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HomeMy WebLinkAbout10-2578C Phel,jn Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 234726 METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA 4000 HORIZON WAY IRVING, TX 75063 Plaintiff V. ROBERT A. PEIFER LINDA L PEIFER 517 WARREN STREET LEMOYNE, PA 17043-2037 Defendants 1•J .J' w"?Y1. 4 ZOtd ASR 20 F ?S 2' "A X 91 b D Pd r C'J ?1 i ; <?idiY ct 4 93915W ' pp r rµ f?. L4 d 3 taV,t ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. /U -- .1 ?- 7 ? c '?" I lal- CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 234726 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 )ou by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 234726 Plaintiff is METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA 4000 HORIZON WAY IRVING, TX 75063 2. The name(s) and last known address(es) of the Defendant(s) are: ROBERT A. PEIFER LINDA I. PEIFER 517 WARREN STREET LEMOYNE, PA 17043-2037 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/25/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR FIRST HORIZON HOME LOANS, A DIVISION OF FIRST TENNESSEE BANK, NA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200742262. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 234726 6 The following amounts are due on the mortgage: Principal Balance $152,426.92 Interest $5,753.15 11/0 1 /2009 through 04/16/2010 (Per Diem $34.45) Attorney's Fees $650.00 Cumulative Late Charges $0.00 10/25/2007 to 04/16/2010 Costs of Suit and Title Search $550.00 Escrow Deficit $3,409.20 TOTAL $162,789.27 7 9 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. Defendants' application for assistance under Act 91 of 1983 has been rejected by the Pennsylvania Housing Finance Agency. File #: 234726 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $162,789.27, together with interest from 04/16/2010 at the rate of $34.45 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: PHELAN HALLINAN & SCHMIEG, LLP awrence T. Phelan Esq., Id. No. 32227 rancis S. HallinanEsq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 234726 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the western line of Warren Street, said point being one hundred sixty- six and three tenths (166.3) feet south of the southwest corner of Walton and Warren Streets; thence in a westerly direction along other lands now or late of R.R. Baugher one hundred (100) feet to a point on the line of property now or late of Aaron M. Fackler and Frances E. Fackler his wife; thence in a southerly direction along the line of said Fackler property fifty-one and five tenths (51.5) feet to the northern line of Lot No. 38 on Plan of Lower Walton as laid out by the Trustees of the Estate of James McCormick, deceased, which Plan is recorded in the Office for the recording of deeds in and for Cumberland County in Plan Book 1, Page 204; thence in an easterly direction along the northern line of said Lot No. 38 on the said Plan one hundred (100) feet to the western line of Warren Street; thence in a northerly direction along the western line of Warren Street fifty-one and five tenths (51.5) feet to a point, the place of BEGINNING. HAVING thereon erected a single two-story frame dwelling house, No. 517 Warren Street, Lemoyne, Pennsylvania. PROPERTY ADDRESS: 517 WARREN STREET, LEMOYNE, PA 17043-2037 PARCEL # 12-22-0820-055 File #: 234726 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: File #: 234726 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA vs. ROBERT A. PEIFER LINDA I. PEIFER Attorney for Plaintiff ~t~~~~ ~~~R~~u~v.~x~ / , ~~, ~ Jam- 7 ~h'1 4.QS- ~S ~ , ~tY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2578-CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ROBERT A. PEIFER, and LINDA I. PEIFER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: ~Y~l. oa ~t c~-~ / eK-~ 4s8.38o ~ ayaa~9 As set forth in Complaint $162,789.27 Interest - 04/17/2010 to 06/03/2010 TOTAL $1,653.60 $164,442.87 I hereby certify that (1) the Defendant's last known address is 517 WARREN STREET, LEMOYNE, PA 17043-2037, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~~ .,-~ '" ~~,/ Lawr ce T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire ~ourtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 1.T7~_ PHS # 234726 PROTHON TARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA vs. ROBERT A. PEIFER LINDA I. PEIFER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2578-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) islare not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ROBERT A. PEIFER is over 18 years of age and resides at 517 WARREN STREET, LEMOYNE, PA 17043-2037. (c) that defendant LINDA I. PEIFER is over 18 years of age and resides at 517 WARREN STREET, LEMOYNE, PA 17043-2037. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /~-~~~. LJ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ ourtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff METLIFE HOME LOANS A DNISION OF METLIFE BANK NA Plaintiff v. ROBERT A. PEIFER LINDA I. PEIFER Defendant(s) TO: LINDA I. PEIFER 517 WARREN STREET LEMOYNE, PA 17043-2037 DATE OF NOTICE: May 14, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-2578-CIVIL TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT QNCE. )F' YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 234726 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheet .Shah-Jani, Esq., Id. No. 81760 J ne R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19]03 PHS # 234726 METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA Plaintiff v. ROBERT A. PEIFER LINDA I. PEIFER Defendant(s) TO: ROBERT A. PEIFER 517 WARREN STREET LEMOYNE, PA 17043-2037 DATE OF NOTICE: May 14, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-2578-CIVIL TERM CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIZING A LAWYER. PHS # 234726 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 " Lawrence T. Phelan, Esq., Id. N~227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T omano, Esq., Id. No. 58745 Shee R. Shah-Jani, Esq., Id. No. 81760 J me R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 234726 (Rule of Civil Procedure No. 236) -Revised METLIFE HOME LOANS A DIVISION OF METLIFE BANK NA vs. ROBERT A. PEIFER LINDA I. PEIFER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-2578-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ ourtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TD COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Fik;u : ??? °I?OTKONCTAR Attorney Fo Plaintiff 2C 12 OCT 15 A? ? 1 i; I I1PIER?.ANC COUNTY ? NSYLVANIA. 212 OCT CUMSE PEA METLIFE HOME LOANS, A DIVISION OF 11ETLIFE BANK, N.A. Plaintiff vs ROBERT A. PEIFER LINDA I. PEIFER Defendant Court of Common Pleas Civil Division CUMBERLAND County No. 10-2578-CIVIL TERM PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P.. 2352 TO THE PROTHONOTARY: Kindly substitute FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION') is the current holder of the mortgage by virtue of that certain Assignment of Mortgage, which Assignment was recorded on 06/29/2012 in Instrument No. 201219473 of the Recorder of Deeds Office in and for CUMBERLAND County. Kindly nd the information on the docket ac Date: By: Ma PHS # 234726 Esq., Id. No.310592 Plaintiff Cyr. t aa?c? 911 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF Court of Common Pleas METLIFE BANK, N.A. Plaintiff Civil Division V. CUMBERLAND County ROBERT A. PEIFER No. 10-2578-CIVIL TERM LINDA I. PEIFER Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe to mark judgment to FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: ROBERT A. PEIFER LINDA I. PEIFER 517 WARREN STREET LEMOY/NE, PA 17043-2037 Date: PHEL INAN & SCHMIEG, LLP By- M tth B ood, Esq., Id. No.310592 orney for Plaintiff PHS # 234726 r € O F1G'L Phelan Halliinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400! ?T 15 ?? ?'' One Penn Center Plaza Ph ade ia, PA 19103 cliMERLAND COUNTY 215-563-7000 p-1_ 'iSYlltAxtA Attorney For Plaintiff METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff vs ROBERT A. PEIFER LINDA I. PEIFER Defendant Court of Common Pleas Civil Division CUMBERLAND County No. 10-2578-CIVIL TERM TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION'), located 14221 DALLAS PARKWAY, DALLAS, TtX 71254. Date: PHMews AN & SCHMIEG, LLP ByM Cod, Esq., Id. No.310592 A f or Plaintiff PHS 4 234726 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION"). Date: PHEAb ALLINAN & SCHMIEG, LLP By M wood, Esq., Id. No.310592 orney for Plaintiff PHS # 234726 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 10-2578 Civil cIV1L ACT~oN -- i,Aw TO TI-f F. SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FANNIE MAE', (FEDERAL NATIONAL MORTGAGE ASSOCIATION Ph~intiff (s) From ROBERT A. PEIFER, LINDA I. PEIFER 1 ~ You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) Yo~~ are also directed to attach the property of the defendants} not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (bj the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering au~y property of the defendant (sl 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: 5164,442.87 L.L.: interest FROM 6/4/;E010 TO DATE OF SALE ($27.03 PER D[EM) - $27,2] 9.21 Attv's Comm: °% Due Profhy: $2.25 Atty Paid: $250.40 Other Costs: Plaintiff Paid: I?ate: 10/15/12 .-~ ,fi~ David D. Buell, Prothonojtary ~~ ~~ ~ ~ C/~ (Scull ~?'~ ~Q~o~~ - 1<<~~',~'_~~ Deputy RIQUE:STINC PARTY: Name: iYIE~ ISSA J. CANTWELL, ESQUIRE Address: PHELAN HALLINAN & SCHM[EG, LLP 1617 JFK BLVD, SU[TE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney f`or: PLAINTIFF Telephene:215-563-7000 Supreme Court ID No. 308912 PRAECIPE FOR WRIT OF EXECUTIOI~f-(MORTGA,GE FORECLOSURE) P.R.C.P. 318(1-3183 FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff v. ROBERT A. PEIFER LINDA I. PEIFER. Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 06/04/2010 to Date of Sale ($2'.7.03 per diem) TOTAL Note: Please attach description of property. PHS # 234726 ~ S8 , ~~ ~ CST .~ „ q ~ ao ~~~ „ 1 ~q S U~~ ~.~.._ ~ a.~,,\ ,.a ~. 4 C~ _~ 1~ ~ '~ ~ y o~~ n_-- ~s p.~~d ~,.. COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-2578-CIVIL TERM CUMBIE;RLAND COUNTY $1 Ei4,442.87 $27,219.21 .~: ,.D 01.662.08 ~, ~ ~ ~~~ ~ h '_ ," ,~ ,~ ~ Phelan Hallinan & Sch- ,~ P "~~= ~ ~ s ~~ Melissa J. Cantwell, Esq., ld. No.30891''~ c; :: _ Attorney for Plaintiff ~ ~o ~.a -aS~~ C'k~11 a ~y sip ~~a~~q~s ,~,}„ t og ~~ ~ss,~d Q wz o~ ~' a Q ~, a~ az z Oa F OO V H OQ V w~ H~ U .- z O F~ 0 d w Q H x 0 a d z O H Q a a~ w A w w W w: ai z a, w W a Q h w °a W ~ ~ ~ W ~ Q Q A 0 F U w W L ~, o O c :. w 3° w oA w ~o ~ '~ ~ M ~ M T «i O ~ N O f-~ N [j] M ~~ M ~ ~ W CG r ~ f~ [~ w~n a. a~ W Q a. z a. Q u^ 'z a .~ 3 ¢ w ~~ a uZ.i w~~ ~ ° ° b ~3 ~ Q~3 ~ ,, z ,, a~ ao `' z ~b ~~ u N ~ W w ~ ~ ~ 3 '~ .C ~ p ~ U x~ ~~~ ~~E ~ '~ o a~~ ci LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in the Borough of Lemoyne, Gi.-mberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the western line of Warren S1:reet, said point being one hlrndred sixty-six and three tenths (166.3} feet south of the southwest corner of Walton and Warren Streets; thence in a westerly direction along other lands now or late of R.R. Baugher one hundred (100} feet to a point on the line of property now or late of Aaron M. Fackler and Frances E. Fackler his wife: thence in a southerly direction along the line oI~ said Fackler property fifty-one and five tenths (51.5) feet to the northern line of Lot No. 38 on Plan of Lower Walton as laid out by the Trustees of the Estate of James McCormick, deceased, which Plan is recorded in the Office for the recording of deeds in and for Cumberland County in Plan Book 1, Page 204; thence in an easterlly direction along the northern line of said Lot No. ?.8 on the said Plan one hundred (100) feet to the western line of Warren Street; thence in a northerly direction along the western line of'Warren Street fifty-one and five tenths (51.5) feet to a point. the place of BF;GINNING. HAVING thereon erected a single two-story frame dwelling house. TITLE T'O SAID PREMISES IS VF;STED IN Robert A. Peifer and Linda I. Peifer, :his wife, by Deed from Helen Thomas Heilman and John E. Thomas, Executrix and Executer Respectively of the Estate of Helen Leckey Thomas, aka Ruth L. Thomas, Late, dated 02/10/1971, recorded 02/17/1971 in Book Y-23, Page 945. PREMISES BEING; 517 WARREN STREET, LEMOYNE, PA 17043-2037 PARCEL NO. 12-22-0820-055 P~fELAN EIAI.1_:IN:~N & SCHMIEU, LLP Melissa J. Cantwell Esq.. ld. No.308912 1617 JFK l3oulev;ard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 21 ~-X63-70Ut~ 1 ~ , ~ J ~ ~ V gyp.' ( -~ t. FANNIE MAE ("FEDERAL NATIONAL MOR'1'Cr~.t'fi',~':;~z'~r ~ ~,,"tl ASSOCIATION") P 1 ainti fi' v. ROBERT A. PEIFEK LINDA I. PEIF>F:R Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS .~ CIVIL DIVISION NO.: 10-2578-CIVIL TERM CUMBERLAND COUNTY "fhe undersigned attc~~rney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( i the mortgage is an FHA Mortgage ( p the premises is non-owner occupied ( ) the premises is vacant (~~{ } Act 91 procedures have been fulfilled ( > Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1 197.. 47 Pa.B. 3943 "phis certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. B~ ~ C ~`. • allinan & Sc , LLP Melissa J. Canl:well, Esq., Id. Ni>308912 Attorney for Nlaintiff FANNIE MAE 1 "FEDERAL NATIONAL MORTGAGE ASSOCIATION") Plaintiff v ROBERT A. PF;IFER LINDA I. PEIFER Deiendant(s COURT OF ('OMMON PLEAS CIVIL DIVISION NO.: 10-2578-CIVIL TERM CUMBERLANll COUNTY PHS # 23726 AFFIDAVIT PURSUANT TO RULE 3129.1 FANNIF. MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION"), Plaintiff in the above action, by the undersigned attorney. sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 517 WARREN STREET, LEMOYNE, PA 17043-2037. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) _ ';-~ ROBERT A. PEIFER 517 WARREN STREET `= ~"= _„_ LEMOYNE, PA 17043-203'7 - -:~ " - LINDA 1. PEIFER 517 WARREN STREET ° , - ~ ':: LEMOYNE, PA 17043-203'7 ~~~ `' ~~ .. ---?' ,- ?. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonable ascertained, please so indicate) SAME: AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. ~. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF LEMOYNE 665 MARKET STREET LEMOYNE, PA 17043 BOROUGFI OF LEMOYNE 510 HERMAN AVE ATTN: HOWARD E. DOUGHERTY, CMC LEMOYNE, PA 17043-1S:Z2 Name and address of every other person who has any record interest in the property and whose inter~s~ may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TF,NANT/OCCUPANT Sl7 WARRisN STREET LEMOYNE., PA 17043-2037 COMMONWEALTH OF PENNSYLVAMA, BUREAU OF INDIVIDUAL TAX, INHERITANCE. TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY' UNIT, ESTATE RECOVERY PROD RANI DOMESTIC' RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 N.U. BOX 8486 WILLOW C)AK BUILDING HARRISBURG, PA 17105 13 NORTH HANOVER STREET CARLISLE., PA 17013 P.O. BOX 2b75 HARRISBURG, PA 17105 INTERNAL REVENUE; SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTR[CT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~ X904 relating to unsworn falsification to authorities.. y r Date: ~ ~3y ~~ F• ~~~ , ~` ~ ~ .,~ _. Phelan Hallinan & Schniieg, Melissa J. Canhvell, Esq.. Id. No.308912 Attorney for Plaintiff FANNIE MAE ("FEllERA.L NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATIOI~~") : CIVIL DIVISION Plaintiff NO.: 10-2578-CIVIL TERM vs. ROBERT A. PEIFER CUMBERLAND COUNTY LINDA I. PEIFER -_ .~ Defendant(s) -- _ :.y _ _- °:~ NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~-~ ~ `_: - TO: ROBERT A. PEIFIN;R ~~' ` ` ~,.. ~~~ LINDA k. PEIFER - -" .. ~. , 517 WARREN STREET `~ =" LEMOYNE, PA 17043-2037 **THIS FIRM IS. A DEBT COLLEC'COR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS lS NO'T AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT T(:) COLLECT .A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 517 WARREN STREET, LEMOYNE, P.A 17043-2037 is scheduled to be sold at the Sheriff s Sale on [13/06/2013 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $164,442.87 obtained by FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION")~ (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE rI'O PREVENT THIS SHERIFF'S SALE 1~o prevent this Sheriff's Salle, you must take immediate action: 1. "Ihe sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-~63-7000 x1230. ?. You may be able to stop the sale by tiling a petition asking the Court to strike or open the judgment, if the judgment ~~as improperly entered. You may also ask the Cor~rt to postpone the sale for good cause. >. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the ~_nore chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOiJ HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff ~~~ Sale is not stopped, your property will be sold to the highest bidder. Yo~.a may find out the price bid by calling 215-563--7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property . 3. The sale will go through only if the buyer pays the Sheriff tree full amount due in the sale.. I~o find out if this has happened, you may call ~ 15-563-7000. 4. If the amount due from tree Buyer is not paid to the Sheriff, you will remain the owner +~~f the property as if the sale never ha~~ppened. 5. You have the right to ren~~ain in the property until the full amount due is paid to the Shea•iff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict yoia. 6. You may he entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed) distribution is wrong) are tiled with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your horne back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE; LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA l'~7013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue ot~ a Writ oa Execution NO. 10-2578-CIVIL TERM FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") vs. ROBERT A. PEIFER LINDA 1. PEIFER owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania, being (Municipality) 517 WARREN STREET, LEMOYNE, PA 17043-2037 Parcel No. 12-22-0820-055 (Acreage or street address) lmprovernents thereon: RESIDENTIAL DWELLING JUDGMENT AMOUN"T: $164,442.87 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 .I1:K 13oulevard. Suite 1400 Philadelphia. PA 19]03 ?~5-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in the Borough of Lemoyne. Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the western line of Warren Street, said point: being one hundred sixty-six and three tenths (166.:3) feet south of the southwest corner of Walton and Warren Streets; thence in a westerly direction along other lands now or late of R.R. Baugher one hundred (I 00) feet to a point on the lint. of property now or late of .Aaron M. Fackler and Frances E. Fackler his wile; thence in a southerly direction along the line of said Fackler property fifty-one and five tenths (~ 1. ~) feet to the northern line of Lot No. 38 on Plan of Lower Walton as hud out by the Trustees of the. Estate of James McCormick, deceased, which flan is recorded in the Office for the recording of deeds in and for Cumberland County in Plan Book 1, Page 204; thence in an easterly direction along the northern line of said Lot No. 3.3 on the said Plan one hundred (100j feet to the western line of Warren Street; thence in a northerly direction along the western line of Warren Street fifty-one and five tenths (~ I .~) feet to a point, the place of BEGINNING. HAVING thereon erected a single two-story frame dwelling house. TITLE TO SAID PREMISES IS VESTED IN Robert A. Peifer and Linda L Peifer, Isis wife, by Deed from Helen Thomas Heilman a~ld John E. Thomas, Executrix and Executer Respectively of the Estate of Helen Leckey Thomas, aka Ruth L. Thomas, Late, dated 02/10/1971, recorded 02/17/19 ~ 1 in Book ~~-23, Page 945. PREMISES BEING: 517 WARREN STREET, LEMOYNE, PA 17043-2037 PARCEL NO. 12-22-0820-055 PHELAN HALLINAN, LLP y? Attorney for Plaintiff t"?- ? ,'? John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Z -? Philadelphia, PA 19103 ` 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FANNIE MAE ("FEDERAL NATIONAL CUMBERLAND COUNTY MORTGAGE ASSOCIATION") Plaintiff, COURT OF COMMON PLEAS v. ROBERT A. PEIFER LINDA I. PEIFER Defendant(s) CIVIL DIVISION No.: 10-2578-CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817 and/ Certified Mail Return Receipt stamped by the U.S. Postal Service is attached r ibit "A". Date: 2/7,0//j hael Kolesnik, Esq., Id. No.308877 for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 234726 1 'y O;z N R CN I li. R 10 -=°ocP?n4lrop??o ?yx?3 00:%_: > a ; 4m 0104 "1 nz ??Gcnr? -ti 00 ? xz O>7? Cattr ?A ??$D?ncn y>y- >??? so h c-n?z >T '? •a --t?" r?7d> Cr?U!} Yc 's}>Y 40 12 M-4 id or ?? v+x ? pw7DZ ?, N o [s ? ?7 IF x ® cn 2 c. t? A O ^G "? o R° G fr, vCi D 7C z t ?' •? :; s° t 3 "" O tr * 1 r ;o "C Q o -- > a M C ?I < 4 40 W p A w,vn ell y c ,.j r.. krf A R :t In ? G tom! i;;:y ?. ? OIL (?} C ? ? a o cr73? G7 ?? LA th 4m g 3? ? `?? a w w s o u tm vr, *PtTMEY BOWES 0219103 ? ocswi ' ? Q8C,1381191t 1G 2012 Ots > f'a LOi c PD _ a N 0 " ? m -x ? 3 rv r.? r_ 0 =i R r c a as 2 raz >=r °- ? V ? I? ? R ?p ¢? "may t?„t Cl'? C, t1i Cs'! N """; >_ "? m A ? A ?e ro M A a a A 3 + n m a t? r i, =y ? _ G R Ct x s 30 US,E>>pirwy Willi 'amp 600_ Op ;9103 $ 001 . 0OOISS1 t9l JAN 09 2013- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson sheriff ,- CF tt���-�D���'}}-T�1tF(F�17�,": �,k.�qi � 4ititl jp, dd I !�E PD0 f i- :. ' tt .ji' Jody S Smith �1 Chief Deputy _ � . Richard W Stewart f�ff'�pp,��LL��C fL�it tt 3If1 t�f; ^E .. -HF ERJFP CUl"iBERLh1 t0 coUt j�( Solicitor f EWiSYLVA NIA Fannie Mae Case Number vs. Robert A. Peifer(et al.) 2010-2578 SHERIFF'S RETURN OF SERVICE 01/03/2012 Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 517 Warren Street, Lemoyne, PA 17043, Cumberland County on 1/3/12 at 1311 hrs. 01/31/2013 06:17 PM - Deputy Shawn Harrison, 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 TIMOTHY PEIFER- SON, who accepted as"Adult Person in Charge"for Linda I. Peifer at 517 Warren Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 01/31/2013 06:17 PM - Deputy Shawn Harrison, 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 TIMOTHY PEIFER- SON, who accepted as"Adult Person in Charge"for Robert A. Peifer at 517 Warren Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 02/21/2013 Affidavit of Service to Lienholders Filed in Sheriffs Office 03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Francis Hallinan, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $916.28 SO ANSWERS, May 06, 2013 RON R ANDERSON, SHERIFF w-00 M - Q. Pd -e- f� x/3-2 o2 ^:y'.?..a'`.e: ":ffiJt,t Ak FANNIE,MAE FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION") Plaintiff CIVIL DIVISION V. NO.: 10-2578-CIVIL TERM ROBERT A. PEIFER LINDA L PEIFER CUMBERLAND COUNTY Defendant(s) . PHS # 234726 AFFIDAVIT PURSUANT TO RULE 3129.1 FANNIE MAE("FEDERAL NATIONAL MORTGAGE ASSOCIATION"),Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 517 WARREN STREET,LEMOYNE,PA 17043-2037. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) ROBERT A.PEIFER 517 WARREN STREET LEMOYNE,PA 17043-2037 LINDA I. PEIFER 517 WARREN STREET LEMOYNE,PA 17043-2037 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) BOROUGH OF LEMOYNE 665 MARKET STREET LEMOYNE, PA 17043 BOROUGH OF LEMOYNE 510 HERMAN AVE ATTN: HOWARD E. DOUGHERTY,CMC LEMOYNE,PA 17043-1822 6. Name and address'of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 517 WARREN STREET LEMOYNE,PA 17043-2037 COMMONWEALTH OF PENNSYLVANIA, 6TH FLOOR,STRAWBERRY SQ.,DEPT 280601 BUREAU OF INDIVIDUAL TAX, HARRISBURG,PA 17128 INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE,TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: By: Li���o Phelan Hallinan& Schmieg, Melissa J. Cantwell, Esq., Id.No.308912 Attorney for Plaintiff FANNIE MAE ("FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION") CIVIL DIVISION Plaintiff : : NO.: 10-2578-CIVIL TERM VS. ROBERT A. PEIFER : CUMBERLAND COUNTY LINDA I. PEIFER Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROBERT A. PEIFER LINDA I. PEIFER 517 WARREN STREET LEMOYNE,PA 17043-2037 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real estate)at 517 WARREN STREET,LEMOYNE,PA 17043-2037 is scheduled to be sold at the Sheriff's Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$164,442.87 obtained by FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") (the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale,you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-2578-CIVIL TERM FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION") vs. ROBERT A.PEIFER LINDA I. PEIFER owner(s) of property situate in the BOROUGH OF LEMOYNE, Cumberland County, Pennsylvania,being (Municipality) 517 WARREN STREET,LEMOYNE,PA 17043-2037 Parcel No. 12-22-0820-055 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $164,442.87 Phelan Hallman&Schmieg,LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in the Borough of Lemoyne, Cumberland County,Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the western line of Warren Street, said point being one hundred sixty-six and three tenths(166.3)feet south of the southwest corner of Walton and Warren Streets;thence in a westerly direction along other lands now or late of R.R. Baugher one hundred(100)feet to a point on the line of property now or late of Aaron M. Fackler and Frances E. Fackler his wife;thence in a southerly direction along the line of said Fackler property fifty-one and five tenths(51.5)feet to the northern line of Lot No. 38 on Plan of Lower Walton as laid out by the Trustees of the Estate of James McCormick,deceased,which Plan is recorded in the Office for the recording of deeds in and for Cumberland County in Plan Book 1,Page 204;thence in an easterly direction along the northern line of said Lot No. 38 on the said Plan one hundred(100) feet to the western line of Warren Street; thence in a northerly direction along the western line of Warren Street fifty-one and five tenths (51.5)feet to a point,the place of BEGINNING. HAVING thereon erected a single two-story frame dwelling house. TITLE TO SAID PREMISES IS VESTED IN Robert A. Peifer and Linda 1. Peifer,his wife,by Deed from Helen Thomas Heilman and John E. Thomas,Executrix and Executer Respectively of the Estate of Helen Leckey Thomas,aka Ruth L. Thomas, Late,dated 02/10/1 971,recorded 02/17/1971 in Book Y-23,Page 945. PREMISES BEING: 517 WARREN STREET,LEMOYNE,PA 17043-2037 PARCEL NO. 12-22-0820-055 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-2578 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FANNIE MAE(FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff(s) From ROBERT A.PEIFER,LINDA 1.PEIFER (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: $164,442.87 L.L.: Interest FROM 6/4/2010 TO DATE OF SALE($27.03 PER DIEM)-$27,219.21 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $2sd.40 Other Costs: Plaintiff Paid: Date: 10/15/12 David D.Buell,P, ,,,rothonotary (Seal) Deputy REQUESTING PARTY: Name: MELISSA J. CANTWELL,ESQUIRE Address:PHELAN HALLINAN&SCHNIIEG,LLP 1617 JFK BLVD,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 TRUE COPY FROM RECORD Attorney for: PLAINTIFF In Testimom,whereof,I here unto set my hand Telephone: 215-563-7000 and the seat of said Court at Ca fsle,Pa.t� This 15 day of Supreme Court ID No,308912 roth tary On October 26, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA, Known and numbered as, 517 Warren Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 26, 2012 By: ,i a Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-2578 Civil Fannie Mae V& Robert A.Peifer, Linda I. Peifer Atty.:Francis Hailinan By virtue of a Writ of Execution NO, 10-2578-CML TERM, FANNIE MAE("FEDERAL NATIONAL MORT- GAGE ASSOCIATION")vs. ROBERT A.PEIFER,LINDA I.PEIFER owner(s) of property situate in the BOROUGH OF LEMOYNE,Cumberland County, Pennsylvania, being 517 WARREN STREET,LEMOYNE,PA 17043-2037. Parcel No. 12-22-0820-055. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT:$164,442- .87, 90 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this da of Februga, 2013 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 the atr1*otwXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 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: Z010-2= mll 01/22/13 Fannie M Vs 01/29/13 Rolbert A." 02/05/13 Undo 1.P~ Atriy: Franei meninan .. • By virtue of a Writ,"of Execution N0. . . . . . . . . . . . . . . . 10-257&CPAL TERM r FANNIEMAE("FEDERALNATIONAL MORTGAOEA330CIATION") Sworn to and qubscribed before m is 14 day of February, 2013 A.D. VS. ROBERT A:FEIFER LINDA L 1'EIPER owners) of property situate in the V T BOROUGH OF LEMOYNE, lic Cumberland County,Pennsylvania,being. (Muniy) 517 WARREN STREET;LEMOYNE,PA 17043-2037 COMMONWEA F PENNSYLVANIA Parcel No.12.22MM-055 Notarial Seal (Acreage or street address) Holly Lynn Warfel,Notary Public Improvements thereon: RESIDENTIAL Washington Twp.,Dauphin County DWELLING ­="' My Commission Expires Dec.12,2016 JUDGMENT AMOUNT.$164,442.87 MEMRER,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal Nationl Mortgagee Association is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013,under and by virtue of a writ Execution issued on the 15th day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 2578,at the suit of Fannie Mae Federal Nation].Mortgage Association)against Robert A. Peifer and Linda I. Peifer is duly recorded as Instrument Number 201315017. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D., C 43 0 oder of Deeds tr co u nty,Carlisle,PA My commission Expires the First Monday of Jan.2014 _t'i`t Phelan Hallinan,LLP Attorney For Plaintiff Cam` ' 6° " 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 ' 215-563-7000 ' = FANNIE MAE ("FEDERAL NATIONAL Court of Common Pleas . MORTGAGE ASSOCIATION") Plaintiff Civil Division vs CUMBERLAND County ROBERT A.PEIFER No. 10-2578-CIVIL TERM LINDA I.PEIFER Defendant PRAECIPE TO THE PROTHONOTARY: ❑Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑Please mark the above referenced case Settled,Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ®Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑Please Vacate e Judgment entered. Date: PHELAN HALLIN LLP By: Justin qqfo sq.,Id.No.200392 rney r Plaintiff PHS#234726 4.50 PO ARy E�agog(o(y J. Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 FANNIE MAE ("FEDERAL NATIONAL Court of Common Pleas MORTGAGE ASSOCIATION') Plaintiff Civil Division V. CUMBERLAND County ROBERT A.PEIFER No. 10-2578-CIVIL TERM LINDA I.PEIFER Defendant PHS#234726 CERTIFICATION OF SERVICE " I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s)on the date listed below: ROBERT A.PEIFER LINDA I.PEIFER 517 WARREN STREET LEMOYJ PA 1 043-2037 Date: PHELAN HALL N,LLP By: Justin F. K bes Esq.,Id.No.200392 At rney for Plaintiff