HomeMy WebLinkAbout10-2979UDREN 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
LiA AM 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
Plaintiff
V.
Debra L. Blosnich
County
1077-8 Lancaster Boulevard € NO. Ip -019`19
Mechanicsburg, PA 17055
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
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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.
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
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
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O 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.
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. 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: 1077-8 Lancaster Boulevard
MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Upper Allen
COUNTY: Cumberland
DATE EXECUTED: 07/15/05
DATE RECORDED: 07/28/05 BOOK: 1916 PAGE: 1847
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
04/24/10:
Principal of debt due $82,643.21
Unpaid Interest at 5.125%
from 06/01/09 to 04/24/10
(the per diem interest accruing on
this debt is $11.60 and that sum
should be added each day after 04/24/10) 3,796.49
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $156.29 and that sum should
be added on the first of each
month after 04/24/10) 723.80
Late Charges
(monthly late charge of $23.92
should be added in accordance
with the terms of the note
each month after 04/24/10) 215.28
Attorneys Fees (anticipated and actual
to 50 of principal) 4,132.16
TOTAL $92,115.94
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 $92,115.94 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 Pla ntiff
MARK J. UDREN,•E QUIRE
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
Apr-27-2010 03:42pm From-
EXHIBIT A
LEGAL. DESCRIPTION
Apr 27 2016 03,46pm 1`0091042
7-815 P.000/025 F-945
ALL THAT CERTAIN dwelling unit situate in Sunguld Condominium, Upper Allen Township,
Cumberland County, Pennsylvania, designated as Unit No. 1077-8 in the Declaration and Declaration
of Plans of Sunguiki Condominium dated December 6, 1979, and November 29, 1979, respectively,
recorded December 12, 1979, In Cumberland County, Pennsylvania, Miscellaneous Book 249, Page
784 and Plan Hook 37, Page 23, respectively and Amendment to the Declaration and Declaration plans
of Sunguild Condominium both dated February 28, 1986, both recorded March 31, 1986, in
Cumberland County, Pennsylvania, Miscellaneous Book 815, Page 804, and Plan Boole 40, Page 129,
respectively under the provisions of the Unit Property Act of the Commonwealth of Pennsylvania (Act of
July 3, 1963, P.L. No, 196).
TOGETHER with all right of title and interest of, in and to the Common Elements as more fully set forth
In the aforesaid Declaration of Condominium and Declaration Plans, as amended from time to time.
The Grantee, for and on behalf of the Grantee and the Grantee's heirs, personal representatives,
ar inrpgSars and as2ign¢, by tho ooooptanae elf this dae d. wvai iar ds and agrees to pay sum onarges for
the maintenance of, repairs to, replacement of, and expenses; in connection with the Common
Elements as may be assessed from time to time by the Executive Board in accordarx a with the Unit
Property Act of Pennsylvania; and further covenants and agrees that the Unit conveyed by this deed
shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and
706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid
assessments, this covenant shall run with and bind the land or unit hereby conveyed and all
subsequent owners thereof.
The Grantee, for and on behalf of the Grantee and the Grantee's heirs, personal representatives,
successors and assigns, by acceptance of this deed, acknowledges that this conveyance is subject in
every respect to the Declaration, the Declaration Plans, Code of Regulations and all amendments
thereto, and the Grantee further acknowledges that each and every provision of the fbragoing is
essential to the best Interest and for the benefit of all unit owners therein. Grantee and all owners of
units in said Condominium covenant and agree, as a covenant running with the land, to abide by each
and every provision of said documents.
BEING KNOWN and municipally numbered as 1477-8 Lancaster Boulevard, Mechanicsburg,
Pennsylvania 17055.
BEING THE SAME PREMISES which Gary D. Donmoyer, by deed da + ? , 20015 and
intended to be recorded simultaneously herewith in the Office of the Fee
47-55
or eedsc of Cumberland
County, granted and conveyed unto Debra L BIWAIch, Mortgagor herein.
BK1916FG1863
14r2712010 3'05:07 PM CUMBERLAND COUNTY In6L# 2005271 W - Page 17 or 20
DATE: March 19, 2010
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 explains 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 erving your County
are listed at the end of this Notice If you have any questions Xou may call the Pennsylvania Housing
Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact
an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICAC16N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
EXHIBIT A
HOMEOWNER'S NAME(S): BLOSNICH,DEBRA L
PROPERTY ADDRESS: 1077 -8 LANCASTER BL
LOAN ACCT. NO.: 0004092648
ORIGINAL LENDER: n/a
CURRENT LENDER/SERVICER: PNC
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face'hieeting 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
DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS
HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in
which the pr p is locatedare set forth at the end of this Notice. It is only necessaryto schedule one face-to-face meeting.
Advise your lenderimmedi.atelvof your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance fi-om the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sigh and
file a completed I]:omeowner'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
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED
FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTIONCALLED
"TEMPORARYSTAYOF 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 IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL
BE STOPPED.
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 Agencyhas sixty (60) days to make a decisionafter it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,
THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD
NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on
your property located at:
1077 -8 LANCASTER BL
MECHANICSBURG PA 17055
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s)
July 01, 2009 to March 01, 2010 and the following
amount (s) are now past due:
Monthly Payments 634.76
Corporate Fees 0.00
Late Charges 191.36
Non-Sufficient Funds .00
Fax Fees .00
Property Inspection Fees 72.00
Less Suspense Balance _00
Total Amount Past Due $5,984.51
HOPI TO CURE THE DEFAULT - You may cure the default within thirty (30) days
of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
LENDER, WHICH IS $5,984.51, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD-
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PNC Mortgage
Collections Center
3232 Newmark Dr
Miamisburg, OH 45432
This is an attempt to collect a debt, any information obtained will be
used for that purpose-
Enclosure
DR672
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the
date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the
entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. If full payment of the total amount past due is not made within. THIRTY (30)
DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose ugon 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 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 attomey'sfees 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 nay 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 THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default
foreclosure sale and any other costs connected with the 5herttt s date as spectnea in writing oy Lne tenuui auu uy
nerformine 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 Sheriffs Sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required
payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER :
Name of Lender PNC Mortgage
Address: 3232 Newmark Dr.
Fax Number: 937-9104009
Contact Person: Collections Center
E-Mail Address: oss. i iga ion a,pnemortgage.com
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 (CHECK 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.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
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.
UDRENL/AAW OFFICES, P . C?
BY:
Attorneys for Plai iff
MARK J. UDREN, ES RE
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
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. ::COURT OF COMMON PLEAS
3232 Newmark Drive :CIVIL DIVISION
Miamisburg, OH 45342 Cumberland County
Plaintiff o
t-j
Debra L. Blosnich
1077-8 Lancaster Boulevard ENO. 10-2979 r--= N '
Mechanicsburg, PA 17055 C .p
Defendant (s) 31C`?t
ca rn
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 -° ca
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 A., 20 0
2k
UDREN LAW- GFFIC'k5 - p . C . _ .
Attorneys for a €f
Alan M. Minato, Esquire
PA ID 75860
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.
:MORTGAGE FORECLOSURE
Debra L. Blosnich :NO. 10-2979
Defendant(s)
AMENDED 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:
1077-8 Lancaster Boulevard, Mechanicsburg, PA 17055
1. Name and address of owner(s) or reputed Owner(s):
Name Address
Debra L. Blosnich
1077-8 Lancaster Boulevard
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.
1 Courthouse Square
Carlisle, PA 17013
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 Courthouse Square
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
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Sunguild Condo Association
638 Geneva Drive
Mechanicsburg, PA 17055-0
593-11 Geneva Drive
Mechanicsburg, PA 17055
126 South Main Street
P.O. Box 767
Bel Air, MD 21014
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: November ti, 2010
UDREN ?C,
Atto ain iff
Alan M. Minato, Esquire
PA ID 75860
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.
Debra L. Blosnich
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-2979
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S): Debra L. Blosnich
PROPERTY: 1077-8 Lancaster Boulevard, 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 10:00 a.m., 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.
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MARK J. UDREN, ESQUIRE
NJ MANAGING ATTORNEY
TINA MARIE RICH
OFFICE ADMINISTRATOR
UDREN LA W OFFICES, AC.
WOODCREST CORPORATE CENTER
III WOODCREST ROAD
SUITE 200
CHERRYHILL, NEW JERSEY 08003-3620
856. 669. 5400
rAA:
FREDDIE MAC
PEAWSYLVANL4
DESIGNATED COUNSEL
November 16, 2010
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.
Debra L. Blosnich
Cumberland County C.C.P. No. 10-2979
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
/dad
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. 10-2979
V.
Debra L. Blosnich
1077-8 Lancaster Boulevard
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 1W, 2010
ZY UDREN LAW ES;..._.P.-."C*..__?
Attorney for Plainti
Alan M. Minato, Esquire
PA ID 75860
f s
pp4?
.. ?!!7' ., ?._ It L ?? :$%_
aervieeofl'roces{ trti
MCNIorigage, i diti ivion of PNC Sank NA, et. al., Ptaintiflt • `- - APS International, Ltd.
vs. ?0. -800-3328'- 171
Debra L. 13ksrlidt, et. A. 1}efsntiattir(s)
t yp> t,,;?R*:?,Ttt??.a1 BPS lrrrr3^narioal:rl Pia.-.a
'_ 8?Q lrnros t d.
Minneapolis. 11'45433-3122
AP S File*: 111-35- taut
AFFIDAVIT OF SERVICE -- Individual
St, ice of Process ow
VDR LAV, f 171C"ES --Debra L. Blosnich
Ms. Danielle 1)e%ti I Court i as(- Via. 10-2979
773 W oodcreh;t Rd„ Site. 200
Cherrv Hilt. NJ 09003-3620
i
State of _ s 1
l
`?ante of Sen er: undersi-o e . herzw duly swam. deposa:5 and says
that at the time of service. -lr?, wa- of legal age and was not hart}y to {hi .rcttcll,
Date/Time of Service: that on the _/__,day of ' s. 20 t , at 0" }oc M
Place of Service: at 7 tl- g r anr:ccter Rh d -In Mechanksburg, PA 17055
Document; Served: the undersiEnr d .,;::ncd the document, descrily-d as.
\ otice of SheriWs We of Real Property
Serf=ice of Process on: A trite and correct copy of the aforesaid document(s) was served on:
Debra I.. Blosnich
Person Served, and
t I eper cnlaltv cct3vcMethod of Service: ln€ them into the hands of the person to be served-
Bv delis ;in = t11cm ullo tnc hands of a person
of ?uittrl)l< ave. who , c:nl3eci. orwho upon qu4?,tinni tS stated, thatheislte. resides with
Dehr€I L. Blosnich
at the place of service, and whose relationship to th. person is:
0(:.,,criptton otPerson Alic p onr ceiving docurricnts is described as fidlos t,
Receiving Documents: Sep' Shin Color hair f _nlruFacial Blair
` prox. ASt Lj?l?ro>: rlci+ }tt } '? rprta . ? `s~i llt ?` r' 5
ti
tllc l st of m? knowledge and b41cf. said person t,asgaged in th LS 'liiitar at
the tirrrc ol Ss .:n e?.
Signature of Server. €..+ndv i ,n,,;J i ac:lares wider penalty ofpmur4 ' yut?- ed and stern io 1) 1,C)r me this
that th_k?rcgtairtp strut. correct- 'i t;Lav of
} r - ? f ? ? 14 L..?
`'?rr7_.. _., - i ` !`Ut ?i4? ?i,,,f ?`7" •T??'I .?U E_
?r
,U'S InternatioMl. Ltd.
D1r ?^a' Saa
i
UDREN LAW OFFICES, P.C.
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.
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
V.
Debra L. Blosnich
Defendant(s) NO. 10-2979
PETITION FOR POSTPONEMENT OF SHERIFF'S SALE
?."
r*?
Gam"' ? ??
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-G
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 1077-8 Lancaster Boulevard,Mechanicsburg, PA
17055 was originally scheduled for December 8, 2010, then
postponed to January 5, 2011 due to Plaintiff's temporary
moratorium on sheriff sales, then postponed to April 6, 2011.
2. The Plaintiff seeks the postponement of the Sheriff 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
June 1, 2011 Sheriff's sale.
Respectfully submitted,
UDREN LAW OFFICES, P.C.
BY:
NathaK(S,,,*6lf, Esquire
Local Counsel
Alan M. Minato, Esquire
PA ID 75860
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 :COURT OF COMMON PLEAS
PNC Bank, N.A. ':CIVIL DIVISION
Plaintiff :Cumberland County
V.
Debra L. Blosnich
Defendant (s) € NO. 10-2979
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 in order 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 1077-8 Lancaster Boulevard, Mechanicsburg,
PA 17055, to the June 1, 2011 Sheriff's sale as set forth in the
Motion.
Respectfully submitted,
Nathan C. lf, Esquire
Local Co sel
UDREN LAW OFFICES, P.C.
Bic Ww?^>
Attorney"-fc?r- - iff
Awn M. Miflaly, _:)ti.4UII L
PA ID 75860
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.
Debra L. Blosnich
Defendant(s) =NO. 10-2979
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: April 5, 2011
TO: Debra L. Blosnich
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
athan W f, Esquire
Local Counsel
UDREN LAW OFFICES, P.C.
ey or PI-a3-nT-jf f
Alan M. MinatO, Esquire
PA ID 75860
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL DIVISION
PNC Mortgage, a division of
PNC Bank, N.A. e
Plaintiff
rrt
v. NO. 10-2979 rri
?
Debra L. Blosnich
Defendant(s)'
• co
O R D E R`
C-Ij
xa
Cn
a.
co
AND NOW, this day of April, 2011, after
consideration of Plaintiff's Petition for Postponement of
Sheriff's Sale of the mortgaged property located at 1077-8
Lancaster Boulevard, Mechanicsburg, PA 17055, it is hereby
ORDERED that the said Sale currently scheduled for April 6, 2011,
is extended (2) two month(s) to the regularly scheduled
Cumberland County Sheriff's Sale scheduled for June 1, 2011. No
further advertising or additional notice to lienholders or
Defendant(s) is required provided the postponement is announced
at the April 6, 2011 Sheriff's Sale.
TO: Debra L. Blosnich
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Udren Law Offices, P.C.
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Attn: Sale Department
BY THE COURT:
J.
PA j
't
0r
Office of the Sheriff - by
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17103-3387
Z
rn
?Q
C) ,
co
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 C:
CHERRY HILL, NJ 08003-3620 -u3
856-669-5400, pleadings@udren.com ? rn
PNC Mortgage, a division of :COURT OF COMMON PLEAS N ::0p
PNC Bank, N.A. CIVIL DIVISION -4'
Plaintiff Cumberland County '1a
Debra L. Blosnich -
Defendant(s) 'NO. 10-2979
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 1077-8 Lancaster Boulevard,Mechanicsburg, PA
17055 was originally scheduled for December 8, 2010, then
postponed to January 5, 2011-due-to Plaintif-f's temporary
moratorium on sheriff sales, then postponed to April 6, 2011,
then postponed to June 1, 2011 to further complete mortgage loan
account review.
2. The Plaintiff seeks the postponement of the Sheriff sale
(2) two month(s) to allow time to assess the possibility of
loss mitigation.
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. The Honorable M.L. Ebert, Jr., was assigned to this
matter and granted Plaintiff's order to Postpone Sheriff's sale
to June 1, 2011..
WHEREFORE, Plaintiff respectfully prays and requests that
the Sheriff's sale of the mortgaged property be postponed to the
August 3, 2011 Sheriff's sale.
Respectfully submitted,
UDREN LAW OFFICES, P.C.
BY:
Nathan lf, Esquire Attorney -for--Plaintiff
Local o sel
Alan M. Minato, Esquire
PA ID 75860
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.
Debra L. Blosnich
Defendant (s) NO. 10-2979
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 assess the possibility of loss
mitigation.
Therefore, in order for the Plaintiff to be able to properly
conduct itself at the Sheriff's._sale,..,,.,,a postponement of the sake..
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 1077-8 Lancaster Boulevard, Mechanicsburg,
PA 17055, to the August 3, 2011 Sheriff's sale as set forth in
the Motion.
Respectfully submitted,
UDREN LAW OFFICES, P.C.
BY:
N C. if Esquire At r?p° Plaintiff
ocal Coun e
Alan M. Minato, Esquire
PA ID 75860
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.
Debra L. Blosnich
Defendant(s) :NO. 10-2979
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: May 27, 2011
......................................... .
...............
TO: Debra L. Blosnich
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Nathan C W lf, Esquire
Local C sel
UDREN LAW OFFICES, P.C.
r_..,
BY:
Attorney fof--P7'aintiff
Alan M. Minata, Esquire
pr-PF0
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
Ill WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
'._
856-669-5400, pleadings@udren.com c_ C -?
PNC Mortgage, a division of :COURT OF COMMON PLEAS mar=
PNC Bank, N.A. CIVIL DIVISION r- ? ?C
Plaintiff ;Cumberland County N
v.
Debra L
Blosnich <c
=
-s
.
Defendant(s) NO. 10-2979 c
PETITION FOR POSTPONEMENT OF SHERIFF'S SALE
Plaintiff, by its counsel, petitions the Court for a (3)
three 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 1077-8 Lancaster Boulevard,Mechanicsburg, PA
17055 was originally scheduled for December 8, 2010, then
postponed to January 5, 2011 due to Plaintiff's temporary
moratorium on sheriff sales, then postponed to Apri'` 6, 2011,
then postponed to June 1, 2011 to further complete mortgage loan
account review, then postponed to August 3, 2011.
2. The Plaintiff seeks the postponement of the Sheriff sale
(3) three month(s) to allow time to assess the possibility of
loss mitigation.
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. The Honorable M.L. Ebert, Jr., was assigned to this
matter and granted Plaintiff's order to Postpone Sheriff's sale
to June 1, 2011 and then to August 3, 2011.
WHEREFORE, Plaintiff respectfully prays and requests that
the Sheriff's sale of the mortgaged property be postponed to the
November 2, 2011 Sheriff's sale.
Y'
athan C. f, Esquire
Local Co sei
Respectfully submitted,
UDREN LAW OFFICES, P.C.
_-__._._ ..._...__.._ _,_W
r
BY
.............. .
Attorney for Plaint if f
-%ian M. Minato, Esquire
PA ID 75860
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
112 WOODCREST ROAD, SUITE 200
CHERRY HILL, N3 08003-3620
856-669-5403, pleadingsoudren.com
PNC Mortgage, a division of - COURT OF COMMON PLEAS
PNC Bank, N.A. CIVIL DIVISION
Plaintiff =Cumberland County
v.
Debra L. Blosnich
Defendant(s) NO. 10-2979
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 assess the possibility of loss
mitigation.
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 1077-8 Lancaster Boulevard, Mechanicsburg,
PA 17055, to the November 2, 2011 Sheriff's sale as set forth in
the Motion.
Respectfully submitted,
Natha C Wolf, Esquire
Local ounsel
UDREN LAW OFFICES, P.C.
Attorney---for..._.P, aintiff
Aian M. Minato, Esquire
PA In 75860
I.
or gage, a division of :COURT OF COMMON PLEAS
PNC Bank, N.A. CIVIL DIVISION
Plaintiff :Cumberland County
V.
Debra L. Blosnich
Defendant(s) NO. 10-2979
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREOT ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-540p, pleadings@udren.com
PNC M t
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: August 2, 2011
TO: Debra L. Blosnich
1077-8 'Lancaster Boulevard
Mechanicsburg, PA 17055
UDREN LAL?.OF.FIGES_,_ C.
Nathan C--W f, 'Esquire
Local Cou
ii,
Attorney for'PlIa-int-i-ft
Alan M. Minato, Esquire
PA U)
, 011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL DIVISION
PNC Mortgage, a division of r-a
PNC Bank, N.A. r _
Plaintiff ,-n co
-=m = M--
v. NO. 10-2979 -Z:::o
Debra L. Blosnich 3> i <<?n
N fi
Defendant(s) ?
O R D E R
AND NOW, this k) j day of August, 2011, after
consideration of Plaintiff's Petition for Postponement of
Sheriff's Sale of the mortgaged property located at 1077-8
Lancaster Boulevard, Mechanicsburg, PA 17055, it is hereby
ORDERED that the said Sale currently scheduled for August 3,
2011, is extended (3) three month(s) to the regularly scheduled
Cumberland County Sheriff's Sale scheduled for November 2, 2011.
No further advertising or additional notice to lienholders or
Defendant(s) is required provided the postponement is announced
at the August 3, 2011 Sheriff's Sale.
TO: /Debra L. Blosnich
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Udren Law Offices, P.C.
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Attn: Sale Department
Office of the Sheriff
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17103-3387
BY THE COURT :
`%
M.L. EBERT, JR
CT i %rlj'
0Ka
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
011011, 01 Cd1111(lpp11,44
P ED-OFFiCE
CF TI-IE r"R0 TH0;4'0TAR
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
L RIFF
2011 DEC 29 PM 3: 18
CUMBERLAND COUNTY
PENNSYLVANIA
PNC Mortgage
vs.
Debra L. Blosnich
Case Number
2010-2979
SHERIFF'S RETURN OF SERVICE
10/12/2010 05:30 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
10-12-10 at 1730 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and
Description, in the above entitled action, upon the property of Debra L. Blosnich, located at, 1077-8
Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania according to law.
10/21/2010 05:37 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at
1737 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Debra L. Blosnich, by making known unto, Debra
L. Blosnich, personally, at, 1077-8 Lancaster Boulevard, Mechanicsburg, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of
the same.
12/01/2010 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011
12/06/2010 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011
04/06/2011 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/1/2011
05/31/2011 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/3/2011
08/02/2011 As directed by Alan M Minato, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/2/2011
11/02/2011 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 November 02, 2011 at
10:00 AM. He sold the same for the sum of $1.00 to Attorney Alan Minato, on behalf Federal Home Loan
Mortgage Corporation, 8000 Jones Branch Drive, MSTP 202, MClean, VA 22102, being the buyer in this
execution, paid to the Sheriff the sum of $
SHERIFF COST: $952.48 SO ANSWERS,
November 18, 2011 RON R ANDERSON, SHERIFF
li? oo r?'
60
,'.c; COLVITVSUIe She'ff Te! o o't. Inc ??
f
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
Debra L. Blosnich :NO. 10-2979
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:
1077-8 Lancaster Boulevard, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
Debra L. Blosnich 1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS 41 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
on the property:
Name
NONE
Address
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
1 Courthouse Square
Carlisle, PA 17013
1 Courthouse Square
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
Sunguild Condo Association
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Address to Follow
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: August 7, 2010
UDREN CES, P.
B
A e s for Plaintiff
MARK J. UDRE , E
S TUART-W1NNE , -' ,
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
every other person who has any record lien
n
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
Debra L. Blosnich NO. 10-2979
Defendant (s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Debra L. Blosnich
1077-8 Lancaster Boulevard
Mechanicsburg, PA 17055
Your house (real estate) at 1077-8 Lancaster Boulevard,
Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's
Sale on December 8, 2010, at 10:00 a.m. in the Commissioners
Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the
court judgment of $93,984.46, 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 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 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 CERTAJN dwelling unit situate in Sunguild Condominium, Upper Allen Township,
Cumberland County, Pennsylvania, designated as Unit No. 1077-8 in the Declaration and Declaration
of Plans of Sunguild Condominium dated December 6, 1979, and November 29, 1979, respectively,
recorded December 12, 1979, in Cumberland County, Pennsylvania, Miscellaneous Book 249, Page
784 and Plan Book 37, Page 23, respectively and Amendment to the Declaration and Declaration plans
of Sunguild Condominium both dated February 28, 1986, both recorded March 31, 1986, in
Cumberland County, Pennsylvania, Miscellaneous Book 315, Page 804, and Plan Book 49, Page 129,
respectively under the provisions of the Unit Property Act of the Commonwealth of Pennsylvania (Act of
July 3, 1963, P.L. No. 196).
TOGETHER with all right of title and interest of, in and to the Common Elements as more fully set forth
in the aforesaid Declaration of Condominium and Declaration plans, as amended from time to time.
The Grantee, for and on behalf of the Grantee and the Grantee's heirs, personal representatives,
. .t-ssnrs and assigne, by tho ooooptanee of this da641, a wvw nsi ila and agrees to pay such charges for
the maintenance of, repairs to, replacement of, and expenses in connection with the Common
Elements as may be assessed from time to time by the Executive Board in accordance with the Unit
Property Act of Pennsylvania; and further covenants and agrees that the Unit conveyed by this deed
shall be subject to a charge for all amounts so assessed and that, except insofar as Sections 705 and
706 of said Unit Property Act may relieve a subsequent unit owner of liability for prior unpaid
assessments, this covenant shall run with and bind the land or unit hereby conveyed and all
subsequent owners thereof.
The Grantee, for and on behalf of the Grantee and the Grantee's heirs, personal representatives,
successors and assigns, by acceptance of this deed, acknowledges that this conveyance is subject in
every respect to the Declaration, the Declaration Plans, Code of Regulations and all amendments
thereto, and the Grantee further acknowledges that each and every provision of the foregoing is
essential to the best interest and for the benefit of all unit owners therein. Grantee and all owners of
units in said Condominium covenant and agree, as a covenant running with the land, to abide by each
and every provision of said documents.
BEING KNOWN and municipally numbered as 1077-8 Lancaster Boulevard, Mechanicsburg,
Pennsylvania 17055.
BRING THE SAME PREMISES which Gary D. Donmoyer, by deed datelL 2005 and
intended to be recorded simultaneously herewith in the Office of the Rec der eeds of Cumberland
County, granted and conveyed unto Debra L. Siosnich, Mortgagor herein.
BEING KNOWN AS: 1077-8 LANCASTER BOULEVARD
MECHANICSBURG, PA 17055
PROPERTY ID NO.: 42-24-0792-041A-U107708
TITLE TO SAID PREMISES IS VESTED IN DEBRA L. BLOSNICH, SINGLE WOMAN
BY DEED FROM GARY D. DONMOYER, SINGLE MAN DATED 7/15/05 RECORDED
7/28/05 IN DEED BOOK 270 PAGE 540.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 10-2979 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC MORTGAGE, a division of PNC BANK, NA,
Plaintiff (s)
From DEBRA L. BLOSNICH
(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 $93,984.46 L.L. $.50
Interest from 8/4/10 to 12/8/10 ongoing per diem $11.60 to actual date of sale including if sale is held
at a later date -- $1,473.20
Atty's Comm % Due Prothy $2.00
Atty Paid $169.50
Plaintiff Paid
Other Costs
Date: 8/10/10
(Seal)
Deputy
REQUESTING PARTY:
Name: ALAN M. MINATO, ESQUIRE
Address: UDREN LAW OFFICES, PC
WOODCREST CORPORATE CENTER
I l l WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 75860
On September 22, 20 10 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Cumberland County, PA,
Known and numbered as, 1077-8 Lancaster Boulevard,
Mechanicsburg, more fully described on Exhibit "A" filed with this
writ and by this reference incorporated herein.
Date: September 22, 2010
B:
.to
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.
0 isa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
5 da of November, 201
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH. CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
CUMBERLAND LAW JOURNAL
Writ No. 2010-2979 Civil
PNC Mortgage, A Division
of PNC Bank, N.A.
vs.
Debra L. Blosnich
Atty.: Alan M. Minato
ALL THAT CERTAIN dwelling unit
situate in Sunguild Condominium,
Upper Allen Township, Cumberland
County, Pennsylvania, designated as
Unit No. 1077-8 in the declaration
and declaration plans of Sunguild
Condominium, dated December 6,
1979, and November 29, 1979, re-
spectively, recorded December 17,
1979, in Cumberland County, Penn-
sylvania, in Miscellaneous Book 249,
Page 784, and Plan Book 37, Page 23,
respectively, and amendment to the
declaration and declaration plans of
Sunguild Condominium, both dated
February 28, 1986, both recorded
March 31, 1986, in Cumberland
County, Pennsylvania, in Miscel-
laneous Book 315, Page 804, and
Plan Book 49, Page 129, respectively,
under the provisions of the Unit
Property Act of the Commonwealth
of Pennsylvania (Act of July 3, 1963,
P.L. No. 196).
TOGETHER with all rights of
title and interest of, in, and to the
common elements as more fully set
forth in the aforesaid declaration of
condominium and declaration plans,
as amended from time to time.
BEING KNOWN AND NUMBERED
AS 1077-8 LANCASTER BOULE-
VARD, MECHANICSBURG, PENN-
SYLVANIA.
11
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
Zhe;patr?ot News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 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:
10/15110
10/22/10
_ 10/29/10
Sworn to and,,: ibs ribed before me this 1Q dayq?ovember, 2010 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NotarW N
Sherrie L KiwW Notan, PuU c
Lower Paxton 7yvp„ Dauphin Coon
My Comma eoms Nov. 26, 2011
Member, °e1n1Yivan1a Association of Notaries
2010•2879 COU Term
ONC Mo#Vego, A Dhftlon of
PNC Bunk, N.A.
Vs
Debra L. Blosnich
Atty. Alan M Mnato
ALL THAT CERTAIN DWELLING
UNIT SITUATE IN SUNGUILD
CONDOMINIUM, UPPER. :ALLEN
TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, DESIGNATED AS
vNIT NO. 1077-8 IN THE DECLARATION
AND DECLARATION PLANS OF
SUGUILD CONDOMINIUM, DATED
DECEMBER 6, 1979, AND NOVEMBER.
29, 1979, RESPECTIVELY, RECORDED
DECEMBER 17, 1979, IN CUMBERLAND
COUNTY, PENNSYLVANIA, IN
MISCELLANEOUS BOOK 249, PAGE
784, AND PLAN BOOK 37, PAGE 23,
RESPECTIVELY, AND AMENDMENT
1'O THE DECLARATION AND
DECLARATION PLANS OF SUNGUILD
CONDOMINIUM, BOTH DATED
FEBRUARY 28, 1986, BOTH RECORDED
MARCH 31, 1986, IN CUMBERLAND
COUNTY, PENNSYLVANIA, IN
MISCELLANEOUS BOOK 315, PAGE
84 AND PLAN BOOK 49, PAGE
129, RESPEMVELY, UNDER THE
PROVISIONS OF THE UNIT PROPERTY
ACT OF THE COMMONWEALTH OF
PENNSYLVANIA (ACT OF JULY 3, 1963,
P.L. NO. 196).
TOGETHER WITH ALL RIGHTS OF
ME AND INTEREST OF IN, AND TO
THE COMMON ELEMENTS AS MORE
FULLY SET FORTH IN THE AFORESAID
DECLARATION OF CONDOMINIUM
AND DECLARATION PLANS, AS
AMENDED FROM TIME TO TIME.
BEING KNOWN AND NUMBERED
AS 1077-8 LANCASTER BOULEVARD,
MECHANI£SBURG, PENNSYLVANIA.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal Home Loan Mortgage Corporation is the grantee the same having
been sold to said grantee on the 2 day of November A.D., 2011, under and by virtue of a writ Execution
issued on the 10 day of August, A.D., 2010, out of the Court of Common Pleas of said County as of
Civil Term, 2010 Number 2979, at the suit of PNC Mortgage against Debra L. Blosnich is duly recorded
as Instrument Number 201136332.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D. _,2_0,?Z_
of Deeds
ReoW& d Daods, Ora ftW C=*% 0WW PA
DIY WMWM EVkWtoFWMWft Of Jan.2M4