th 't°ASEy ItCH 7, 213 20LO ry: By: NOT SERVED he d of ,20-, at o'clock _. M., Defendant NOT FOUND because: rant _ Bad Address - Moved _ Does Not Reside (Not Vacant) Answer on at at service Refused . ' • r.u and subscribed this day By: ATTORNEY FOR PLAINTIFF Lawreoa T. Phelan, Esq., Id. No. 32227 Francis S. HaBfnan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 C7 Michele M. Bradford, Esq., Id. No. 69849 ;. 7 r--3 G=) Judith T. Romano, Esq., Id. No. 58745 ? = ? Sheetal R. Shah-Jan!, Esq., Id. No. 81760 _ j, t ? Jenine R. Davey, Esq., Id. No. 87077 uZ ?? rY" S r- Lauren R. Tabas, Esq., Id. No. 93337 t-- Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 P M E Id N 61791 t l h J Imo 'ry - K e er u ca y, sq., . o. . + i Andrew 1.. Spivack, Esq Id. No. 84439 Jahne McGuinness, Esq„ Id. No. 90134 ? '-1"t Chrisovalente P. Fliakos, Esq., Id. No. 94620 ;?? } ., t Joshua 1. Goldman, Esq., Id. No. 2051M7 Courteney R. Dunn, Esq., Id. No. 206779 T`-•- ? Q Andrew C. Brnmbkly FFss??'' d. No. 208375 One Penn Center at Suburban Station ""-- C-- ,? ._..; 1617 John F. Kennedy Blvd., Suite 1400 - -• - Philadelpbin, PA 19103.1814 - --J (215) 563-7000 ?0 V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHASE HOME FINANCE LLC CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) CIVIL DIVISION No.: 09-7963 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 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 (Fo m 3817) and/or Cert' ied Mail Return Receipt stamped by the U.S. Postal Service is att the hereto Exhibit "A ? La ce Z11 helan; Esq., I No. 32227 FrIrt ci S. inan, Esq. d:. No. 62695 ? Da ie G. Schmieg, Esq., Id. No. 62205 ? Mic le M. Bradford, Esq., Id. No. 69849 ? J dit T, Romano, Esq., Id. No. 58745 heetalR.. Shah-Jani, Esq., Id. No. 81.760 Jenine R. Davey, Esq.; Id. No. 87077 "Y ? Lauren R. Tabas; Esq., Id. No. 93337 a ? Vivek Srivastava, Esq., Id. No. 202331 _ ? Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61191 ? 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 Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It ma not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 221 137 4 Q C.` n a G r F C a? cn ? V7 N ? cn •? a1 U ,c w ? T e.,?oOp t 'a s~ Ri N 'C7 ar 15 ? Q p? C O Vi A y V3 o ? ? 0 so 6l 3000d1Zwoa:a31Jv" yO N b °r o?oz 9? inr 99z«ztooo ot,670 VU z o - ` 1 . N SjM99A3Nlld - X . ` .. ? v E ro ,moo. ? ?.of ? o a M ?w ? vi ??. p.j N c ci 'E '!?'?' (n a+ 0.1 I. ' 1? C U .y ? tJ G , c H w o,'r iz ? H A ? b W a ?: a z 5 N ? W N p U ?Wy ^ (7 "'? U ? a a E ., , Ad ?, G? H a a F" O G. ? C? o H M W a i N i :N 4' ?O o w WWI o u A,;Wa a c LM T t- r? '"q a? c? o ~ ? ? v? L a ?. ? 'O ? . > ® V .C q ' y y > "'? '? Q y+ ?0 C L °? "? a r /1 Qi W W W d` I:n m V U V C ?. c•. ?v .. O M Py b y ?' p v?? ?a >-. 'CJ V1 p, £! ?. ,, ?+ . W FW ? W UWW a U a. O ,? E.., F., M W ? w 3 d N. L c x o ? CE 4 1. .C +-p, ,'o, o? o ? v' L' L O O L ? p W c p " n;a W U 0? G? ?+ ?t W ? Z ? o o- x'r:: o Z? u ai ? ? 4) os Co ? ... v ?^- ?.Q 9z r?., ca' W 3 W F p pM AU?U O ?? R UAF C G.yMO•?- COD Lz w1-mi V1C/J ?N x zO? ?U.aU OOd U-.U WW x o0 Ha N ,o Z a x ? -z -x ? i `7V i /f r M6 6 3(1a0dIZ W08J (1311VIN OO OZ t7OAON sszciztiooo ;Z 4 U C.) ti !? f i s3ANOR A3Nild Z S 'sy r ,t _ x C Q O N O N W 7C J ?. w d Ova V Wa a x ao '??p'?q? ? dCL boa ?UC)OUaF. -°a"' LoQ.E W?Q?O (j u fT. U.aW a ?Wr7Q o-aW?DU' a?i?rr?L1a:Woo ?a p3r?p?;aGq•aAQ9Z o ?I????UxCaQU,?QCG3 Q z U W z p c ?OH?`OL?-W?ZOW"aW GL W'?gwaOU°oOQ Li.U v E Z3 X -x x Z K -K z -K v -x z -x U CCS V1 "Q ? ?? 4 - F C N M zoo 11 i -x -z K -K -z -K -x -x r M ti N N CL M Q W F" E- CG w Lz. J) U z GL? U ? v C ? O i, y L1 O F rd -U ? ' S O C - p. E x F cN G-1 ? ? N 7 ? CD C ? ? w d N R ? 7 ? aJ C U U ? > p,00 UO ? O ?,o o m o 0 ^ C O T- ? o ? n F > wOo 0 w C w O V t0 ?(?/7 N L O -'O ro y E ? O F r' 'C1 - O 0 ?. w U I: N a° cG U U aO w G C ' U ? z ; ? U H ? t o T W 'O U G 'N U 1? CHASE HOME FINANCE LLC Plaintiff V. FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-7963 CIVIL TERM CUMBERLAND COUNTY PHS # 221137 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed; the following information concerning the real property located at 24 WEST MAPLE WOOD AVENUE, MECHANICSBURG, PA 17055-6428. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 3211 NORTH FRONT STREET HARRISBURG, PA 17110 251 'SAINT JOHNS DRIVE CAMP HILL, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) COMMERCE BANK/HARRISBURG, N.A. 100 SENATE AVENUE CAMP HILL, PA 17011 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) BUROUGH OF MECHANICSBURG WEST STRAWBERRY & NORTH MARKET STREET MECHANICSBURG, PA 17055 BUROUGH OF MECHANICSBURG 36 WEST ALLEN STREET C/O DAVID J. SPOTTS, ESQUIRE MECHNICSBURG, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA JENNIFER E. LAFFERTY C/O MICHAEL SCHERER, ESQUIRE FRANCIS J. LA.FFERTY, IV C/O DEBRA D. CANTOR, ESQUIRE MCNESS, WAL,LACE & NURICK, LLC 24 WEST MAPLEWOOD AVENUE MECHANICSBURG, PA 17055.6428 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 19 W SOUTH STREET CARLISLE, PA 17013-3444 100 PINE STREET P.O. BOX 1166 HARRISBURG, PA 17011-1166 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 falsific ro to authorities. By: Atto ey or Plaintiff Phela H Ilinan & Schmieg, LIMP ? La rep ce T. Phelan, Esq., Id. No. 32227 ? Fra ci S. Hallinan, Esq., Id. No. 62695 [] Dam G. Schmieg, Esq.; Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ?' udith 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 M Vivek:Srivastava, Esq., Id. No. 202331 F] Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 C] Andrew L. Spivack, Esq., Id. No. 84439 D 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson EiLEO-OFFICE Sheriff tilp of ?uu+t?r ri- -HE PROTHO?iC DR Jody S Smith °"Y Chief Deputy APR I I API 10: 3 9 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Chase Home Finance LLC vs. Case Number Jennifer E. Lafferty (et al.) 2009-7963 SHERIFF'S RETURN OF SERVICE 10/13/2010 03:00 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on 10-13-10 at 1457 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jennifer E. & Franci J. Lafferty, IV, located at, 24 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania according to law. 10/22/2010 05:40 PM - Deputy Michael Barrick, being duly sworn according to law, served the requested Notice of Sheriffs Levy, Sale and Posting of Schedule of Distribution and Plaintiffs Notice of Sheriffs Sale and Debtor's Rights by "personally" handing a true copy to a person representing themselves to be FRANCIS LAFFERTY- HUSBAND, who accepted as "Adult Person in Charge" for Jennifer E. Lafferty at 251 Saint Johns Drive, Lower Allen Township, Camp Hill, PA 17011. Copy of the Plaintiffs Notice attached to and made part of the within record. 11/01/2010 03:47 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jennifer E. Lafferty at 251 Saint Johns Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County. 11/02/2010 Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Francis J. Lafferty at 24 West Maplewood Avenue, Mechanicsburg, Cumberland County. 12/02/2010 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/28/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 4/1/11. SHERIFF COST: $741.34 April 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF fa . S-6 i e0 e1391 (c) GountySiite Shenff, Telec:x?tT. h?r. CHASE HOME FINANCE LLC Plaintiff V. FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-7963 CIVIL TERM CUMBERLAND COUNTY PHS # 221137 AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 3211 NORTH FRONT STREET HARRISBURG, PA 17110 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) COMMERCE BANK/HARRISBURG, N.A. 100 SENATE AVENUE CAMP HILL, PA 17011 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. ' 7. Name and addre$, 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 24 WEST MAPLEWOOD AVENUE MECHANICSBURG, PA 17055-6428 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 United States Internal Revenue 13th Floor, Suite 1300 Special Procedures Branch 1001 Liberty Avenue Federated Investors Tower Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 JENNIFER E. LAFFERTY 19 W SOUTH STREET C/O MICHAEL SCHERER, ESQUIRE CARLISLE, PA 17013-3444 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. July 12, 2010 ay: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 [ rancis 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 CHASE HOME FINANCE LLC VS. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO. 09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV CUMBERLAND COUNTY JENNIFER E. LAFFERTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FRANCIS J. LAFFERTY, IV 3211 NORTH FRONT STREET HARRISBURG, PA 17110 JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 * *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 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055- 6428 is scheduled to be sold at the Sheriffs Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $218,569.35 obtained by CHASE HOME FINANCE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs 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. 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 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of West Maplewood Avenue at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned Plan of Lots; thence along the northern side of West Maplewood Avenue, South 68 degrees 52 minutes 10 seconds West, a distance of one hundred two and forty-nine hundredths (102.49) feet to the eastern side of South Frederick Street; thence along the eastern side of South Frederick Street, North 14 degrees West, a distance of one hundred sixteen (116) feet to a point; thence North 66 degrees 59 minutes 30 seconds East, a distance of eighty-eight and fourteen hundredths (88.14) feet to the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan; thence along said dividing line, South 21 degrees 7 minutes 50 seconds East, a distance of one hundred seventeen and ninety-nine hundredths (117.99) feet to a point on the northern side of West Maplewood Avenue, at the point or place of Beginning. CONTAINING 11,095 square feet and being Lot No. 1 on the final subdivision plan for Harson, Inc., as recorded in the Cumberland County Recorder's Office in Plan Book 50, at Page 74, and being 24 West Maplewood Avenue, Mechanicsburg, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Francis J. Lafferty, IV and Jennifer E. Lafferty, h/w, by Deed from Stewart C. Taylor, married man, dated 01/04/2006, recorded 01/10/2006 in Book 272, Page 3531. PREMISES BEING: 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428 PARCEL NO. 16-24-0787-135. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-7963 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC Plaintiff (s) From FRANCIS J. LAFFERTY, IV AND JENNIFER E. LAFFERTY (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$218,569.35 L.L.$.50 Interest INTEREST FROM 06/09/2010 TO DATE OF SALE ($35.93 PER DIEM) - $ 6,575.19 Atty's Comm % Due Prothy $2.00 Atty Paid $219.00 Other Costs Plaintiff Paid Date: JULY 16, 2010 Buell, P othonotary (Seal) By: Deputy REQUESTING PARTY: Name FRANCIS S. HALLINAN, 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. 62695 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 24 West Maplewood Avenue, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: state Coordinator 4 N PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Edit SWORN TO AND SUBSCRIBED before me this 5 dg ay November 2010 (f-.Z IzAca....:e - '?i Notary NOTARIAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Y CUMBERLAND LAW JOURNAL Writ No. 2009-7963 Civil Chase Home Finance LLC VS. Jennifer E. Lafferty, Francis J. Lafferty, IV Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 09-7963 CIVIL TERM, CHASE HOME FINANCE LLC vs. FRANCIS J. LAFFERTY, IV, JENNIFER E. LAF- FERTY, owners of property situate in the Borough of Mechanicsburg, Cum- berland County, Pennsylvania, being 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428. Parcel No. 16-24-0787-135. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $218,569- .35. 73 The Patriot-News Co. - 2620 Technology Pkwy Suite 300. Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Zhe Patti* ot 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: 2009-7963 CMI Term 10/15/10 Chase Home Finance LLC 10/22/10 Vs Jennifer E. Lafferty „ 10/29/10 Francis J. Lafferty, IV Atty: Daniel Schmleg By virtue of a Writ of Execution N0.09-7963 ?- CIVIL TERM CHASE HOME FINANCE LLC VS. Sworn to an?osubscribe fore me this TO day of November, 2010 A.D. FRANCIS J. LAFFERTY, IV % JENNIFER E. LAFFERTY , owner(s) of property situate in the Boro* of Mechanicsburg, Cumberland County, Notary Public Pennsylvania, being (Municipality) 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428 Parcel -0787-135. COMMONWEALTH OF PENNSYLVANIA (Acreage or or street address) Improvements thereon: RESIDENTIAL I Not" thin DWELLING Sherrie L Klsrw, ry public JUDGMENT AMOUNT: $218,569.35 rower Paxton Twp., County MY Commission LhNrv. 26, 2011 Member Qennsvivania Association of Notaries Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff CHASE HOME FINANCE LLC Plaintiff Vs FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) k. ) Court of Common Pleas -Om Civil Division r--z Cumberland County zo - No 09-7963 CIVIL TERM'? . , PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P.. 2352 TO THE PROTHONOTARY: Kindly substitute JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE LLC the current Plaintiff in the foreclosure action by virtue of a corporate merger, whereby CHASE HOME FINANCE LLC is now JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE LLC Kindly amend the information on the docket accordingly. Date: PHEL N HA INAN & SCHMIEG, LLP 7/)L By: ?( a-A Lawrence T. Phelan, Esq., d. 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 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089p----- Attorneys for Plaintiff PHS # 221137 Qlc 4 U9,00 f'&OLI CV IlUAW Q,? a(o ?-tqY SOrnieg, LLP .-...3 161'7 .JFF: 13oulevard, Suite 1,100 Attorney For Plaintiff = One Penn Center Plaza trt ? _. Philadelphia, PA 1910 ? 15-_56--_7000 -YI ; CHASE HOME FINANCE LLC Plaintiff Vs Court of Common Pleas r p c? Civil Division may. Cumberland County FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) : I No. 09-7963 CIVIL TERM r CD _4 PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC located at 10790 Rancho Bernardo Road, San Diego, CA 92127. Date: HE N HA L AN & 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 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912-? Attorneys for Plaintiff PHS # 221137 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC. Date: P HE AN FIA;LUNAN & SCHMIEG, LLP By: ?I 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 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 / Melissa J. Scheiner, Esq., Id. No. 30891Y Attorneys for Plaintiff PHS # 221137 PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215 563-7000 CHASE HOME FINANCE LLC Plaintiff Vs FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendant(s) ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County No. 09-7963 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff s Praecipe to mark judgment to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428 t>> ?? _? Date: By: Lawrence T. Phelan, Esq., Id. . 227 Francis S. Hallinan, Esq., Id. No. 626 5 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 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 ,--` Melissa J. Scheiner, Esq., Id. No. 3089th Attorney for Plaintiff PHS # 221137 + i cis 1 J 1 F-f�� O Ii t; , Phelan Hallinan, LLP 20'3 MAR 22 M 1 ; Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNT)', One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. No.: 09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendants MOTION TO MAKE RULE ABSOLUTE JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC, by and through its attorney,hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: I. A Motion to Reassess Damages was filed with the Court on February 15, 2013. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendants on February 7, 2013 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. 3. A Rule was issued by the Honorable Thomas A. Placey on or about February 25, 2013 directing the Defendants to show cause by March 20, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 221137 4. The Rule to Show Cause was timely served upon all parties on February 28, 2013 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. 5. Defendants failed to respond or otherwise plead by the Rule Returnable date of March 20, 2013. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. Phelan Hallinan, LLP DATE: By: d��� r ttothan Lobb,Esq., Id.No.312174 rney for Plaintiff 221137 Exhibit "A" 221137 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania and New Jersey February 7,2013 FRANCIS J. LAFFERTY,IV JENNIFER E. LAFFERTY 24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055-6428 RE: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M CHASE HOME FINANCE,LLC v. FRANCIS J.LAFFERTY,IV and JENNIFER E. LAFFERTY Premises Address:24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055 CUMBERLAND County CCP,No. 09-7963 CIVIL TERM Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days,by 2/12/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yours, Allison F , Esq.,Id.No.309519 Attu Enclosure 221137 `I } e .Mal Q�ti N� S„ M;. 1 lwl RIM .........•" ? dq 9 w S' h W ILLIM c� a g kN o T >s 11 r Exhibit "B" 221137 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC, Plaintiff V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT FRANCIS J. LAFFERTY, IV and 2009-07963 CIVIL TERM JENNIFER E. LAFFERTY, Defendants MORTGAGE FORECLOSURE IN RE: PLAINTIFF'S MOTION TO REASSESS DAMAGES ORDER OF COURT AND NOW, this 25th day of February 2013, upon consideration of Plaintiffs Motion to Reassess Damages, a Rule is issued upon Defendants to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Rule upon Defendants. RULE RETURNABLE twenty (20)days from the date of service. Distribution List: Thom a `A. Placey C:P.J. Allison F. Zuckerman, Esq. Francis J. Lafferty, IV Jennifer E. Lafferty 3 Exhibit "C" 221137 Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 w � JPMORGAN CHASE BANK, NATIONAL Court of Comrrr ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division "' °mac, Plaintiff :n CUMBERLAN ' Ott vs. r _s rn No.: 09-7963 C'lVl TjCR.M.." FRANCIS .]. LAFFERTY. IV JENNIFER E. LAFFERTY Defendants CERTIFICATION OF SERVICE ` ` I hereby certify that a true and correct copy of the Court's February 25,2013 Rule directing the Defendants•to show cause as to why Plaintiff s Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. FRANCIS J. LAFFERTY,IV FRANCIS J.LAFFERTY,IV ' ` JENNIFER E. LAFFERTY 3211 NORTH FRONT STREET 24 WEST MAPLE'WOOD AVENUE -HARRISBURG,PA 17110 MECHANICSBURG,PA 17055-6428 JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 Phelan Hallinan, LLP, DATE: f. r> r1tor�an;Lobb,Esq.,Id No.312174 ncy for Plaintiff 221137 Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County VS. No.: 09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV ; JENNIFER E. LAFFERTY Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute was served upon the following individuals on the date indicated below. FRANCIS J. LAFFERTY,IV FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY 3211 NORTH FRONT STREET 24 WEST MAPLEWOOD AVENUE HARRISBURG, PA 17110 MECHANICSBURG,PA 17055-6428 JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 Phelan Hallinan, LLP DATE: 3AI / By: J an Lobb,Esq.,Id. No.312174 ttorney for Plaintiff 221137 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. No.: 09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY Defendants i ORDER AND NOW,this day of MAKA , 2013, upon consideration of Plaintiffs Motion to Make Rule Absolute, it is hereby ORDERED and DECRE$D,that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $202,722.26 Interest Through February 22, 2013 $47,088.24 Late Charges $330.65 Legal fees $1,300.00 Cost of Suit and Title $1,054.25 Property Inspections $462.00 Appraisal/Brokers Price Opinion $250.00 Escrow Deficit $14,082.04 221137 Suspense/Misc. Credits ($59 .25) TOTAL ° $266,696.19 Plus interest at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. Y T COURT: i J. Thomas A. Placey - Common Pleas Judge ty C-.y M.'p —i zz M O G -C 2p 3 � ��+Elkn �LF,1riv�Q�� 221137 PRAECIPE TO ENTER JUDGMENT PURSUANT-TO COURT ORDER JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, COURT OF COMMON PLEAS SB/M TO CHASE HOME FINANCE,LLC Plaintiff CIVIL DIVISION V. NO.;09-7963 CIVIL TERM FRANCIS J. LAFFERTY,IV JENNIFER E.LAFFERTY CUMBERLAND COUNTY Defendant(s) PRAECIPE TO ENTER JUDGMENT PURSUANT TO COURT ORDER To the Prothonotary: Kindly Enter Judgment per the Court Order dated March 26, 2013 in favor of the Plaintiff and against FRANCIS J. LAFFERTY,IV and JENNIFER E. LAFFERTY, defendants. As Set Forth in the Order $266,696.19 Phelan Hallinan,LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff , *77 w„. n ca I�O.5o PO Pt,FT- al IWfIga Oo4ce IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division I Plaintiff CUMBERLAND County VS. No.: 09-7963 CIVIL TERM FRANCIS J. LAFFERTY,IV JENNIFER E. LAFFERTY Defendants ORDER AND NOW,this day of , 2013,upon consideration of Plaintiff's x Motion to Make Rule Absolute,it is hereby ORDERED and DECRE$D,that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $202,722.26 Interest Through February 22,2013 $47,088.24 Late Charges $330.65 Legal fees $1,300.00 Cost of Suit and Title $1,054.25 Property Inspections $462.00 Appraisal/Brokers Price Opinion $250.00 Escrow Deficit $14,082.04 221137 Mp ' Suspense/Misc. Credits ($59125) TOTAL "$266,696.19 Plus interest at six percent per annum. i Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. s ' Y T COURT: J. Thomas A. Placey �- Common Pleas Judge O Cl rrI r Cn C:) :E Li p'es k4a,/rA 31-)&11j 221137 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M TO COURT OF COMMON PLEAS CHASE HOME FINANCE,LLC Plaintiff CIVIL DIVISION V. NO.: 09-7963 CIVIL TERM FRANCIS J.LAFFERTY,TV JENNIFER E.LAFFERTY CUMBERLAND COUNTY Defendant(s) To the Prothonotary: P c Issue writ of execution in the above matter: . Amount Due $266,696.19 C/)r— 7.0n <:;> . <= , Interest from 02/23/2013 to Date of Sale $8,504.96 < a, ($43.84 per diem) �n D - ca TOTAL $275,201.15 Phelan Hallinan,LLP• --` Adam H.Davis,Esq. Id.-No:203034 Attorney for Plaintiff Note: Please attach description of property. PHS#221137 *(,-)$.50 P 1) 160.00 a8F 1W. 3 N „ 7 . 56 1 .00 C1 4. 00 8.00 � 1,010,81_ PD A7ry 02.025 IJU�(� ►a.q5&5o e#0,18958q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMOk'AN`CHASE BANK,NATIONAL ASSOCIATION,S/B/M TO CHASE HOME FINANCE,LLC Plaintiff V. ; § FRANCIS J.LAFFERTY,IV JENNIFER E.LAFFERTY Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Filed: Address where papers may be served: 1 FRANCIS J. LAFFERTY,IV Phelan Hallinan,LLP 3211 NORTH FRONT STREET Adam H.Davis,Esq.,Id.No.203034 HARRISBURG,PA 17110 Attorney for Plaintiff 24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055-6428 JENNIFER E.LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL,PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 09-7963 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,s/b/m to CHASE HOME FINANCE,LLC, Plaintiff(s) From FRANCIS J.LAFFERTY,IV and JENNIFER E. LAFFERTY (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 gamishee(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: $266,696.19 L.L.: Interest from 2/23/13 to Date of Sale($43.84 per diem) -- $8,504.96 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,010.84 Other Costs: Plaintiff Paid: Date: 4/24/13 David D.Buell,Prothon tary (Seal) By: Deputy REQUESTING PARTY: Name: ADAM.H.DAVIS,ESQUIRE Address: PHELAN HALLINAN LLP 1617 JFK BOULEVARD,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No.203034 PHELAN HALLINAN, LLP Attorneys for Plaintiff Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M COURT OF COMMON PLEAS TO CHASE HOME FINANCE, LLC Plaintiff CIVIL DIVISION V. NO.: 09-7963 CIVIL TERM FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY CUMBERLAND COUNTY Defendant(s) , CERTIFICATION 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 ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff r, a 1 �' .... C? U --< I'D JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS IkSSOCIATION, SB/M TO CHASE HOME FINANCE, LLC CIVIL DIVISION Plaintiff NO.: 09-7963 CIVIL TERM V. FRANCIS J. LAFFERTY, IV CUMBERLAND COUNTY JENNIFER E.LAFFERTY Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO CHASE HOME FINANCE,LLC,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 24 WEST MAPLEWOOD AVENUE,MECHANICSBURG,PA 17055-6428. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) FRANCIS J.LAFFERTY,IV 3211 NORTH FRONT STREET HARRISBURG,PA 17110 24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055-6428 JENNIFER E.LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL,PA 17011 -- t"nov M" .V a M 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) y FRANCIS J.LAFFERTY,IV 3211 NORTH FRONT STREET ` == HARRISBURG,PA 17110 ""4 C-4 24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055-6428 JENNIFER E.LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL,PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) COMMERCE BANK/HARRISBURG,N.A. 100 SENATE AVENUE CAMP HILL,PA 17011 PHS #221137 �f L_ 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) BOROUGH OF MECHANICSBURG 36 W ALLEN STREET C/O DAVID J.SPOTTS,ESQUIRE MECHANICSBURG,PA 17055 BOROUGH OF MECHANICSBURG 36 WEST ALLEN STREET MECHANICSBURG,PA 17055 BOROUGH OF MECHANICSBURG 36 WEST ALLEN STREET MECHANICSBURG,PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 24 WEST MAPLEWOOD AVENUE MECHANICSBURG,PA 17055-6428 FRANCIS J.LAFFERTY,IV,ESQUIRE NORFLEET&LAFFERTY LLC 1300 MARKET STREET SUITE 202E LEMOYNE,PA 17043 FRANCIS J.LAFFERTY,IV 100 PINE STREET C/O DEBRA D.CANTOR,ESQUIRE P.O.BOX 1166 HARRISBURG,PA 17108 JENNIFER E.LAFFERTY BARIC SCHERER C/O MICHAEL A.SCHERER,ESQUIRE 19 W SOUTH STREET CARLISLE,PA 17013-3444 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 PHS #221137 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING 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: Z�% By: eA vt i Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PHS #221137 '�JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, COURT OF COMMON PLEAS S/B/M TO CHASE HOME FINANCE, LLC CIVIL DIVISION Plaintiff NO.: 09-7963 CIVIL TERM VS. FRANCIS J. LAFFERTY, IV CUMBERLAND COUNTY JENNIFER E. LAFFERTY Defendant(s) c-r C, cm 7 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY -v,= w --s zm TO: FRANCIS J. LAFFERTY, IV FRANCIS J. LAFFERTY,IN9 r- 24 WEST MAPLEWOOD AVENUE 3211 NORTH FRONT STR4 o.: MECHANICSBURG, PA 17055-6428 HARRISBURG, PA 17110 ' , D C JENNIFER E. LAFFERTY 251 SAINT JOHNS DRIVE CAMP HILL, PA 17011 "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 24 WEST MAPLEWOOD AVENUE,MECHANICSBURG, PA 17055- 6428 is scheduled to be sold at the Sheriff's Sale on 09/04/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$266,696.19 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M TO CHASE HOME FINANCE, LLC (the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOIJ 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. 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 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg,Cumberland County,Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at a point on the northern side of West Maplewood Avenue at the dividing line between Lots Nos. I and 2 on the hereinafter mentioned Plan of Lots;thence along the northern side of West Maplewood Avenue, South 68 degrees 52 minutes 10 seconds West,a distance of one hundred two and forty-nine hundredths(102.49)feet to the eastern side of South Frederick Street;thence along the eastern side of South Frederick Street,North 14 degrees West,a distance of one hundred sixteen(116)feet to a point;thence North 66 degrees 59 minutes 30 seconds East,a distance of eighty-eight and fourteen hundredths(88.14)feet to the dividing line between Lots Nos. I and 2 on the hereinafter mentioned plan;thence along said dividing line, South 21 degrees 7 minutes 50 seconds East,a distance of one hundred seventeen and ninety-nine hundredths (11799)feet to a point on the northern side of West Maplewood Avenue,at the point or place of Beginning. CONTAINING 11,095 square feet and being Lot No. I on the fmal subdivision plan for Harson,Inc.,as recorded in the Cumberland County Recorder's Office in Plan Book 50,at Page 74,and being 24 West Maplewood Avenue,Mechanicsburg,Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Francis J. Lafferty, rV and Jennifer E.Lafferty,h/w,by Deed from Stewart C.Taylor,married man,dated 01/04/2006,recorded 01/10/2006 in Book 272,Page 3531. PREMISES BEING:24 WEST MAPLEWOOD AVENUE,MECHANICSBURG,PA 17055-6428 PARCEL NO. 16-24-0787-135 SHORT DESCRIPTION By virtue of a Writ of Execution No. 09-7963 CIVIL TERM JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE,LLC V. FRANCIS J. LAFFERTY, IV JENNIFER E. LAFFERTY owner(s) of property situate in the BOROUGH OF MECHANICSBURG, CUMBERLAND County, Pennsylvania,being 24 WEST MAPLEWOOD AVENUE MECHANICSBURG A17055-6428 Parcel No. 16-24-0787-135 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $266,696.19 Attorneys for Plaintiff Phelan Hallinan, LLP AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M CHASE HOME FINANCE,LLC PHS#221137 DEFENDANT SERVICE TEAM/1Xh FRANCIS J.LAFFERTY,IV COURT NO.:09-7963 CIVIL TERM JENNIFER E.LAFFERTY SERVE JENNIFER E.LAFFERTY AT: TYPE OF ACTION 251 SAINT JOHNS DRIVE XX Notice of Sheriff's Sale ,v, CAMP TULL,PA 17011 SALE DATE: September 4,2013 **DIVORCED.One cannot accept service for the other** SERVED Seved and made known the Y—'20 Ao to JENNIFER E.LAFFERTY,Defendant on day of o'clock M.,at A7ipT -1 04fi, QQG in the manner described below:Defendant Xsonally 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 Defendants company. Other: ace Description: Age Height 2 1 Weight R Other I, y1Lti' a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unsworn falsification to authorities. DATE:_�'_HKM15 NAME: R� PRINTED NAME: AQ0VMA Pe(EP(13 TITLE: NOT SERVED On the day of 20 ,at o'clock M.,1, a competent adult hereby state tha-t- e endant NOTMUNMeca7u—se: Vacant —Does Not Exist Moved —Does Not Reside(Not Vacant) —No Answer on Sat at Service Refused/ Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 0103 (215)563-7000 _ C" PHELAN HALLINAN,LLP Attorney for Plaintiff ran r�rt-r' Adam H.Davis,Esq.,Id.No.203034 1617 JFK Boulevard, Suite 1400 s� One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis @PhelanHallinan.com C:) e?i- 21.5-563-7000 tv rR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY ASSOCIATION,S/B/M CHASE HOME FINANCE, LLC COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION V. No.: 09-7963 CIVIL TERM FRANCIS J.LAFFERTY,IV JENNIFER E.LAFFERTY Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(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". // Adam H.Davis,Esq.,Id.No.203034 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 plaintiff 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. PH#714980 Name and Mclan I[all inam LLP Address Of Ibl7JFK Boulevnrd,Suilc 1400 mm Sends One Perm Coster Pl3= tj Ptilndcl hin,PA 14103 AZ,K7M1C-09/0412013 SALE tv Lire Article Number Name of Addressc Strtet and Past Office Address Postaec � 1 "`* TENANTJOCCUPANT SOAS y z 341VF N1AP7 A w sc 1CSB 1 DFCt1T 1 G AW 4 to 2 •*" BOROUGH OF t+1EC11AMCSDURG $OAS 36 WEST ALLEN'SfRF,FT 1 k2 :1 MECHANICSBURG PA.17055 pCN 3 .... BOROUGH OF n7tCHANtCSBURG 00 UAVIII J.]1'O 11S,&SQUIRE $OAS 36 W ALLEN STREET MMIAN1C58URC,PA:170SS 19 '••' COMMERCE BANK/HARRISBURG.N.A. SOAS 7 r 100 SENATE A VENUE CAMP HILL PA 17011 FRANCIS J.LAFFEIITI t1',-;ESQUIREN $0.45 NORFLEET&LAFFERTY LLC 1300 LEM t''S 7`tlt 1'SU11'E 2016 PA 17043 r• 6 •... JENNII'ER F,LAFFERTY C+O MICIIAEL A.SCUERER,ESQUIRC $0.45 BARIC SCHFRF.R 191VSOUTHSTREFT CARLISLE,PA 17013-3441 i '••* DOMESTICRELATIONSOF SOAS CUMBERLAND COUNTY 1I sSt 13 NORTH HANOVER 51 REt! CARLISLE,PA 17013 0 •'•' COMNIONIVEALTH OF PENNSYLVANIA SOAS pEPARTM1lF.NT OF WEI,TARE (?" P,O,ROX?6'15 HARRISBUR PA 17105 9 "" INFERNAL REVENUE SERVICE ADVISORY $OAS 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA IS212 10 ••*" U.S.DEPARTMENT OF JUSi7CE SOAS U.S.ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEVERALBUILDING 11!WALNUT STREET,SUITE 210 PO RON 11714 - 14ARRISBURC PA 17108.1794 11 ""' BOROUGH OF MECI1ANICSBURG SOAS tiV&Sr STRAWBERRY STREET AT NORTH MARKET STREET MECHANICSBURG PA 17055 12 '"'* KAN(:iSJ.LArfKR1 Y,IV $OAS C/O DEBRA D.CANTOR,F—mQUIRE tOO PINESTREET _O..BOX 1166 HARR1SRURG 1'A 1710A RI;:FRAM, .S."FFF.RTY )V:CISMRF:RI AN11—,,PHS k 22111711021 Poisio 1 of I Wrtt Teom 54,50 'ea,+N..b. f 7da1.*'umin.fPirow Pap,nwia.Pa{N,m.N TN fJl deala.titn.t.oh,en.p.6rJ taaU Ja..m•ani rnsmriwlre�uu.Mmai,the,eaa.a"..iwhm.fr pwWa to d,< 'kas Lned by So*t Rece1 td r Pot OTxe Re:eirint;2mnbyrcl rma+xmuiva of mm:RaAk do vmmu under r+q=s 110doro,alm t%vru wim ivaasace a$10,090 R+Pace subca fo a iu+8 dS590�t00 rer eeeaTrax.Yne mariairre udermir•prnbt^ro i:spresa.�tul uaetaadse o 1500.Ti,e rncimsm i�de^.v,+itj Iwat4:is 17iAMJ f,cpMnW,ra,i,aa,..i(t upiml iasvacr Su Demcanth�t.i.himv,t RSOO b917 am 5411 fw lin.a.:w,vt norm.38771~usimile N3mc and Fhclan lialiinan.LL' Address Of 16171FK Boulevard.Sidle 1400 y� M Sender One Pam Center Plaza t V Phitadel hia,PA'19103 A7,011 I C-09104/'2013 SALE Line AnicteNumber N.ameofAdd"ssM8tre4N,and lost Office Address Posing (00 'IENANIIUCCUPANI 10.45 0 24 WEST MAPLEWOODAVENCE ^ MECHANICSBURC PA 17055.6120 _ �q 2 "•' BOROUCtl O£MECIIAN'IC:SBURC $0.45 ?' 16 WEST 11 1.FN kTRF rr l a •^ ,, RSECHARICSBURG PA 17355 3 •" BOROUGH OFMECIIANIC.SBURG C/O DAVID J.SF07TS,F.SQUIRF 10,45 q:e4 36 W ALLEN STREET voc MECI"ICSBURG PA 17055 4 ""' COMMERCE HANKINAKRISIIURG.N.A. ...30.45 •'•- 100 SENATE AVENUE _ CAMPHILI PA 17011 ' { vfia FRAIVCISJ.LA£FERTV,TV,FSQUIR£ 50145 NORPLIZE,T.&.LAFFF,RTV I,I,C 1300 MARKET STREET SUITE 2020 a LEMOVRE,PA 1ID43 y i 3fl'1 6 "•' JF1h 741FERL.L AFFER'T'YC/0MICHAELA.SCH£RER,ESQUIRF, $OAS, ✓"�t BARIC SCIIERER ,Y 1911'SOUI7i SMELT CARLISL PA 17013-3444 7 •'•• DOMESTICREL.ATiONS OF - ' 30.43 ` It• CUMBERLAND COW TV ,w 13 NORTH IWVOVRR STP.Err _ CARLISLE PA17013 S °••• COMMONWEALTH OF PENNSYLVANIA '50.45 DEPARTMENT OF WELFARE P.O.BOX 267S IIARIU5BUPG PA I?10S 9 "'"" It"CRNALREVENCESERVICCADVISORY - .$0.45 1000 LlBtRTT'AVENUE ROOM 704 . PrITSBURCH PA IM22 t 10 U.S.DEPARTMENT OFJUSTICE $0.45 11.5.ATTORNFY FOR THR Mlnnt.F.n1S'f'RifT or PA TEDERAL BUILDING 228 NVALNUT'STREET,SUITE 210 PO BOX 11754 HARRISBURG.PA 11103.1754 1I •'*' BOROUGH OFMECHANICSSURG 30.45 WEST STRAWBERRY FMELT ATNORTH MARKET'STREET MECHANICSBURC PA 1705'_ 12 FRANCIS J.I.A'FFERTV.IV SOAS C/O DEBRA D.CANTOR.ESQUIRE OD PINE STREET .0.BOX 1166 HARRISBURG PA 17108 R- FRANCIS 11 AFFERTY TV CIUMBERL.AND PHS R 22113711021 Page 1 of I QVrltTeam 5430 Tatsl)N.ba of Iml Nunba orPiezea taamrur.Pa 04m W - - Ilrt raadalxatia+M»t ut is rcpuled an dl dcmcfK eM vtemotims1 mrstard—if.Ile mmtrrumlm&mnity psyobh for tit Pxta wvd m1 swM F.MW11 at/Eft Office gtetivlog kmplgkei reuaarrt M ore jioiUW ekatrems sMda r Vrea Ntall raw,at ttM=99M Unwre><t IsSKOW PO pie pelea to.a lane of 55M.Mr5 M *' ..TTe m*irtmm rn2tmeiry,rryebk rw r.,.rer ltal n+'sJ+rnitr is 5591.the m.mt n b'*e y Paysbku S25.4M lm Ugis=mA ran rincc"k—1 Trim c.Sm Deeestie V it Mr l R90$913 and 5921 fm lwmions of rav�ro Form 387^Facsituite AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M CHASE HOME FINANCE,LLC PH#221137 DEFENDANT SERVICE TEAM/lxh FRANCIS J.LAFFERTY,IV COURT NO.:09-7963 CIVIL TERM JENNIFER E.LAFFERTY SERVE FRANCIS J.LAFFERTY,IV AT: TYPE OF ACTION i 1300 MARKET STREET XX Notice of Sheriff's Sale SUITE 202B SALE DATE: September 4,2013 ^'t LEMOYNE,PA 17043 ,�;; � t^: SERVED t C:�) Sery d�nnd mad known to FRANCIS J.LAFFERTY,N,Defendant on the l(?day of ,2*at k ���o'clock .M.,at i300 MACC�SC't St.l'�E2 �the manner described below: cd -- Defendant rsonally served. �'n dult 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: p �a�s Description: Age Height Weight Race Sex M Other I, f� 0EkC)IJ a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities. DATE: ��� NAME: l� PRINTED NAME: 17y TITLE: S SFC�C—CL NOT SERVED On the day FOUN of 20_,at o'clock_.M.,I, a competent adult hereby state that ndant OTN D—because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ��,w»�tr G toc:t�br�t�ld Jody S Smith ` Chief Deputy PH 2: 2 r ` o Richard WStewart tF - t +` Solicitor OFFICE OF THE SHERIFF f EtI*S�L YA i IA Chase Home Finance LLC vs. Case Number Francis J. Lafferty, IV(et al.) 2009-7963 SHERIFF'S RETURN OF SERVICE 06/24/2013 04:30 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 24 West Maplewood Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 07/16/2013 04:58 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jennifer E Lafferty at 251 N. Saint Johns Drive, Camp Hill, PA 17011, Cumberland County. 09/04/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Joseph Schalk on behalf of Federal National Mortgage Association , being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $844.92 SO ANSWERS, November 26, 2013 RON R ANDERSON, SHERIFF �2 �,5 � (c)COUMYSLUte Shesriif,Teleosoft.In-- On April 25, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 24 West Maplewood Avenue, Mechanicsburg, Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: April 25, 2013 By: Real Estate Coordinator LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2009-7963 Civil Term CHASE HOME FINANCE LLC vs. FRANCIS J.LAFFERTY,IV, Jennifer E. Lafferty Atty.:Joseph Schalk By virtue of a Writ of Execution No. 09-7963 CIVIL TERM, JPMORGAN CHASE BANK, NATIONAL ASSO- CIATION, sibim TO CHASE HOME FINANCE, LLC v. FRANCIS J. LAF- FERTY,IV,JENNIFER E.LAFFERTY owner(s) of property situate in the BOROUGH OF MECHANICSBURG, CUMBERLAND County, Pennsyl- varna,being 24 WEST MAPLEWOOD AVENUE, MECHANICSBURG, PA 17055-6428. Parcel No. 16-24-0787-135. Improvements thereon:RESIDEN- TIAL DWELLING. Judgment Amount:$266,696.19. 73 v PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Mane Coyne, J ditor SWORN TO AND SUBSCRIBED before me this da y of August, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-Nows Co. `1900 Patriot,Drive Zbe r Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is�the Controller 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 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/Community Weekly editions which appeared on the date(s) indicated below. That neither he 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 he 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. 2009.7963 CWn Term C"SV WME FINANCE LLC This ad ran on the date(s)shown below: VS. FRANCIS J.LAFFERTY,Iv 07/28/13 JWKdfar E R dh"y Atty; JOSeph Schalk 08/04/13 By virtue of a writ of Execution No.09-7 3 08/11/13 CIVITERM JP MORGAN CHASE BANK,NATIONAL' ASSOCIATION, SIBIM TO CHASE' . . . HOME FINANCE,LLC V.AxCtsJ ,IV Sworn to a0d subscribed fore m is 23 day of August, 2013 A.D. MOUFERE LAFFERTy owners) of property� shate in the BOROUGH OF MECHANICSBURG, c CUMBERIAND Gnt", Pennsylvania,- Public '"being 24`WEST MAPLEWOOD AVENUE, MECHANICSBURG,PA 17055-6428 Parft!No.16.24-0787.135 (Acreage Ofstreeteddre%) COMMONWEALTH OF PENIS'3YLVANIA NnG thereon: RESIDENTIAL Notarial Seal Judgment Amount$26(696.19 Holly Lynn Warfel,Notary Public Washington Twp.,Dauphin County My Commission Expires Dec.12,2016 PicF a—r$ {'FNNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal National Mortgaize Association is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 24th day of April, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 7963, at the suit of JP Morgan Chase Bank,NA S/B/M to Chase Home Finance LLC against Francis J. Lafferty IV and Jennifer E. Lafferty is duly recorded as Instrument Number 201338252. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. 02©L.3 w Recorder of Deeds �Ccor of umbedand Courtly,Carlisle,PA Ay Commissio Expires the First Monday of Jan.2014