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Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 227168 SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE P.O. BOX 27767 RICHMOND, VA 23224-7767 Plaintiff V. THOMAS L. LEONARD 537 SOUTH 3RD STREET LEMOYNE, PA 17043-2005 Defendant FILE J-; r tl3C v? i.., a u THE I 20110 JAN 21 Ph 1: 5'Z ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM I NO. /D - 'Yl• ?r u i 1??2 CUMBERLAND COUNTY 0 ln-00 3v- 11 e K-4 4v?y7? q--1k- a3 b? File #: 227168 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 227168 Plaintiff is SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE, P.O. BOX 27767 RICHMOND, VA 23224-7767 2. The name(s) and last known address(es) of the Defendant(s) are: THOMAS L. LEONARD 537 SOUTH 3RD STREET LEMOYNE, PA 17043-2005 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 09/24/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR SUNTRUST MORTGAGE, LLC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200737609. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2009 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 #: 227168 6. The following amounts are due on the mortgage: Principal Balance $127,121.56 Interest $3,744.44 08/01/2009 through 01/19/2010 (Per Diem $21.77) Attorney's Fees $650.00 Cumulative Late Charges $120.06 09/24/2007 to 01/19/2010 Property Inspections $9.00 Costs of Suit and Title Search $5S9_00 Subtotal $132,195.06 Escrow Credit $0.00 Deficit $0.00 Subtotal $OM TOTAL $132,195.06 7 8. Plaintiff is not seeking a judgment of personal liability (or an in nn .rc onaam 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. 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. File #: 227168 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $132,195.06, together with interest from 01/19/2010 at the rate of $21.77 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By. Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 227168 LEGAL DESCRIPTION ALL THAT CERTAIN parcel of ground situate in the Borough of Lemoyne, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southwestern side of South Third Street (formerly Rossmoyne Street), said point being located and referenced Eastwardly a distance of two hundred fifty (250.0) feet from the right-of-way line of Walton Street; thence along the Southwestern side of South Third Street, South forty-six (46) degrees, thirty (30) minutes East, a distance of fifty (50) feet to a point at lands now or late of C.H. Runkle; thence along same, South forty-three (43) degrees, thirty (30) minutes West, a distance of two hundred seventeen and eight-tenths (217.8) feet to a point on Lot No. 5 on the hereinafter mentioned Plan of Lots; thence along same, North forty-six (46) degrees, thirty (30) minutes West, a distance of (50) feet to a point at Lot No. I-A; thence along the same, North forty-three (43) degrees, thirty (30) minutes East, a distance of two hundred seventeen and eight-tenths (217.8) feet to a point at the place of BEGINNING. CONTAINING ten thousand, eight hundred; ninety (10,890) square feet, more or less, and having thereon erected a dwelling house, known as No. 537 South Third Street. BEING Lot No. 2-A on Re-subdivision Plan of Lots of 'Lower Walton', dated January 30, 1968, and recorded in Plan Book 1, Page 204, Cumberland County Records. UNDER AND SUBJECT, NEVERTHELESS, to the easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would File #: 227168 'reveal, including the right to use an 18 feet driveway as set forth in Deed Book 36-D, Page 29. BEING THE SAME PREMISES which Jerry L. Cook, an adult individual, by deed dated July 8, 2004, and recorded on July 8, 2004, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 264, Page 308, granted and conveyed unto Thomas L. Leonard and Amanda L. Leonard, husband and wife, the Grantors herein. PROPERTY BEING; 537 SOUTH 3an STREET PARCEL# 12-22-0822-294 File #: 227168 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsifications to authorities. ttoiney for Plaintiff DATE: lD -I I= File #: 227168 SHERIFF'S OFFICE OF CUMBERLAND COUNTY r_- Ronny R Anderson '? - Sheriff TP. ???U1r at ?u?tibrr/?r? Jody S Smith c?: ` `???? ' Chief Deputy Edward L Schorpp Solicitor DUCE Suntrust Mortgage, Inc. Case Number vs. 2010-461 Thomas L. Leonard SHERIFF'S RETURN OF SERVICE 01/22/2010 04:04 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on January 22, 2010 at 1604 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Thomas L. Leonard, by making known unto himself personally, at 537 S. 3rd Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 January 25, 2010 R ANDERSON, SHERIFF Deim y Sheriff' (c) CountySuite Shenff. Teleosoft. Inc. fi1LED-C=D=ICE ?1r THE PR OTHO'etC1ARY 2010FEB -9 A1410: 46 9-'' 3t4OYL ANI A Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Plaintiff VS. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-461 CIVIL TERM THOMAS L. LEONARD CUMBERLAND COUNTY Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 227168 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for PlaWiifk--\ . / By: ?. ? AeT elan, Esq Id. No. 32227 ? F nan, Esq. Id. No. 62695 ieg, Id. No. 62205 rd, 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 R Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: 2-5-10 PHS #: 227168 VERIFICATION a v; "1-2 hereby states that he/she is ec? re ec a Us4-of SUNTRUST MORTGAGE CORPORATION, servicing agent for Plaintiff in this matter, that he/she is authorized To take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: G Name: av;c? (,JQ Title:.- ,ectc5-- re S?ec??c ?S Company: SUNTRUST MORTGAGE CORPORATION File #: 227168 Leonard Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Plaintiff VS. THOMAS L. LEONARD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-461 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: PHS #: 227168 THOMAS L. LEONARD 537 SOUTH 3RD STREET LEMOYNE, PA 17043-2005 Phelan Hallinan & Schmieg, LLP Attorney for f)l jiuW By: ?.. ? Law nc T. Phelan, q., Id. No. 32227 ? Fricis . Hallinan sq., Id. No. 62695 ? Daniel G. g, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 [Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: 2-5-10 PHS #: 227168 v Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. VS. THOMAS L. LEONARD Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-461 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against THOMAS L. LEONARD, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $132,195.06 Interest - 01/20/2010 to 02/24/2010 $783.72 TOTAL $132,978.78 I hereby certify that (1) the Defendant's last known address is 537 SOUTH 3RD STREET, LEMOYNE, PA 17043-2005, and (2) that notice has been gi n in accordance with Rule 237.1, copy attached. f? 1 Lawre e . Phelan, E quiff Franc' S Hallinan, E uire Dani 1 G Schmieg squire Michele Br rd, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Phrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: J?&Aek /,d/6 PHS # 227168 PROTHONOTARY 2U' j }i11 1 hi? Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. VS. THOMAS L. LEONARD Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-461 CIVIL TERM fpN.6GPA,t y ?? 9i633? VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant THOMAS L. LEONARD is over 18 years of age and his last known address is 537 SOUTH 3RD STREET, LEMOYNE, PA 17043-2005. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ? La L.ford, lan, Esq.,' Id. No. 32227 ? Fr ci an sq., Id. No. 62695 ? D 'el Esq., Id. No. 62205 ? MicheEsq., 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 ? , aime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised SUNTRUST MORTGAGE, INC. VS. THOMAS L. LEONARD : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. 10-461 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on By: DEPUTY _a- If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PRE VIO USL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONL Y ENFORCEMENT OFA LIEN AGAINST PROPERTY. ** SUNTRUST MORTGAGE, INC. v Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-461 CIVIL TERM THOMAS L. LEONARD Defendant(s) TO: THOMAS L. LEONARD 537 SOUTH 3RD STREET LEMOYNE, PA 17043-2005 DATE OF NOTICE: February 12, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER PHS # 227168 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER.LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 LIBERTY AVENUE (717) 240-6195 ARL , PA 17013 17) 249-3166 By: LawreXce TWlan, Esq., Id. No. 32227 Francis S. Ha linan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 227168 .. IN THE COURT OF COMMON PLEAS MAY ~ ~ 2010 CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD Civil Division No. 10-461 CIVIL TERM ORDER AND NOW, this ~~ ~ day of /~~ ~ , 2010, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendant, THOMAS L. LEONARD, by: 1. Posting of the premises: 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043. 2. First class mail to THOMAS L. LEONARD at the mortgaged premises located at 537 SOUTH 3RD STREET A/K1A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043; and 3. Certified mail to THOMAS L. LEONARD at the mortgaged premises located at 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043; and 4. Publication in accordance with PA. R.C.P Y T RT: n c- Cc: THOMAS L. LEONARD 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET LEMOYNE, PA 17043 n /Y1.~ lit A-I- ~~~. ~~- ~f~~~o ~1 J. `a- r, ~=' := ~_ .~ ~= C G "'~ 227168 3 _... a .'.,{ t :~ '`' ~J --, rri -~ = ,~ =:a .) r, Cn ~~.c. f~l.El~-~:lG~ IN THE COURT OF COMMON PLEAS f~~ 'n-r,~ pr~t~-~r~,-~x~Y CUMBERLAND COUNTY, PENNSYLVANIA 1~1Q M~ Y 13 AM !Q: 3 7 SUNTRUST MORTGAGE, INC. Court of Common Pleas Plaintiff CUA6~,.i~;,'...~`:; ~ ='UMY Yeti f Civil Division ~iJ+tiSYj,~,/,~z,~;~ v. THOMAS L. LEONARD Defendant CUMBERLAND County No. 10-461 CIVIL TERM ~/J/)ORDER AND NOW, this~day of ' " ` , 2010 the Prothonotary is ORDERED to amend the in rem judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc in this case as follows: Principal Balance $127,121.56 Interest Through June 2, 2010 $6,642.67 Per Diem $21.77 Late Charges $200.10 Legal fees ~ $650.00 Cost of Suit and Title $570.00 Sheriff's Sale Costs $0.00 Property Inspections/ Property Preservation $9.00 Appraisal/Brokers Price Opinion $0.00 Mortgage Insurance Premium / $0.00 Private Mortgage Insurance Non Sufficient Funds Charge $0.00 Suspense/Misc. Credits ($0.00) Escrow Deficit $673.70 TOTAL $135,867.03 Plus interest from June 2, 2010 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote figure. Sheriff's commission is not included in the above B RT J. s/~ a~~v ~~~~~>s ' -~ ~ '' Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Es ., Id. No. 62205 Michele M. Bradford, ~sq., Id. No. 69849 Judith T. Romano, Esq, Id. No. 58745 Sheetal R. Shah-Jani, Esg. Id. No. 81760 Jenine R. Davey, Esq., Id PTO. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq. Id. CIO. 86657 Peter J. Mulcahy, ~s , Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGumnessx Esq., Id. No. 90134 Chrisovalante P. Fhakos, 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, Surte 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 n. ' ~i. ~~ `: ~ SUNTRUST MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION THOMAS L. LEONARD Defendant(s). NO. 10-461 CIVIL TERM AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to THOMAS L. LEONARD on MAY 26, 2010 in accordance with the Order of Court dated MAY 20, 2010. The property was posted on MAY 29, 2010. Publication was advertised in CUMBERLAND LAW JOURNAL on JUNE 4, 2010 & in THE SENTINEL on JUNE 2, 2010. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. n 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 Dated: ~ 1~~~ d tal R. Shah-Jani, Esq., Id. No. 81760 nme 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 IN THE COURT OF CONIlVION PLEAS MAY ~ 9 201() CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, 1NC. vs. THOMAS L. LEONARD Civil Division No. 10-461 CIVIL TERM ORDER AND NOW, this ~~ ~ day of /~/q ~ , 2010, upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendant, THOMAS L. LEONARD, by: 1. Posting of the premises: 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043. 2. First class mail to THOMAS L. LEONARD at the mortgaged premises located at 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043; and 3. Certified mail to THOMAS L. LEONARD at the mortgaged premises located at 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043; and 4. Publication in accordance with PA. R.C.P Y T RT: J. Cc: THOMAS L. LEONARD 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET LEMOYNE, PA 17043 227168 3 2 AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY SUNTRUST MORTGAGE, INC. PHS # 227168 DEFENDANT SERVICE TEAM/ iin THOMAS L. LEONARD COURT NO.: 10-461 CIVIL TERM SERVE THOMAS L. LEONARD AT: TYPE OF ACTION 537 SOUTH 3RD STREET XX Notice of Sheriff s Sale A/K/A 537 SOUTH THIRD STREET SALE DATE: 08/04/2010 LEMOYNE, PA 17043-2005 ***PLEASE POST PER COURT ORDER*** SERVED ,~,h Served and made known toTi}nM(~S )- ~ f~NAIIv ,Defendant on the~day of ~_, 2p 10 , at ~3Q, o'clock g. M., at X37 S , 3Rv S~,t~ EMoyNC ~Q , 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: ~OS'7BD T-~oP~aTy Description: Age Height Weight Race Sex Other h ~7N~A-LD ~~e Lam, a competent adult, being duly sworn according to law, depose and state that I ersonall rue and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, P sued in the c p~o~case on the date and at the address indicated above. Sworn to and subs~~c~~'bed ________.-- before me this ~`1K'~ day Kl;~~?~~ ~;~~ i~ i. `l CIJRTY of~~, 201Q, ~ hrj' ,,s:'- i°i"3L?C S?~:.rl. t~;' rtl}~;~ d~R;iFY 2013 7 ~ ~ ~ No y: , COMMI~~it}iv L,A~'[RE5 MARCH (~ ~~~( ~~ NOT SERVED On da , 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 fore me this _ day ~ of B Y~ Notary: ATTORNEY FOR PLAINTIFF Lawrence T. PhcWn, Esq., Id. No. 32227 Frvncis S. Haltinan, Fsy., Id. No. 62695 Daniel G. Schmie8, F_sq., Id. Nu. 62205 Michele M. Bradford, F_sq., Id. No. 69849 Judi[h T. Romano, Esq., Id. Nu. 58745 Sheets( R Shah•Jani, Fsq., Id. No. 81760 Jenine R. Davey, Esy., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Fsq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinntss, Esq., Id. No. 90134 Chrisovalan[e P. Fliakos, Esy., Id. No. 94620 Joshua I. Goldmaq Fsq., Id. No. 205047 Courtcnay R. Dung Fsy., Id. No. 206779 Andrew C. Bramble[(, Esq., Id. No. 208375 Onc Pcnn Cenlcr al Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 ~~ ~e n ~v . ~~ ~ r t , ~ in J~ w N .-. p ~O oo ~l O~ cn ~ w N ~ N '~~. d ~ ~ ~ " ' ~ a z~ ~ * * * ~ „ ~ ~~ ., ~- ~- * * ,~ ~'= ~i~?7 ~~W~ ~x ~ 'til N ~ "~w~Y x ca. O ;,o p~ o v~ r ' 'b ~ ~ ~, ~~ (9 rn o y y~.V.y / ~ ~ V ~/ ~ H ~ y ~ y ~ ~ ~ O Oyyz l9 ox~ a 0 O ~ ~~„3 O 0 ~ ~ L/~ O H , `` ~ ~; 'y ~ ~ a Q v ^ y ti ~ ~ H N M 1\~ _~ C IJQ ~Q~(~ Ppsrq v ~' O o . ~ ~~ `~ Z PITNEY 60WE5 1 'ir d ~+ ~~ 02 1M ~ ~~.2~'0 0004277256 MAY 26 2010 MAILED FROM ZIP CODE 1 910 3 -n ~' a ~ ~a p ~ ~ ~ y ~ "S II ~O~ .~ ~~a ~ O ~ ~ ~ Y ~~ r HN H~ IM Nr Wiz ~~ ,~ ~ ~ 7 C A A O O 7178 2417 6099 0057 7323 4/KXC THOMAS L. LEONARD 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET LEMOYNE, PA 17043-0000 --fold here (regular) -- fold here (6x9) --fold here (regular) ,USPS -Track & Confirm Page 1 of 1 #~INtI"EflST~ P~ST,Qt.SEfz1/lCE~ Home I Fieio I si°n Ia -.- Track & Confirm FA s Tack & confirm Se>~r~h Rr~sufts Label/Receipt Number: 7178 2417 6099 0057 7323 Class: First-Class Mail® Service(s): Return Receipt Electronic Status: Delivered Your item was delivered at 10:11 AM on June 24, 2010 in PHILADELPHIA, PA 19103. Tir~k & Confirm Enter Label/Receipt Number. ~~°__S~! Detailed Results: • Delivered, June 24, 2010, 10:11 am, PHILADELPHIA, PA 19703 • Notice Left, June 01, 2010, 12:48 pm, LEMOYNE, PA 17043 • Forwarded, May 28, 2010, 9:13 am, LEMOYNE, PA ^ Acceptance, May 26, 2010, 4:54 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, May 28, 2010 Natifica~tian 0(-tions __ _ __ __ __ __ __ ....................__.................... Track & Confirm by email Get current event information or updates for your item sent to you or others by email. (tio> ;€ Return Receipt (Electronic) Verify who signed for your item by email. ~+Go>'~ Site_Map_ Cusfc~m.~c.~stryir.X Form.;s ~ev'S..Se.[vic~s. C.arPgr~ CopyrightC~> 2010 U5PS. All Rights Reserved. No FEAR Act EEO Data FOIA ~ '~ '" P_ri.Ya&Y.P41i.~x T_errrtY of..~lsg. k}y.~ing~~..G.4.$15zmer Siv~tgw..aY. http://trkcnfrm l .smi.usps.com/PTSInternetWeb/InterLabelInquiry.do?strOrigTrackNum=... 06/26/2010 c ~~ ~ ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 lL ~~-- Lisa Marie Coyn ,Editor ~. SWORN TO AND SUBSCRIBED before me this 4 day of June. 2010 '- Notary / ~~ NOTARIAL SEl1l DEBORAH A COLLMI6 Negry ~Ne OOIIOUGH, CUMBERLAND COUNTY My Commission Fxn+~p~ 4r~ as 911id COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 June 4, 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. . ~ x CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S 8ALE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Term NO. 10-461 SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: THOMAS L. LEONARD Being Premises: 537 SOUTH 3RD STREET a/k/a 537 SOUTH THIRD STREET, LEMOYNE, PA 17043- 2005. Being in LEMOYNE Township, County of CUMBERLAND, Common- wealth of Pennsylvania. Parcel Number 1: 12-22-0822- 294. Improvements consist of residen- tial property. Sold as the property of THOMAS L. LEONARD. Your house (real estate) at 537 SOUTH 3RD STREET a/k/a 537 SOUTH THIRD STREET, LEMOYNE, PA 17043-2005 is scheduled to be sold at the Sheriff's Sale on AU- GUST 4, 2010 at 10:00 A.M., at the CUMBERLAND County Courthouse to enforce the Court Judgment of $132,978.78 obtained by, SUNTRUST MORTGAGE, INC. (the mortgagee), against the above premises. PHELAN HALLINAN 8s SCHMIEG, LLP Attorneys for Plaintiff June 4 • ,~ PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland fames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13~, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed nofice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): June 2, 2010 COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-461 CIVIL TERM SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD NOTICE TO: THOMAS L. LEONARD NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" Being Premises: 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043-2005 Being in LEMOYNE Township, County of CUMBERLAND Commonwealth of Pennsylvania Parcel Number 1:12-22-0822-294 Improvements consist of-residential property. Sold as the property of THOMAS L. LEONARD Your house (real estate) at ~ TH ~RD TR ET A/WA ,~,~7 UTH THIRD STREET. LEMOYNE. PA 17043-2005 is scheduled to De sold at the Sheriff's Sale on AUGUST 4 2010 at 10:00 AM, at the CUMBERLAND County Courthouse to enforce the Court Judgment of 5132.978.78 obtained by, SUNTRUST MORTGAGE. I~ (the mortgagee), against the above premises. PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. % //Ii Sworn to and subscribed before me this ~ ~oiu . ~~ Notary Public . My commission expires: NOTAflIAI SEAL 9AMS1 ANN HECKENOORN Notary Publk CARLi8LE BOROUtiH, Ct1M8ERLANO CNTY My Commission Expires Jan 27, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ M Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Suntrust Mortgage, Inc. (et al.) vs. Thomas L. Leonard ~4~t~t,, ~~ ~c~~a~~~~,~ ~~ ~'~~ l,:f- Gf i~ c r , -..E ~rEfttFF Case Number 2010-461 SHERIFF'S RETURN OF SERVICE 04/06/2010 07:53 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1950 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 Thomas L. Leonard, located at, 537 South 3rd Street, a/k/a 537 South Third Street, Lemoyne, Cumberland County, Pennsylvania according to law. 04/22/2010 04:59 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Thomas L. Leonard, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Thomas L. Leonard, defendant does not reside at: 537 S. 3rd Street: a/k/a 537 South Third Street, Lemoyne, forwarding left at Post Office of: 717 Market St, # 396, Lemoyne, PA is a secured box at the UPS Store. 05/27/2010 Property sale postponed to 8/4/2010. 08/04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on August 4, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $87,000.00 to Max J. Myers, of, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 09/03/2014 Proposed Schedule Of Distribution Posted on 913/10, copies mailed to parties. cab. SHERIFF COST: $2,840.96 SO ANSWERS, October 21, 2010 RON R ANDERSON, SHERIFF ~ ~Dd ~ , ~-~e.. ~ ~~~ ~~, ~.~t~~i~ (c; GountySuite Shenff. Te~eosoft. U.c. y,ry iy ~ N"/f D~ y FILED-O~FPCE of ~~~ ~~~r~-~r~~t,~,;~J ~~~%r7~FO..~ti`3E1J ~la~Ldlti1 1 7i'~a?`At^ 1 ?~ F1~ t ~ , ', SCHEDULE OF DISTRIBUTION Date Filed: 09/04!10 Writ No. 2010-461 Civil Term Suntrust Mortgage, Inc. -vs- Thomas L. Leonard 537 South 3Td Street, a/k/a 537 South Third Street Lemoyne, PA 17043-2005 Sale Date: August 4, 2010 Buyer: Max Myers Bid Price: $ 87,000.00 Total Due: $ 135,867.03 Per Order of Court to Reassess Damages DISTRIBUTION: Receipts: Cash on Account (03!17/2010): $ 1,500.00 Cash on Account (08/04/2010): 8,700.00 Cash on Account (08/16!2010): 83,723.76 Total Receipts: $ 93,923.76 ~ .. Disbursements: Sheriff s Costs Legal Search Transfer Tax State Transfer Tax Local Faith Nicola, Lemoyne Borough Tax Collector Borough of Lemoyne, (Sewer/Refuse) Attorney Daniel Schmieg Suntrust Mortgage, Inc. Total Disbursements: Balance for distribution: So Answers: onny R. Anderson. a =:- ~~-:: ~ .. Sheriff 2,540.96 300.00 1,691.88 1,691.88 1,356.26 393.49 1,500.00 84,449.29 ($ 93,923.76) 00.00 c ~ SUNTRUST M(?~'I=G~GE, FNC. Plaintiff CIVIL DIVISION v. THOMAS L. LEONARD a COURT OF COMMON PLEAS NO. 10-461 CIVIL TERM Defendant(s) CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 SUNTRUST MORTGAGE, INC., 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 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIItD STREET, LEMOYNE, PA 17043-2005. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) 2. 3 THOMAS L. LEONARD Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET LEMOYNE, PA 17043-2005 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) CHASE BANK USA, N.A. 3700 WISEMAN BOULEVARD SAN ANTONIO, TX 78251 CHASE BANK USA, N.A. 436 SEVENTH AVENUE, SUITE 1400 C/O JAMES C. WARMBRODT, ESQUIRE PTTTSBURGH, PA 15219 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. a- 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 THOMAS LEE LEONARD C/O SHANE B. KOPE, ESQUIRE AMANDA LOUISE LEONARD 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET LEMOYNE, PA 17043-2005 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 395 SAINT JOHN CHURCH ROAD, SUITE 101 CAMP HILL, PA 17011 303 CHARLES ROAD MECHANICSBURG, PA 17050-3004 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 March 9, 2010 Phelan Hallinan & Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ F cis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R Shah-Jani, Esq., Id. No. 81760 ^ Jenine R Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ~, ::rTHOMAS L. LEONARD 3 =~ { COURT OF COMMON PLEAS .; i Plaintiff : CIVIL DIVISION I i E NO, 10-461 CIVIL TERM ~' CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY - TO: THOMAS L. LEONARD . 537 SOUTH 3RD. STREET - A/K/A S37 SOUTH THIRD STREET - LEMOYNE, P~:17043-2005 .;: ~,_ _; - `"- * *THIS FIRM TS A DEBT :COLLECTOR ATTEMP'I'llVG TO COLLECT A DEBT AND ANY INFORMATION OBTAINED ~: ~?~ ~ - WIT.L BE USED FOR THAT PURPOSE. lF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE TN BANKRUPTCY, -- - THIS IS NOT AND STl<OULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY -- ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 537 SOUTH 3RD STREET A/K1A 537 SOUTH THIRD STREET, " LElVYOYNE, PA 17043-2005 is scheduled to be sold at the Sheriffls Sale on JITNE 2, 2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of -~ $132,978.78 obtained by SUNTRUST MORTGAGE, INC. (the mortgagee} against you. In the event the sale is I coritinued, 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 fmd 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 lave of stopping the sale. (See notice on page two on how to obtain an attorney.) . If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the rice bid by calling 215-Sb3-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed ro the value of yoµr 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 cal1215-563-7004. 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 parcel of ground situate in the Borough of Lemoyne, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southwestern side of South Third Street (formerly Rossmoyne Street), said point being located and referenced Eastwardly a distance of two hundred fifty (250.0) feet from the right-of-way line of Walton Street; thence along the Southwestern side of South Third Street, South forty-six (46) degrees, thirty (30) minutes East, a distance of fifty (50) feet to a point at lands now or late of C.H. Runkle; thence along same, South forty-three (43) degrees, thirty (30}minutes West, a distance of two hundred seventeen and eight-tenths (217.8) feet to a point on Lot No. 5 on the hereinafter mentioned Plan of Lots; thence along same, North forty-six (46) degrees, thirty (30) minutes West, a distance of (50) feet to a point at Lot No. I-A; thence along the same, North forty-three (43) degrees, thirty (30) minutes East, a distance of two hundred seventeen and eight-tenths (217.8) feet to a point at the place of BEGINNING. CONTAINING ten thousand, eight hundred, ninety (10,890) square feet, more or less, and having thereon erected a dwelling house, known as No. 537 South Third Street. BEING Lot No. 2-A on Re-subdivision Plan of Lots of'Lower Walton', dated 3anuary 30, 1968, and recorded in Plan Book 1, Page 204, Cumberland County Records. UNDER AND SUBJECT, NEVERTHELESS, to the easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal, including the right to use an 18 feet driveway as set forth in Deed Book 36-D, Page 29. UNDER AND SUBJECT, NEVERTHELESS, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. TITLE TO SAID PREMISES IS VESTED IN Thomas L. Leonard, an adult individual, by Deed from Thomas L. Leonard and Amanda L. Leonard, h/w, dated 09!24/2007, recorded 09/28/2007 in Instrument Number 200737608. PREMISES BEING: 537 SOUTH 3RD STREET, A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043-2005 PARCEL N0.12-22-0822-294 SHORT DESCRIPTION By virtue of a Writ of Execution NO.10-461 CIVIL TERM SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD owners} of property situate in the BOROUGH OF LEMOYNE, Cumberland County, (Municipality) Pennsylvania, being S37 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET. LEMOYNE. PA 17043-2005 (Acreage or street address) Parcel Na.12-22-0822-294 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $132,978.78 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT r • ~ COMMONWEALTH bF PENNSYLVANIA) NO 10-461 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUNTRUST MORTGAGE, INC., Plaintiff (s) From THOMAS L. LEONARD (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 $132,978.78 L.L.$.50 Interest from 2/25/10 to Date of Sale ($21.86 per diem) -- $2,142.28 Atty's Comm % Due Prothy $2.00 Atty Paid $174.90 Other Costs Plaintiff Paid Date: 3/10/10 David D. Bu 1, Prothonotary (Seal) By; Deputy REQUESTING PARTY: Name: MICHELE M. BRADFORD, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 69849 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA, Known and numbered as, 537 South 3rd Street, a/k/a 537 South Third Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 Real Estate Coordinator 8S .8 d Z 1 ~tl~I Q;fll `i , ~; ~~lu~r~.~ :. .., . 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 Cazlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chazacter of publication are true. --_ arnt i:o. aoio-~i ciu Suntruat Mortgage, Inc. vs. Thomas L. Leonard Atty: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 10-461 CIVIL, SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD, owner of property situ- ate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania, being 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIRD STREET, LEMOYNE, PA 17043-2005. Parcel No. 12-22-0822-294 Improvanenta thereon: RESIDEN- TW., DWELLING. JUDGMENT AMOUNT: $13~,978- .78. ~- isa Marie Coyne ditor SWORN TO AND SUBSCRIBED before me this 30 da of Aril 2010 J Notary NOTARIAL SEAL OE80RAH A COLLINS Notarlr Peblls CARLISLE BOROUtiH, CUMBERLAND COUNTY My Commiaslon Expiraa Apr 28, 201~t & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-461 held August 4, 2010 EFFECTIVE DATE: August 4, 2010 PREMISES: 537 South 3rd Street, Borough of Lemoyne, Cumberland County, Pennsylvania, Tax Parcel No. 12-22-0822-294 (also known as 537 South Third Street, Lemoyne) (the "Premises") RECITAL: Being the same premises which Thomas L. Leonard and Amanda L. Leonard, husband and wife, by their Deed dated September 24, 2007 and recorded September 28, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania at Instrument No. 200737608, granted and conveyed unto Thomas L. Leonard. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: 1. Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriff s sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriff s sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2010. 20. Subject to the spousal rights, if any, of any spouse of Thomas L. Leonard. -2- . ~ 21. Mortgage in the amount of $130,000.00 from Thomas L. Leonard to Suntrust Mortgage, Inc. dated September 24, 2007 and recorded September 28, 2007 to Instrument No. 200737609, assigned February 24, 2010 in Instrument No. 201004671 to Suntrust Mortgage, Inc. 22. Judgment against Thomas L. Leonard in the amount of $132,978.78 in favor of Suntrust Mortgage, Inc. in an action of mortgage foreclosure on March 1, 2010 to No. 2010- 00461, amended by Order dated May 12, 2010 and entered May 13, 2010 in the amount of $135,867.03. 23. Judgment against Thomas L. Leonard in the amount of $5,386.21 in favor of Chase Bank USA N A entered December 30, 2009 to No. 2009-6680. 24. Subject to all building setback lines, easements, notes, conditions, restrictions and all other matters appearing on the Plan of Lower Walton recorded in Plan Book 1, Page 204. 25. Subject to the right of way noted in Deed Book "D", Volume 36, Page 29 as cited in Instrument No. 200737608. 26. Subject to the legal operation and effect of the civil complaint filed by Discover Bank against Thomas L. Leonard on June 23, 2010 docketed to No. 2010-4204. 27. Subject to the rights of others in and to any portion of the Premises within or adjoining South Third Street and/or Walton Street. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -3- writ No. 2010-461 Civil Suntrust Mortgage, Inc. . vs. Thomas L. Leonard Atty: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 10-4b1 CIVIL, SUNTRUST MORTGAGE, INC. vs. THOMAS L. LEONARD, owner of property situ- ate in the BOROUGH OE LEMOYNE, Cumberland County, Pennsylvania, being 537 SOUTH 3RD STREET A/K/A 537-SOUTH THIRD STREET, LEMOYNE, PA 17043-2005. Parcel No. 12-22-0822-294 Improvements thereon: RESIDEN- TIALDWELLING. JUDGMENT AMOUNT: $132,978- .78. EXHIBIT A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffl s Deed in which Max & Nina Myers is the grantee the same having been sold to said grantee on the 4th day of Aug st A.D., 2010, under and by virtue of a writ Execution issued on the 10th day of March, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 461, at the suit of Suntrust Mortgage Inc against Thomas L Leonard is duly recorded as Instrument Number 201030260. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ / '~ day of A.D. ©/O ..The Patriot-News Co. 2020 Technology Pkwy ' Suite 30.0. Mechanicsburg, PA 17050 Inquiries - 717-255-8213 the patriot-News 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severalty 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 -`NrRNo.2010-461 ClvilTerm Suntrust Mortgage, Inc. Vs. Thomas L. Leonard Atty: Daniel Schmieg By virtue of a Writ of Execution N0. ]0-46] CIVIL TERM SUNTRUST MORTGAGE, II3C. vs. THOMAS L. LEONARD owner(s) of property situate in the BOROUGH OFLEMOYNE, Cumberland County, (Municipality) Pennsylvania, being 537 SOUTH 3RD STREET A/K/A 537 SOUTH THIltD STREET, LEMOYNE, PA.17043-2005 (Acreage or street address) PARCEL N0.12-22-0822-294 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $132,918.78 This ad ran on the date(s) shown below: ~, ~„ Sworn to an s scribed before me this,18 d of May, 2010 A.D. ~ Yi =L.~ Notary Public - - . COMMONWEALTH CAF PENNSYLVANIA Notarial Seel Sherrie L. Klstter, Notary PubNc Lower Paxton Tw{s., Dauphin ~„My MY Commission ~~ ryo~,, 28, 2011 Member, Pennsytvani~~ Associakion of Notaries 04116/10 04/23/10 04/30/10