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HomeMy WebLinkAbout10-2904UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 .-ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION 3232 Newmark Drive Miamisburg, OH 45342 :Cumberland County Plaintiff V. Christopher A. Toddes Maria R. Sprow NO. 10 809 North Arch Street Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE C ) . w? V CTS .? Cam? a J- 4J t. L " -avy, 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 g9oZad lac(. e?Ee /S616 R-a aye,9lk HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. Current assignments of mortgage of record are as follows. Assignor: Commerce Bank/Harrsburg, N.A. Assignments of Record to: National City Mortgage Company Recording Date: 09/16/04 Book: 711 Page: 2996 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. The Mortgage and Note was modified in accordance with the Modification Agreement recorded on 10/05/04 at Book: 712 Page: 264. Said Mortgage and Modification Agreement are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g). Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 809 North Arch Street MUNICIPALITY/TOWNSHIP/BOROUGH: City of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 09/15/04 DATE RECORDED: 09/16/04 BOOK: 1880 PAGE: 4677 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 04/21/10: Principal of debt due $149,269.28 Unpaid Interest at 5.75% from 04/01/09 to 04/21/10 (the per diem interest accruing on this debt is $23.52 and that sum should be added each day after 04/21/10) 9,053.30 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $414.18 and that sum should be added on the first of each month after 04/21/10) 3,029.87 Late Charges (monthly late charge of $46.54 should be added in accordance with the terms of the note each month after 04/21/10) 279,24 MIP/PMI 196.72 Attorneys Fees (anticipated and actual to 5°s of principal) 7,463.46 TOTAL $170,076.87 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $170,076.87 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: Attorneys for P1 ntiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 04-26-'10 13:11 FROM-- Aar-26-1010 11,49ns From- LF"L DrESCB.T.FTION T-162 P0009/0012 r-546 T-TTB P,000/012 F-878 A" Tw CmAn piece or parcel of land Situate in weehanicabu[g, camberlmd qty, Pesntasylva nia, ' Wre patti,aalarly bound+ptd `anti demer[Aee{ as #a3i?owa ? to vlt_:.- BEG3:NMC at a point on t'he weatata 123kc of Arch Stet, which point 3s also at the dlarision line bet Lots 13 and IA. &uctc c on the h"eina a ftex ancloned Plan of lAts;, 'tbence• Borth 78 degrees 00 minutes Vc t 123.35 face to -a point; thence North 12 d8greea 00 misuten Best 65 Pact to &point at the division 34ae of Lora, 12, and -13 on ctbwe hereiaOtar mentioned r2m of Late; thence slant caid divigicm dine south _7g degrum go minutes East 113.35 feet to a point on the Vesterm Iltte of Arch Street; tbeuea Sonia 12 deveca 00 011111tas.>aeat 65 feet to'the po3ot and place of BAG. MING Lot No. 13, hock G on the Fir al Plan of Parts of Aloa m A. Cv DA B, r, G and B ,*nnw wad Perk, as recarded in the Owmbcr1and County liew rder's Office in Plate Sack 27, 1'sge 20. ri"=C TKM'W E8EC1U s dvclliag, numbered b09 N. Arch Sttaet, H hnicalburg: T Certify this to be recorded In Cumberland County PA Recorder of Deeds nu i a 0nnr-J, -QQ Appendix A DATE: 0 a V7l2009 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. Specific information about: the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may, be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAY'S OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agencv. The naive, address and phone number of Consumer Credit Counseling Agencies serving Your County are listed at the end of his Notice. If you have any Questions- y-Qu may call the Pennsylvania Housing Finance A,gencv toll free at 1-800-342-1397. (Persons with impaired hearing can call. (717780-1862). 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 Er ADJUNTO ES DE SUMA I IPORTANCIA, PUES AFECTA SU DERECHtI A CONTINUAR Z"?]ENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA USIA TRADUCC16N INMEDIATAMENTE LLAM.ANDO ESTA AGENCIA (PENNSYLN'ANI A HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA Uri 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 HIPOTEC A. EXHIBIT A PA3;-: O.4 HOME01Nt'NLR'S NAM (S r SPRC W-N ARIA R TCIDDL,S,CHRISTOPHI R A PROPERTY ADDRESS: 909N ARCH ST LOAN ACCT. NO.: 00 03-567381 ORIGINAL LENDER: n/a CURRENT LENDERrSERVICER: National City Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTkNCE PROGRAM YOU MAY BE ELIGTBLE FOR FINANCIAL ASSTSTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOI' MAKE FTM3RE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOW'NER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUIT-LSTANCES BEYOND YOUR CONTROL, + IF YOIJ 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 -- Linder 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'inucting with one of the consumer credit: counseling agencies listed at the end of this Notice, THIS MEETING: MUST OCCUR WITHIN (331 DAYS OF THE DATE OF THIS NOTICE, IF YOU DO NOT . IIPL.Y FOR EMERGENCY MART iA TF ASSISTANCE YOU MUST 1312 N _* YOUR MORTGAGE IP T DATE. THE. PART F TTU TT .E CALLED "HOIN T i'RF YO tR MORTGAGE DEFAULT"- EXPI.AINS I10W TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meetwith 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 minting. The names addresses and t lenhonen um rs of d sionat d consumer credit , sns IinLagencies for the county in which thegLoojjg y is located arc set forth at the end cif this Notic e, It is only neccssan7 to schedulc one. face-to-face meeting. Advise your lenderimmediatelof your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pager for specific information about the nature of your default. i 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 1-Torneowncr'sLmcrgency Assistance Program Application with one of the designated consumer credit 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 forwaMed to PHFA and rcecivui within thiny (30) days of your face-to-face meeting with the counseling agency. 310L' SHOULD FILE A HE4 AP APPLICATION AS S(N),'1,* AS POSSIBLE IF YO[` HAVE A ,-IIEETIJV(KITH A COQ 1'SEL1.%G AGENCY Fi7TR1A 33 DAYS OF' THE POSTMARK DATE OF THIS ,' OTICE AAA FILE AN APPLICATI(IN WITH PHFA N'ITHIN 30 DA IN OF THAT MEETING, THEY THE LENDER WILL BE TEifPORARIL Y PRE t E A7ED FROM STARTI.N`GA FORECLOSURE AGAINST YO1IR PROPERTY, AS FXPPLALI'ED ABOVE, IN THE SECTION CALLED "TE.MPORARYSTAYOF FORECLOSEIRE"; YOU 11AVE THE RIGHT TO FILE A HEAL4PP APPLICATION MEN BEYOND THESE TIME PERIODS: A LATE 4PPLICATIOA KILL NOT PREIEN'T THE LEA'DE'R FROV STARTING A FORE'CLOSCRE ACTION, BUT IF YOI?R APPLIC:ATIO, IS EI'EN'Tt,,4LLY,4PPROt'ED.4TAN)' TIrNE BEFOREA SHERIFF:S SOLE, THE FORECLO LV RE BILL BE STOPPED. NF.GE 2 of 4 AGENCY ACTION - Available funds for emergencymongage assistance are very limited. They will be disbursed by the Agency under the eltaibihty criteria established by the Act. The Pennsylvania Housing Finance Agcncyhas sixty (60) days to make a decisionaftVr 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 ATTEM PT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance,) IF YOU O 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 ib 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 ins-tal meats. 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 u1jon your mortgaged proper IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged 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 procecdingsagainst 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's 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 ether reasonable costs. If you cure the defatdt within the THIRTY (30) DAY period„ you MH not be renuired to nay= attorne}:'s fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT 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 nrevent the monaaa Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if van had never defaulted EARLIEST PO IB.F SHERIFF'S SALE, DATE. -- It is estimated that the earliest date that such a Sheriff's Sale of the mnrt gaged property could be held would be approximately nine -ten munths from the date of this Notice. A notice of the actual date of the Shariff -sSalc 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 tiny time exactly what the required payment or action will be by contacting the lender. Name of Lender: National City Morteaee Miamisburg„ OH 45432 Phone Number: 1-800-523-8654 Fax Number: 937-910-4009 Contact Person: Customer Counseling Department 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 lire in the property after the Sheriff sStile, 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 or may notX (C l IEC'K ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. PROF i OF 4 YOU MAY ALSO HANT THE RIGHT; • TO SELL THE. PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO 13ORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEIST. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. + TO HAVE THE f' ORTOAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT IIAD OCCURRED, IF YOU CURE THE. DEFAULT, (HOWEVER, Y(?I? DO NOT HAVE THIS RI{ IIT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR AN'Y OTHER LAR'SUIT INSTITUTED UNDER THE MORTGAGE DOCLI DENTS. • TO ASSERT ANY OTIIER DEFENSE YOU BELIEVE YOU, MAY IIAVE TO SUCH ACTION BY TILE LENDER. • TO SEEK. PROTECTION CINDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERN"ING YOUR COUNTY (Fill in a list of all Cvanselin$ A,cencies listed in Appendix C, FOR THE CO€WTYin which the provern, is located, using additional paces if necessary PACE 4OF4 Wk M M r? Amok MN = Naumaf City martgagv Mortgage i?tiz 4 5,342' 1820 Dayton Ohio 45401-1820 71078381654020628813 aiiang Address: §>r xs' 9 L40'1-1-KT.Q 05895-0000091-001-001-000-000-000 TODDES,CHRISTOPHER A 809 N ARCH ST MECHANICSBURG PA 17055-2702 Certified Mail/Return Receipt Requested Loan No: 0003567381 Current Servicer: National City Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 809 N ARCH ST MECHANICSBURG PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) 3 and the following amount(s) are now past due: Monthly Payments $1,345.01 Corporate Fees $0.00 Late Charges $93.08 Non-Sufficient Funds $0.00 Fax Fees $0.00 Property Inspection Fees $9.00 Less Suspense Balance $0.00 Total Due $4,137.11 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): 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 PAYING THE LENDER, WHICH IS $4,137.11, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD- Payments must be made either by cashier's check, certified check, cash or money order made payable and sent to: National City Mortgage Customer Counseling Department 3232 Newmark Dr Miamisburg, OH 45432 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter:( Do not use if not applicable). This is an attempt to collect a debt, any information obtained will be used for that purpose. Enclosure DR673 Appendix A DATE: 07.'0712009 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 MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice ezplains how the Program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your Couniv are listed at the end of this Notice. If you have any Q-ue ion _ you may call the Pe n ylv ni Housing Finance Ageney toll free at 1-800-342-2397. (Pe on with impaired hearing can call (717 -1864). 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 SOMA IMPORTANCIA, PUES AFECTA SU DER-ECHO A CONTINUAR ViViENDO EST SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDLATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PAGE 1CF4 HOMEOWN1 R'S NANVII (S): SPROW,MARIA R TODDES,CHRISTOPHER A PROPERTY ADDRESS: 809 N ARCH ST LOAN ACCT. NO.: 000367381 ORIGINAL LENDER: nfa CURRENT LENDER/SERVICER: National City Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCTAL 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'bsecting 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 YOUR MORTGAGE UP TO Tl A TT TTTT7 T A TT !lT TTTTLI ATl1TTr1T7 -AT T T7Tl IITTl1TTr T!l !^T TT)T' vl1T TTl T. dl1T]•T!-A I' T' T`%TT` A T TT TII T^VTfT A'LTC I IOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you. mcctwith 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 telenhonenumbers of designated consumer credit counseling agencies for the county in which the =12= is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lenderimmediatelyofyour 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 Homeow-ner's EmergencyMortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowncr'sEmergency Assistance Program Application with one of the designated consumer credit 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 HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELINTG AGENCY PITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANr APPLICATION' 97TH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PRETIENTED FROMSTARTING A FORECLOSURE AGAI.NrST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE"YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION LS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFFS SALE, THE FORECLOSURE WILL BE STOPPED. PAGE 2 OF 4 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.) 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 instalments. 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 mortgaged QrouerLV IF T MORTGAGE I FORECLOSED UPON -- The mortgaged 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's 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 default within the THIRTY (30) DAY period, you will not be required to 1}av attorney's fees OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the TI l1RTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and g'_revent the sale at any time un to one hour before the Sheriff s Sale. You may do so by ravine the total amount then past due, plus costs connected with the Sheriff s Sale as snccificd in writing by the lender and by performing any other requirements under the mortgage 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 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 nine - ten months from the date of this Notice. A notice of the actual date of the Sheriff sSale 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. Name of Lender: National City Mortgage Address: 3232 Newmark Dr. Miamisburg, OH 45432 Phone Number: 1-800-523-8654 Fag Number: 937-910-4009 ntact mail, EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff s 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 Sheriff s 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 or may not X (CI IECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. PAGE 3 of 4 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 IIAVE TILE MORTGAGE RESTORED TO TIIE SAME POSITION AS IF NO DEFAULT IIAD OCCURRED, IF YOU CURE TIIE DEFAULT. (IIOWEVER, YOU DO NOT IIAVE TIES RIGIIT 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 OTIIER DEFENSE YOU BELIEVE YOU MAY IIAVE TO SUCII ACTION BY TIIE LENDER- * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all CounselinP Ajeencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary}, PAGE 4OF4 V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: _ Attorneys fo Plaintiff MARK J. UDRE, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~{~ Jody S Smith Chief Deputy n ~ ~ 201D ~~' t 3 Pi~"`i Z~ 4p Edward L Schorpp Solicitor ~F~ << . ~ ~~ ~~~~;,: ;_ r- , i~~i~!i~S~tiV~~~1A PNC Mortgage vs. Christopher A. Toddes (et al.) Case Number 2010-2904 SHERIFF'S RETURN OF SERVICE 05/11/2010 02:58 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1453 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Maria R. Sprow, by making known unto herself personally, at 809 N. Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. GERALD WORTHINGTO PUTY 05/11/2010 02:58 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1453 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christopher A. Toddes, by making known unto Maria R. Sprow, Wife of defendant at 809 N. Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. GE LD WORTHINGTO EPUTY SHERIFF COST: $53.44 May 12, 2010 SO ANSWERS, ,~ RON R ANDERSON, SHERIFF (cj Counir Suite ShenfF. Teleosi:fl. Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes €NO. 10-2904 Maria R. Sprow Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue writ of Execution in the above matter: Amount due c; C ^~ ~ _ -: r .. ~ 1__ -~-, G1 ~ ; i' ,, r- ,. _ - .-. , t- , ,... _~. ,, _; r _: r5 ~ ~ `z:= $172,291.91 Interest From 06/16/2010 4,139.52 to Date of Sale December 8, 2010 Ongoing Per Diem of 23.52 to actual date of sale including if sale is held at a later date (Costs to be added) g'o1.~.0~ ~~~y $ UD OFFICES, C. BY: ~/ y, Da ~sfs B~ Q Od ~~ r' 7 ~-• `~ Sb P ~ ~y Attorne aintiff MARK J. UDREN, E STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE s , .~d J7 u`. c ~.L UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff 'Cumberland County v. :MORTGAGE FORECLOSURE C'> Christopher A. Toddes NO. 10-2904 ~ -~ _ ~ '' v 'n Maria R. Sprow '~' ~f;, c_ •--~ - Defendant (s) - c.µ_ ~" ~''~~,r, r 7 CERTIFICATE TO THE SHERIFF ,=' ; '~ - ;-_~. c.., ~~"' I HEREBY CERTIFY THAT: _r _ I. The judgment entered in the above matter is based on an Action,, r=r A. In Assumpsit (Contract) ~ ~ ;, ;-' B. In Trespass (Accident) _ ,, :; X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged prope rty. II. The Defendant(s) own the property being exposed to sale as: A. An individual B. Tenants by Entireties X C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW O A Plaintiff MARK ~: ~'Ei~fi; UIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID # 04302 STUART WINNEG, ESQUIRE - ID # 45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County v. n r; € MORTGAGE FORECLOSURE ~ ~ ~~~' ~ - '_' E~.. __ _i _ C. _ : ~ "'fit P_ ~ f `mot r_ . ~ Christopher A. Toddes €NO. 10-2904 _ ~ ? +, ~"' Maria R. Sprow - - De f endant (s ) , ~ ~ _. ~- -~ = ~ +` ,~.`~ ~~ C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW nF~Tr~F~ , P . C . B~-- Y '_ L Attorne~v , -fn+----nJ,~int i f f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE "UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. '-CIVIL DIVISION Plaintiff =Cumberland County v. ~ v - MORTGAGE FORECLOSURE T, ~~ ° `' `~ ~ :ter Christopher A. Toddes NO. 10-2904 f_ n'_t`~ -;~r~ Maria R. Sprow ~-' , ` Defendant (s) = TM, '' - -'` -; - _ r ~ '_'! AFFIDAVIT PURSUANT TO RULE 3129.1 ~, ~.' ~+ _~. PNC Mortgage, a division of PNC Bank, N.A., Plaintiff i n the above action, by its attorney, Mark J. Udren, ESQ., set s forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 809 North Arch Street, Mechanicsburg, PA 17055 1. Name and address of Owners} or reputed Owner(s): Name Address Christopher A. Toddes Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 809 North Arch Street Mechanicsburg, PA 17055 2. Name and address of Defendants} in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mortgage, a division 3232 Newmark Drive of PNC Bank, N.A. Miamisburg, OH 45342 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N Hanonver Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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 Tenants/Occupants 809 North Arch Street Mechanicsburg, PA 17055 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. sec. 4904 relating to unsworn falsification to authorities. DATED: July 1, 2010 LAW OF S, P.C. BY: At or Plaintiff MARK J . UDREA~, QUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID STUART WINNEG, ESQUIRE - ID LORRAINE DOYLE, ESQUIRE - ID ALAN M. MINATO, ESQUIRE - ID CHANDRA M. ARREMA, ESQUIRE - WOODCREST CORPORATE CENTER #04302 #45362 #34.576 #75860 ID #203437 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of PNC Bank, N.A. Plaintiff v. Christopher A. Toddes Maria R. Sprow Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2904 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Christopher A. Toddes Maria R. Sprow PROPERTY: 809 North Arch Street Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING l ! ~,~.` __ i N C~ C~ ~_.» ~, ~._ ~..J ;7 ~w Gr -_.; Yl 1~ ~ -r-, i~T" Z: The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 8, 2010, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. . UDREN LAW OFFICES, P.C. ., ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes €NO. 10-2904 ~.. Maria R. Sprow ~ ~ -;i Defendant (s ) "=~~ NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~'`~~ w ,r TO: Christopher A. Toddes '` --- 809 North Arch Street ~ -- ~-= =~~~ Mechanicsburg, PA 17055 '~ ~` Your house (real estate) at 809 North Arch Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $172,291.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take ixmnediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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 TARE 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 856-669- 5400. 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 856-669-5400. 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. 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 Schedule of Distribution is filed. 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 TARE 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. LAWYER REFERRAL SERVICB 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff =Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes €NO. 10-2904 Maria R. Sprow Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 C1 ~~ ca C ~,, _Tyti ~"'~ f.. v --1 1_ 'TI r--~ _~ ti.._~ ; -~ .- w +_ . ~~~ , ~~ ~-_ r-- - ~ .. _ 4,. Your house (real estate) at 809 North Arch Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $172,291.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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 cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 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 856-669- 5400. 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 856-669-5400. 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOOED 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. LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-2904 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK, N. A. Plaintiff (s) From CHRISTOPHER A. TODDES AND MARIA R. SPROW (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$172,241.91 L.L.$.50 Interest FROM 06/16/2010 TO DATE OF SALE DECEMBER 8, 2010 -ONGOING PER DIEM OF $23.52 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD ATT A LETER DATE - $4,139.52 Atty's Comm % Due Prothy $2.00 Atty Paid $185.94 Other Costs Plaintiff Paid Date: July 13, 2010 psi ~~.roc ~- ,~~~0 David D. Buell, Prothonotary ~~ ~~~ n ' (Seal) By: ~ i~uQ ~ :~~A.YJY1 ~ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQ. Address: UDREN LAW OFFICES, P.C., WOODCREST CORPORATE CENTER, ll l WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRB - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of PNC ;COURT OF COMMON PLEAS Bank, N.A. :CIVIL DIVISION 3232 Newmark Drive =Cumberland County Miamisburg, OH 45342 Plaintiff ;MORTGAGE FORECLOSURE v. Christopher A. Toddes NO. 10-2904 Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: N C ~ "'_ -l . _~ ~_ ~.., c! --a _- __I r= - -. ~ _ ., , 4.J ; . t: c. _~r: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Christopher A. Toddes and Maria R. Sprow for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 04/22/2010 to 06/15/2010 Late charges per Complaint From 04/22/2010 to 06/15/2010 Escrow payment per Complaint From 04/22/2010 to 06/15/2010 TOTAL $170,076.87 1,293.60 93.08 828.36 $172,291.91 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. "ti Y Attorneys for ~3~i.utff MARK J. UDREN, ESQUIRE ,S''P T WINNEG, ESQUIRE LORRAI ESQUIRE ALAN M . MINATO , ~'~ CHANDRA M. ARKEMA, DAMAGES ARE HEREBY ASSESSED AS INDICATED RE DATE : JL ~ 3 ~ ~~~ /'S/ ~~-~~ =(X-4~ ~- ~CCe'.~" PRO PROTHY - ~~L~~~ ~ c~~° ~~~~ ~~~r~~ ~ ~~~~ ~ ~~es ~~( UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONY, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udren.com PNC Mortgage, a division of PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff V. Christopher A. Maria R. Sprow 809 North Arch Mechanicsburg, Toddes Street PA 17055 Defendant (s) CO1Pp COURT OF COMMON PLEAS CIViL DIVISION Cumberland County c ~. -'t Lx_ IT] r't_: No. tv -a4aY ~~~ ., ~-~ ':. _} .~:. ~!^ D COMPLAINT IN MORTGAGE FORECLOSURE "'-~...~ G; O -~ c~ ~:~ .z .. ~.. -n iil~ -"; =. 'T ':.n `. ~~ .,~ YOU HAVE SEEN 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 ar 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 /1 1 f•.l t,~ f !~'~ ?tit f _.~~- „ 1 ~ .1, ~. ATTORNEY FOR PLAINTIFF Verbal Confirmation of Service of Complaint Date: ~"' ~~ Spoke with: __~~ .~,~ Df at Defendant ~~, ` ~~~~~ ~ ~~~~ was served on ~~~~ Defendant at Defendant was served on ~`"~ was served on at Are there any additional fees due? Yes No If so how much? $ Notes: UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRB - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRA,INE DOYLE, 83QUIRE - ID #34576 ALAN M. MINATO, BSQUIRB - ID #75860 CHANDRA M. ARKEMA, ESQUIRB - ID #203437 LOUIS A. STMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #1~A40~'- D-'I PNC Mortgage, a division of PNC Bank, N.A. Plaintiff v. Christopher A. Toddes Maria R. Sprow Defendant(s) TO: Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Date of Notice: June 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County N0. 1fl-2904 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE 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 Y0~7R PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCfES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE NECES DADODEECOMPARARECERIUSTED ENTCORTEIOIESCUOCHP.REPREUBA ALGUNAD DiCTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHO~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DE$T COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DE$T COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. N! A. L. wooacrest c:o orate center 111 Woadcrest oad, Suite 200 Cherry Hill, New Jersey 08003-3620 [TOKEN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STIIART WINNEG, ESQIIIRB - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, BSQIIIRB - ID #75860 CBANDRA M. ARKEMA, SSQU'IRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGIIERITE L. THOMAS, ESQUIRE - ID #204460 WOODCRBST CORPORATE CENTER 111 WOODCREST ROAD. SUITS 200 CHERRY SILL, NJ 08003 856-669-5400 ~e o5, a-1 PNC Mortgage, a division of PNC Bank, N.A. Plaintiff v. Christopher A. Toddes Maria R. Sprow Defendant(s) TO: Christo her A. Toddes 809 Nor~h Arch Street Mechanicsburg, PA 17055 Date of Notice: June 2, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAII3TIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2904 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE 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 YO{3R PROPERTX OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE XOU WITH INFORMATION ABOUT AGENC~ES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3266 B00-990-9108 NOTIFICACION IbiPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA SIN NECESIDAD DE COMPARARECER LISTED EN CORTE O ESCUCH~IR PREUBA ALGUNA D'ICTAR SENTENCIA EN SU CONTRA LISTED PUEDE PERDER BIENES Y OTRQS DERECHOS~, IMPORTANTES. DEBE LLE~IAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI LISTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE P{JEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER ~2EFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO TB$ FAIR DEBT COLLECTION PRACTIC85 ACT, IBIS LAW FIRM IS D8EldED TO SE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION 08TAINED WILL SE IISED FOR '~'~n'f' pnR_pOSS. CHANDRA~ Nt. ~ A1tKEi~A, E"SQQU2RE LOUIS A. SIMONI, ESQQUIRE ADAM L. KAYES, ES¢L~IRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Koad, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINB DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff ;Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes Maria R. Sprow Defendant (s) ' NO. 10-2904 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. loo), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment Defendant: Age: Residence: Employment: Christopher A. Toddes Over 18 As captioned above Unknown Maria R. Sprow Over 18 As captione ove Unknown Sworn to and subscribed before me this 1ST day o~ July, 200 _ _ __,___ Not~iry L~ublic." ~_ CARA STEAKS NOURYa~IICOF I~EWJ8~5EY =Go~nNs~on ~ 1QIt5/10'13 Name: ~ Title: A Company: U R PLAINTIFF FFICES, P.C. - UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 080Q3-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes NO. 10-2904 Maria R. Sprow Defendant (s ) TO: Christopher A. Toddes 809 North Arch Street Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 , UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division of PNC :COURT OF COMMON PLEAS Bank, N.A. ;CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff ;MORTGAGE FORECLOSURE v. Christopher A. Toddes NO. 10-2904 Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Defendant (s ) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Christopher A. Toddes and Maria R. Sprow for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $170,076.87 Interest Per Complaint 1,293.60 From 04/22/2010 to 06/15/2010 Late charges per Complaint 93.08 From 04/22/2010 to 06/15/2010 Escrow payment per Complaint 828.36 From 04/22/2010 to 06/15/2010 TOTAL $172,291.91 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN Y• Attorneys for tiff MARK J. UDREN, ESQUIRE 'g~T~&$T WINNEG, ESQUIRE LORRAINh ~©YIaE, ESQUIRE ALAN M. MINATO, E IRE CHANDRA M. ARKEMA~~UIRE DAMAGES(~ARE HEREBY ASSESSED AS INDICATED DATE : ~14~ /7 0~-4 /G PRO PROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF J "~+ MARR J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #453.62 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County v. :MORTGAGE FORECLOSURE Christopher A. Toddes Maria R. Sprow =NO. 10-2904 Defendant(s) TO: Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren Esquire At this telephone number: 856-669-5400 . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com PNC Mortgage, a division of PNC :COURT OF COMMON PLEAS Bank, N.A. ;CIVIL DIVISION 3232 Newmark Drive Cumberland County Miamisburg, OH 45342 Plaintiff ;MORTGAGE FORECLOSURE v. Christopher A. Toddes € NO. 10-2904 Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Christopher A. Toddes and Maria R. Sprow for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $170,076.87 Interest Per Complaint 1,293.60 From 04/22/2010 to 06/15/2010 Late charges per Complaint 93.08 From 04/22/2010 to 06/15/2010 Escrow payment per Complaint 828.36 From 04/22/2010 to 06/15/2010 TOTAL $172,291.91 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. Attorneys for tiff MARK J. UDREN, ESQUIRE ~S'~U~tT WINNEG, ESQUIRE LORRAINE'~D~YI.~E, ESQUIRE ALAN M. MINATO, ~'~~SQ.I~IRE CHANDRA M. ARKEMA, UIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: /3~ o?C//D PRO PROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of PNC Bank, N.A. I COURT OF COMMON PLEASC-) 3232 Newmark Drive :CIVIL DIVISION o Miamisburg, OH 45342 = Cumberland County rncD c: r?t Plaintiff -0n r ? V. . .,?T> fv CD r-X -4c) <O -0 E3` t Christopher A. Toddes Maria R. Sprow NO. 10-2904 c C7rn 809 North Arch Street' Mechanicsburg, PA 17055 --E Defendant (s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November 2010 UDDR_?.DI--B- -Q? Z BY Att or Plaintiff Alan M. Minato, Esquire PA ID 75$60 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of PNC Bank, N.A. Plaintiff V. Christopher A. Toddes Maria R. Sprow Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-2904 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Christopher A. Toddes and Maria R. Sprow PROPERTY: 809 North Arch Street, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 8. 2010, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. n 0 CD D O Q CL CD Cl) a N v" ;U O A 0 i 9 i (7 c cr CD v 7 Q -n O 3 w co V V CD CT c w c-o co A O 3 n O m a Q V O 7 O T O K O 7 r,? i i > > i Cp m v rn cn A6 Dv o CT A W N -? O m a U)6?3 CL Qc 7fDM v v Z> c ? CA.W CD M > CA (D ? m Co fD c?D ? N ^iv `? o /?iN TT KwV T 7-00?w-4 . i. ToT;u To ^ ? i m o ?.Z3 '?.p v CD i)- Nn O CZ ?'?O ° M O ?p = -<Z N 2N 52,C m (n m'Z3 o Z ? Q xZ R D D 0M M M CL -UQ n - -0 o fl: CT CD o *? 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O to v qp ?? c; 1 N N n m0 m MARK J. UDREN, ESQUIRE NJMANAGINGATTORNEY TINA MARIE RICH OFFICE ADMPVISTRATOR November 16, 2010 UDREN LA W OFFICES, P. C. WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856. 669. 5400 FAX.• 856. 669. 5399 FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL Prothonotary of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Re: PNC Mortgage, a division of PNC Bank, N.A. VS. Christopher A. Toddes Maria R. Sprow Cumberland County C.C.P. No. 10-2904 Dear Prothonotary: In connection with the above file, enclosed please find Praecipe to File Proof of Service for filing. Also enclosed is an extra copy of the Praecipe to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance with this matter. Sincerely yours, Danielle Devlin Foreclosure Specialist /dbs Enclosure CC: Sheriff of Cumberland County UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff :NO. 10-2904 V. Christopher A. Toddes Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: November k0, 2010 2,1 UDREN LAW OFFICES, P.C. Y: AttorneX.._fn if f Alin M. Minato, Esquire PA ID 75860 to E.` Tort rage, a division of PNC Bank, NA, et A, Plaintiffs; Y3. Christopher A. Todd s, et at., Ddend aattr3 i'DRE FAWOFFICS Ms. Danielle Devlin I 1I Woodcrest Rd., Ste_ 2110 Cherr7HtlL NU 08003-3620 a -cr#ce of Process by 4 SOPS International, Ltd. 1-800-328-7171 eN, at r R*nrtotv4.t. Aft intrmatkortat Plaza ,_.... ?.a - 7800 Cilenrcn Rd. %linneapolis, NTN 55439-3122: APS Fite* 707333 hWli AFFU).AV`1 ' OF SERVICE - Individual Service. of Process on. --tvittria R. Sprow C our - (Ame'_ No. 1 C1-2904 51aFc n3 _>rt' } ss Name of I.Q;ez-s,°er: D? Is r" itza (,i St'r% I cr: I"tact• of tiCrvirc: Document" Served; %ervice of Process ott_ k'erson Served, and Method of Service; I kvsc:ription of Person Receiving t1ocuments: >>i. '" rF 'E` unci?- ,irt :d, heir dull swcateluuases and says rt that at the timr, of servi.: c, s ltc -?N°as of h;gal age and was not a party to this action: that on tl,L. da4' of _ 'X" o'clock %4 at 80q'evarthArrf, -Street the und€ rsi t.d sLL;rvej the documents described as Notice of Sherffs Saleof Real Property t=t Merl n1cxbuELPA T^0--,; A true and correct copy, of the aforesaid doaument(s) was served on: 'Maria IZ, Sprow ----- _ --_........ c=a. personally delittz-in-T Them into the hand, o; tjt ps?rson to be smed. 'Bv deli-erinp th-?m jttc) the !lands of a person of suitable ai"ti. who t Sri lc d or who uprn q a? tl nnlm, stated, that tar =:f, r:sidas with Marina R. Sprom at the place Of service, and whose rulaiionshia to the person is: 'l'ie pemon receiving doL m cnts is described a; bllo s . Sex Shan C'otor Y } `' l-latr Color .Approx..4Oe _ _ Ltypt'e? l z i ??ht P pr -"j) i 'the l3 at o rCt4' l tlC3iti !EC :? :iltu t . «-., Sa::r >;it; was not engaRGd ij- the ', S Mil -, ai fit_ finte of sc 'ive. Signature of Server. C n,t°rsiszzaetl dc, lanes ultd:r penally of peritm ?:tnd st?cirr tc, F fora me this r that ttu "tct ' r+t tjdL° t-- tyts:: endtltlG'c .41 - t - - ---------- i pI - F illc l tiomd, Ltd_ M ort agge, a division of P*'C Bank" NA, et. W., Plaintiff(s) Vs. C'hrictophe: A• `foddes, et. al., Defendant?,o Serval of Tract-, b ti AP'Stlaternattonal, Ltd. 5e aSTY"IN,01TIONAL APS InWrnatiasr.i; p::jza 7800 Gienroy Rd. ' Minneapolis, '!l'- '45439-3122 APS File. 107353'0)01 L DREN t,.?tW OFFICES M S, Daweile Devlin III oodcrest ltd., Ste. 200 C"herryAlltNJ tll3€!OX3620 AFFIDAVIT OF SERVICL -- Individual `xcr c;r of Prom& on --Christopher A- Toddes Court Case No. 10-2904 k Mail, of: )ss. sarate of ' ei, f'r: undersigned, being Jul swam, dcposc* and says that at the tune of s?rwice, !;,h,: ww, oflt:gal age and was not :: party to aria aQuon, ilatc•," 'inaa o Service: that on the j. sia". of €7 , at • ct" lock M Place of Ser+ice at 809NorshArch S;reca to Nfec ntexhura, PA 170.5 Document, served: the undor-slQ71ed .:.:n-cd the documents described as: Notice of S heritf's `?aie of Real Property Service of Proc..ess on: A true: and az ;l copy of the aforesaid document(s) was served on, Christopher A. Toddes lte :C I. Person +?' ,?eu, and Method to! Secs ice: Bs? per4onally deliverim, thorn into tir.: hand, of the t on to B? delivering them into thi:: hanclr a person of suit,oblc: age, who verified, or whoa up+,, i gtaesti ownv st tied_ that he she rc;sides with :hrusitophea A,Toddek a, tt :i,: L O S r iCU. and whose rviatior ship Io the pemn t Description; 01Person Me p r-S3ra rea,;uislm dva;urn-nt is tes ti?t as tallow Receivirxg Documents'. Sex Skin Color_ y??_ Bair. C€tlor t? F-cial i-lair 1 . ' ttprc>- Ave {3prcax, Height :ta{,rcx. Weight o the best of nay knowledge and belief_ said per or :gas not engaged in the [-`S :, Jllilary at tht: tiSri'- ignature of Server: T--pdcnipic cl dt;clares under penalty, of perjury Subsertbed and sy6oi-ft to N.A'Or: me this ? '1t:at t.lt feu trctIm i 20 is-tz ttc, aac rrv t. 1 a' 01 -------------- 21 APS Itrtecnationalw, Ltd. ?' r a."'J ta? I H OF PENNSYLVF?N4r" t;_?na ? ti ., ?'? = Gsyto , Kota r," PC"P!#?G ^*%TH$SifatY ?%L?'$S JUiti j ;[U UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com ° PNC Mortgage, a division of =COURT OF COMMON PLEAS PNC Bank, N.A. =CIVIL DIVISION Plaintiff Cumberland County V. Christopher A. Toddes Maria R. Sprow NO. 10-2904 3 t Defendant(s) } PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a (2) two month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 809 North Arch Street, Mechanicsburg, PA 17055 was originally scheduled for December 8, 2010, then postponed to January 5, 2011, due to Plaintiff's moratorium on Sheriff's Sale, then postponed to March 2, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's sale (2) two month(s) to allow time to further complete mortgage loan account review. 3. Pursuant to local rule the defendant(s) are unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. No Judge has been assigned to this matter. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the May 4, 2011 Sheriff's sale Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Attorney for laintiff ChWKft M. Arkema, Esquire PA ID 203437 UDREN LAW OFFICES., P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadingsOudren.com PNC Mortgage, a division of ECOURT OF COMMON PLEAS PNC Bank, N.A. =CIVIL DIVISION Plaintiff -.Cumberland County V. Christopher A. Toddes Maria R. Sprow =NO. 10-2904 Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to further complete mortgage loan account review. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 809 North Arch Street,Mechanicsburg, PA 17055, to the May 4, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, ha lf, Esquire Local unsel UDREN LAW OFFICES, P.C. BY. Attorney for Plaintiff Chandra M. Arkema, Esquire PAID 203437 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 . 856-669-5400, pleadings@udren.com PNC Mortgage, a division of ;COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff "Cumberland County V. Christopher A. Toddes Maria R. Sprow NO. 10-2904 Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's sale was served upon the following person(s) named herein at their last known address or their attorney of record by: xxxx Regular First Class Mail Certified Mail Other Date Served: March 1, 2011 TO: Christopher A. Toddes 809 North Arch Street Mechanicsburg, PA 17055 Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 UDREN LAW OFFICES, P.C. r r I f a ra ? BY: Attorney for Plaintiff OwWra M. Arkema, Esquire PA 10 203437 f l S000, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION PNC Mortgage, a division of PNC Bank, N.A. Plaintiff V. NO. 10-2904 Christopher A. Toddes Maria R. Sprow Defendant (s) r 0 R D E R AND NOW, this /f day of March, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 809 North Arch Street, Mechanicsburg, PA 17055, it is hereby ORDERED that the said Sale currently scheduled for March 2, 2011, is extended (2) two month(s) to the regularly scheduled Cumberland County Sheriff's Sale.scheduled for May 4, 2011. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 2, 2011 Sheriff's Sale. TO: Christopher A. Toddes 809 North Arch Street Mechanicsburg, PA 17055 ?"Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 BY THE COURT: J. Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department V Office of the Sheriff Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 oo 1' eS yKC,. '1 z0( 31)111 - 1XI z ?'Tj e,?I, & ShWR)FF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ° I L `) 0 i Sherifff , I Jody S Smith Chief Deputy Richard W Stewart Solicitor Cr :r , __= :.. ?trr Hill J+E` 24 AN PENNSY# ,/90111 -? PNC Mortgage vs. Christopher A. Toddes (et al.) Case Number 2010-2904 SHERIFF'S RETURN OF SERVICE 10/15/2010 08:40 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 10-15-10 at 2040 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Christopher A. Toddes & Maria R. Sprow, located at, 809 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. 12/08/2010 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/05/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/02/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/4/2011 05/04/2011 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, Pennsylvania on May 04, 2011 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Federal Home Loan Mortgage Corporation, 8000 Jones Branch Drive, MSTP 202, McLean, VA 22102. SHERIFF COST: $958.60 SO ANSWERS, June 23, 2011 RON R ANDERSON, SHERIFF Kt2d / d' &I, jee) (ci GbumySuite Sheriff. Teieosoft, Inc. 1 .1 "DREN '-.AW V)FFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WTNNEG,,ESQUIRE - ID #45362 :'JORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER :111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Christopher A. Toddes :NO. 10-2904 Maria R. Sprow Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Mortgage, a division of PNC Bank, N.A., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 809 North Arch Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Christopher A. Toddes Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 809 North Arch Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS ##1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Mortgage, a division 3232 Newmark Drive of PNC Bank, N.A. Miamisburg, OH 45342 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept: Domestic Relations Section Commonwealth of PA, Department of Revenue 7. Name and address of has knowledge who has affected by the sale: Name Tenants/Occupants 809 North Arch Street Mechanicsburg, PA 17055 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. sec. 4904 relating to unsworn falsification to authorities. DATED: July 1, 2010 1 Courthouse Square Carlisle, PA 17013 13 N Hanonver Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 every other person of whom the plaintiff any interest in the property which may be Address 5 ? W OFF S, P. C. .11 BY: or Plaintiff MARK J. UDREN, QUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW' OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. SDREN, ESQUIRE - ID #04302 ,,StUART WINNEG-,.ESQU:LRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. M,INATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of €COURT OF COMMON PLEAS PNC Bank, N.A. ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Christopher A. Toddes NO. 10-2904 Maria R. Sprow Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Christopher A. Toddes 809 North Arch Street Mechanicsburg, PA 17055 Your house (real estate) at 809 North Arch Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $172,291.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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 cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay; you may call: _(856) 669-5400. 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 856-669- 5400. 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 856-669-5400. 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. 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 Schedule of Distribution is filed. 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. LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOW, TO WIT: BEGINNING AT A POINT ON THE WESTERN LINE OF ARCH STREET, WHICH POINT IS ALSO AT THE DIVISION LINE BETWEEN LOTS 13 AND 14, BLOCK C ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE NORTH 78 DEGREES 00 MINUTES WEST 113.35 FEET TO A POINT; THENCE NORTH 12 DEGREES 00 MINUTES EAST 65 FEET TO A POINT AT THE DIVISION LINE OF LOTS 12 AND 13 HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVISION LINE SOUTH 78 DEGREES 00 MINUTES EAST 113.35 FEET TO A POINT ON THE WESTERN LINE OF ARCH STREET; THENCE SOUTH 12 DEGREES 00 MINUTES, WEST 65 FEET TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 13, BLOCK G ON THE FINAL PLAN OF PARTS OF BLOCKS A, C, D, E, F, G AND B WYNNEWOOD PARK, AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 27, PAGE 20. HAVING THEREON ERECTED A DWELLING NUMBERED 809 N. ARCH STREET, MECHANICSBURG. BEING KNOWN AS: 809 North Arch Street Mechanicsburg, PA 17055 PROPERTY ID NO.: 18-22-0519-246 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER A. TODDES, SINGLE MAN, AND MARIA R. SPROW, SINGLE WOMAN AS JOINT TENANTS WITH THE RIGHT OF SURVIVORSHIP BY DEED FROM LLOYD F. LAMASON AND SUSAN L. LAMASON, HUSBAND AND WIFE DATED 09/15/2004 RECORDED 09/16/2004 IN DEED BOOK 265 PAGE 1268. ?DREN l,AW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J.-UDREN, ESQUIRE - ID #04302 STUART WINNEG, - ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. M.INATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ]ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Mortgage, a division of :COURT OF COMMON PLEAS PNC Bank, N.A. ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Christopher A. Toddes `:NO. 10-2904 Maria R. Sprow Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Maria R. Sprow 809 North Arch Street Mechanicsburg, PA 17055 Your house (real estate) at 809 North Arch Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $172,291.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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 cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 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 9VEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 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 856-669- 5400. 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 856-669-5400. 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. 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 Schedule of Distribution is filed. 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 TARE 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. LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle, PA 17013 717-249=3166 800-990-9108 ASSOCIATION DE LICENCIDADOS 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOW, TO WIT: BEGINNING AT A POINT ON THE WESTERN LINE OF ARCH STREET, WHICH POINT IS ALSO AT THE DIVISION LINE BETWEEN LOTS 13 AND 14, BLOCK C ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE NORTH 78 DEGREES 00 MINUTES WEST 113.35 FEET TO A POINT; THENCE NORTH 12 DEGREES 00 MINUTES EAST 65 FEET TO A POINT AT THE DIVISION LINE OF LOTS 12 AND 13 HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVISION LINE SOUTH 78 DEGREES 00 MINUTES EAST 113.35 FEET TO A POINT ON THE WESTERN LINE OF ARCH STREET; THENCE SOUTH 12 DEGREES 00 MINUTES, WEST 65 FEET TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 13, BLOCK G ON THE FINAL PLAN OF PARTS OF BLOCKS A, C, D, E, F, G AND B WYNNEWOOD PARK, AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 27, PAGE 20. HAVING THEREON ERECTED A DWELLING NUMBERED 809 N. ARCH STREET, MECHANICSBURG. BEING KNOWN AS: 809 North Arch Street Mechanicsburg, PA 17055 PROPERTY ID NO.: 18-22-0519-246 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER A. TODDES, SINGLE MAN, AND MARIA R. SPROW, SINGLE WOMAN AS JOINT TENANTS WITH THE RIGHT OF SURVIVORSHIP BY DEED FROM LLOYD F. LAMASON AND SUSAN L. LAMASON, HUSBAND AND WIFE DATED 09/15/2004 RECORDED 09/16/2004 IN DEED BOOK 265 PAGE 1268. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-2904 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC MORTGAGE, A DIVISION OF PNC BANK, N. A. Plaintiff (s) From CHRISTOPHER A. TODDES AND MARIA R. SPROW (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$172,291.91 L.L.$.50 Interest FROM 06/16/2010 TO DATE OF SALE DECEMBER 8, 2010 - ONGOING PER DIEM OF $23.52 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD ATT A LETER DATE - $4,139.52 Atty's Comm % Atty Paid $185.94 Plaintiff Paid Due Prothy $2.00 Other Costs Date: July 13, 2010 (Seal) REQUESTING PARTY: David D. Buell, Prothonotary By: ? I ?JJ9 i? (/ Deputy Name MARK J. UDREN, ESQ. Address: UDREN LAW OFFICES, P.C., WOODCREST CORPORATE CENTER, I I I WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 On September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 809 North Arch Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: U -? Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, ditor SWO TO AND SUBSCRIBED before me this 5 day of November, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 4* CUMBERLAND LAW JOURNAL 2010-2904 civil PNC Mortgage, a Division of PNC Bank National Association vs. Christopher A. Toddes Maria R. Sprow Atty.: Mark J. Udren ALL THAT CERTAIN piece or par- cel of land situate in Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follow, to wit: BEGINNING at a point on the western line of Arch Street, which point is also at the division line between Lots 13 and 14, Block C on the hereinafter mentioned Plan of Lots; thence North 78 degrees 00 minutes West 113.35 feet to a point; thence North 12 degrees 00 minutes East 65 feet to a point at the division line of Lots 12 and 13 hereinafter mentioned plan of lots; thence along said division line South 78 degrees 00 minutes East 113.35 feet to a point on the western line of Arch Street; thence South 12 degrees 00 minutes, West 65 feet to the point and place of BEGINNING. BEING Lot No. 13, Block G on the final plan of parts of Blocks A, C, D, E, F, G and B Wynnewood Park, as recorded in the Cumberland County Recorder's Office in Plan Book 27, Page 20. HAVING THEREON ERECTED a dwelling numbered 809 N. Arch Street, Mechanicsburg. BEING KNOWN AS: 809 North Arch Street, Mechanicsburg, PA 17055. PROPERTY ID NO.: 18-22-0519- 246. TITLE TO SAID PREMISES IS VESTED IN Christopher A. Toddes, single man, and Maria R. Sprow, single woman as joint tenants with the right of survivorship by deed from Lloyd F. Lamason and Susan L. Lamason, husband and wife dated 09/15/2004 recorded 09/16/2004 in Deed Book 265 Page 1268. 123 ,The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 t4ePatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 10/29/10 ber, 2010 A.D. L- COMMONWEALTH OF PENNSYLVANIA Notmial N Sherrie L Klow, Notary public Lower Paxton TWP•, Dauphin county MY Commission Expkas Nov. 26, 2011 Member, PennsVlvania Association of Notaries 2I10.2904 Civil Term PNC mortgage, a Division of PUC Book National Association Vs Christopher A. Toddes Maria R. Sprow Atty: Mark J Ndren ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MECHANICSBURG, CUMBERLAND COUNTY. PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOW, TO WIT: BEGINNING AT A POINT ON THE WESTERN LINE OF ARCH STREET WHICH POINT IS ALSO AT THE DIVISION LINE BETWEEN LOTS 13 AND 14, BLOCK C ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE NORTH 78 DEGREES OO MINUTES WEST 113.35 FEET TO A POINT, THENCE NORTH 12 DEGREES 00 MINUTES EAST 65 FEET TO A POINT AT THE DIVISION LINE OF LOTS 12 AND 13 14EREINAFITR MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVISION LINE SOUTH 78 DEGREES 00 MINUTES BAST 113.35 FEET TO A POINT ON THE WESTERN LINE OF ARCH STREET; THENCE SOUTH 12 DEGREES (N1 MINUTES, *-EST 65 FEET 'TO THE POINT AND PLACE OF BEGINNING. BEING LOT NO. 13, BLOCK G ON THE F[NAL PLAN OF PARTS OF BLOCKS A, C, D, E, F, G AND B WYNNEWOOD PARK, AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN ?LAN BOOK 27, PAGE M HAVING THEREON ERECTED A DWELLING NUMBERED 809 N. ARCH STREET, MECHANICSBURG. BEING KNOWN AS: 809 North Arch Street, Mechanicsburg, PA 1.7055 PROPERTY ID NO.! 18.22.0519-246 TITLE TO SAID PREMISES IS VESTED IN CHRISTOPHER A TODDES, SINGLE MAN, AND MARIA R. SPROW, SINGLE WOMAN' AS JOINT TENANTS WITH THE RIGHT OF SURVIVORSHIP BY DEED FROM LLOYD F I.kMASON AND SUSAN L. LAMASON, HUSBAND AND WIFE DATED 09115004 RECORDED 09IIfi(1V004 IN DEED BOOK 265 PAGE 1268. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which PNC; Mortgage is the grantee the same having been sold to said grantee on the 4 day of May A.D., 2011, under and by virtue of a writ Execution issued on the 13 day of Jam, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 2904, at the suit of PNC Mortgage against Christopher A Toddes & Maria Sprow is duly recorded as Instrument Number 201117749. IN TESTIMONY WHEREOF, I have herqunto set my hand - ands Llof said office this 2 ? day of ? girder of Deeds of OF^ O nbedtd 0=4 CerAele, PA nissi Expires to Frst Monday of Jan. 2014