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Home My WebLink About10-1725Phelan 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 t.-?ivek 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 231819 SOVEREIGN BANK 601 PENN STREET READING, PA 19601 Plaintiff V. REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 Defendant '.r- i Eft- . z~ F"??_' ?7AF?Y 2010 MAR 10 A 1I1: 2S CUM".'- ATTORNEY r . t ?. Sri: tlfr! FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. to - Iq 5 Ciy't i erg CUMBERLAND COUNTY File #: 231819 *qA. oo Pic.". ao qal qq5 ?.T 05871 ATT`! 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 #: 231819 1. Plaintiff is SOVEREIGN BANK 601 PENN STREET READING, PA 19601 2. The name(s) and last known address(es) of the Defendant(s) are: REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 08/31/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Instrument No. 200734253. 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 11/0 1 /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 #: 231819 6. The following amounts are due on the mortgage: Principal Balance $83,096.18 Interest $2,253.03 10/01/2009 through 03/08/2010 (Per Diem $14.17) Attorney's Fees $650.00 Cumulative Late Charges $104.96 08/31/2007 to 03/08/2010 Property Inspections $10.35 Costs of Suit and Title Search $551-00 Subtotal $86,664.52 Escrow Credit $0.00 Deficit $472.97 Subtotal $472-97 TOTAL $87,137.49 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability 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 #: 231819 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $87,137.49, together with interest from 03/08/2010 at the rate of $14.17 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. By: PHELAN HA*70INO & SCHMIEG, LLP ? Lawrence TVPhelan, 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 ? Judi T. Romano, Esq., Id. No. 58745 ? Sh t. R. Shah-Jani, Esq., Id. No. 81760 ? J 'ne R. Davey, Esq., Id. No. 87077 ? auren 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 #: 231819 LEGAL DESCRIPTION ALL THAT certain house and lot of ground (25 feet) situated on North West Street, in the fifth ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: ON the West by North West Street; on the north by property now or formerly of the heirs of Charles Shapley, Deceased; on the East by a private alley; and on the South by property now or formerly of W. H. Brown; containing 17 1/2 feet, more or less, in front on said West Street and extending in depth 100 feet, more or less, to said private alley on the East. Said lot of ground has thereon erected the Northern half of a frame dwelling house known as No. 445 North West Street, and necessary outbuildings. BEING the same premises which Donna Young Jones and Nicole Maria Jones n/k/a Nicole Marie Madrigal by deed dated October 10, 2006 and recorded October 11, 2006 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 277, Page 420, granted and conveyed unto Carlisle Housing Opportunities Corporation, Grantor herein. PREMISES BEING: 445 NORTH WEST STREET PARCEL: 06-20-1798-230A File #: 231819 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: 0 4t"-Y File #: 231819 '' ~ ~' !. . ~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Sovereign Bank Civil Division vs. No. 10-1725-CIVIL TERM Rebecca M. West : 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 Complaint and all future pleadings on Defendant, Rebecca M. West, by: 1. Posting of the premises: 445 North West Street, Carlisle, PA 17013 by the Sheriff or a non-party competent adult; 2. First class mail to Rebecca M. West at the mortgaged premises located at 445 North West Street, Carlisle, PA 17013; and 3. Publication in accordance with PA. R.C.P. 430. JUN 2 2 2010 ~ 3 It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. Cc: /Rebecca M. West 445 North West Street Carlisle, PA 17013 ~Re~b~e./cca M. WesLt , PHS# 231819/~cvc' ~' ~~~ "-~~~~ ~•~ ~~ I 2 Y T T: J. N _ a ~_.J O ~ ,--~.' rT ' c- c~i ~ on - ~; t r~ n - ~ ~~ '~f. ~ 7 '~~~ .ti `. 4..~ r ~~ rf ~ ~ 1, ~ ~ -._ 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., ld. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SOVEREIGN BANK Plaintiff vs. REBECCA M. WEST Defendants 231819 ao l o ~v(r ~ Pin 3 :.'~ .: i ~; 1 i '? ..~~: _ . i ._ ~'. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 10-1725-CIVIL TERM ~~ 0.00 P D AT1^/ ~~g8uq~q ~# a~c~aay TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ,L/ I`T,awrence 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 ^ Jud' h T. Romano, Esq., Id. No. 58745 ^ S etal R. Shah-Jani, Esq., Id. No. 81760 nine 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 Date: August ~, 2~1 ~ /cvc, Svc Dept. File# 231819 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 .ludith "t. Romano, Esq., [d. 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., ld. 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 SOVEREIGN BANK Plaintiff VS. REBECCA M. WEST Defendant(s) ATTORNEYS FOR PLAINTIFF c~ rJ .. .- - O ~,~; ~~ ~~- ~-~ - ~~ ~-V ~,; _ i -_ -~ -~ ~ .~ _. . ~.., .~ '• ~ - :... - COURT OF COMMON PLEAS 6~ CIVIL DIVISION CUMBERLANDCOUNTY NO. 10-1725 AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER FILE# 231819 PBW I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following person, REBECCA M. WEST at 445 North West Street, Carlisle, PA 17013; on August 16, 2010, in accordance with the Order of Court dated June 23`a, 2010. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: August 16, 2010 PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, 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 nth 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 ,i. 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 FILE1t 231819 PBW FILED-OfIr E -F ?TASY I".iclan I la'lin in K Schmicg. LLP iiw-cncc I' Phelan, Fsq., Id. No. 32227 r,Mcis S. I1?t11inan, I;sq.. Id. No. 62695 I )anicl G. S?_hmic. 1:sq.. Id. No. 62205 \lichclc M. I3radlbrd, Esq.. Id. No. 69849 .;with I Romano. Esq., Id. No. 587,15 ??cctal R. Shah-J,mi. Fsci- Id. No. 81760 .ILnwnc R. Dnt,!\. ?:sc.. Id No. 87077 1 lLffen R. I ibas. F--sq.. Id. No. 93337 luck Sri?a;ta?a. I:sq., Id. No. 202331 n 13. Joncs. Esy„ Id. No. 86657 cicr .1. Nlulcahv, 1-.sq., Id. No. 61791 Andrew L. Spivack. Esq., Id. No 84139 McGi;inrc;s. Esq.. Id. No. 90131 Oiiismalan.c 11. Hiakos. !:sq.. Id. No. 94620 o?hua 1. Golclmi m. l:sq.. id. No. 205047 ? ?.nulena? R 1}.iii), i:sq.. Id. No. 206779 13ramhlctt, 1?.sc.. Id. No. 208375 617 JFK 13ou1:vt,rd. Suite 1400 )nc Penn Ccntcr Plaza i'hiladclphi?l. PA 19103 ' i 563-7(101) - - - - - - SOVFRI",IGN BANK Plaintiff 20 GOUNW A FFORNF.Y FOR PLAINTIFF CO[1R1 01'COMMON PLEAS CIVIL DIVISION \'S. Defendants CUMI3E,RLAND COUNTY No. 1O-17?5-CIVII.I];RM PILA ?CIPF. TO REINSTATE, CIVIL. ACTION/MORTGAGE FORECLOSURE. 410.00 ISO A" ?-? 9a s?Ra 4 7303 ?'.?1819 O 1] 11' PRO'll ION0 1"MZY: Kiudl. reinstate the Civil Action in Mortgage I"oreclostu-c with reicrcrnce to the above captioned matter. PI IFLAN I IA?LI\N j?-, ACIIM11'G, I.I.P try ? -- =-- ? Lawre e Phelan Esq., Id. No. 32227 ? bran S. allina , lsq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq.. Id. No. 69849 ? 11-1dith 'I'. Romano, I:sq., Id. No. 58745 ? Sheetal R. Shah-,Iasi, :sq., Id. No. 81760 ? lenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Taxis, Esq.. Id. No. 93337 ? Vivelc Srivastava, Esq., Id. No. 202331 ? Jay 13. ,)ones, Esq., Id, No. 86657 ? Peter J. Mulcahy. Esq., Id. No. 61791 ? Andrew L. Spivack, Esq.. Id. No. 84439 .laime McGuirnncss. I;sq., Id. No. 90134 hrisovalantc I'. Fliakos, I-:sq.. Id. No. 94620 ?_J .loshua 1. Goldman. I-sq., Id. No.'_05047 C`ourtcnay R. Dunn. F'sq.. Id. Nc. 206779 ? Andrew C. I3ramblctt. Fsq.. Id. No. 208375 Attornevs for Plaintiff )ate: Au(,-ust24 _2010 cSvc I)cht. Ifilch ? ? 1819 FiLEQ-OF~'ICE flF ThlE P~~'IiONOTAR 2~Ifl SEP 22 PIS !~ I Q 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 ~ 15-56'~-7000 c~~~eES~~.A~ao caur~i~ PESYL1~lANlA ATTORNEYS FOR PLAINTIFF SOVEREIGN BANK PLAINTIFF VS. REBECCA M. WEST DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 10-1725-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT BY PnSTiNG PiTRSI<lANT Tn (''ni1RT nRnFR FILE# 23 ] 819 cvc Post by: AFFIDAVIT OF SERVICE -CUMBERLAND (PBW) PLAINTIFF SOVEREIGN BANK COUNTY: CUMBERLAND COURT NO. 10-1725 DEFENDANT REBECCA M. WEST SERVE AT: Rebecca M. West 445 North West Street Carlisle, PA 17013 ***PLEASE POST THE PROPERTY*** ***IN ACCORDANCE WITH THE***** ***ATTACHED COURT ORDER****** TYPE OF ACTION XX Mortgage Foreclosure Eviction XX Civil Action Complaint on Promissory Note ' Served Served nd made known to ~C~ ~ - Iti ~$r Defendant on the '~' day of (.(~S ~ 2DID at :13 o'clock, . M., at ~i~ /1f„2r1/- WEST' l 5 L6y p~ , 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/relationship. __ ManagerlClerk 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 office of said defendant company. _~ Other: Q ~ ~~ Description: Age Height Weight Race Sex Other 1, ~rQ-[~D f ~LL-a competent adult, being duly sworn according to law, depose and state that I personally posted a true and correct copy of the Complaint in Mortgage Foreclosure issued in the captioned case on the date and the address indicated above. Swnrn to and subscribed Before me his oZ? day of Notary: By; On the ay of Defendan D because: ov Unknown Other: ~~~t-~-a Kt~:6~RLY CURTY NOTr1itY PUBLIC Not Served STATE OF NEW ERSEY 200_, at o'clock _.M., ~dY CO~iMlSS;ON E:c?IRES MARCH 7, 2013 No Answer Vacant Sworn to and subscribed Before me this day of , 200_. Notary: FII_Ek 231819 PBW By: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esquire Francis S. Hallman, Esquire Davie) G. Schmieg, Esquire 1 PENN CENTER AT SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 (215)563-7000 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SOVEREIGN BANK VS. REBECCA M. WEST Attorney for Plaintiff Zm Ti- ? , -? ? a : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-1725-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 REBECCA M. WEST, 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: Y4 oo ?b 231819 Gxr- ?1 ? As set forth in Complaint $87,137.49 Interest - 03/09/2010 to 12/16/2010 $4.010.11 TOTAL $91,147.60 I hereby certify that (1) the Defendant's last known address is 445 NORTH WEST STREET, CARLISLE, PA 17013-1960, and (2) that notice has been given 'a-acco;di- with Rule 237.1, copy attached. .Lj-bawfence 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 lison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. r DATE: Iq-17 "/& PHS # 231819 PROTHONO ARY 231819 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff SOVEREIGN BANK : CUMBERLAND COUNTY 601 PENN STREET : COURT OF COMMON PLEAS READING, PA 19601 VS. REBECCA M. WEST : CIVIL DIVISION : No. 10-1725-CIVIL TERM AFFIDAVIT 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 REBECCA M. WEST is over 18 years of age and resides at 445 NORTH WEST STREET, CARLISLE, PA 17013-1960. 231819 This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. _-- December 16, 2010 ence 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 ?ew C. Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff 231819 (Rule of Civil Procedure No. 236) - Revised SOVEREIGN BANK : CUMBERLAND COUNTY VS. : COURT OF COMMON PLEAS REBECCA M. WEST : CIVIL DIVISION : No. 10-1725-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on 12.-1-7 -( D By: If you have any questions concerning this matter please 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 [eA11 drew C. Bramblett, Esq., Id. No. 208375 i son F. Wells, Esq., Id. No. 309519 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 YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 231819 SOVEREIGN BANK Plaintiff V. REBECCA M. WEST Defendant(s) TO: REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 DATE OF NOTICE: December 2, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-1725-CIVIL TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE. YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. PHS # 231819 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: nce T. Phe an, Esq., Id. No. 2227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza P iladelphia, PA 19103 4-?. 1309.71 PHS # 231819 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1725 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK Plaintiff (s) From REBECCA M. WEST (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 $91,147.60 L.L. $.50 Interest FROM 12/17/10 TO DATE OF SALE ($14.98 PER DIEM) -- $2,501.66 Atty's Comm % Due Prothy $2.00 Atty Paid $195.90 Other Costs Plaintiff Paid Date: 1/7/11 (Seal) By: REQUEST IN6 PARTY: Name: CO_URTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Deputy id D. Buell, Prothonotary Supreme Court ID No. 206779 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 SOVEREIGN BANK COURT OF COMMON PLEAS Plaintiff v REBECCA M. WEST Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 12/17/2010 to Date of Sale ($14.98 per diem) TOTAL pd- " o 1133. N0 " qI - UG ls? jG? Ov ?lGOGI lG 6 R#Y &i'" n n n pro 16t,10 76 10 2,S3 35u ?/•sU G?LL CIVIL DIVISION NO.: 10-1725-CIVIL TERM CUMBERLAND COUNTY C.j.. ...W,r -10 M x- 91147.60 U,)r- t- $2,501.66 $93,649.26 ti A rney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivck 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 1 1 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 Note: Please attach description of property. PHS # 231819 •o a? y a 3 v0? a? WW z Q a v?• U 4 w z 0 W N V7 h pip ? .•-? M ? ? ? ? OO O ar M?'D o??pMN 0,?zR oc" zW WC .. o 6 ozv'ZNr,-`? o o? o oz° Oar ?+ p"zzz o oIQ zz :, z d • W o a';° d d?z?ZZz?z;d d .•o °~Z O t V;2 d"dtiib ov `?W °y d O y a" -z y y c c U [? Q ?W W W-oW.^CVy"5rd HW W_gW y y O -g A F'' CE1 ,? p w o a f ? N zs 2 A u 0 C.1 C) CA . -4 0! SO p UW PGa UA ?C, h va o?ya°i???-??°y°yo W W o . 02 0 -wo A%, Ilk! o waoaaoooaoaooao? a ?U ,,,I LEGAL DESCRIPTION ALL THAT certain house and lot of ground (25 feet) situated on North West Street, in the fifth ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded ar.( described as follows, to wit: ON the West by North West Street; on the north by property now or formerly of the heirs e; f Charles Shapley, Deceased; on the East by a private alley; and on the South by property now or formerly of W. H. Brown; containing 17 1/2 feet, more or less, in front on said West Street and extending in depth 100 feet, more or less, to said private alley on the East. Said lot of ground has thereon erected the Northern half of a frame dwelling house known as No. 445 North West Street, and necessary outbuildings. TITLE TO SAID PREMISES IS VESTED IN Rebecca M. 'ir'e 1- [ Opportunities Corporation, dated 08/31/2007, recorded 08/31/2007 in Instrument Number 200734252. PREMISES BEING: 445 NORTH WEST STREET, CARLISLE, PA 1.7013-1960 PARCEL NO. 06-20-1798-230A Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SOVEREIGN BANK Plaintiff V. REBECCA M. WEST Defendant(s) 2 11 JAN -1 rIU ENNSY VA 1 4! °; f.j PENNSYLVANIAN CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 10-1725-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: rney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? 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 shua 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 SOVEREIGN BANK COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 10-1725-CIVIL TERM REBECCA M. WEST Defendant(s) CUMBERLAND COUNTY PHS # 231819 AFFIDAVIT PURSUANT TO RULE 3129.1 SOVEREIGN BANK, 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 445 NORTH WEST STREET, CARLISLE, PA 17013-1960. Name and address of Owner(s) or reputed Owner(s): Name REBECCA M. WEST Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE .•? ?? Fes` Address (if address cannot be reasonably -um c .'- ascertained, please so indicate) Z r f C" 445 NORTH WEST STREET z? --A C' CARLISLE, PA 17013-1960 -,? Y - -:7 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. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) CARLISLE HOUSING OPPORTUNITIES 60 WEST PENN STREET CORPORATION CARLISLE, PA 17013 SOVEREIGN BANK 1130 BERKSHIRE BOULEVARD WYOMISSING, PA 19610 ORRSTOWN BANK 77 EAST KING STREET SHIPPENSBURG, PA 17257 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. I 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 Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 445 NORTH WEST STREET CARLISLE, PA 17013-1960 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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. January, 2011 By: Attey for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? 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 J?Ftourtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 SOVEREIGN BANK : COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO.: 10-1725-CIVIL TERM REBECCA M. WEST Defendant(s) CUMBERLAND ( UwY- b Mr NOTICE OF SHERIFF'S SALE OF REAL PROPERTY et TO: REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 "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 445 NORTH WEST STREET, CARLISLE, PA 17013-1960 is scheduled to be sold at the Sheriffs Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $91,147.60 obtained by SOVEREIGN BANK (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: 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, g''l Jurlg,nent 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 house and lot of ground (25 feet) situated on North West Street, in the fifth ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: ON the West by North West Street; on the north by property now or formerly of the heirs of Charles Shapley, Deceased; on the East by a private alley; and on the South by property now or formerly of W. H. Brown; containing 17 1/2 feet, more or less, in front on said West Street and extending in depth 100 feet, more or less, to said private alley on the East. Said lot of ground has thereon erected the Northern half of a frame dwelling house known as No. 445 North West Street, and necessary outbuildings. TITLE TO SAID PREMISES IS VESTED IN Rebecca M. West, by Deed from Carlisle Housing Opportunities Corporation, dated 08/31/2007, recorded 08/31/2007 in Instrument Number 200734252. PREMSES BEING: 445 NORTH WEST STREET, CARLISLE, PA 17013-1960 PARCEL NO. 06-20-1798-230A FILED-OFFICE OF THE FPJTHONGT I'RY 2011 MR 28 AM 10, 00 CUMBERLAND COUNTY PEN SYLV ,,h'IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SOVEREIGN BANK Plaintiff V. REBECCA M. WEST Court of Common Pleas Civil Division CUMBERLAND County No.: 10-1725-CIVIL TERM Defendant RULE AND NOW this day of ;011 a Rule is entered upon the Defendant to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY T OURT J. 231819 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 '1?0/If ? Alkaon F. Welts, SgR. ? are , { 1linaA e&b teq 231819 231819 I APR --4 AM 9: 142 rUMBERLAND COUNTY PENNSYLVANIA 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 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SOVEREIGN BANK Plaintiff V. REBECCA M. WEST Defendant ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-1725-CIVIL TERM CERTIFICATION OF SERVICE 231819 I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of April 15, 2011 was sent to the following individual on the date indicated below. REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 Phelan Hall' & Schmieg, LLP DATE: ( 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 ? Sheet R. Shah-Jani, Esq., Id. No. 81760 ? Je ' e R. Davey, Esq., Id. No. 87077 VveVi'k en R. Tabas, Esq., Id. No. 93337 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 1. 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 ATTORNEY FOR PLAINTIFF 231819 IN THE COURT OF COMMON PLEAS _ OF CUMBERLAND COUNTY, PENNSYLVANIA c? 'Ti SOVEREIGN BANK C CUMBERLAND COUNTC W ? ? `F Plaintiff, = -am COURT OF COMMON P ' S z° v. ? ?? CIVIL DIVISION zr --+o D-r ? REBECCA M. WEST r y ? Defendant(s) No.: 10-1725-CIVIL TERM y=a = 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 (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached heret &,sq... Z'. ? Lawrence T. PhId. No. 32227 ? Francis S. HalliId. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? J ith 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 1. 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 y ti 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 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 # 231819 ao bq ? M U ? ['I B o l6 l 3ao3diz woaj a3iivw II,OZ L0 W 99ZLLZt6000 o9£'EQ $ VU zo 5 ?1SGti S':j1?? z O O 0 ? ti U a Qo W a Q O N O Yj N ?-r c F, •a •? o A ? ? W `? b u o :. n a F 'n W r O ?W ? O c °' rn WW aiF,o °?v? a,w °NFQ oE0.'_ o ?t?Go?x?Q P?+ vU On w C °d? v'^ g of Ozd' Wv? Cq u o °Wa.W3 rnu 51 d''`Fa cvxo. 3 dN ?- ''? '- L. ~ C6 cn V) n??0 e3a?'" 4 Bz,Z„ 8 8Z 8 0. L d?°L??3viuii? ?CYW?MO O et Oar,,cc OdOed+' zE-.rUAU,-.UUAax,?..,rs,p?wA0u uo y? # K K 49 N J'yox d. 0 a~ N M w w Ir IGO u m r gy - L ? a ? z , N C J u a ?I f ON a M a o ? o V a°a U tc U ?. o W o a ?p u c r L, E Z M 2? M T Z I , ?? ? I I I I I I £o L6 L 3aOadlZ woad a311VW LLOZ tl 2NVW 98ZCLZO000 09z3o $ wL zo zssI Cw R 1 ? i ?'` s may; W pb' C ?ccN TS ? G p y U G O C '? E °'u v°.a E ,,,'a 0 U• _? =? $00 .?v. Q u r .? 6 ? ?F? ?_ F '? .€ - E u v 's ? c ? A ? E 'Eo v W x ?lc5 gW c u g $? ?j?w 0 8 ?, ??$?E ?oo'vo '?' C N C k' U W K '? .-. i p O = N _? FS E'? c ?j v Em .o a 0 a u ? 0 a°, w 0 z?3 F C Q a G E y E v` vi ? z' Z O -? '" cv `' v .,, a oo a ° c i -, ?t v? b O? M W a •c Q U ? F V W W S y,. F w ?; a . 3 a ? a x V = ? r v i ? y % M ? ca ? ? c U ??a z a t. y z U N 3 SOVEREIGN BANK vs. REBECCA M. WEST IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Court of Common Pleas Civil Division n N C-- CUMBERLAND Co* 3 No.: 10-1725-CIVIL 9=,::, ?.? Defendant , -0 ORDER AND NOW, this ;7 day of A, 2011, upon consideration of PlainW? Cs V ? r Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant 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 true ror off' o r' --4 3r to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $83,096.18 Interest Through June 1, 2011 $8,561.79 Per Diem $13.90 Late Charges $104.96 Legal fees $1,925.00 Cost of Suit and Title $2,552.08 Property Inspections/ Property Preservation $144.90 Escrow Deficit $2,469.15 TOTAL $98,854.06 Plus interest from June 1, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. Allison F Wells, '--Rebeam wes+ I,op'Sl',I oh LB Y URT: J. 231819 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson' Sheriff w4tt?ti'' pi 4 trrrr(,rf?}iN J 1 t7 r It?e Jody S Smith Chief Deputy i P IC, -2 PH 2: I, r Richard W Stewart Solicitor r ?. a {, ? ? { Sovereign Bank vs. Rebecca M. West Case Number 2010-1725 SHERIFF'S RETURN OF SERVICE 03/11/2011 01:12 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by postinc a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 445 North West Street, Carlisle, PA 17013, Cumberland County. 03/25/2011 08:23 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Rebecca M. West, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 45 North West Street, Carlisle, PA 17013, defendant is not known at address per post office, did not leave a forwarding address. 06/01/2011 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, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Atty Daniel Schmieg, on behalf of Sovereign Bank, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $740.34 August 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF Coi.m S Ito She! .'t. relro.,oft. In... SOVEREICN BANK Plain,ff V. REBECCA M. WEST Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-1725-CIVIL TERM CUMBERLAND COUNTY PHS # 231819 AFFIDAVIT PURSUANT TO RULE 3129.1 SOVEREIGN BANK, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Executi , ;F f led, the following information concerning the real property located at 445 NORTHWEST STREET, CARLISLE, PA 17013 0f)i . 1. Name and address of Owner(s) or reputed Owner(s): Nar!t REBECCA M. WEST 2. Natii<_ and address of Defendant(s) in the judgment: Name ';; VM F AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 445 NORTH WEST STREET CARLISLE, PA 17013-1960 Address (if address cannot be reasonably ascertained, please so indicate) 3. N & t,, arid last known address of every judgment creditor whose judgment is arecord lien on the real property to be sold: Address (if address cannot be reasonably ascertained, please indicate) t a. s of last recorded holder of every mortgage of record: Address (if address cannot be reasonably ascertained, please indicate) SING OPPC1Ki u N i 1'IES 60 WEST PENN STREET ??,A [ON CARLISLE, PA 17013 HANK 1130 BERKSHIRE BOULEVARD WYOMISSING, PA 19610 s k ?1.S'FOWN BANK 77 EAST KING STREET SHIPPENSBURG, PA 17257 5. tt,,l address of every other person who has any record lien on the property: Address (if address cannot be reasonably ascertained, please indicate) 6 address of every other person who has any record interest in the property and whose interest may be affected by the Address (if address cannot be reasonably ascertained, please indicate) i tic? ind address of every other person of whom the plaintiff has knowledge who has any interest in the property which may r ,', rt:ct-d by the sale: rn Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 445 NORTH WEST STREET CARLISLE, PA 17013-1960 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Df rwrtment of Welfare Ia ternal Revenue Service Advisory I. S. Department of Justice LJ.S. Attorney for the Middle District of PA 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowled,jk? or information and belief. I understand that false statements herein are made subject to the penalties of 18 1"t A. § 4904 relating to unsworn falsification to authorities. JanuarY4 ;. 2011 By: A e tty for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? 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 LEFTCourtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 SOVEREIGN BANK COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO.: 10-1725-CIVIL TERM REBECCA M. WEST Defendant(s) CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: REBECCA M. WEST 445 NORTH WEST STREET CARLISLE, PA 17013-1960 * *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 445 NORTH WEST STREET, CARLISLE, PA 17013-1960 is scheduled to be sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $91,147.60 obtained by SOVEREIGN BANK (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 T,,; prevent this Sheriff s Sale, you must take immediate action: 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 iudg;nent 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.) t 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 house and lot of ground (25 feet) situated on North West Street, in the fifth ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: ON the West by North West Street; on the north by property now or formerly of the heirs of Charles Shapley, Deceased; on the East by a private alley; and on the South by property now or formerly of W. H. Brown; containing 17 1/2 feet, more or less, in front on said West Street and extending in depth 100 feet, more or less, to said private alley on the East. Said lot of ground has thereon erected the Northern half of a frame dwelling house known as No. 445 North West Street, and necessary outbuildings. TITLE TO SAID PREMISES IS VESTED IN Rebecca M. West, by Deed from Carlisle Housing Opportunities Corporation, dated 08/31/2007, recorded 08/31/2007 in Instrument Number 200734252. PREMISES BEING: 445 NORTH WEST STREET, CARLISLE, PA 17013-1960 PARCEL NO. 06-20-1798-230A SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-1725-CIVIL TERM SOVEREIGN BANK vs. REBECCA M. WEST owner(s) of property situate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being (Municipality) 445 NORTH WEST STREET, CARLISLE, PA 17013-1960 Parcel No. 06-20-1798-230A (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $91,147.60 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1725 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK Plaintiff (s) From REBECCA M. WEST (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 $91,147.60 L.L. $.50 Interest FROM 12/17/10 TO DATE OF SALE ($14.98 PER DIEM) -- $2,501.66 Atty's Comm % Due Prothy $2.00 Arty Paid $195.90 Other Costs Plaintiff Paid Date: 1/7/11 David ue11, Proth otary (Seal) By: Deputy REQUESTING PARTY: Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 TRUE COPY FROM, RECORD In Testimcny ?.ahereof, 1 here unto set my hand and the , of , d at varlisle, Pa.' i Thls.?day of , 201 -- r tnonotary t On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 445 North West Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-1725 Civil Sovereign Bank VS. Rebecca M. West Atty.: Daniel J. Schmieg By virtue of a Writ of Execution NO. 10-1725-CIVIL TERM, SOV- EREIGN BANK vs. REBECCA M. WEST, owner(s) of property situate in the BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being 445 NORTH WEST STREET, CARLISLE, PA 17013-1960. Parcel No. 06-20-1798-230A. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $91,147- .60. 90 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: April 22, April 29, and May 6, 2011 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. Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this of Ma 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. r 2020 TechRolo9y Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe Patti* ot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 2020 Technology Pkwy, Suite 300, 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 she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 05/06/11 4 C : . Aur. vinueofaWrit ofiro. Sworgfo a subscribed b e e this 3 d May, 2011 A. D. IMMS&PAIL'VRM SOVERFOf%ANK REBECCA M. WEST Pte( of Propem'situoin Notary Public ft WROV OF CARIALF, ox0ber}nd cmuty, Pcwovama, Wag 445 NORTH WESTSnWa CARLISLE. PA 170 1%0 C MMONWEALTH parcel No. 06=?FI ZXA PENNSYLVANIA (Aacw or sfivd ) Sherrie L gNoWW stw NNotar, Publics lm DVAUJIM pmq Lower Pax6Dn TWP., Dauphin Coon My CWnwon 50M Nov. 26, 2011 3U17f}MWT AMULINR I6?,1049 Member, Pennsylvanla Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Sovereign Bank is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 7 day of J_ uarv, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 1725, at the suit of Sovereign _Bank against Rebecca M. West is duly recorded as Instrument Number 201121384. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of LLv ti•a , A.D. cab Recorder of DG?ds %Mft Comma ta fJ ft . P11 "Y