HomeMy WebLinkAbout10-1978SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson F'LE0-0 R1
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Jody S Smith zu,
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Chief Deputy
Richard W Stewart CiUMp -ER?iLAND CJW "'
Solicitor nF f V?ft i t ? ??, A
PNC Bank, NA
vs.
Raymond Devereaux
Case Number
2010-1978
SHERIFF'S RETURN OF SERVICE
03/18/2011 04:53 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 2023 Yale Avenue, Camp Hill, PA 17011, Cumberland County.
03/18/2011 02:47 PM - Deputy Michael Barrick, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be Richard Snelbaker - Attorney
for Defendant, at 44 W. Main Street, Mechanicsburg, PA 17055, Cumberland County at which time
Acceptance of Service form was completed.
04/11/2011 Stephen Bender, Deputy Sheriff, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Steven
M.Keister at 574 Valley Street, Summerdale, PA 17093, Cumberland, County.
06/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned
"stayed",due to
No Representative being present at the 6/1/11 Real Estate Sale.
SHERIFF COST: $778.59
June 02, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant
AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1
PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker
Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the
following information concerning the real property located in the Borough of Camp Hill, County
of Cumberland and Commonwealth of Pennsylvania:
Name and address of the Owner or Reputed Owner:
RAYMOND DEVEREAUX, c/o Richard C. Snelbaker
ADMINISTRATOR OF THE 44 W. Main Street
ESTATE TODD R. DEVEREAUX Mechanicsburg, Pa 17055
RAYMOND DEVEREAUX, 2702 Logan Street
ADMINISTRATOR OF THE Camp Hill, PA 17011
ESTATE TODD R. DEVEREAUX
2. Name and address of Defendant in the judgment:
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire
ASSOCIATION Michael C. Mazack, Esquire
Tucker Arensberg, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
4. Name and address of last recorded holder of every mortgage of record:
PNC BANK, NATIONAL
ASSOCIATION
c/o Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
Tucker Arensberg, P.C.
1500 One PPG Place
Pittsburgh, PA 152225
5. Name and address of every other person who has any record lien on their
property:
UNKNOWN
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:
CUMBERLAND COUNTY 1 Courthouse Square
TREASURER Carlisle, PA 17013
CUMBERLAND COUNTY
TAX CLAIM BUREAU
1 Courthouse Square
Carlisle, PA 17013
BOROUGH OF
CAMP HILL
TAX COLLECTOR
CAMP HILL SCHOOL
DISTRICT
CAMP HILL SCHOOL
DISTRICT
COMMONWEALTH OF PA
DEPARTMENT OF REVENUE
c/o Janet Miller
1939 Walnut Street
Camp Hill, PA 17011
2627 Chestnut Street
Camp Hill, PA 17011
c/o Janet Miller
1939 Walnut Street
Camp Hill, PA 17011
P.O. Box 2675
Harrisburg, PA 17105
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:
CUMBERLAND COUNTY P.O. Box 320
DOMESTIC RELATIONS OFFICE Carlisle, Pennsylvania 17013
TENANT/OCCUPANT
2023 Yale Avenue
Camp Hill, Pa 17011
-2-
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive
abstract of the condition of the title of the real estate which is being sold under this execution.
No person or entity is entitled to rely on any statements made herein in regard to the condition
of the title of the property or to rely on any statement herein in formulating bids which might be
made at the sale of the property.
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. Section 4904 relating to unsworn falsification to
authorities.
Dated: ??/o/l
By
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
Attorneys for Plaintiff
Sworn to and subs
this day
My CoRwAissibn Expires:
BANK FIN:396875-1 000011-144437
-3-
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
No. 10-1978
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Raymond Devereaux,
Administrator of the Estate
Todd R. Devereaux
2702 Logan Street
Camp Hill, PA 17011
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
Pennsylvania, directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
4T" FLOOR, JURY ASSEMBLY ROOM
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
on June 1, 2011, at 10:00 AM, the following described real estate, of which Raymond
Devereaux, Administrator of the Estate Todd R. Devereaux, are the owners or reputed owners:
Please see attached description of property.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure
action of
PNC BANK, NATIONAL ASSOCIATION
vs.
RAYMOND DEVEREAUX, ADMINISTRATOR OF THE ESTATE TODD R. DEVEREAUX
at Ex. No. 10-1978 in the amount of $161,500.74.
date. against property must be filed at the Office of the Sheriff before the above sale
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution
is filed in the Office of the Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is
a judgment against you. It may cause your property to be held or taken to pay the judgment.
You may have legal rights to prevent your property from being taken. A lawyer can advise you
more specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)-249-3166
1-800-990-9108
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to
help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale
occurs, a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or
objection you might have within twenty (20) days after service of the Complaint in Mortgage
Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a reasonable excuse for
failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be
delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the
mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a
valid return of service of the Complaint and Notice to Defend or if the judgment was entered
before twenty (20) days after service or in certain other events. To exercise this right you would
have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any
other legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE
DEFECTS IN T-HE SHERI_F__F'_S_SALE. _ TO EXERCISE THIS-RIGHT YOU-SHOULD-FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
Brett A. Solomon, Esquire
Pa. I. D. No. 83746
Michael C. Mazack, Esquire
Pa. I.D. No. 205742
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
Attorneys for PNC Bank, National Association,
Plaintiff
BAN K_FI N:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
LEGAL DESCRIPTION OF REAL ESTATE
ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the southern side of Yale Avenue (50 feet wide) at the dividing line
between Lots Nos. 192 and 193, Section "D" on the hereinafter mentioned Plan of Lots; thence
southwardly along said dividing line, one hundred forty-five (145) feet to Lot No. 169, Section
"D"; thence along said Lot No. 169, Section "D", South 82 degrees 48 minutes West, sixty-four
and eight-five hundredths (64.85) feet to the east side of South 21 st Street; thence along the
east side of South 21 st Street, North 9 degrees 7 minutes West, one hundred twenty-nine and
fifty-seven hundredths (129.57) feet to a point; thence along a curve to the East having a radius
of fifteen (15) feet, an arc distance of twenty-four and seven hundredths (24.07) feet to a point
on the south side of Yale Avenue; thence North eighty-two (82) degrees 48 minutes East along
the south side of Yale Avenue, fifty-four and fifty-seven hundredths (54.57) feet to Lot No. 192,
Section "D", the place of BEGINNING.
BEING Lot No. 193, Section "D" in the Plan of College Park, as recorded in the Office of the
Recorder of Deeds of the County of Cumberland, Pennsylvania, in Plan Book 4, at page 108.
HAVING thereon erected a dwelling known as 2023 Yale Avenue, Camp Hill, PA.
K
BEING THE SAME PREMISES WHICH Diana K. Devereaux, by deed dated January 22, 2008
and recorded January 28, 2008 in the Office of the recorder of deeds in and for Cumberland
County in Instrument 20080275,9, granted and conveyed unto Todd R. Devereaux.
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 10-1978 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s)
From RAYMON DEVVEREAUX, ADMINISTRATOR OF THE ESTATE TODD R DEVEREAUX
(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 $147,204.72
L.L.$.50
Interest FROM 6/2/10 THROUGH 9/7/11 AT $25.4269 PER DIEM -- $11,747.23
Atty's Comm %
Atty Paid $174.00
Plaintiff Paid
Date: 2/24/11
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs LATE CHARGES ($121.47/MO. FOR
6/10 TO 8/11) -- $1,822.05
ATTORNEYS' FEES AND COSTS
$723.74
?J ?ee/
id D. Bue , Prothonotary
By:
Deputy
Name: BRETT A. SOLOMON, ESQUIRE
Address: TUCKER ARENSEBERG, P.C.
1500 ONE PPG PLACE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-566-1212
Supreme Court ID No. 83746
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the see! of said Court at Carlisle, Pa.
This do ah day of t? la .20 Jr
Prothonotary
t.?
On March 3, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
Camp Hill Borough, Cumberland County, PA,
Known and numbered as, 2023 Yale Avenue,
Camp Hill, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: March 3, 2011
By:
Real Estate Coordinator
k.
...+ m ... ? v ._k t..rr
CUMBERLAND LAW JOURNAL
writ No. 2010-1978 Civil
PNC Bank, NA
VS.
Raymond Devereaux, Adminstrator
of the Estate of Todd R. Devereaux
Atty.: Brett A. Solomon
ALL that certain tract or parcel of
land and premises, situate, lying and
being in the Borough of Camp Hill,
County of Cumberland, and Com-
monwealth of Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the
southern side of Yale Avenue (50 feet
wide) at the dividing line between
Lots Nos. 192 and 193, Section "D"
on the hereinafter mentioned Plan of
Lots; thence southwardly along said
dividing line, one hundred forty-five
(145) feet to Lot No. 169, Section
"D"; thence along said Lot No. 169,
Section "D", South 82 degrees 48
minutes West, sixty-four and eight-
five hundredths (64.85) feet to the
east side of South 21 st Street; thence
along the east side of South 21st
Street, North 9 degrees 7 minutes
West, one hundred twenty-nine and
fifty-seven hundredths (129.57) feet
to a point; thence along a curve to the
East having a radius of fifteen (15)
feet, an arc distance of twenty-four
and seven hundredths (24.07) feet
to a point on the south side of Yale
Avenue; thence North eighty-two (82)
degrees 48 minutes East along the
south side of Yale Avenue, fifty-four
and fifty-seven hundredths (54.57)
feet to Lot No. 192, Section "D", the
place of BEGINNING.
BEING Lot No. 193, Section "D" in
the Plan of College Park, as recorded
in the Office of the Recorder of Deeds
of the County of Cumberland, Penn-
sylvania, in Plan Book 4, at page 108.
HAVING thereon erected a dwell-
ing known as 2023 Yale Avenue,
Camp Hill, PA.
BEING THE SAME PREMISES
WHICH Diana K. Devereaux, by
deed dated January 22, 2008 and
recorded January 28, 2008 in the Of-
fice of the recorder of deeds in and for
Cumberland County in Instrument
200802759, granted and conveyed
unto Todd R. Devereaux.
17
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.
L',,/Lisa Marie Coyne, E itor
SWORN TO AND SUBSCRIBED before me this
da 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.
2020 Technology-Pkwy
Suite 300
Mectranicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
i4ePatriot News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 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
(??g J r
Sworn to and subscribed before me this 23 day of Koy, 2011 A.D.
Notary Public
CijMMONWEALT'H OF PENNSYLVANIA.
--- --- Notarial Sea--- --__-.._.._
Sherrie L Kiser Notary Public
Lc wer Paxton TiNp., Dau In i
My Commission t Ph County
50"_ Nov. 26, 2011
?emhe-'ennsylvanda Association of Nr
rie
2ot? m qwAt, ##A
Ys
RsYrnond DOVOM8 4
AdR Of iha Estltte of
lbdd P. AttyBrett At wn
ALL that certain tract or parcel of
land and, premises, situate, lying
and being in the Borough of Camp
of Cumberland, and
Co County of Pennsylvania,
morre p
Coe pararticcullarl described as follows.. BEGINNING at a point on the southern side of Yale Avenue (50 feet wide) at the
193,
dividing line between Lots Nos 192 red
Section "D" on the herefnafte along
plan of Lots., thence southwardly
said dividing hue, one hundred forty-five
Section
(145) feet to Lot No. 169, 169ctio
thence along said Lot No. , Section
,+D" South 82 degrees 48 minutes 6W4 85)
sixty-four and eight *e hundredths
feet to the east side of South 2181 Street;
thence along the east side of South 21st
Street, North 9 degrees 7 minutes West,
one humlred lvtenty-ame and filt,-seven
hundredths (129.57) feet to a point; thence
along a curve to the Fast having a radius of
are distance of twenty
fifteen (15) feet, an
four and seven hundredths (2'p feet to
a point on the south side of Yale Avenue:
thence North eighty" O (82) degrees
48 minutes East along the south sides of
fuur and fft n
Yale Avenate+ ftnl 192,
hundredths (54.57) fret to j., of No. G
motion „D„ the place of B&' D' in
BEING Lot No. 193, $e?OII recorded
Park, 85
the plan of College he Rehr of
Office of the eland -9 the
in the ,
De Of the
Pennsylvania, in Flar? Boole 4, ae 108.
W erected a dwelling
VG thereon
knownas 2,023 Yale Avenue, Camp Hdl>PA
BEING Tpy- SAW y deed ? January
Diana K De
22, 2008 and recorded January 28, 2008 in in and
the. Office of the recorder of deeds ent
for Cumberla granted and conveyed unto
X802759, gr
Todd R. Devereaux.
?J
d
R2 Y. a
OF THE PrROMHO)NOTAPY
20119 VIR 19 PM 1: 11
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P ' ?k
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
VS.
RAYMOND DEVEREAUX, ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
I hereby certify that the
property to be foreclosed
upon is:
2023 Yale Avenue
Camp Hill, Pennsylvania 17011
Borough of Camp Hill
Tax Parcel No. 01-22-0536-140
Brett A. Solomon
Attorney for Plaintiff
CIVIL DIVISION
No. It) - ?.vI lerm
CIVIL ACTION - COMPLAINT IN
MORTGAGE FORECLOSURE
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of record for this party:
Brett A. Solomon, Esquire
Pa. I.D. #83746
bsolomona.tuckerlaw.com
Michael C. Mazack, Esquire
Pa. I.D. #205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
0--
4q'A.00 PA Arrq
Ck1 3330q7
10 a39/7`j
BANK FIN:372160-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No.
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE ESTATE OF
TODD R. DEVEREAUX,
Defendant.
IMPORTANT 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)-249-3166
1-800-990-9108
BANK FIN:372160-1 000011-144437
AVISO
Le han de mandado a usted en la corte. Si usted quiere defenderse de estas demandas expeustas en las
paginas siguientes, usted tiene viente (20) dias de pla/o al partir de la fecha de la demanda y ]a
notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregara la
corte enroma ascrita sus defenses o sus objecones a las demandas en contra de su persona. Sea avisado
que si usted no se defiende, la corte tomara medidasy puede continuar la demanda en contra suy a sin
previo aviso a notificacion. Ademas, la corte puede decider a favor del demande\ante y require que usted
cumpla con todas las provisioner de esta demanda. Usted puede erder dinero o sus propiedades o ostro
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIALAMENTE. SI NO TIENE ABAGADO O SI
NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENIRA ESRITA ABAJO
PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)-249-3166
1-800-990-9108
BANK FIN:372160-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No.
VS.
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE ESTATE OF
TODD R. DEVEREAUX,
Defendant.
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW COMES PNC Bank, National Association ('Bank"), by and through its
counsel, Tucker Arensberg, P.C., and avers the following in support of its Complaint in Mortgage
Foreclosure:
1. PNC Bank, National Association, is a national banking association organized
under the laws of the United States of America with a principal place of business at One PNC Plaza, 249
Fifth Avenue, Pittsburgh, Pennsylvania 15222-2707.
2. Defendant, Raymond Devereaux, Administrator of the Estate of Todd R.
Devereaux ("Defendant"), is adult individual whose last known address is 2702 Logan Street, Camp Hill,
Pennsylvania 17011.
3. On or about May 24, 2007, the Defendant executed a Direct Installment Loan
Disclosure Note ("Note") whereby Defendant promised to pay to Bank the principal amount of
$134,264.50 plus interest as provided therein. A true and correct copy of the Note is attached hereto as
Exhibit "A" and incorporated herein.
4. The obligations evidenced by the Note are secured by a Mortgage dated May 24,
2007 (the "Mortgage") given by the Defendant and Diana K. Devereaux to Bank, encumbering certain
real property located at 2023 Yale Avenue, Camp Hill, County of Cumberland, Pennsylvania, as more
BANK FIN:372160-1000011-144437
particularly described therein ('"Premises"). The Mortgage was recorded on June 6, 2007 in the Office of
the Recorder of Deeds of Cumberland County, Pennsylvania in Mortgage Book Volume 1995, Page 195.
A true and correct copy of the Mortgage is attached hereto as Exhibit "B" and incorporated herein.
5. Diana K. Devereaux has not been named as a Defendant in this matter and the
Plaintiff releases her from liability for the debt secured by the Mortgage.
6. Todd Devereaux died on December 3, 2009 and Raymond Devereaux has been
named Administrator of the Estate of Todd Devereaux.
7. The Defendant is in default of the provisions of the Note for failure to make
payment when due and therefore the Defendant is in default of the Mortgage. The Note is due from July
23, 2009 and as of January 25, 2010 was past due in the amount of $4,932.38.
8. The Defendant is the record and real owner of the Premises.
9. There has been no assignment, release or transfer of the Note or Mortgage.
10. On or about September 22, 2009, Notice was sent to Defendant in accordance
with 35 P.S. §1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983 - Act 91 of 1983)
and 41 P.S. §403 (Act 6 of 1974) that an action on said Mortgage may be commenced after 31 days from
the date of the Notice. Said Notice further advised Defendant of Defendant's rights and obligations in
accordance with the Act. A copy of the Notice is attached hereto as Exhibit "C", collectively, and
incorporated herein.
11. The amount due Bank under the Note and Mortgage as of January 25, 2010 was
as follows:
Principal $129,079.96
Interest through January 25, 2010
(continuing thereafter at $25.4269 per diem) 5,751.66
Late Charge 921.45
Attorneys' Fees 1,015.00
Costs to be added
TOTAL $136,768.07
BANK FIN:372160-1000011-144437
12. The total amount due to Bank under the Note and Mortgage as of January 25,
2010 was One Hundred Thirty-Six Thousand Seven Hundred Sixty-Eight and 07/100 Dollars
($136,768.07), plus costs and attorneys' fees.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of One Hundred Thirty-Six Thousand Seven Hundred Sixty-Eight and 07/100 Dollars
($136,768.07), plus continuing interest at the contract rate from January 25, 2010, late charges, reasonable
attorneys' fees and costs of foreclosure and sale of the Premises.
TUC AREN , P.C.
By:
Brett A. Solomon, Esquire
Pa. I.D. #83746
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
Attorney for PNC Bank, National Association,
Plaintiff
BANK FIN:372160-1000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No.
VS.
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE ESTATE OF
TODD R. DEVEREAUX,
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
I, Brett A. Solomon, Attorney for PNC Bank, National Association, being duly sworn according
to law, hereby depose and say that the Defendant, Raymond Devereaux, A inistrator of the Estate of
of the Unit ates America to the best of
Todd R. Devereaux, is not a member of the military seP
my knowledge, information, and belief. /
y
Brett A. Solothon
Attorney for PNC Bank, National Association
My Commission Expires:
2010 TM P NN YL.VAHIA
corms r +Sod pwa
ZL 2013
CAW
BANK FIN:372160-1000011-144437
Sworn to and subscribed before me
(page 2 of - S)
Direct Installment Loan DrUclomre and Note QPNCBANK
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(DPNCBANK
Admin of the Est of Todd Devereaux -Raymond
2023 Yale Ave
Camp Hill, PA 17011
ACT 91 NOTICE
Date: February 5, 2010
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER 'S EMERGENCY MORTGAGE AS SISTANCE PROGRAM =MAP) may be able to help
to save your home. This notice explains how the Progra m works. T o see if HEMAP can hel p, You must MEET
WITH A CONSU MER CREDIT COUNSELING AGE NCY WIT HIN 33 DAYS OF THE DATE OF THIS
NOTICE Take this Notice with You when you meet with the Counse ling Agency. The name, address and phone
number of Consumer Credit Counseling Agencies serving Your Coun ty are Bated at the end o f this Notice If you
have any questions you may call the Pennsylvania Housin g Finance Agency toll free at 1-800-342-2397. (Persons
with impaired hearing can call (717) 780-1869.)
This Notice contains important legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area.
The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUBS AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGBILE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): Admin o f the Est of Todd Devereaux -Raymond severe clo
Richard Snelbaker,E sa / Admin of the Eat of Todd
Deverea ux Raymond Deverea c/o Richard Saelbaker.Esg
PROPERTY ADDRESS: 2023 Yal e Ave, Cam p HUI, PA 17011
LOAN ACCT. NO.: 040-01-0 0811170815 5
ORIGINAL LENDER: PNC
CURRENT LENDER/SERVICER: PNC Bank. N.A.
Member of The PNC Financial Services Group EXHIBIT
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
E
PNCBANK
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE S IGIBLE FOR FINANCIAL ASSISTANCE ZMCH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time
you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the
end of this Nance. THIS MEETING MUST OCCUR ]EMM (331 DAYS OF THE DATE OF THIS NOTICE.
ff YOU DO NOT APPLY, FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST Bum INQ YOtJi_?
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of
this meeting. The names. addresses and teleuhme numbers of deli lk corer credit cmLnseling ftgies for the
county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-
to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later
in this Notice (see following pages for specific information about the nature of your default.) You have the right to
apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program To do so, you must fill
out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania. Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOUSHOULD FILEA HEMAPAPPUCATIONAS SOONASPOSSIBLE IF YOUHAVEA MEETING
WITHA COUNSELINGAGENCY WI7]'MN33 DAYS OF THEPOIS'TMARKDATE OFTHISNOTICEAND.
FILEANAPPLICATION WITHPHFA WITIMV 30 DAYS OF THAT MEETDVG, THEN TIME LMWER WHL
BE TEMPOR4RILYPRE'VENTED FROMSTARTINCA FDREC;LOSUREAGAINST YOUR PROPERTY, AS
EXPLAINEDABOVA IN717ESECITONC4=D "TEVPORARYSTAYOFFORECLOSURE"
YOUHAVE THERIGHT 7V FILEAHEMAPAPPLICATIONEVENBEYOND THESE TIMEPERIODS A
L4 TEAPPLICA77ON WILL NOT PREVENT THE LENDER FROMSTAR722VGA FDRECZOSUREACTION,
BUT IF YOUR APPLIG 77ONIS EVENTTIALLYAPPROVEDATANYTIME BEFOREA SHERIFF'S SALF,
THE FORECLOSURE WILL BE SZVPPED.
Member of The PNC Financial Services (croup
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PNCBANK
AGENCY ACTION -Available finds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can
still apply for Emergency Mortgage Assistance)
HOW TO CURE YOUR. MORTGAGE DEFAULT Bring it UR to date).'
(ACT 6)
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at:
2023 Yale Ave Camp Hill. P 17011
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Monthly vavments in the amounts of $8.86.95 for each of the months from July 2009 through January 201
Other charges (explain/itemize): Late Charges of, $921.45
TOTAL AMOUNT PAST DUE: $6,740.7
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,740.78, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent
to: PNC BANK, NA, 2730 Liberty Avenue, 2nd Floor, Mailstop: P5-PCLC-02-N, Pittsburgh, PA 15222
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreelm mn lour mortgaged nronerty.
IF TM MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the
mortgage debt; If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actual ly incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you core the default within the THIRTY (30) DAY vedod. von
will not required to pay a rney fees.
OTHER LENDER REMEDIES-The lender may also sue you personally forthe unpaid principal balance and all other
sums due under the mortgage.
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PNC?ANY ATFR+$SA E-
RIGH t pQ [TAR TAE DEFA&T PRIOA1SH? Ifyou have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, yQu still have the rigbt to cure the default and pmymt
the sale at anytime up to one hour before the Sheriff's Sala You may do so by paying the total amount then past due, plus
any late or other charaes then due reasonable attorney's fees and costs connected with the foreclosure sale and my other
etc connected with Sheriffs Sale as sMi ied in writing by the lender and by perform n? a am _ other requirements under the
molIgUt. Curing your default In the manner set forth in this notice will restore your mortgage to the same position
as if you had never defhulted.
RA Y EST POWBLE =MUFFS SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgaged property could be held would be approximately six (6) months from the Date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at anytime exactly what the required payment or action will be by
contacting the lender.
HQW TO CONTACT TAE LENDER:
Name of Lander: PNC Bank. N.A.
Address: 2730 Liberty Avenue 2nd Floor Mailstm: P54N3X42-N Pittsburgh. PA 1527.2
Phone Number; 14M04784027
Fax Number. f412)768-3562
Contact Person: Paul Sharkadv
F,M-WI Address: PsuLSharkady(WNC.2 m
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE--You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours.,
PaW Sharkady
original sent: U.S. Mail certified, postage prepaid PNC Bank, National Association
copy sent: First Class, U.S. Mail, postage prepaid
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PNCBANK Date: February 5, 2010
Admin of the Est of Todd Devereaux Raymond
44 W Main St
Mechanicsburg, PA 17055
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage o n your home i s in def ault, and th e lender intends to fo reclose. Specific
information about the na
The HOMEOWNER`S EMERGENCY MO
to save your home. This notice explains h
WrTH A CONSUMER CREDIT COUN ture of the de
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ou must MEET
TE OF THIS
NOTICE Take this Notice with You when You meet with the Co unseling Ag ency. The name. ad dress and phone
number of Consumer Credit Counseling A ¢encles servin g your County are listed at the end of th is Notice. If You
have any questions, you may call the Penns vWWa Housi ng Fina nce Agency toll free at 1-800-342-2397 (Persons
with impa ired hearing c an call (717) 80-1 869.)
This Notice contains important legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain It. You may also want to contact an attorney in your area.
The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): Admin of the Est of Todd Devereaux Raymond Deverea c/o
KdINJ Snelbaker.Esa
PROPERTY ADDRESS: 2023 Yale Ave. Camp Hill, PA 17011
LOAN ACCT. NO.: 040-01-008111708155
ORIGINAL LENDER: PNC
CURRENT LENDER/SERVICER: PNC Bank. N.A.
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
O PNCBANK
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FO SURE AND HELP YOU MAKE EMW M0RT9A0 PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,
AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notlee (plus three (3) days for mailing). During that time
you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NO'T'ICE
IF YOU DO NOT APPLY FOR EMIE?RGRICY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CAU ED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE
CONSUMER REDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies listed at the and of this notice, the lender may NOT take action against you for thirty (30) days after the date of
this meeting. The names. addro ses and telephone numbers of desigg consumer credit counseling agencies for the
cg in which the L Duty is located are set forth at the end of this Notice. It is only necessary to schedule one face-
to-face meeting. Advise your lender fly of your intentions.
APPLICATION FOR MORTGAGE ASSISTAN - Your mortgage is in default for the reasons set forth later
in this Notice (see following pages for specific information about the nature of your default.) You have the right to
apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill
out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAPAPPLICATIONAySOON AS POSSIBLE IF YOUHAVEA MEETING
WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE 1"
FILE ANAPPLICATION WITHPHFA WITHIN 30 DAYS OF THAT MERIWO, THEN THE LENDER WILL
BE TEMPORARIL Y PREVENTED FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE "
YOU HAVE TAE RIGHT TO FILEA HEMAPAPPLICATIONEVENBEYOND THESE TIME PERIODS A
LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,
B UT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,
THE FORECLOSURE WILL BE STOPPED.
Member of The PNC Financlat Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PNCBANK
AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your a licabon.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can
still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date).'
(ACT 6)
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at:
2023 Yale Ave. Camp Hill. PA 17011
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Monthly payments in the amounts of $886.95 for each of the months from July 2009 through January 2010.
Other charges (explain/itomize): Late Charges of. $921.45
TOTAL AMOUNT PAST DUE: 66 7? 740.78
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,740.78, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent
to: PNC BANK, NA, 2730 Liberty Avenue, 2nd Floor, Mailstop: P5-PCLC-02 N, Pittsburgh, PA 15222
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within TH M (30) DAYS of the date of
this Notice, the lender intends to exercise Its rights to accelerate the MgK§MWe debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon vour mortgaged nrooertv.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the
mortgage debt If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will stil l be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you cure the defaalt within the THIRTY (30) DAY yedod, -you
will n!d be Mquired to pal attorney fees
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
PPRIOR TO SHERIFF'S SALE - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun. Yam still have the ngdt to cure the aerault ana prevem
the We at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus
anv late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other
mortgUL Curing your default in the scanner set forth in this notice will restore your mortgage to the same position
as if you had never defaulted.
s Sale of the
ff
y'AR TEST P SSIBL•F MMUFF'S SAl[ gDATE- It is estimated thatthe earliest date that such a Sheri
mortgaged property could be held would be approximately six (6) months from the Date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at anytime exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LFNDER•
Name of Lender: PNC Bank. N.A.
Address 2730 LibertyAyeeua 2nd Floor Mailstou• P5 PCLC-_Gz N Pittsburgh PA 15222
Phone Number: 1.500-678-0027
Fax Number (412)768-356
Contaet Person: Paul Sbarkadv
E-Mail Address: PanLShark*dyQPNC.com
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE--You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT ORTO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours,
Paul Sharkady
original sent: U.S. Mail certified, postage prepaid PNC Bank, National Association
copy sent: First Class, U.S. Mail, postage pt+epaid
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
Q PNCBANK Date: February 5, 2010
Raymond Devereaux Administrator of the Est o
2023 Yale Ave
Camp Hill, PA 1701.1
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY M ORTGAGE ASSISTAN CE PROGRAM (HEN") may be able to help
to save your home. This notice explains how the program works , To see if HEAW can hel p, you must MEET
WITH A CONSUM ER CREDIT COU NSELING AGENCY W ITHIN 33 DAYS OF THE DATE OF THIS
NOTICE. Take this N otice with you when You meet with the Co unseling Agency. The nam& address and phone
number of Consumer Credit Counseling Agencies serving Your C ounty are listed at the end o f this Notice. If you
have any questions, you may call the Pen naylyania Housine Finance Agenev toll free at 1-800 -342-2397. (Persons
with impaired hearing can call (717) 780-1869.
This Notice contains important legal information. If you have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area.
The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN AD,IUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGBILE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Raymond Devereaux Administrator of the Est of T
Devereaux / Raymond Devereaux Administrator of The Est
of Todd Devereaux
2023 Yale Ave, Camp Hill, PA 17011
040-01-008111708155
PNC
PNC Bank, , N.A.
Member of The PNC Financial Services oroup
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
Q PNCBANK
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time
you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEET2M MUST OCCUR WI1HIN 0331 DAYS OF THE DATE OF THIS NOTICE.
IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST RING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies 1 isted at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of
this meeting. The names. addresses and telephone numbers of desi&WQd consumer credit coynseling agencies for the
county in which the uroaerty is located are sat forth at the end of this Notice. It is only necessary to schedule one face-
to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons sex forth later
in this Notice (see following pages for specific information about the nature of your default.) You have the right to
apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program To do so, you must fill
out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOUSHOULD kUEAHEMWAPPLICATIONASSOONASPOSSIBLE IFYOUHAVEAMEETING
WITHA COUNSELEW AGENCY WI77MV 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND
FILEANAPPLICA770N WITH PHFA W 77MV 30 DAYS OF THAT MEETING, THEN THE LENDER WILL
BE TEMPORARILYPREVENTED FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABO VF, IN THE SECH70N CALLED -TEMPORARYSTAY OF FORECLOSURE "
YOUHAYE7HERIGHTTOFILE AHEW"APPLICA770NEVEIVBEYOND7HF.SE77HEPEItIODS A
LATEAPPLICATIONWILLNOTPREVENT THE LENDER FROM STAR nNGA FORECLOSUREACTION,
BUT IF YOUR APPLICA770NIS EVENTUALLYAPPROVED ATANY TIME BEFOREA SHERIFF'S SALE,
THE FORECLOSURE WILL BE STOPPED.
Member of The PNc Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
?PNCBANK
AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed
by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can
still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Brim it up to date).'
(ACT 6)
NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at:
2023 Yale Ave. Camp Hill. PA 17011
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Monthly navments in the amounts of $886.95 for each of the months from July 2009 thropgh January 2010.
Other charges (explain/itemize): Late Cbaraes of. $921.45
TOTAL AMOUNT PAST DUE: $6,740.78
HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,740.78, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent
to: PNC BANK, NA, 2730 Liberty Avenue, 2nd Floor, Mailstop: P5-PCLC-02-N, Pittsburgh, PA 15222
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to Ibnxiose neon our mwj=ed,nro
IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will stil I be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If_ you care the default within the THIRTY (30) DAY period, you
will not reguired to pay attorney fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
Member of The PNC Financlat Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
O PNCBANK PRIOR TO ?+ ?KfFF'S s
RIGH CIMR THE DEFAULT - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, yo_ still have the ri_¢bt to cure the default and prevent
the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus
any late or other charges than due reasonable attorney's fees and costs connected with the foreclosure sale and any other
cos rs connected with Shereffs Seale as sagif e d in yLdd Q by ft lender and by =forming o? ther requirements under the
fig, Curing your default in the manner set forth In this notice will restore your mortgage to the same position
as if you had never defaulted.
EARLIEST POSSIBLE SIM FF'S SALE DATE - It is estimated thatthe earliest date that such a Sheriffs Sale of the ,.
mortgaged property could be held would be approximately six (6) months from the Date of this Notice. A notice of the
actual date of the Sherif'f's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at anytime exactly what the required payment or action will be by
contacting the lender.
09W TO CONTACT THKLEN?ER'.
Name of Lender: PNC Bank.
Address 2730 Liberty Avenue. and Floor. Mallstoo• PS-PC CC- -N Pittsbur4h PA LIA"
Phone Number: 1-800-07MO2
Fax Number: (412)768-M2
Contact Person: Paul Sharkedv
E-Mail Addrea• PauLSbarkadv aIZPNC com
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT•
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours,
c
Paul Sharkady
original sent: U.S. Mail certified, postage prepaid PNC Bank, National Association
copy sent: First Class, U.S. Mail, postage prepaid
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
Q PNCBANK Date. February 5, 2010
Raymond Devereaux Administrator of The Est o
2702 Logan St
Camp Hill, PA 17011
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. SPecitlc
information about the nature of the default Is Provided in the attached paces.
The HOMEOWNEW S EMERGE NCY MORTGAGE A SSISTANCE PROGRAM (HEMAP) may be able to help
to save your home. T his notice e xplains how the urma m worlts. To see if HEMAP can help. You must MEET
WITH A CONSU MER CRED IT COUNSELING AG ENCY WPTHIN 33 DAYS OF THE DATE OF THIS
NOTICE. Take this Notice with y ou when you meet with the Counseling Agent The name. address and phone
number of Consumer Credit Coun seling Agencies servin g Your County are listed at the end of this Notice. If You
have any questions, yo u may call t he Pennsylvania Housi ng Finance Agency toll free at 1-800-342-2397. (Persons
with impaired hearing can can (717) 780-1869.
This Notice contains Important legal information. If yon have any questions, representatives at the Consumer
Credit Counseling Agency may be able to help explain It. You may also want to contact an attorney in your area.
The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION P&WDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIRSU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Raymond Devereaux Administrator of The Est of Todd
Devereaux
2023 Yale Ave. Camp Hill. PA 17011
040-01-00811170815
PN. C
PNC Bank. N.A.
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
Q PNCBANK
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR ROME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,
AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure
on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time
you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE
IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING XQUR
MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling
agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of
this meeting. The names addresses and telchone numbers of ¢esigmted consumer credit counWjUg mcies for the
County in which the proRcM is located are set forth at the end of this Notice. It is only necessary to schedule one face-
to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the. reasons set forth later
in this Notice (see following pages for spec information about the nature of your default.) You have the right to
apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill
out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received
within thirty (30) days of your face-to-face meeting with the counseling agency.
YOUSHOULD FILEA HEMAPAPPLIC4TIONASSOONASPOSSIBLE IF YOUHAVEA MEETING
WITH A COUNSELING A GENCY W 77MV 33 DAYS OF THE POSTMARK DATE OF THIS NOTICEAND
FILE ANAPPLIC4TION WITHPHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL
BE TEMPORARILYPREVE.NTED FROMSTARTINGA FORECLOSURE AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE "
LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,
BUT IF YOUR APPLICATION IS EYENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,
THE FORECLOSURE 07LL BE STOPPED.
A
Member of The PNC Financial Services (croup
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
MPNCBANK
AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty
(60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be
pursued against you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have hied bankruptcy you can
still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date).
(ACT 6)
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at:
2023 Yale Ave. Camp Hill. PA 17011
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
Monthly payments in the amounts of $886.95 for each of the months from July 2009 through JmLu= 20 10.
Other charges (explain/itemize): Late C 5921.45
TOTAL AMOUNT PAST DUE: $6.740.78
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,740.78, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent
to: PNC BANK, NA, 2730 Liberty Avenue, 2nd Floor, Mailstop: P5-PCLC-02-N, Pittsburgh, PA 15222
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its dghts to accelerate the mortamm debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon Your mortraeed nroeeerty.
IF THE, MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to
$50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If you cure the defnuit within the THIRTY (30) DAY uerlod. von
will not be required to aav attorney fees.
OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
Member of The PNC Financial Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsytvania 15222
PNCBANK
RIGHT TO CURE THE DE AULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the
THIRTY (30) DAY period and foreclosure proceedings have begun, You still have the right to cure the default and reg vent
the We a a time MR to one hour before the SheriWs Sale You may do so by Rlyjgg the total amount then 2nd due Dlug
gay late a otter c arses then dw. reasonable attorney's fees and costs connected with the foreclosure male and my other
nnate rnnrn&#.d with Sherifl!'s We as snenified in writing by the lender and by nerformine anv other reauirements under the
mortgage. Curing your default In the manner set forth in this notice will restore your mortgage to the some position
as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the
mortgaged property could be held would be approximately six (6) months from the Date of this Notice. A notice of the
actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: PNC Bank. MA.
Address: 2730 Liberty Avenue. 2nd Floor. Manstow MPCLC4)2-N. Pflfsbureh. PA 15222
Phone Number: 14500-87$-0027
Fax Number: (412)768-3562
Contact Person: Paul Sbadodv
E-Mail Addrus: PayUharkadvAPNC.con
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You may not sell or transfer your home to a buyer or transferee who will assume
the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW
MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,
IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE TIMES IN ANY CALENDAR YEAR)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY
OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours,
Paul Sharkady
original sent: U.S. Mail certified, postage prepaid PNC Bank, National Association
copy sent: First Class, U.S. Mail, postage prepaid
Member of The PNC Financlat Services Group
Consumer Loan Center 2730 Liberty Avenue Pittsburgh Pennsylvania 15222
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VERIFICATION
I, Diane Williams, Foreclosure Manager, and duly authorized representative of PNC Bank,
National Association, depose and say subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn
falsification to authorities, that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are
true and correct upon my information and belief.
IX Williams
C
Foreclosure Manager
PNC Bank, National Association
BANK_FIN:366094-1 000011-097225
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONALASSOCIATION,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAU ,ADMINISTRATOR
OF THE ESTATE TODD . DEVEREAUX,
AFFIDAVIT OF SERVICE OF AMENDED
COMPLAINT IN MORTGAGE
FORECLOSURE
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of record for this party:
Brett A. Solomon, Esquire
Pa. I.D. #83746
bsolomonntuckerlaw com
Michael C. Mazack, Esquire
Pa. I.D. #205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412)566-1212
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BANK_FIN:3 8525 61 000011-1
1N THE COURT OIL COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREA X,
ADMINISTRATOR OF ESTATE OF
TODD R. DEVEREAUX,
I, Brett A.
Complaint in Mortgage F~
Snelbaker, Esquire, Coun
R. Devereaux, on the 23`d
business address of
17055.
AFFIDAVIT OF SERVICE
Esquire, do hereby verify that a true and correct copy of the Amended
closure issued at the above number and term was served upon Richazd C.
for the Defendant, Raymond Devereaux, Administrator of the Estate of Todd
y of April, 2010 by First Class United States Mail Mail Postage Prepaid at the
er & Brenneman, P.C., 44 West Main Street, Mechanicsb}>~;'P~nnsylvania
Brett A. Solomon, Esquire
Attorney for PNC Bank, National Association
Sworn to and ;
before me this
wily, 2010.
J. Ajrpdry p+DMc
~ph, A~rY Coy
BANK FIN:38525Cr1 000011-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX, ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
BANK_FIN:382003-2 000011-144437
CIVIL DIVISION
No. 10-1978 ? o -°
:77 rn
PRAECIPE FOR DEFAULT JUP-GMENT
zj C)
IN MORTGAGE FORECLOSU' - `°
> r, o
Filed on behalf of PNC Bank, NatL` 6
' 50
Association, Plaintiff 0 -
--<
Counsel of record for this party:
Brett A. Solomon, Esquire
Pa. I.D. #83746
bsolomona,tuckerlaw.com
Michael C. Mazack, Esquire
Pa. I.D. #205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
"14c)6 Po wt
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C? !533
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION
Plaintiff, ) No. 10-1978
VS. )
RAYMOND DEVEREAUX, )
ADMINISTRATOR OF THE ESTATE OF )
TODD R. DEVEREAUX, )
Defendant. )
PRAECIPE FOR DEFAULT JUDGMENT IN MORTGAGE FORECLOSURE
TO: Prothonotary
Kindly enter Judgment against the Defendant above named in default of an Answer, in the amount
of $147,207.72 plus continuing interest at the contract rate together with late charges, costs of suit and
attorney fees on the declining balance computed as follows:
Amount claimed in Complaint $136,768.07
Interest from 1/26/10 to 6/1/10 @$25.4269 per diem 3,203.80
Late Charges from 2/10 to 6/10 @$121.47 per month 607.35
Additional Bank Costs (Delinquent real estate taxes paid
By PNC to prevent free and clear tax sale) $6,628.50
Total $147,207.72
*Includes credit for payments made on account. Interest, late charges, attorney's fees and charges
and record costs of this proceeding will continue to accrue from the date of entry of judgment.
I hereby certify that the appropriate Notice of Default, as attached has been mailed in accordance with PA
R.C.P. 237.1 on the date indicated on the Notice.
TUCKER AARENSBERG, P.C.
Michael C. Mazack, Esquire
Attorney for PNC Bank, National
Association, Plaintiff
Plaintiff: PNC Bank, National Association
c/o TUCKER ARENSBERG. P.C., 1500 One PPG Place, Pittsburgh, PA 15222
Defendant: Raymond Devereaux, Administrator of the Estate of Todd R. Devereaux, 2702 Logan Street,
Camp Hill, PA 17011
Raymond Devereaux, Administrator of the Estate of Todd R. Devereaux,
c/o Richard C. Snelbaker, Esquire, 44 W. Main Street, Mechanicsburg, PA 17055
BANK_FIN382003-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE ESTATE OF
TODD R. DEVEREAUX,
Defendant.
TO: Raymond Devereaux, Administrator
Of The Estate of Todd R. Devereaux
c/o Richard C. Snelbaker, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
DATE OF NOTICE: May 19, 2010
No. 10-1978
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU
IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU
CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)-249-3166
1-800-990-9108
Attorney for Plaintiff, PNC Bank, National Association
BANK_FIN:352647-1 000011-139297
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Notice was served upon the Defendant, Raymond Devereaux,
Administrator of the Estate of Todd R. Devereaux, by depositing thereof in the United States mail, first
class postage prepaid, on the 19s' day of May 2010, at the following address:
Raymond Devereaux, Administrator
Of The Estate of Todd R. Devereaux
c/o Richard C. Snelbaker, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
P.C.
Brett A. Solomon, Esquire
Attorney for Plaintiff, PNC Bank,
National Association
B AN K_F IN: 3 81010.1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
CIVIL DIVISION
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE ESTATE OF
TODD R. DEVEREAUX,
Defendant.
TO: Raymond Devereaux, Administrator
Of The Estate of Todd R. Devereaux
2702 Logan Street
Camp Hill, PA 17011
DATE OF NOTICE: May 19; 2010
No. 10-1978
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU
IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU
CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)-249-3166
1-800-990-9108
P.C.
Brett A. Solomon, Esquire
Attorney for Plaintiff, PNC Bank, National Association
BANK_FIN:381010. 1 000011-144437
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Notice was served upon the Defendant, Raymond Devereaux,
Administrator of the Estate of Todd R. Devereaux, by depositing thereof in the United States mail, first
class postage prepaid, on the 19'' day of May 2010, at the following address:
Raymond Devereaux, Administrator
Of The Estate of Todd R. Devereaux
2702 Logan Street
Camp Hill, PA 17011
TUCKER ARENSBER".C.
Brett A. Solon6i, Esquire
Attorney for Plaintiff, PNC Bank,
National Association
BANK_FIN:381010.1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, )
Plaintiff, )
VS. )
RAYMOND DEVEREAUX, )
ADMINISTRATOR OF THE ESTATE OF )
TODD R. DEVEREAUX, )
Defendant. )
CIVIL DIVISION
No. 10-1978
AFFIDAVIT OF NON-NMITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
I, Michael C. Mazack, being duly sworn according to law, hereby depose and say that the
Defendant, Raymond Devereaux, Administrator of the Estate of Todd R. Devereaux, is not a member of the
military service of the United States of America to the best of my knowledge, information, and belief.
Michael C. Mazack, Esquire
Sworn to d sul
t h is ----k U
My Commission Expires:
2010.
COMMONWEALTH OF PENNSYLVANIA
Notiri'91 `x?91
Kelly J. Miz, ?,; . ; p,y
city of P
fi rY olic
My b- h• ?.9herrv Counly
Member, Penns p res May 23- 2013
Assoc?atlon of Notaries
B ANK_F IN:3 82003-1 000011-144437
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-1978 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s)
From RAYMON DEVEREAUX, ADMINISTRATOR OF THE ESTATE TODD R DEVEREAUX
(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 $147,204.72
L.L.$.50
Interest FROM 6/2/10 THROUGH 9/7/11 AT $25.4269 PER DIEM -- $11,747.23
Atty's Comm % Due Prothy $2.00
Atty Paid $174.00 Other Costs LATE CHARGES ($121.47/MO. FOR
6/10 TO 8/11) -- $1,822.05
ATTORNEYS' FEES AND COSTS
$723.74
Plaintiff Paid
Date: 2/24/11
avid D. Buell, rothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name: BRETT A. SOLOMON, ESQUIRE
Address: TUCKER ARENSEBERG, P.C.
1500 ONE PPG PLACE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-566-1212
Supreme Court ID No. 83746
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
2023 Yale Avenue
Camp Hill, Pa 17011
(Borough of Camp Hill)
Tax Parcel No: 01-22-0536-140
CIVIL DIVISION
No. 10-1978
PRAECIPE FOR WRIT OF EXECUTION IN
MORTGAGE FORECLOSURE
Filed on behalf of PNC Bank, Nati --
Association, Plaintiff Fri f*, "?--
0 ?r
Counsel of Record for this Party: " '
Brett A. Solomon, Esquire,
Pa. I. D. No. 83746 -.> J
Michael C. Mazack `-
Pa. I.D. No 205742 F
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
II Sv
? pia - t?U
a sa
'* / 761, 616
C 3y3 L/3v
'q#9 joietn"',
PB?
)9 /1 4ay
?d 44>
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
2023 Yale Avenue
Camp Hill, Pa 17011
(Borough of Camp Hill)
Tax Parcel No. 01-22-0536-140
CIVIL DIVISION
No. 10-1978
PRAECIPE FOR WRIT OF EXECUTION IN
MORTGAGE FORECLOSURE
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of Record for this Party:
Brett A. Solomon, Esquire
Pa. I. D. No. 83746
Michael C. Mazack
Pa. I. D. No 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
L
¦ . .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
CIVIL DIVISION
No. 10-1978
Defendant.
PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE
TO: Prothonotary of Cumberland County:
Kindly issue a Writ of Execution in Mortgage Foreclosure in the above matter as follows:
Judgment Amount ........................................................................ $147,207.72
Interest from 6/2/10 through 9/7/11 at $25.4269 per diem ........... 11,747.23
Late Charges ($121.47/mo. for 6/10 to 8/11) ............................... 1,822.05
Attorneys' Fees and Costs .......................................................... 723.74
Sub-total ................................................................................... $161,500.74
Costs (to be added by the Prothonotary) ...................................
TOTAL
Plus interest accruing thereafter at the rate of $25.4269 per diem, late charges,
additional attorneys' fees and costs and additional expenses incurred by the Bank, continuing
through the sheriffs sale of the subject premises and distribution of the proceeds derived
therefrom.
TUCKER ARENSBERG, P.C,---?
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
Attorneys for PNC Bank, National Association
Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
..off ? --3
°
;:? UZI
- r
may, ru ?,
I, Michael C. Mazack, Esquire, being duly sworn according to law, hereby depose and
say that the Defendant, Raymond Devereaux, Administrator of the Estate Todd R. Devereaux,
is not a member of the military service of the United States of America to the best of my
knowledge, information and belief.
Sworn to and subscribed before me
Michael C. Mazack, Esquire
COMMONWEALTH OF PENNSYLVANIA
this day o 2011. Notarial Seel
Kelly J. Mizak. Notary public
City of 0iitsburgri. A11 heny County
MY commission Expires May 23, 2013
Member, Pennsylvania Association of Notaries
My Commission Expires:
BANK_FIN:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
CIVIL DIVISION
No. 10-1978
AFFIDAVIT PURSUANT TO PA. R.C.P.
3129.1
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of Record for this Party:
Brett A. Solomon, Esquire
Pa. I.D. No. 83746
Michael C. Mazack
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
r;"1
rrI Vr Fl -
U) r
t'5 .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant
AFFIDAVIT PURSUANT TO Pa. R.C.P. 3129.1
PNC Bank, National Association, Plaintiff in the above action, by its attorneys, Tucker
Arensberg, P.C., set forth as of the date of the Praecipe for Writ of Execution was filed the
following information concerning the real property located in the Borough of Camp Hill, County
of Cumberland and Commonwealth of Pennsylvania:
Name and address of the Owner or Reputed Owner:
RAYMOND DEVEREAUX, c/o
ADMINISTRATOR OF THE
ESTATE TODD R. DEVEREAUX
RAYMOND DEVEREAUX,
ADMINISTRATOR OF THE
ESTATE TODD R. DEVEREAUX
Richard C. Snelbaker
44 W. Main Street
Mechanicsburg, Pa 17055
2702 Logan Street
Camp Hill, PA 17011
2. Name and address of Defendant in the judgment:
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire
ASSOCIATION Michael C. Mazack, Esquire
Tucker Arensberg, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
4. Name and address of last recorded holder of every mortgage of record:
PNC BANK, NATIONAL c/o Brett A. Solomon, Esquire
ASSOCIATION Michael C. Mazack, Esquire
Tucker Arensberg, P.C.
1500 One PPG Place
Pittsburgh, PA 152225
5.
6
7.
Name and address of every other person who has any record lien on their
property:
UNKNOWN
Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
CUMBERLAND COUNTY
TREASURER
1 Courthouse Square
Carlisle, PA 17013
CUMBERLAND COUNTY
TAX CLAIM BUREAU
BOROUGH OF
CAMP HILL
TAX COLLECTOR
CAMP HILL SCHOOL
DISTRICT
CAMP HILL SCHOOL
DISTRICT
COMMONWEALTH OF PA
DEPARTMENT OF REVENUE
1 Courthouse Square
Carlisle, PA 17013
c/o Janet Miller
1939 Walnut Street
Camp Hill, PA 17011
2627 Chestnut Street
Camp Hill, PA 17011
c/o Janet Miller
1939 Walnut Street
Camp Hill, PA 17011
P.O. Box 2675
Harrisburg, PA 17105
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:
CUMBERLAND COUNTY
DOMESTIC RELATIONS OFFICE
P.O. Box 320
Carlisle, Pennsylvania 17013
TENANT/OCCUPANT
2023 Yale Avenue
Camp Hill, Pa 17011
-2-
The information provided in the foregoing Affidavit is provided solely to comply with the
Pennsylvania Rules of Civil Procedure 3129.1, and it is not intended to be a comprehensive
abstract of the condition of the title of the real estate which is being sold under this execution.
No person or entity is entitled to rely on any statements made herein in regard to the condition
of the title of the property or to rely on any statement herein in formulating bids which might be
made at the sale of the property.
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. Section 4904 relating to unsworn falsification to
authorities.
Dated:!
By:
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
Attorneys for Plaintiff
Sworn to and subscrit
this day of
My Coffin; ssibn Expires:
BANK_FIN:396875-1 000011-144437
-3-
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
CIVIL DIVISION
No. 10-1978
AFFIDAVIT OF ACT 6
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of Record for this Party:
Brett A. Solomon, Esquire
Pa. I. D. No. 83746
Michael C. Mazack
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION
Plaintiff, ) No. 10-1978
vs. )
RAYMOND DEVEREAUX, )
ADMINISTRATOR )
OF THE ESTATE TODD R. DEVEREAUX, )
Defendant. )
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY )
Before me, a Notary Public, personally appeared Michael C. Mazack, Esquire, being duly
sworn, deposes and says:
THAT Notice of PNC Bank, National Association, intention to foreclose, pursuant to 41
P.S. §403 (Act 6 of 1974), was given to Defendant on or about February 5, 2010.
Michael C. Mazack, Esquire
Sworn to and subscri
this N:--) day a
Notary-P-ublic
My Commission Expires:
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City Kelly J. Jr Mrzaal 3eei ry 4SYL4
11. My Cp M'tsburgh pM i a Public
•? Member, Pennsnip1n3a 3,2013
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Assn . _
BANK_FIN:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
Plaintiff, No. 10-1978
vs.
AFFIDAVIT OF ACT 91
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Filed on behalf of PNC Bank, National
Defendant. Association, Plaintiff
Counsel of Record for this Party:
Brett A. Solomon, Esquire
Pa. I.D. No. 83746
Michael C. Mazack
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION
Plaintiff, ) No. 10-1978
vs. )
RAYMOND DEVEREAUX, )
ADMINISTRATOR )
OF THE ESTATE TODD R. DEVEREAUX, )
Defendant. )
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF ALLEGHENY
Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and
County, personally appeared Micheal C. Mazack, Esquire, who being duly sworn, deposes and
says:
THAT Notice pursuant to 35 P.S. §1680.403 (Homeowner's Emergency Mortgage
Assistance Act of 1983 -- Act 91 of 1983) was given to Defendant on or about February 5, 2010.
Michael C. Mazack, Esquire
Sworn to and subs(
this 1-7 day
My Commission Expires:
COMM0NWL-AL7H
Notari I eBENNSYLVgNLA
1 Kelly" Mizak. N
C ote
nY of Pittsburgh All rY Public
MY Commi ?heny Coun
Member, Penn sy a As s May 23, 2013
sociabon of Notaries
BA N K_F I N:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
CIVIL DIVISION
No. 10-1978
AFFIDAVIT OF LAST KNOWN ADDRESS
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
Filed on behalf of PNC Bank, National
Association, Plaintiff
Counsel of Record for this Party:
Brett A. Solomon, Esquire
Pa. I.D. No. 83746
Michael C. Mazack
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
CU -Y^
7u
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION
Plaintiff, ) No. 10-1978
vs. )
RAYMOND DEVEREAUX, )
ADMINISTRATOR )
OF THE ESTATE TODD R. DEVEREAUX, )
Defendant. 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
AFFIDAVIT OF LAST KNOWN ADDRESS OF DEFENDANT
Before me the undersigned, a Notary Public in and for aforesaid Commonwealth and
County, personally appeared Micahel C. Mazack, Esquire, who being duly sworn, deposes and
says as follows:
That he is counsel for the Plaintiff in the above referenced matter.
2. That to the best of his knowledge, information and belief, the last known address
of Defendant is 2702 Logan Street, Camp Hill, Pa 17011.
TUCKER ARENSBERG, P.C.
Michael C. Mazack, Esquire
Attorneys for Plaintiff
Sworn to and subscri d efore me COMMONWEALTH OF PENNSYLVANIA
Notada,S-.,---
this _ day of 11. c-yo lly gG zak. Notary pilbij,c
AII
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ien+ County
MY commission F
Xpf
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Member, Pennsylva .... 2013
Radon or cries
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My Commission Expires:
BANK_FIN:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
CIVIL DIVISION
No. 10-1978
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Raymond Devereaux,
Administrator of the Estate
Todd R. Devereaux
2702 Logan Street
Camp Hill, PA 17011
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TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County,
Pennsylvania, directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
4T" FLOOR, JURY ASSEMBLY ROOM
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
on September 7, 2011, at 10:00 AM, the following described real estate, of which Raymond
Devereaux, Administrator of the Estate Todd R. Devereaux, are the owners or reputed owners:
Please see attached description of property.
The said Writ of Execution has been issued on a judgment in the mortgage foreclosure
action of:
PNC BANK, NATIONAL ASSOCIATION
vs.
RAYMOND DEVEREAUX, ADMINISTRATOR OF THE ESTATE TODD R. DEVEREAUX
at Ex. No. 10-1978 in the amount of $161,500.74.
Claims against property must be filed at the Office of the Sheriff before the above sale
date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exemptions to Distribution or a Petition to Set Aside the Sale must be filed with the
Office of the Sheriff no later than ten (10) days from the date when the Schedule of Distribution
is filed in the Office of the Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is
a judgment against you. It may cause your property to be held or taken to pay the judgment.
You may have legal rights to prevent your property from being taken. A lawyer can advise you
more specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)-249-3166
1-800-990-9108
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to
help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale
occurs, a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or
objection you might have within twenty (20) days after service of the Complaint in Mortgage
Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you
promptly file a petition with the Court alleging a valid defense and a reasonable excuse for
failing to file defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be
delayed pending a trial of the issue of whether the plaintiff has a valid claim to foreclose the
mortgage or judgment.
You may also have the right to have the judgment stricken if the Sheriff has not made a
valid return of service of the Complaint and Notice to Defend or if the judgment was entered
before twenty (20) days after service or in certain other events. To exercise this right you would
have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any
other legal or equitable right.
YOU MAY ALSO HAVE THE RIGHT TO HAVE THE SHERIFF'S SALE SET ASIDE IF
THE PROPERTY IS SOLD FOR A GROSSLY INADEQUATE PRICE OR IF THERE ARE
DEFECTS IN THE SHERIFF'S SALE. TO EXERCISE THIS RIGHT YOU SHOULD FILE A
PETITION WITH THE COURT AFTER THE SALE AND BEFORE THE SHERIFF HAS
DELIVERED HIS DEED TO THE PROPERTY. THE SHERIFF WILL DELIVER THE DEED IF
NO PETITION TO SET ASIDE THE SALE IS FILED WITHIN THE TEN (10) DAYS FROM THE
DATE WHEN THE SCHEDULE OF DISTRIBUTION IS FILED IN THE OFFICE OF THE
SHERIFF.
Brett A. Solomon, Esquire
Pa. I.D. No. 83746
Michael C. Mazack, Esquire
Pa. I.D. No. 205742
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
Attorneys for PNC Bank, National Association,
Plaintiff
BANK FIN:396875-1 000011-144437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
LEGAL DESCRIPTION OF REAL ESTATE
ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the southern side of Yale Avenue (50 feet wide) at the dividing line
between Lots Nos. 192 and 193, Section "D" on the hereinafter mentioned Plan of Lots; thence
southwardly along said dividing line, one hundred forty-five (145) feet to Lot No. 169, Section
"D"; thence along said Lot No. 169, Section "D", South 82 degrees 48 minutes West, sixty-four
and eight-five hundredths (64.85) feet to the east side of South 21 st Street; thence along the
east side of South 21St Street, North 9 degrees 7 minutes West, one hundred twenty-nine and
fifty-seven hundredths (129.57) feet to a point; thence along a curve to the East having a radius
of fifteen (15) feet, an arc distance of twenty-four and seven hundredths (24.07) feet to a point
on the south side of Yale Avenue; thence North eighty-two (82) degrees 48 minutes East along
the south side of Yale Avenue, fifty-four and fifty-seven hundredths (54.57) feet to Lot No. 192,
Section "D", the place of BEGINNING.
BEING Lot No. 193, Section "D" in the Plan of College Park, as recorded in the Office of the
Recorder of Deeds of the County of Cumberland, Pennsylvania, in Plan Book 4, at page 108.
HAVING thereon erected a dwelling known as 2023 Yale Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Diana K. Devereaux, by deed dated January 22, 2008
and recorded January 28, 2008 in the Office of the recorder of deeds in and for Cumberland
County in Instrument 200802759, granted and conveyed unto Todd R. Devereaux.
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
No. 10-1978
vs.
RAYMOND DEVEREAUX,
ADMINISTRATOR
OF THE ESTATE TODD R. DEVEREAUX,
Defendant.
LEGAL DESCRIPTION OF REAL ESTATE
ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the southern side of Yale Avenue (50 feet wide) at the dividing line
between Lots Nos. 192 and 193, Section "D" on the hereinafter mentioned Plan of Lots; thence
southwardly along said dividing line, one hundred forty-five (145) feet to Lot No. 169, Section
"D"; thence along said Lot No. 169, Section "D", South 82 degrees 48 minutes West, sixty-four
and eight-five hundredths (64.85) feet to the east side of South 21St Street; thence along the
east side of South 21St Street, North 9 degrees 7 minutes West, one hundred twenty-nine and
fifty-seven hundredths (129.57) feet to a point; thence along a curve to the East having a radius
of fifteen (15) feet, an arc distance of twenty-four and seven hundredths (24.07) feet to a point
on the south side of Yale Avenue; thence North eighty-two (82) degrees 48 minutes East along
the south side of Yale Avenue, fifty-four and fifty-seven hundredths (54.57) feet to Lot No. 192,
Section "D", the place of BEGINNING.
BEING Lot No. 193, Section "D" in the Plan of College Park, as recorded in the Office of the
Recorder of Deeds of the County of Cumberland, Pennsylvania, in Plan Book 4, at page 108.
HAVING thereon erected a dwelling known as 2023 Yale Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Diana K. Devereaux, by deed dated January 22, 2008
and recorded January 28, 2008 in the Office of the recorder of deeds in and for Cumberland
County in Instrument 200802759, granted and conveyed unto Todd R. Devereaux.
Brett A. Solomon, Esquire
Michael C. Mazack, Esquire
FI???-B?r firs
T81 on,
??? t APR 2S PH 3: 27
CUMBERLA O COUNTY
IN T? E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BA K, NATIONAL ASSOCIATION, CIVIL DIVISION
Plaintiff,
No. 10-1978
vs.
RAYMO D DEVEREAUX,
ADMINISTRATOR
OF THE STATE TODD R. DEVEREAUX,
VERIFICATION OF SERVICE OF NOTICE
OF SALE TO DEFENDANTS AND LIEN
CREDITORS PURSUANT TO PA.
R.C.P. 3129
Defendant.
Filed on behalf of PNC BANK
NATIONAL ASSOCIATION, Plaintiff
Counsel of record for this party:
Michael C. Mazack, Esquire
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
SALE DAITE: September 7, 2011
IN T? E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BA14K, NATIONAL ASSOCIATION
Plaintiff,
vs.
RAYMO D DEVEREAUX,
ADMINISTRATOR
OF THE STATE TODD R. DEVEREAUX,
Defendant.
CIVIL DIVISION
No. 10-1978
VERIFICATION OF SERVICE OF NOTICE OF SALE
TO DEFENDANTS AND LIEN CREDITORS
e undersigned does hereby certify that service of the Notice of Sale was completed on
Defendant, Raymond Devereaux, Administrator of the Estate Todd R. Devereaux, by certified
mail at 4 last known address of 2702 Logan Street, Camp Hill, PA 17011 on March 9, 2011. A
copy of toe certified mail receipt is attached hereto as Exhibit "A".
undersigned does hereby certify that the undersigned personally mailed a copy of
the Notic? of Sale in the above captioned matter by First Class Mail to all Lien Creditors and
Parties of Interest on April 12, 2011, as evidenced by P.S. Form 3817 attached hereto as
Exhibit
Sworn to nd subscribed before me
this day of D(, ( 2011.
Michael C. Mazack, Esquire
Notary P blic
My Commission Expires:
BANK_FIN:4 5319-1 000011-144437
commo W TH of Vc N"' PENNSYLVANIA
Notarial Seal
Amy B. Hauch, Notary Pui L r, qty of pnouryh, NleyhenY mi3 a Assodadon of Notaries
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i `11 COMPLETE THIS SECTION
¦ Complete Items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the, reverse
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or on the front if space permits.
1. Article Addressed to:
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? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number 7009 2820 0004 4081 9491
(rmnsfer from service laW -
PS Form 3811, February 2004 Domestic Return Receipt
102595-02-M-1,1
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Plaintiff, No. 10-1978
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:VLREAUX, VERIFICATION OF SERVICE OF NOTICE
QTOR OF SALE TO DEFENDANTS AND LIEN
"ATE TODD R. DEVEREAUX, CREDITORS PURSUANT TO PA.
R.C.P. 3129
Defendant.
Filed on behalf of PNC BANK
NATIONAL ASSOCIATION, Plaintiff
Counsel of record for this party:
Michael C. Mazack, Esquire
Pa. I.D. No. 205742
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, Pennsylvania 15222
(412) 566-1212
SALE DATEk September 7, 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION
Plaintiff,
vs.
RAYMOND EVEREAUX,
ADMINIST TOR
OF THE ES ATE TODD R. DEVEREAUX,
Defendant.
CIVIL DIVISION
No. 10-1978
VERIFICATION OF SERVICE OF NOTICE OF SALE
TO DEFENDANTS AND LIEN CREDITORS
The ndersigned does hereby certify that service of the Notice of Sale was completed on
Defendant, Raymond Devereaux, Administrator of the Estate Todd R. Devereaux, by certified
mail at his last known address of 2702 Logan Street, Camp Hill, PA 17011 on June 18, 2011. A
copy of the certified mail receipt is attached hereto as Exhibit "A".
The undersigned does hereby certify that the undersigned personally mailed a copy of
the Notice o Sale in the above captioned matter by First Class Mail to all Lien Creditors and
Parties of Interest on June 29, 2011, as evidenced by P.S. Form 3817 attached hereto as
Exhibit "B". ?-?
Sworn to an subscribed before me
this day of J i q c , 2011.
Michael C. Mazack. Es' r
Notary Publi
My Commis:
Expires:
COMMONWEALTH OF PENNSYt.VAMA
w?ty
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4. Restricted Delivery? (Extra Fee) p yes
2. Article Number 7 010 0290 0001 4377 8 313
(Transfer from service label)
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-115
¦ Complete Items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson' '
Sheriff
Jody S Smith
Chief Deputy t, J
Richard W Stewart
Solicitor
PNC Bank, NA
vs.
Raymond Devereaux
Case Number
2010-1978
SHERIFF'S RETURN OF SERVICE
06/20/2011 10:35 AM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 2023 Yale Avenue, Camp Hill, PA 17011, Cumberland County.
06/23/2011 02:37 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be SANDRA
SHOWERS, SECRETARY FOR RICHARD SNELBAKER, ATY, who accepted as "Adult Person in
Charge" for Raymond Devereaux at c/o Richard Snelbaker - Atty, 44 W. Main Street, Mechanicsburg, PA
17055, Cumberland County.
06/30/2011 07:38 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ,
Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Raymond Devereaux at 2702 Logan Street, Camp Hill Borough, Camp Hill, PA 17011, Cumberland
County.
09/07/2011 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, Cumberland County, PA on September 7, 2011 at 10:00 a.m..
He sold the same for the sum of $1.00 to Attorney Brett Solomon, on behalf of, PNC; Bank National
Association, of, 620 Liberty Avenue, Pittsburgh, PA 15222, being the buyer in this execution, paid to the
Sheriff the sum of $
SHERIFF COST: $949.15 SO ANSWERS,
October 11, 2011 RON R ANDERSON, SHERIFF
On June 9, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
Camp Hill Borough, Cumberland County, PA,
Known and numbered as, 2023 Yale Avenue,
Camp Hill, more fully described on Exhibit "A." filed
with this writ and by this reference incorporated herein.
Date: June 9, 2011
By:
Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2010-1978 Civil deed dated January 22, 2008 and
recorded January 28, 2008 in the Of-
PNC Bank, NA fice of the recorder of deeds in and for
vs. Cumberland County in Instrument
200802759, granted and conveyed
Raymond Devereaux, Adminstrator unto Todd R. Devereaux.
of the Estate of Todd R. Devereaux
Atty.: Brett A. Solomon
ALL that certain tract or parcel of
land and premises, situate, lying and
being in the Borough of Camp Hill,
County of Cumberland, and Com-
monwealth of Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the
southern side of Yale Avenue (50 feet
wide) at the dividing line between
Lots Nos. 192 and 193, Section "D"
on the hereinafter mentioned Plan of
Lots; thence southwardly along said
dividing line, one hundred forty-five
(145) feet to Lot No. 169, Section
"D"; thence along said Lot No. 169,
Section "D", South 82 degrees 48
minutes West, sixty-four and eight-
five hundredths (64.85) feet to the
east side of South 21 st Street; thence
along the east side of South 21st
Street, North 9 degrees 7 minutes
West, one hundred twenty-nine and
fifty-seven hundredths (129.57) feet
to a point; thence along a curve to the
East having a radius of fifteen (15)
feet, an arc distance of twenty-four
and seven hundredths (24.07) feet
to a point on the south side of Yale
Avenue; thence North eighty-two (82)
degrees 48 minutes East along the
south side of Yale Avenue, fifty-four
and fifty-seven hundredths (54.57)
feet to Lot No. 192, Section "D", the
place of BEGINNING.
BEING Lot No. 193, Section "D" in
the Plan of College Park, as recorded
in the Office of the Recorder of Deeds
of the County of Cumberland, Penn-
sylvania, in Plan Book 4, at page 108.
HAVING thereon erected a dwell-
ing known as 2023 Yale Avenue,
Camp Hill, PA.
BEING THE SAME PREMISES
WHICH Diana K. Devereaux, by
23
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 15, July 22 and July 29, 2011
Affiant further deposes that he is authorized to verify this statement b:y 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.
sa Marie Coyne, ditor
U
SWORN TO AND SUBSCRIBED before me this
da of Jul 2011
Notary ,
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUI4TY
My Commission Expires Apr 28, 2014
The Patriot-News Co,
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
the Patriot News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 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 tile,
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:
07/15/11
07/22/11
r? 07/29/11
............ LL
?_.... .
',/18 dAfrof August,, 2011 A. D.
Sworn to and sy scribed before e this
Notary Public
COMMONWEALTH OF PENNSYLVANIA
l? Notarial Seal -
Sherrie L. Kisner, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Nov. 26, 2011
Member P-cnnsvivania Rssociatinn of Notaries
2010-IM CNN Term
PIC Rod; INA
vs
A of the Eftft of
TOM R. Devergeux
Atir. Brett A. Solomon
ALL that certain tract or parcel of land
and premises, situate, lying and being
in the Borough of Camp Hid, County
of Cumberland, and Commonwealth of
Penns,'Iva* more particularly described
as follows: i
BEGINNING at a point on the southern
side of Yale Avenue (5o feet wide) at
the dividing line between Lots Nos. 192
and 193, Section "D" on the hereinafter
mentioned Plan of Lots; thence
forty along (x145 ? Lot
hundred
No.e
169, Section "D"; thence along said Lot
No. 169, Section "D", South 82 degrees
48 minutes Westt siaty-four and eight-five
hundredths (64.85) feet to the east side of
South 21st Street; thence along the east
side of South 21st Street, North 9 degrees
7 minutes West, one hundred twenty-nine
and fifty-seven hundredths (12957) feet
to a Point thence along a curve to the
East having a radius of fifteen (15) feet,
an arc distance of twenty-four and seven
hundredths (24.07) feet to a point on the
south side of Yale Avenue;'thence North
eighty-two (82) degrees 48 minutes East
along the south side of Yale Avenue, fifty.
four and fifty-seven hundredths' (5457} feet
to Lot No. 192, Section "D", the place of
BEGINNING.
BEING Lot No-193, Section "D" in the
Plan of College Park, as recorded in the
Office of the Record& of Deeds of the
County of Cumberland; Pennsylvania, in
Plan Book 4, at page 108.
HAVING thereon erected a dwelling
known as 2023 Yale Avenue, Camp Hill,
PA
BEING TBE SAmE PR.EAGSES WHICH
Diana K. Devereaux, by deed dated
Jani:;uy 22; 2008 and recorded January
28, 2008 in the Office of the recorder of
deeds in and for Cumberland County
in Instrument 200802759, granted and
conveyed unto Todd R Devereaux.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Zie ler, Recorder of'Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which PNC Bank N A is the grantee the same having been sold to said grantee on
the 7th day of September A.D., 202011, under and by virtue of a writ Execution issued on the 3rd day of
June, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number
1978, at the suit of PNC Bank N A against Raymond Devereaux, Administrator of the Estate of Todd R.
Devereaux is duly recorded as Instrument Number 201128253.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
of Deeds
Wft Cute: AA