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HomeMy WebLinkAbout10-3026UDREN 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. SIMONI, ESQUIRE - ID #200869 t- MADAM 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 ATTORNEY FOR PLAINTIFF n _,2 cz, -? PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive Miamisburg, OH 45342 '=.Cumberlanc Plaintiff V. Brian M. Heller County Jennifer N. Heller NO. 10 - 13W(o 107 West High Street Room 213 Carlisle, PA 17013 Defendant(s) Civi 1 er*t COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL -*ga.oo PA AT7q e 150-781 O ayl7aa SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 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 provisioner 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. Cumberland County Bar Association 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: 1875 Douglas Drive MUNICIPALITY/TOWNSHIP/BOROUGH: North Middleton Township COUNTY: Cumberland DATE EXECUTED: 9/28/05 DATE RECORDED: 9/30/05 BOOK: 1925 PAGE: 598 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 4/27/10: Principal of debt due $102,749.12 Unpaid Interest at 6.250 from 6/1/09 to 4/27/10 (the per diem interest accruing on this debt is $17.59 and that sum should be added each day after 4/27/10) 5,808.95 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $181.26 and that sum should be added on the first of each month after 4/27/10) 659.96 Late Charges (monthly late charge of $29.31 should be added in accordance with the terms of the note each month after 4/27/10) 339.24 Attorneys Fees (anticipated and actual to 5°s of principal) 5,137.49 TOTAL $115,299.76 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 $115,299.76 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: I 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 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. $ND$0004343259DR67103-19-10 March 19, 2010 Jennifer N Heller 102 W High St 1 Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan No. 0004343259 Current lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 1875 Douglas Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) July 01, 2009 and the following amount(s) are now past due: Monthly Payments 6,953.82 Corporate Fees -2,223.11 Late Charges 309.93 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 72.00 Less Suspense Balance .00- Total Amou 7,335.75 HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 7,335.75, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, 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: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 EXHIBIT A Enclosure (F) DR671 052 LWC This is an attempt to collect a debt, any information obtained will be used for that purpose. @ND@ 41 $ND$0004343259DR67003-19-10 March 19, 2010 Brian M Heller 102 W High St 1 Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan Number: 0004343259 Current Lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 1875 Douglas Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) July 01, 2009 and the following amount(s) are now past due: Monthly Payments 6,953.82 Corporate Fees -2,223.11 Late Charges 309.93 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 72.00 Less Suspense Balance .00- Total Amount Past Due $ 7,335.75 HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 7,335.75, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash ul I wi Bey uruer maae payable and sent to: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR670 082 LWC This is an attempt to collect a debt. Any information obtained will be used for that purpose. @ND@ 41 $ND$0004343259DR67303-19-10 March 19, 2010 Jennifer N Heller 1875 Douglas Dr Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan Number: 0004343259 Current Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 1875 Douglas Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) July 01, 2009 and the following amount(s) are now past due: Monthly Payments 6,953.82 Corporate Fees -2,223.11 Late Charges 309.93 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 72.00 Less Suspense Balance .00- Total Amou 7,335.75 HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 7,335.75, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER, WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, cash Ivy U1 UGr rnaue payaoie ana sent to: PNC Mortgage Attn: Collections Center/136-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR673 055 LWC This is an attempt to collect a debt. Any information obtained will be used for that purpose. @ND@ 41 $ND$0004343259DR67203-19-10 March 19, 2010 Brian M Heller 1875 Douglas Dr Carlisle PA 17013 Certified Mail/Return Receipt Requested Loan No. 0004343259 Current Lender/Servicer: PNC Mortgage HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on NATURE OF THE DEFAULT your property located at: 1875 Douglas Dr Carlisle PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s) July 01, 2009 and the following amount(s) are now past due: Monthly Payments 6,953.82 Corporate Fees -2,223.11 Late Charges 309.93 Non-Sufficient Funds .00 Fax Fees .00 Property Inspection Fees 72.00 Less Suspense Balance .00- Total Amou 7,335.75 HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days HOW TO CURE THE DEFAULT of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 7,335.75, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES LENDER 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: PNC Mortgage Attn: Collections Center/B6-YM09-01-1 3232 Newmark Dr. Miamisburg, OH 45342 Enclosure (F) DR672 055 LWC This is an attempt to collect a debt, any information obtained will be used for that purpose. @ND@ 41 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,?AW OFFICES, P.C. BY: ,? Attor eys for P intiff MARK J. UDREN, 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 JUN ~~ 5 ZU~u IN THE CO'QRT OF CONIlZON PLEAS OF CUb~ERLAND COUNTY CIVIL DIVISION PNC Bank Mortgage, a division of PNC Bank NA Plaintiff €NO. 10-3026 v. Brian M. Heller Jennifer N. Heller Defendant (s) // O R D E R AND NOW, this ~~i~~ day of ~'~ c 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Jennifer N. Heller, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular. mail to the last known address of Defendant (s) , Jennifer N. Heller at 102 West High Street Room 213 Carlisle, PA 17013~~el6i. by posting the mortgaged premises _ located at 1875 Douglas Drive Carli le, PA 7 13~ 717 ~ ~~Itc~~tR.~ ~- 1 ~ / c3v? ~ ~ l~ '~ t-7 ~~-.~ S > ~ t ~tR ~i U 2 ~ L11' c ~ ~ L L~j t ~ ~ tir`. ~ c>~ zi r` r C ~ ~ ~~ ~~ ~ S y v ~ t Z BY THE COURT n ~ .~ tom. ~~ q ~ ~ ; 'ii ~' ' _ _.._ - r-z n _ ~ c~~ `~, ~~ ' ~ _c ,~' ~, 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. 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 PNC Bank Mortgage, a division of PNC Bank NA Plaintiff v. Brian M. Heller Jennifer N. Heller Defendant(s) ATTORNEY FOR PLAINTIFF C~ cN~ _; C ~ ca ~~ ~_ ~ ~~ rw ~ ~ ~" r ~ ~~ ~,y ~, ; ~. ; :- ~ t ~, .. ~ i i.: c>;; _< COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: June 23, 2010 UDREN_LA~1~,C~',~'ICES, P.C. B / Attorne or Pla iff MARK J REN, ESQUIRE STUAR W NNEG, ESQUIRE LORRA E DOYLE, ESQUIRE ALAN M. INATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~».a~pd~-~, ~ i 5~~~ R~ a-yy~~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~-LE~ r ~ ,; ;~ ~~t~ptr dC ~tttnb~t.fT~~ '"~~ T:-{~ 1~-?`"t : ' >`.`"~'i~~Y Jody S Smith Chief Deputy ~~ 1 ~ j' 'r,, 20 f 0 JUL ~ ~9' ~S~ 46~ ~ ,~~, Richard W Stewart Solicitor ~ F ice of THE SuE~rFF CUt1 _~~ uMY PNC Mortgage Case Number vs. Brian M. Heller (et al.) 2010-3026 SHERIFF'S RETURN OF SERVICE 06/29/2010 William Cline, Corporal, who being duly sworn according to law, states that on June 29, 2010 at 1315 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer N. Heller, pursuant to order of court by posting the premises located at 1875 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. LLIAM CLINE, DEPU SHERIFF COST: $39.40 June 30, 2010 SO ANSWERS, ~ll~~~~ RON R ANDERSON, SHERIFF (cj CountySuite Sheriff, Teleosoft. Inc. Y UDREN LAW OFFICES, P.C. MARK J. REN, ESQUIRE - ID #04302 STUART WI EG, ESQUIRS - ID #45362 LORRAINE OYLE, ESQUIRS - ID #34576 ALAN M. M NATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. ~IMONI, ESQUIRE - ID #200869 ADAM L. YES, ESQUIRE - ID #86408 MARGUERIT L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODC EST ROAD, SUITE 200 CHERRY HI L, NJ 08003-3620 856-669-5 00, leadin s@udren.com PNC Bank'Mortgage, a division of PNC Bank NA Plaintiff v. Brian M.'Heller Jennifer', N. Heller Defendant (s ) w '-- -r; ~i~ -~; _! ~_ . . •_~ e-r `,~~ ATTORNEY FOR PLAINTIFF n N 0 c._. r° ' r7 --t E COURT OF COMMON PLEAS,-; ~' :CIVIL DIVISION "- Cumberland County `%-~'~ r~r= ~~ -:~ r NO. 10-3026 ~ r== VERIFICATION OF SERVICE BY CERTIFIED MAIL AND ', REGULAR MAIL PURSUANT TO COURT ORDER UDREN ,LAW /~F~~ CES , P . C . B The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter h~ mailed a true and correct copy of the Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular f~.rst class mail, to the last known address of Defendant (s) as follo~nrs DATE MAILED : ~- -~ ~G Jennifer N. Heller 102 West High Street Room 213 Carlisle, PA 17013 I verify ',,that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties] relating to unsworn falsification to authorities. Dated : ~ ~~ ~~ At ~ fd~ Plaintiff MAR RE ESQUIRE STUAR EG, ESQUIRE LORRAI OYLE, ESQUIRE ALAN M. NATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~~ ~ ~ ~- ~~ TT ~..- ~v r r~- ~_ ~-- O Or'' ~ /~ J V f1 J j ~ •.~J T ~~ "~ ~o~~ =ooh n 0 ~~o~ o~Dm -i J rr~ _cn ¢:, r'7 :~ •' ~ +C7 m ~ ~~ .. :~, ~ . ~` ~' ~- .~~~ m~oE~~ ~ ~ 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 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCRSST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff Brian M. Jenni f er 107 West Room 213 Carlisle V. Heller N. Heller High Street PA 17013 Defendant(s) NO. 10-3026 PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: 1. } ?o S Kindly file the attached Proof of Publication with regard to UDREN `/11 \I\ 1 \ BY: the captioned matter. DATE: August 17, 2010 -f Attorneyd D MARK J. U STUART WI LORRAINE YI ALAN M. MI Z CHANDRA M. ADAM L. KAYE.. MARGUERITE L. P. C. I,Hlaintitt - ESQUIRE ESQUIRE ESQUIRE ESQUIRE EMA, ESQUIRE ESQUIRE THOMAS, ESQUIRE A. (610)254-9980 Fax: (610)254-9982 Udren Law Offices, P.C. Attn: Melissa McCully Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 WJM William J. Mansfield, Inc. Legal Advertising Suite 1209 998 Old Eagle School Road Wayne, PA 19087-1805 Your choice for legal adverlrsing Since 1935 In Re: Mortgage Foreclosure PNC vs. HELLER (NO. 10-3026) Service Charge: 20.00 Publications: The Carlisle Sentinel; Carlisle, PA 17013 308.29 Published: 7/19/2010 Cumberland Law Journal; Carlisle, PA 17013 295.00 Published: 7/23/2010 Total Due: $623.29 INVOICE PAYMENT NOT CONTINGENT ON CLIENT REIMBURSEMENT. ALL INVOICES ARE NET 30 DAYS Note: Please return this copy of the bill with your check to insure proper credit. Thank you. UDRENN Invoice#:2010070174 Date: 8/13/2010 T a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz July 23, 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. sa Marie Coyne, 'tor SWORN TO AND SUBSCRIBED before me this 23 day of July. 2010 Notar?y MOTNUAL SEAL ONORAM A COU MB MoWy Pubk CCUMnf OOf{MiIM - t0/4 Y/ EgMa Apr KOZ 'LZ UP S9Jldx3 UOISSIwwo0 AW AlNO ONVil1mno 'Hsnouos 31SIldVO ollgnd AMON NHOON3103H NNV 19WV9 iv3S iviuvioN :sandxa uotssi HMOa XW aggnd AJUION srq} aut azo;aq pagt qns pup of uaotAS an i} we 00 uoppagqnd;o zapejuga pup aaejd'autp o} se 4uautalr4s SuT02aio; alp uT Suopp2ajju pp 4mv pue'4uautaspaanpp JO aapou piusa.xo;p alp;o aa44pul pafgns aqj ui palsaialui ;ou si aqs/aq;pq} sasodap zaq}tn; luuT;;V saAE!)4.l wept/ '!uc w!S 'V slno-l 'ewo> JV T q EJPUe99 L£464Z £LOLL Vd'als!IJeO'laaiK NOIIVIOOSSV dV9 A1Nf 0046-£4Z- £LOLL Vd'aISIIONI S30IAH 319191.13 Ol S301AH3S -IV93l Ij3djo AVW 1VH1 S310t 01 3-19V 39 ),VW 3oldd0 SIHl'H3AMV 1 V 3HIH Ol OH( Nkjo Oll OJ 83AMVl V 3AVOH ION 00 nOA dl 0INO 1V I1 no/ of lueliodwi slg6g a01410 Jo ,(l,ac ;alla,pejalue aq Aew luaw6pnl e pup noA InogUM peeoo d Au 1swe6e gUol les swlelo agl 01 suolioalgo ao sasualap lnoh lint oomuedde ua1111M a 6uuelue /q'paNas aae 00!10N PUe'. . 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BRIAN M. HELLER and JENNIFER N: HELLER, Defendants COMPLAINT IN MORTGAGE FORECLOSURE TO: JENNIFER N. HELLER, Defen- dant, whose last known addresses are 102 West High Street, Room 213, Carlisle, PA 17013 and 1875 Douglas Drive, Carlisle, PA 17013. You are hereby notified that Plaintiff, PNC BANK MORTGAGE, A DIVISION OF PNC BANK NA, has filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of Cumberland County, Penn- sylvania, docketed to NO. 10-3026, wherein Plaintiff seeks to foreclose on the mortgage secured on your prop- erty located, 1875 Douglas Drive, Carlisle, PA 17013, whereupon your property would be sold by the Sheriff of Cumberland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE .SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAW- YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OF- FER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166/(800) 990-9108 MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, EQUIRE ALAN M. MINATO, EQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. Attorneys for Plaintiff 111 Woodcrest Rd. Ste. 200 Cherry Hill, NJ 08003 (856) 669-5400 July 23 , 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 Bank Mortgage, a division of COURT OF COMMON PLEAS PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive €Cumberland County Miamisburg, OH 45342 Plaintiff :MORTGAGE FORECLOSURE V. Brian M. Heller :NO. 10-3026 Jennifer N. Heller 107 West High Street Room 213 Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: ?Y}i :S?L ;'? J. V'i. f??. ?:?i 1.l Ei P,• 2U cull COUNW Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Brian M. Heller and Jennifer N. Heller 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 $115,299.76 Interest Per Complaint 2,163.57 From 04/28/2010 to 08/28/2010 Late charges per Complaint 117.24 From 04/28/2010 to 08/28/2010 Escrow payment per Complaint 725.04 From 04/28/2010 to 08/28/2010 TOTAL $118,305.61 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. UDR NW FFI S, C. BY: Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ? oo P LORRAINE DOYLE, ESQUIRE C ALAN M. MINATO, ESQUIRE gg8., CHANDRA M. ARKEMA, ESQUIRE _-n"/ DAMAGES ARE HEREBY ASSESSED AS INDI DATE : $/,30//0 PRO 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 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive Miamisburg, OH 45342 =Cumberland County Plaintiff V. Brian M. Heller C0 Jennifer N. Heller € NO. 1O _3bP(0 ?tvi !ems 107 West High Street Room 213 Carlisle, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff lit Cixurb'V 44 Jody S Smith Chief Deputyx Richard W Stewart Solicitor OF-ME r TM srOMFF PNC Mortgage Case Number vs. 2010-3026 Brian M. Heller (et al.) SHERIFF'S RETURN OF SERVICE 06/29/2010 William Cline, Corporal, who being duly sworn according to law, states that on June 29, 2010 at 1315 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer N. Heller, pursuant to order of court by posting the premises located at 1875 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. WILLIAM CLINE, DEPU SHERIFF COST: $39.40 June 30, 2010 SO ANSWERS, RONITY R ANDERSON, SHERIFF ;c Cow yStge Sheriff. 7eiecsoft. Ir. 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 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 ??B12a320-2 NAC Bank Mortgage, a division of PNC Bank Plaintiff V. Brian M. Heller Jennifer N. Heller Defendant(s) TO: Jennifer N. Heller 102 West High Street, Room 213 Carlisle, PA 17013 Date of Notice: August 17, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 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 YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 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 UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCH'AR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r, ALAN M. MINATO ESQUIRE CHANDRA M. ARKEMA ESQUIRE ADAM L. KAYES, tSQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 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 #D812n32?-2 PNC Bank Mortgage, a division of PNC Bank NA Plaintiff V. Brian M. Heller Jennifer N. Heller Defendant(s) TO: Jennifer N. Heller 1875 Douglas Drive Carlisle, PA 17013 Date of Notice: August 17, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 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 YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TARE 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 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 UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, 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 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE U30 FOR THAT PURPOSE. RE C AD BALM . YAYES, SQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center Ill Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 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 ?t0812032Q-2 PNC Bank Mortgage, a division of PNC Bank NA Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Brian M. Heller Jennifer N. Heller `:NO. 10-3026 Defendant(s) TO: Jennifer N. Heller 107 West High Street, Room 213 Carlisle, PA 17013 Date of Notice: August 17, 2010 IMPORTANT NOTICE 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 YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE 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 TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. L v+.»r ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.G. 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 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 ?as12a?2a-s PNC Bank Mortgage, a division of PNC Bank NA Plaintiff V. Brian M. Heller Jennifer N. Heller Defendant(s) TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Date of Notice: August 17, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 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 YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 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 UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, 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 LLAMk POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHANDRA M. A ADAM L. KA MARGUERITE L. Woodcrest Cc 111 Woodcrest Cherry Hill, New orate Center )ad, Suite 200 ersey 08003-3620 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 PNC Bank Mortgage, a division ;COURT OF COMMON PLEAS of PNC Bank NA CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342• Plaintiff ;MORTGAGE FORECLOSURE V. Brian M. Heller € NO. Jennifer N. Heller 107 West High Street Room 213 Carlisle, PA 17013 Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF M SS COUNTY OF Montgomery 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 Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age; Residence: Employment: Brian M. Heller Over 18 As captioned above Unknown Jennifer N. Heller Over 18 As captioned above Unknown Sworn to and subs ribed before me this /q day of 20/0. Not 7f"'_c 1 L "-P T t le :yeu 10 eed er, 1 Company : At 0-k-' /J k KNftLSpr w, N*Y 4nxd.fxtkSt*? * r CMWM cmAtU6,2011 UDREN LAW OF?ICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. 131DREN, ESQUIRE - ID #04302 STUART W:[NNEG, 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 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 Judgment Judgment in Replevin $ 3o y Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment 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. ATTORN MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 +' ? J A4111: 05 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ClJg1N ?:= t ' 1 -UNT1( WOODCREST CORPORATE CENTER pWN SYNANIA 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff Cumberland County V. Brian M. Heller ::NO. 10-3026 Jennifer N. Heller Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: August 30, 2010 UDR 4N LAW OFFIC S, P.C. BY : MMA a hP0ffU1 Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:-. 4 me • Ka eehamer CoTitle: kA?thorizem Co, mpany : i??- A- Brian M. Heller Jennifer N. Heller Loan #0004343259 MJU #08120320-2 (Cumberland County, Pennsylvania) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 lLED-OF^? ALAN M. MINATO, ESQUIRE - ID #75860 ?1}^r "}£1j CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER u 3 d : ?? 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 1XjuPdfY pleadings@udren.com PENNSYLV" PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant (s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $118,305.61 Interest From 08/29/2010 1,794.18 to Date of Sale December 8, 2010 Ongoing Per Diem of 17.59 to actual date of sale including if sale is held at a later date (Costs to be added) *44.00 PID ATr1/ 59. So 0-sr 3Q.y0 u gA.00 ., 0.00 14.oo a.SG y ayl.?O - Pb Ayry P.C. UD LAnW?OFF?jI S bm BY a 1A A al Att'dr1'feys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 401-00 't?:ue(o .50 LL c* 1593ap 0 a4lgys ICE wa ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID ALAN M. MINATO, ESQUIRE - ID CHANDRA M. ARKEMA, ESQUIRE - WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com #34576 RLEO-CMr!C ? #75860 ID #203437 05 p, OUNlY PEN?SYUANIA PNC Bank Mortgage, a division ':COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: 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 property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties 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: UDREA SAW OFFICES, P.C. BY: Attorneys for Plaintiff 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 Fll.`"1C?ARY ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200r,KaU CHERRY HILL, NJ 08003-3620 (y?$YLV 856-669-5400 pleadingsCudren.com PNC Bank Mortgage, a division =COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(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. UDREUI JAW OFFICES,- P.C. BY: l// V" & J/ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE .ff pleadings@udren.com PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 FILED- r1CE ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 3 a AN 11: d? 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 CWB&L? v 000MY PENNM/AM 856-669-5400 AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank Mortgage, a division of PNC Bank NA, 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: 1875 Douglas Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Brian M. Heller Jennifer N. Heller 1875 Douglas Drive Carlisle, PA 17013 107 West High Street Room 213 Carlisle, PA 17013 and 102 West High Street, Room 213 Carlisle, PA 17013 and 1875 Douglas Drive Carlisle, PA 17013 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 Bank Mortgage, a division of PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 National City Bank 6750 Miller Road Brecksville, OH 44141 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 Commonwealth of PA 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Bureau of Individual Tax Inheritance Tax Division, 6th P1. Strawberry Square, Dept. 280601 Harrisburg, PA 17128 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 1875 Douglas Drive Carlisle, PA 17013 .. 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 30, 2010 UDREX,LAW OFFICES- P.C. BY:i it r?11 (,rig/ (yv Attor ys for P1 1ntiff 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 T04CF9-M ALAN M. MINATO, ESQUIRE - ID #75860 ( 'fNF CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 3u 05 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioner's Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 Douglas Drive Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER HIS HELLER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HOSNIAH BAYAT, WIFE DATED 09/28/2005 RECORDED 09/30/2005 IN DEED BOOK 271 PAGE 1101. 'CF rt ??{??p t?1 Cpl UDREN LAW OFFICES, P.C. ATTORNEY FOR P&44 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. ::MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer 107 West Room 213 Carlisle, N. Heller High Street PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioner's-Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 4750 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1575 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: PROPERTY ID NO. 1875 Douglas Drive Carlisle, PA 17013 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER HIS HELLER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HOSNIAH BAYAT, WIFE DATED 09/28/2005 RECORDED 09/30/2005 IN DEED BOOK 271 PAGE 1101. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 flTD-OME ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER i 1, t - l AM1I *OS 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 aw-Ri,,%-46 Wulm PFJWt?lLVANIA 856-669-5400 pleadings@udren.com PNC Bank Mortgage, a division `COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer N. Heller 102 West High Street, Room 213 Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioner's Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 wi?-'1 be sold to the highest bidder. You may find out the price bid by calling 856-6E9- 5400. :?. You may be able to petition the Court to set aside ttie 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE,' LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR., AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 Douglas Drive Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER N. HELLER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HOSNIAH BAYAT, HIS WIFE DATED 09/28/2005 RECORDED 09/30/2005 IN DEED BOOK 271 PAGE 1101. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3026 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK MORTGAGE, a division of PNC BANK N A, Plaintiff (s) From BRIAN M. HELLER and JENNIFER N. HELLER (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 $118,305.61 L.L.$.50 Interest from 8/29/10 to Date of Sale (12/8/10) Ongoing per diem of $17.59 to actual date of sale including if sale is held at a later date -- $1,794.18 Atty's Comm % Due Prothy $2.00 Atty Paid $241.70 Other Costs Plaintiff Paid Date: 8/30/10 4Daviuell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: CHANDRA M. ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank mortgage, a division of PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff V. Brian M. Heller ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Jennifer N. Heller :NO. 10-3026 c-) 102 West High Street _ c Room 213 Carlisle, PA 17013 '- Defendant(s) rv Q 0 r-?t c-? c...? U AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.x,--, :11! ca Plaintiff, by its/his/her Attorney hereby verifies that: co C) n rat r?- -o m MC3 C) -A C3 x -n ©-n ;e i5 CD to D 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: December ,?3, 2010 TTi PR19 T,AW n77TrRq _ P r _ BY At I 1 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County v. MORTGAGE FORECLOSURE Brian M. Heller NO. 10-3026 Jennifer N. Heller Defendant(s) AMENDED AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.1 and 76 PNC Bank Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1875 Douglas Drive(North Middleton Township), Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Jennifer N. Heller 102 West Hig] Carlisle, PA 1875 Douglas Carlisle, PA 2. Name and address of Defendant(s) in the Name Address SAME AS #1 ABOVE Z Street, Room 213 17013 Drive 17013 judgment: 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Seneca Street Partnership P.O. Box 337 Shippensburg, PA 17257 4. Name and address of of record: Name the last recorded holder of every mortgage PNC Bank Mortgage, a division of PNC Bank NA National City Bank Address 3232 Newmark Drive Miamisburg, OH 45342 6750 Miller Road Brecksville, OH 44141 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 1 Courthouse Square Carlisle, PA 17013 13 North Hanover 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 1875 Douglas Drive Carlisle, PA 17013 The statements are true and correct, based upon 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: December 27, 2010 UDR BY: Att 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 Bank Mortgage, a division of PNC Bank NA Plaintiff V. Brian M. Heller Jennifer N. Heller Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Brian M. Heller and Jennifer N. Heller PROPERTY: 1875 Douglas Drive (North Middleton Township), Carlisle, PA 17013 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 Commissioner's 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. 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E C s z c n a c? r N N a ma a? oa u -mo 1= :3 <Z CO) i o y {?a F N E U) t X ' ZQ ? J r N M t n c - o ? O r N o N y a - C m IL C_ ?O !a m Y C m w 3 m a F V m m CL O v C4 O O U. CT CA m 2 ti M C ^L` W U N O N M O N co W 2 Z L C C p C ca G C cu AML W MARK J. UDREN, ESQUIRE NJ MANAGING ATTORNEY TINA MARIE RICH OFFICE ADMINISTRATOR December a1 , 2010 UDREN LAW OFFICES, A C. WOODCREST 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 One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff :NO. 10-3026 V. Brian M. Heller Jennifer N. Heller 102 West High Street Room 213 Carlisle, PA 17013 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: December 21 , 2010 UDREN LAW OFFICES, X. BY: Attorn for a B. PNC Bank M age, a division of PI NC BankNA, et. al., Plaintiff(s) . Vs. 'Brian Ili. Roller, et. at., Defendants Service of Process b1 ,4PS International, Ltd. 1-800-328-7171 Minneapolis. l? 5439-31.22 Service of Process on- ,egg IN-?,?ti?ATif)N,? ' ??5'itttertk'ititlGNl1'la:.a 7804 GCenroy ltd. ?'iPS Cte#: 107351-0001 AFF'ID?AVIT F SERVICE ®IndividuaI t? DREN LAW OFFICES tiriaxt M. Heiler Court Case No. 10-3026 Ms. Danielle Deviin 111 W'oodcrest Rd., Ste. 200 Cherry Hill, N3 08003-3620 - state 01-. Y ro * `: r a*+ ) $s• County of pry ? Name of Server: n f n undersigned, being duly sworn. deposes and says that at the time of service, s/he was of legal age and was not a party to this action; 20 1 N, . at i. o'clock M Daterrimer of Service: that on the day of Place of Service; at 1875 Douglas Drive Carlisle, PA 17013 Documents Served: the undersigned served the documents described as: Notice of'Sherffrs Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was sensed on: Brian A Heller Person Served. Method of Service- er: ce- By personally delivering' them into the bands of the person to be seared. - 7_1 By delivering theta into the hands of a person of suitable apt-,. who verified, or who upon questioning stated, that he she resides with Brian 141. Heiler at the place of service. and whose relationship to the person is: Description of Person `I`he person rece -vin.g documents is describer) as follows: Receiving Documents-. Sex „Lt- -, Skin Color W , : ;Hair Gaiar , l ti Approx. Ap ? Approx. Height ?Er °} kp] r. To the best of my knowledge and be-lief, said perso4-3A-as noses the time of service. Signature of Server: Undersigned declares under penalty of perjury that the foregoinfi is.true and correct, ?r, iga<s:ure du 5arag rr AI'S Intex7iaatlonal, Ltd. Facial :Hair 1? r??. rox_''eight q-P i 6 S aged in the US Military at u` . ckrib4d and svgcrn to before the lay of ' z? j V TJota--? ?ai?E ? _ ?: Eirttt?' S,?{?^t?i"r18?t? 4rcue f t; °wy? ?.. i.. fi0 ,ea'1u?y1 2?f Y ? U PNC Bang Mortgage, a division of PNC BankNA. et. al., Plaintiff(s) Vs. Brian M. Helier, et_ al... Defendant06 UDREi LAW OFFICES M s. Danielle Devlin -Jennifer N. Helier, by posting Court Case No. 10-3020 111 1V ooderest Rd.. Ste. 200 Cherry Hill, N3 08903-3620 State of. c A ) s5. County of.,. i . 4s ?1?= 3 4 Name of Server: undersigned, being; dull nvom deposes and says that, at the time of service, s/he waalof legal ae-e and was not a party 1,; this action. DatetTime of Service: that on the a day € f 20C? , a - ScloLk- T Place of Service: at 1875 I)ou;las Drive in Carlisle. PA 17913 Documents Served: the undersigned served the docurrienu described as: Notice of Sheriffs, Sale of Real Property wf Order Service of Process; on: A. true and correct copy, o "the aforesaid document(s) was on: Jennifer X Heller, bN posting; Person Served, anti By anal(' delivering them into the hands of the person to be served. y delivering; them into the hands of a person of suitable ague, who verified, or who upon questionings stated.. that he}she resides with Jennifer N. Heller, by posting at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Deceiving Documents: Se Skirt Color Hair Color Facial Hair -Approx.. A Appro,, height ripprn:c. Weight To the est of my Knc ,vtedgc and b-vIiwf, said person was not eno _7cd in the LAS Military at the e of s wiem., Signature of Server. U ersigncid cieelares/under penalh, cif, jur Subscribed and stivo to before me this the fs r mina ifi tru and cores ay o , 2{7 ?-?} d,/' 2? ter urc {Sent -- - he ?C:01n=sion E iress APS Irlt eruattional, Ltd. GC7WDh3WEAi.TH OF 0Eta^;3 l'LANIA PdGta lai Sea` i'ammic. retats, Noteiry Puy -c Rte Can r'ssz ? pie :rcpt, 9,2Q 11 Mvnibiv Ptnvivssvania Assmiation of Notaries Service or Process by All's International, Ltd. r4 1-800-328-7171 aPg ?r t!.?rrcrrr?y 4PS International Plazas ° --7 3800 Glenm Rd- _ Minneapolis, l4il+ 55439-3122 ,PS Pile #. 107351-Ctt X33 AFFIDAVIT OF SERVICE -- Individual Service of Proms ow i. UDREN LAW OFFICES, AC. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE 111 WOODCREST ROAD NJ MANAGING ATTORNEY SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH OFFICE ADMINISTRATOR December 2.1 , 2010 AX: 556. 66Y . JJYY FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSEL Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 Gentlemen: In connection with the above file, enclosed please find Praecipe to File Proof of Publication. I have enclosed 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 1 a r 1 ? k s "^ zai 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 Bank Mortgage, a division ;COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive ::Cumberland County Miamisburg, OH 45342 Plaintiff :NO. 10-3026 V. Brian M. Heller Jennifer N. Heller 102 West High Street Room 213 Carlisle, PA 17013 Defendant(s) PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proof of Publication with regard to the captioned matter. DATE: December a1 , 2010 UDR BY: Att .IPX . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 November 19, 2010 6?r- A Marie Coyne, dito SWORN TO AND SUBSCRIBED before me this 19 day of November, 2010 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 26, 2014 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. CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 10-3026 PNC Bank Mortgage, a division of PNC Bank NA,3232 Newmark Drive, Miamisburg, OH 45342, Plaintiff Brian M. Heller and Jennifer N. Heller, 102 West High Street, Room 213, Carlisle, PA 17013 Defendants NOTICE OF SALE OF REAL PROPERTY To: Jennifer N. Heller, Defendant, 1875 Douglas Drive, Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive (North Middleton Township), Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010 at 10:00 a.m. in the Commissioner's Hear- ing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of 118,305.61, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. PROPERTY DESCRIPTION: ALL THAT CERTAIN tract of parcel of land and premises situate, lying and being in North Middleton Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEING Lot No. 103 on the Resub- division Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumber- land County in Plan Book 39, Page 30; containing 148.42 feet along the north along Lot No. 102, Section 12, containing 47.503 feet along the east along Noll Manor, Section 8; contain- ing 148.94 feet along the south along Lot No. 104, Section 12;%nd contain- ing 47.50 feet along the west along Douglas Drive as shown on the Plan. CONTAINING 7,062 square feet and being improved with a town- house known as and numbered 1875 Douglas Drive, Carlisle, Penn- sylvania. BEING KNOWN AS: 1875 Douglas Drive, Carlisle, PA 17013. PROPERTY ID NO.: 29-16-1094- 359. TITLE TO SAID PREMISES IS VESTED IN Brian M. Heller and Jen- nifer N. Heller, his wife by deed from Ahmad Bayer and Hosniah Bayat, his wife dated 09/28/2005 recorded 09/30/2005 in Deed Book 271 Page 1101. 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 UDREN LAW OFFICES, P.C. Attorneys for Plaintiff 111 Woodcrest Rd. Ste. 200 Cherry Hill, NJ 08003 (856) 482-6900 Nov. 19 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland James Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 17, 2010 COPY OF NOTICE OF PUBLICATION NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10-3026 PNC Bank Mortgage, a division of PNC Bank NA 3232 Newark Drive Miamisburg, OH 45342, Plaintiff V. Brian M Heller and. Jennifer N. Heller, Defendants 102 West High Street Room 213 Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY To: Jennifer N. Heller, Defendant 1875 Douglas Drive Carlisle, PA 17013 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. E Your house (real estate) at 1875 Douglas Drive (North Middleton Township), Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010 at 10:00 am in the Commissioner's Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment 01 $118,305.61, obtained by Plaintiff above (the mortgagee) apaplst you. It the sale is postponed, the property will be rebated for *WNeid Avapeble gale, PROPERTY DESCRIPTION: ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN ON SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.30 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET, AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 Douglas'Drive Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BPIIAN M.'HELLER AND JENNIFER N. HELLER, HIS WIFE BY DEED FROM AHMAD SAYAR AND' HOSNIAH BAYAT, HIS WIFE DATED 09128/2005 RECORDED 091301006 IN DEED BOOK 271 PAGE 1101. Mark J. Udren, Stuart Winneg, Lorraine Doyle, Alan M. Minsio, Chandra M. Arkema, Louis A. Simons, Adam L. Keyes and Marguerite L Thomas, Attorneys for Plaintiff Urden Law Office, P.C. 111 Woodcrest Road, Sufte 200 Cher NJ 08003 Sworn to and subscribed before me this J-N e '-f o updua A'11-\C"VJ4J? Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 r MARK J. UDREN, ESQUIRE NJ MANAGING ATTORNEY TINA MARIE RICH OFFICE ADMINISTRATOR December al , 2010 UDREN LA W OFFICES, AC. WOODCREST CORPORATE CENTER Ill 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 One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 Dear Prothonotary: In connection with the above captioned matter, enclosed please find Verification of Service by Certified Mail and Regular Mail Pursuant to Court Order. I have enclosed a copy of the first page 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 Enclosures r. 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive ::Cumberland County Miamisburg, OH 45342 Plaintiff V. Brian M. Heller Jennifer N. Heller :NO. 10-3026 102 West High Street Room 213 Carlisle, PA 17013 Defendant(s) VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter a true and correct copy of the Notice of Sale was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: 10/21/2010 Jennifer N. Heller 102 West High Street, Room 213 Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: December I , 2010 UDREN LAW OFFIC C. BY: Attor f r P1 PA ID 49736 JUN 'f 5 Cl? i IN THE COURT OF_COMKON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION PNC Bank Mortgage, a division of PNC Bank NA P ls.:i.12t:- f f P70. 10-3026 iT . Brian M. Heller Jennifer N. Heller Defendant(s) / 0 R D.E R AND NOW, this 4 to day of TIU? C 2010, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsecruenm pleadings on Defendant(s), Jennifer N. Heller, shall be complete when r Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all sLbsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Jennifer N. Heller at 102 West High Street Room 213 Carlisle, PA 17015 as by posting the mortgaged premises located at 1875 Douglas Drive Carii le, PA 17013 , 7T1 plot j r BY THE COURT : ?. f N !". CJ (r ?.. «.D L-D 1 mj00 LL L ammn L? Cc d y am?g m '??7f A Q E N N °O- y E Ifj m y.r V v?°EW`m n N a E0?6 2 (A LCD E ? Eo R NN= CC _ Ea -0 N n Q mCyCCC O y L O C 'C O? N (n LL _m4)ym? NOw C0 m ?y Erc« mmm?mE- w '-y t0 QLL H"a mo L 0 I W m - . 5O M En a ?Emoma a aOU M d MU)n.op M° c MU) >,00 w? y N? O 'O (A Q m 'o c 3 y S - • O 4) M U -9 x y "v N i E'e v o QU d °U Q y C mE_$? m w % EEN° C N W U D yDEoac - ` U d .2 ES' Mo ° m ?n p0 C C v ? m jN m O Y (`0 c C O= E ? ? 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L LL ti M O LL U) a C cu L N E N ( O N M O N_ co 4t a) Z L c ^c' W cu L am N cu co Certified Mail Provides: ¦ A mailing receipt ¦ A unique identifier for your mailpiece ¦ A record of delivery kept by the Postal Service for two years Important Reminder;: r Certified mail may ONLY be combined with First-Class Mail® or Priority Mailm. s Certified Mail is notavailable for any class of international mail. s NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. s For an additional fee, a Return Receipt may be requested to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece "Return Receipt Requested°. To receive a fee waiver for a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is required. t For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement "Restricted Delivery". e If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. PS Form 3800, August 2006 (Reverse) PSN 7530-02-000-9047 > W N zO w ? o r ? L N r N ?? 2. 1313 ? ? o o w U a a E o c O : Ln 2 0 v Z m M D m n c $ ni N vi ' o 3 Zr O a ? wo 0 C3 y "= ¢ C7 d X m Ci C3 E I r m m m y c ce) N d] E 0 CL ' a E O EE E o t." t T m CY O= 0 "2 BCD W 1 8 x E ? ce) ? m 0 d ?cQ N fi a ? pm j 0 E -5 p}i- W t6 :3 CL r -.2 < a Z _[L ? i ? ? N `CD t N C C U N N m C a E r 00 mCC ?3sm ? O M"iL+ Q c1N? Q M (W U E ? Z \ co M av «L c m EE E C- CO O -?? H L° E CJ0 0:QO ¢ Q LL rn N a y+dz.B?ws %4?? COLA dd 'als!l?a? )Nxoaod- d i C3 0 0 ELZ Woo'd ` s v__' 199JIS u !H ISaM Z06 v o J9119H 'N Ja1luua? °' IM o ,oes seed g a6eisod Igiol E- L' (pe robe) iuewesiopu3) C3 C3 sed tienlle0 popmS88 O O (peilnbad iuewesiopu3) O C3 eieH eed idleoey wruey p O Weuu6od .f= aed PBINLe'J f1J ru $ e6eisod Q' Q' W W W W Ln Ln Ln OG W W @DIAIOS ., rJ t: r J.r .; z",gileH, ` a?ygr Willi CL LU Z a: C) LL ?c LL ? ? ?sC? C_ tJ 0 wu=© 0 CJ N }4 rA IJ C, r-{ (n r- N x -' -rt j-)+ zx ?,.ur ai ? rn r 4-• QJ N fA r r, n 0 O 0 O N f0 r--I tr 0 Q Lr r- oc r 1 n d 1 f 4 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 p 856-669-5400, pleadings@udren.com .- PNC Bank Mortgage, a division =COURT OF COMMON PLEAS nrn ?T+-- -a of PNC Bank NA CIVIL DIVISION Plaintiff Cumberland County -4r" -+? V. C? b o"TZ Brian M. Heller Z ; Jennifer N. Heller ?NO. 10-3026 p Defendant (s) -;0 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 1875 Douglas Drive (North Middleton Township) Carlisle, PA 17013 was originally scheduled for December 8, 2010, then postponed to January 5, 201:1 due to Plaintiff's temporary moratorium on Sheriff sales, then postponed to April 6, 2011. 2. The Plaintiff now seeks the postponement of the Sheriff's 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 J. Wesley Oler, Jr., was assigned to this matter and granted Plaintiff's motion for special service. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the July 6, 2011 Sheriff's sale. l.lli, L".;"d u--- el Respectfully submitted, UDREN LAW OFFICES, P.C. BY :... -.1 ! i f 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 Bank Mortgage, a division =COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff -Cumberland County V. Brian M. Heller Jennifer N. Heller ::NO. 10-3026 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 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(x) 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 1875 Douglas Drive (North Middleton Township), Carlisle, PA 17013, to the July 6, 2011 Sheriff's sale as set forth in the Motion. Respectfully submitted, UDREN LAW OFFICES, P.C. BY :"rw t Nathan olf, Esquire p° f Local C sel Awn PA 10 Minatof '?5860Quire 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. Brian M. Heller Jennifer N. Heller NO. 10-3026 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: April 5, 2011 TO: Brian M. Heller 102 West High Street Room 213 Carlisle, PA 17013 Jennifer N. Heller 102 West High Street Room 213 Carlisle, PA 17013 1875 Douglas Drive and Carlisle, PA 17013 1875 Douglas Drive and Carlisle, PA 17013 UDREN LAW OFFICES, P.C. Nath Loca f, Esquire el Bl? t Ptttorney""fir "Flt"iff Alan M. Knato, Esquire PA ID 75860 f 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION PNC Bank Mortgage, a division of PNC Bank NA Plaintiff c C= V. NO. 10-3026 rn,m Brian M. Helle r Jennifer N. Heller cn? Defendant(s) ?"? ct? >Q a O R D E R ;Z C) ?;. C o? -f C) AND NOW, this )j t day of April, 2011, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 1875 Douglas Drive (North Middleton Township), Carlisle, PA 17013, it is hereby ORDERED that the said Sale currently scheduled for April 6, 2011, is extended (3) three month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for July 6, 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. BY THE COURT: TO:-/Brian M. Heller / 102 West High Street Room 213 and Carlisle, PA 17013 Jennifer N. Heller ? 102 West High Street Room 213 and Carlisle, PA 17013 V Udren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department C) -t -Orn --tom rD -n C rs 1875 Douglas Drive Carlisle, PA 17013 1875 Douglas Drive Carlisle, PA 17013 Owes Of f ice of the Sherif f , kWa ddeliWn9Q(,by Cumberland County Courthouse One Courthouse Square Carlisle, PA 17103-3387 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r .- FI - -;1 I j: '(C Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r ltP?? ? pi l C C' t a, TE t t L; L i P`d '?/ ' {{ r ? '-yPY PNC Mortgage vs. Brian M. Heller (et al.) Case Number 2010-3026 SHERIFF'S RETURN OF SERVICE 09/27/2010 Jody S. Smith, Chief Deputy, who being duly sworn according to law, states that on 9/24/10 at 1249 hours she 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: Jennifer N. Heller, by making known unto, Jennifer N. Heller, personally, at, The Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10/08/2010 05:00 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1656 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 Brian M. & Jennifer N. Heller, located at, 1875 Douglas Drive, Carlisle, Cumberland County, Pennsylvania according to law. 10/12/2010 07:19 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-12-10 at 1916 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: Brian M. Heller, by making known unto Brian M. Heller, personally, at, 1875 Douglas Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/06/2010 As directed by Chandra Arkema, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04106/2011 As directed by Chandra Arkema, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/6/2011 07/06/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $795.19 SO ANSWERS. July 12, 2011 RON R ANDERSON, SHERIFF _?? (. ?? f lei C L; , ' 4? / ,? T-TrRFN T_"?TAT ^F'FI^ES, P.C. IUL .k.I J 1:,D'.4EN, ESQUIRE - ID #04302 E T.T %:IhNE'G, ESQUIRE - ID #45362 1-CRF-A.INTi DOYLE, ESQUIRE - ID #34576 ALAt? M. MINATO, ESQUIRE - ID #75860 CHANDRA t!:. ARKEMA, ESQUIRE - ID #203437 WOCL)CRES.. CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY H::LL, NJ 08003-3620 856-•669-5400 pleading:;@udren.com PNC Bank, Mortgage, a division of PNC Bank NA Plaintiff v. Brian M. Heller Jennifer N. Heller Defendant(s) 1r.T^.'CPSTF'.' F'C"" ?L? .TNTIF'F' € COURT OF COMMON ]?.LEI-?S =CIVIL DIVISION € Cumberland Count,., 'MORTGAGE FORECLOSURE NO. 10-3026 AFFIDAVIT PURSUANT TO RULE 2129.1 PNC Bank Mortgage, a division of PNC Bank NFL, Plaintiff in the above action, by its attorney, Mark J. UdrerL, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was failed the following information concerning the real property located at: 1875 Douglas Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Brian M. Heller 1875 Douglas Drive Carlisle, PA 1.7013 Jennifer N. Heller 107 West High Street Room 213 Carlisle, PA 1.7013 and 102 West High Street, Room 2"13 Carlisle, PA 1.7013 and 1875 Douglas Drive Carlisle, PA 1.7013 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 Bank Mortgage, a division of PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 National City Bank 6750 Miller Road Brecksville, OH 44141 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 Commonwealth of PA 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 Bureau of Individual Tax Inheritance Tax Division, 6th Fl. Strawberry Square, Dept. 280601 Harrisburg, PA 17128 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 1875 Douglas Drive Carlisle, PA 17013 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 30, 2010 UDREN,LAW OFFICES- P.C. B Y :1 Attor ys for P1 intiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE =-F-7Y .: 1.7° "F T CE S , P.C. M.F.Y J. '.D:R]=:N,, ESQUIRE - ID #04302 t -1L,TST I+:N \]i G, ESQUIRE - ID #45362 ..jCRJ,A.INI;' DO`.''LL, ESQUIRE - ID #34576 ALP.F+( M. 11?:INATO, ESQUIRE - ID #75860 CHA 0R.A V. ARKEMA, ESQUIRE - ID #203437 1g00DCRE::':: CORPORATE CENTER 111 WOOLi:: RE:3T ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856--669-5406 pleading:a@udren.com PNC Bane Mortgage, a division of PNC Funk NA Plaintiff v. Brian M. Heller Jennifer N. Heller Defendant(s) ATTCFNFY 7C.'•,. ;,:'IAINTIFF :COURT OF COMMON PLEAS =CIVIL DIVISION :Cumberland County `MORTGAGE FORECLOSURE NO. 10-3026 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioner's Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 P4 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 145.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 1.04, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 Douglas Drive Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER N. HELLER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HOSNIAH BAYAT, HIS WIFE DATED 09/28/2005 RECORDED 09/30/2005 IN DEED BOOK 271 PAGE 1101. PNC Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller NO. 10-3026 Jennifer N. Heller Defendant(s) 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 TO: Jennifer 107 West Room 213 Carlisle, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY N. Heller High Street PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on December 8, 2010, at 10:00am in the Commissioner's Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of 118,305.61, 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: 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. r-.ay aeec. an attorney "to assert your rights. The sooner you contact -_, -::e rioe chance you will have of stopping the sale. See notice on pce two on how to o;otain 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 nia,y 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMLSES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 145.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED IA71TH A TOWNHOUSE KNOWN AS AND NUMBERED 1575 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: PROPERTY ID NO.: 1875 Douglas Drive Carlisle, PA 17013 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER N. HELLER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HOSNIAH BAYAT, HIS WIFE DATED 09/28/2005 RECORDED 09/30/2005 IN DEED BOOK 271 PAGE 11 10 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-3026 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK MORTGAGE, a division of PNC BANK N A, Plaintiff (s) From BRIAN M. HELLER and JENNIFER N. HELLER (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 $118,305.61 L.L.$.50 Interest from 8/29/10 to Date of Sale (12/8/10) Ongoing per diem of $17.59 to actual date of sale including if sale is held at a later date -- $1,794.18 Atty's Comm % Due Prothy $2.00 Atty Paid $241.70 Plaintiff Paid Date: 8/30/10 (Seal) Other Costs Deputy REQUESTING PARTY: Name: CHANDRA M. ARKEMA, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 203437 On September 22, 210 10 the :Sheritt levied upon the defendant's interest iri the real property situated in North Middleton `I ownship, Cumberland County, 1'A, Known and numbered as, j 875 Douglas Drive, Carlisle. more fully described oii Exhibit "A ' tiled with this writ and by this reference incorporated herein. Date: September 1. 0 0 B Rea Estate Coordinator .1 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 SWORN TO AND SUBSCRIBED before me this 5 da of November, 2010 i Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-3026 Civil PNC Mortgage, A Division of PNC Bank, N.A. vs. Brian M. Heller Jennifer N. Heller Atty.: Chandra Arkema ALL THAT CERTAIN tract of parcel of land and premises situate, lying and being in North Middleton Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEING Lot No. 103 on the Resub- division Plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumber- land County in Plan Book 39, Page 30; containing 148.42 feet along the North along Lot No. 102, Section 12, containing 47.503 feet along the east along Noll Manor, Section 8; contain- ing 148.94 feet along the south along Lot No. 104, Section 12; and contain- ing 47.50 feet along the west along Douglas Drive as shown on the plan. CONTAINING 7,062 square feet and being improved with a town- house known as and numbered 1875 Douglas Drive, Carlisle, Penn- sylvania. BEING KNOWN AS: 1875 Douglas Drive, Carlisle, PA 17013. PROPERTY ID NO.: 29-16-1094- 359. TITLE TO SAID PREMISES IS VESTED IN Brian M. Heller and Jen- nifer N. Heller, his wife by deed from Ahmad Bayar and Hosniah Bayat, his wife dated 09/28/2005 recorded 09/30/2005 in Deed Book 271 Page 1101. 51 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 cZhe Patriot-N(ws 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 r _. t Sworn to and'fiubscribed tbece me this 19'yay?bf November, 2010 A.D. i I/ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary Public i Lower Paxton Twp., Dauphin County My Commisslon Expires Nov. 26, 2011 Member, Ponnsylvania Association of Notaries 2010-3M CM Term PNC Mertpp, A Dkision of PNC Bank, N.A. Vs Brian M. Heiler Jennifer N. Heller Atfy: Chandra Arkema ALL THAT CERTAIN TRACT OF PARCEL. OF LAND AND PREMISES SITUATE, LYING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND :_OUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 1.03 ON THE RESUBDIVISLON PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148,42 FEET ALONG THE NORTH ALONG LOT NO. i02, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR; SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT N0.104, SECPION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 Douglas Drive, Carlisle, PA 17013 PROPERTY ID NO.: 29.16-1094.359 ITTLE TO SAID PREMISES IS VESTED IN BRIAN M.HELLER AND JENNIFER N. HELL.ER, HIS WIFE BY DEED FROM AHMAD BAYAR AND HO$NIAH BAYAT, HIS WIFE DATED 09/281 5 RECORDED M/3011J10.5 IN DEED BOOK 271 PAGE 1101. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3026 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK MORTGAGE, A DIVISION OF PNC BANK NA, Plaintiff (s) From BRIAN M. HELLER, 1875 DOUGLAS DRIVE, CARLISLE, PA 17013 AND JENNIFER N. HELLER, 107 WEST HIGH STREET, ROOM 213, CARLISLE, PA 17013 (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: $118,305.61 L.L.: Interest from 8//29/10 to Date of Sale March 7, 2012 ongoing per diem of $17.59 - $9,797.63 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $1,058.39 Other Costs: Plaintiff' Paid: Date: 11/8111 David D. Buell, Prothonot (Seal) B Deputy REQUESTING PARTY: Name: PAIGE M. BELLINO, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 309091 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE c Brian M. Heller :NO. 10-3026 Jennifer N. Heller , Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY : - Issue Writ of Execution in the above matter: -=? Amount due $118,305.61 Interest From 8/29/10 9,797.63 to Date of Sale March 7, 2012 Ongoing Per Diem of 17.59 to actual date of sale including if sale is held at a later date (Costs to be added) UDREN LAW OFFICES, P.C. 0 C? L` it l0. (( Cc u << BY: B?a At rney for Plaintiff Cam. ? y a3 9 V70 7 bA?- eR ,& T? UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF PNC Bank: Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) CERTIFICATE TO THE SHERIFF ._ co I. The judgment entered in the above matter is based on an Action: _ A. In Assumpsit (Contract) E. 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 property. II. The Defendant(s) own the property being exposed to sale as: A.. An individual X -B. Tenants by Entireties 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 OFFICES, P.C BY :P76A A 'P Y1/-\ ttorneyj for Plaintiff cte 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 Bank. Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA =CIVIL DIVISION Plaintiff :Cumberland County `. V. MORTGAGE FORECLOSURE -? - . s ?-D Brian M. Heller :NO. 10-3026 - Jennifer N. Heller -? c Defendant(s) 3> n r €Y 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 statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. r 4_ f° gym: ??; UDREN LAW OFFICES, P.C. BY: ?/i1l 1.1 YYl I lr? t I t n, Attobney for Plaintiff ?N i r 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 Bank: Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA ;CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) . c:> t AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1875 Douglas Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Jennifer N. Heller 107 West Hig: Carlisle, PA 1875 Douglas Carlisle, PA 2. Name and address of Defendant(s) in the Name Address SAME AS #1 ABOVE z Street, Room 213 17013 Drive 17013 judgment: 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Seneca Street Partnership P.O. Box 337 Shippensburg, PA 17257 4. Name and address of the last recorded holder of every mortgage of record: Name Address PNC Bank Mortgage, a division 3232 Newmark Drive of PNC Bank NA Miamisburg, OH 45342 National City Bank 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 13 N. Hanover 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 1875 Douglas Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating unsworn falsification to authorities. 1F ?. `C DATED : ° *' ti e-! 2011 UDREN LAW OFFICES, P.C. BY Attorney for Plaintiff 6750 Miller Road Brecksville, OH 44141 every other person who has any record lien UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF PNC Bank: Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA 'CIVIL DIVISION Plaintiff :Cumberland County V. =MORTGAGE FORECLOSURE Brian M. Heller :NO. 10-3026 Jennifer N. Heller Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 ?? rn C7? r. c-? "7 '7 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 Bank Mortgage, a division of PNC Bank NA COURT OF COMMON PLEAS 3232 Newmark Drive CIVIL DIVISION Miamisburg, OH 45342 -Cumberland County Plaintiff v rn Z 30 - rn . u Brian M. Heller .? ...i Jennifer N. Heller NO. 10-3026 ,Cp y, ?„?. 107 West High Street _ Z-.a Room 213 x -? _ D Carlisle, PA 17013 Defendant(s) -r 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: DeCeIAMT , `4- UDREN LAW OFFICES, P.C. ` BY • A rn s for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank Mortgage, a division of PNC Bank NA Plaintiff V. Brian M. Heller Jennifer N. Heller Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Brian M. Heller Jennifer N. Heller PROPERTY: 1875 Douglas Drive (North Middleton Township) Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 7. 2012, 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. s N N LL _ N N Y o E W ? U) LL N C m - U ? N O? N (n LL N N N OL, O N ? 0 co OD LL N E 0- Z7 Lw GO 8 mC `y E ?3 Z iE c „m,mC m y N 0 E (nom xp y d0 QC01N 00 O N LL 3 w U N Y V ? CLi U C O m ai .c ? C u L" C O 00 m Yp p .2 Q nm a O U N C d N D1 > Uw?? cm zL) O y 0 n ? - N O N U N 3 C O _ m - a x O (D LL 2 C W ?m?? a) m N .o N O a m N O m 5 U U M 0 N V ? M CL C ryj N aD > (>?? in tL00Z °-' O?J ?N= W C } WC?W crox 0 ou Q N N 42 N -'o a) zQ0 N N v v Q U O N O a v c m N N N d Q 0 N E M 3Ob1SOd Sn E0020 wol-3 pa!!ew = tibOZftrL/l'? O v zo --ml04n9`'U WO L. U OZ m Q Q~„a? Q2 o QO aa)iM a n M LL E N cn t r LL O ? ?- c Z =) yN Q 3 c 4) o Wpm ?. >I-M r' :) •= a c6 Q?c° Q Un oo a ?mNp• U mgr a?!" ZW? -U) CL ? cc) DN " - =! (n X O? 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UDREN, ESQUIRE NJMANAGINGATTORNEY TINA MARIE RICH OFFICE ADMINISTRATOR December 16, 2011 UDREN LA W OFFICES, AC. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 PAX: 556. 669. 5399 FREDDIE MAC PENNSYLVANIA Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 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 IT ... 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION 3232 Newmark Drive :Cumberland County Miamisburg, OH 45342 Plaintiff :NO. 10-3026 V. Brian M. Heller Jennifer N. Heller 1875 Douglas Drive Carlisle, PA 17013 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: ?eeg Ar 16, "?o nI- SO()U0/ ? (A, aopa- UDREN OFFICES, P.C. BY: 4 624 Atto n or -Plaintiff )M?es ittombrur7, P? fi'? 3s 1`'NC. Rani, Mortgage. it division or M Rank, NA, et, al.. Plaintiffs; t s, Brm M.llciie: e!.. x Defendanets? UDREN LAW OFFICES tVU. Danielle Devlin 3 l 9 l ooocrest Rd.. Ste. 200 Chem Cfill. N,t 08003-36211 Service of Process bt :BP'S International, Ltd. 1.-800-328-7171 PS IN 6S n ?I.A i!(7• `~ APS fnternationai f l37 7800 Gienroy Ro. Minneapolis, WN 55439-3322 APS File #s. 1137 001 AFFIDAVIT OF SERVP"7'--a individual Service of Process on: --Brian M. Heller € Curt Case No. 10-3026 i istate of.--t Ct mit that being duly swore., deposes and saes Name cif Server. - that at `Ile Ime -A'service, s/he wat~ of te'gal age and was not ra party to this action.- bate''l' me of Servic that ore thv day of 26 at a ctocl ? (°I placer of Service, tK 18,75 ESnnstas Drive , to Citrlisle, PA 17111" _ _-- Documents Served. the un:iersigned served the documents described as: Notice of Sheriff's Safe of Real Proper t,. Service of [process of.- A true and correct copy of the aforesaid documents, was serval ten: Brian M. Heller Served, Person : i ? By personali}r deiiverin them into the rands of the person to be served. ce off tier*? ice. Ser Method Method By delivering them into tiae hand, of a; person of suitable age. -vNho verified, or who upon questioning stated, that helshe resides with Brian M. Helicr w tide, piace of service, an whose relationship to the person is: Description of Persor: I ri, w, oti receiving, documents is described ac: col! +v S: Receiving Documents. Sexl,rc?lor „. hair Co F'rtc.ial Bair Apprt, Appro : ?i 11 t: {pe i7i F.l?,•!:: P? .,.._. lit peraC3t, was that enga :'dnn tiw l tt1 .:?., of servicw: Sionaturt of server iantddeclaresIIn CltrDenaIIVof'per Iurt? Sub '4kYo"' t' 1 th€!, thE: foregoing, IS true an corre';,' l T() '• `` Signature of Server AP I nternatr`onal, Ltd, O4MONWEAL.'ftt OF FEWSY emir Notanat Sea, uWor', 140, PU 9 n t 4" 20 MEif9Ek, FEM FtL4, f M AR1ES C.:arak Iaa:: :; thvisiun of PNC Hanle NA, et. Al., Piaintifflsp vs. imN. lleiier».. ai., t)etendant{ Service of Process n% A°S International. Ltd. 11?S tNTr-U'1' 'rtoNA, ,,BPS interBanonai Plaza 7800 Gienrov Ka. Vlinneapoiis. NIN 55434-3122 APS File #. 11as71-m102 AFFIDAVIT OF ERVICF -- Individual Service of Process on. fJDREN LAW OFFICES _,fennifer N. 1ieile. , bz pasting 'ourt -asp N;-. 10-3026 Ms. taanielie Devlin 111 woodcrest Rd., Star. 200 Cheri Mill, NJ 08003-3620 Slate o€: } Ss. CounC&' ,,Me of undersigned, being dull' swore, deposes and says that at the time of service...=1lte was oz legal age and was riot a party to this action 2 [.Iota +1'tnre at: ea ~?ic^, that 1a1a the- dad, of a c tiloei ? ?I Place of Service. at 187,5 Douglas Drive in Carlisle, PA 17013 Documents e r ve the undersione d served the documents described as: Notice of SherifPs Sale or heal Property %,/ Order Service of Flr(wes on: A true and correct eopy of the aforesaid dtaeurnent(s) was served ow Jennifer N. Heller, by posting Peron Served:, aria' Method of Service; By persona by delivering then,, into the hands of the person to be scrved, By deliverint* them into the hands of- a Person of suitable age, -vvho verified, or who upon questioning stated- that hekbe resides with Jtmnifer N. Heller, hjF posting a` the place of service, and whose relationship to the person is: Description of Persor= Tuc person receiving ducirnents is d scribeci its follows- Receiving Documents: Sep -, Sin Color Hair Color Facin l-mir ppro=:. Ave Approx. Height Appro.. V .•; -,t 'h., the best of my k.nov iedge and Deli: ry. said person was no,, engaged ir; Me, US Militar' at the time of service, Slanature ofSer a ?>r. C,na. psi l-nivd do Clare nettalty of perjury Subscribed and swar t hufrre me this lore rail,, is trtlc ar'icl correct. (1_ ; iv C)t . 20 is SigUatt,rc of Server Nota5; Nubi , r,;:: sic rtiExpirc s _ l' International, Ltd. MMONWEat-? ? ?- ANNA Nn-, I SUS?^ -' „L, ,xiand LountYy i F ta?P+gEr,, ?n?F A.SS 4a:+?Y UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE 111 WOODCREST ROAD NJ MANAGING ATTORNEY SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH OFFICE ADMINISTRATOR FAX. 856. FREDDIE MAC PENNSYLVANIA December 16, 2011 Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 Gentlemen: In connection with the above file, enclosed please find Praecipe to File Proof of Publication. I have enclosed 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 "'Om r r 'V r% UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank Mortgage, a division of PNC Bank NA 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff V. Brian M. Heller Jennifer N. Heller 1875 Douglas Drive Carlisle, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-3026 PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proof of Publication with regard to the captioned matter. DATE : ?l@^1'P?ihor ,TOVIWAI LI, aU,a UDREN W OFFICES, P.C. BY: Oa_? /lA'yoahA,I? AttooTriv " for Pla(intiff ?A ,?' 30'135e,ci ?AT E" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland fackie Cox Sales DIrPI tnr of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 21, 2011 COPY OF NOTICE OF PUBLICATION cuififaial couefw.+? CIVIL ACTi(MH.A'!r No, 164M PNC 88stlcMortQage, a oviolon of I14C 8an% NA, Pfakdifl vs. Wan M. Heller arW Jennifer N.' Rohr Dek"danIN NOTICE OF SALE OF REAL 108OPERTY TO: JannBer N. Heller Defendant, Whole fast WW" addraaaaa eras 1875 Drive, E;" ; PA 17013'arW 107 West High Stroet, !loom 213, = PA 17013. Your house (real write) at 1875 Duug*s D&O (MOM MiddisW Township), Cadisle, PA 170I308h9Adedtobe add at.* Sheriffs Sale on Mereh 7, 2012 at 10:00 a.m. in rie: Cumberland C CeuWetae, COmmlaalonere Hearing Room, 2nd Floor, C *ft, PA, to animus #W court judgment of $118,305.61, obtained by PUMti f above (fM r oWN&gse) tgalna(yot+_ If the OF A AHMAD SAYAT AND HOSNM SAYAT, HtS WIPE DATE RECORDED OMMEM1s IN f7EED BOOK 271 PAGE 1101. Udren Lew Offices, P.C., A sortieys for PIaf W III Wt Cherry NIOWaMl03' Spite 200 "M. Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication ar e. i Sworn subscribed before me this My commission expires: NOTARIALc IAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH i4Y Commission Ex CaMBaEiRND CNTY p '014 a: { Notary Public PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 November 25, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Li Marie Coyn ditor SWORN TO AND SUBSCRIBED before me this 25 day of November, 2011 Notary 6td?Ri DE?Qi? P IN Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 UDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE Ill WOODCREST ROAD NJMANAGINGATTORNEY SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH OFFICE ADMINISTRATOR December 16, 2011 PAX: 856. 669 FREDDIE MAC PENNSYL VANL4 DESIGNATED COUNSEL Prothonotary of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller Jennifer N. Heller Cumberland County C.C.P. No. 10-3026 To whom it may concern: In connection with the above captioned matter, enclosed please find the following: 1. Certificate of Service to be filed; 2. Copy of first page to be time stamped and returned to me in the enclosed self-addressed stamped envelope. Your assistance in this matter is greatly appreciated. Sincerely yours, Danielle Devlin Foreclosure Specialist /dad Enclosures ' ;" ?i- 11 C 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION :Cumberland County Plaintiff V. :NO. 10-3026 Brian M. Heller Jennifer N. Heller Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that true and correct copies of Notice of Sale was served upon the following person (s) named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: 11/14/2011 TO: Jennifer N. Heller 102 West High Street, Room 213 Carlisle, PA 17013 UDREN W OFFICES, P.C. BY: Atto/n for 1 intiff F N 17 JUN IN THE COURT OF C-OM DN PLEKS OF CUMBERLAND COU1177Y CIVIL TDI'dTSIDN PNC Earle Mortgage, a division of PNC Bank NA P1a;ntiff rro. 1o-3oy? ?r . Brian Yl He l ter Jennifer A. Helier Def ndant t s) O R D.E R AhD NOW, this ? l7 day of Tlu)l CL ? 2010, upon consideration of Plainti-f`S Motion and tl° kffidav-it of Good Fait-A: inves-L-igattion attacihed hereto, it is hereby OPDEPED tbat- se.`Vl ^e Of the Complaint =r. Mor=gaae Foreclosure and ali subsemzen_ pleadings ail Defendant(s), i1enni,fe.r N. Re_lez, shall, he complete when Piainti.ff or 2-s counsel or age: rw has tiiaille_Cj .-.:-.2e and cogent copies of file compls.int in Mortgage and &"l vfbsemment pleadings by certified mail and regular mail _o the last known address of DefeAurant (s) ! Jennifer IN. Heller at 102 West E?1J1 St=est Room 213 Car isle, ?A an b poc'1_i:1g the :IIor aa?fed UreR1iG^_6 _ located at b7? Douglas DriVt Carlisis, PA 17C.??Y V-)' -L' f I L??d?iG%??°?> i , y I .?.- O l r7 ? 1"? L --,•• ^ 7? G-? ??7 ?j Q/! ?.i c j ?. i ? C ;.! ? ? ?.?„I) (n ? ?,/,?, ? ?? ??4 r L ?? d u ?- v > Jy 5 ,tiZ1 t e2 BY THE COURT ., TF v, O C31 C C31 m O s O 1 0 z= U) mm rn _ 'T1 n. ? a c 3 (n cr ?. o w c°o T N ° r C --1 ? N 3 '2 : c?9 cDa c0 w rr r.? a 0 to Om m ? N v 0 Z 3 ? o ? o ff co ,m V / I' iyaaw? 7 w???201 N 03y ? 7 Q ???p..00 rnNa?m 4j'K O?j C 03 ?? N d V ? y 'fl 3?'-'Nao;io N ? mo??go G > A Mo vmm C Q 0 r W ? ? d )d ?,?d acmes v 3 d - 7? N ? IQ Gy ,y N > 0, f0o m a {p d, d wQ?3'oon d ? 9 b C? _ j N g - N o' Jda^ 0 Sc mm- K I. o Q s 7? m i N _- d Q N N? W 0?0 Chi zi j 3 "•- Q'(Dd,yd y L G %. 7 N?m? a;d O?A? oc C"'o_ ymda+po N G 7 W d p..m d m O ?, r,, N 'm ro $ m tl) Zq Nv' O. r CD W q a y N: v yc 000 N Z a ..? An N _ - : 5^ CD co r c o tc W to 0 T `-' C5 CD CD m f- < t) rn ANN p •o ? W =i '4 0 3 m ITi N ? 0 p ° I I I N 016H2651W16 $01.159) 11/1412011 Mailed From 08003 VS POSTAGE ? ? ? ? n co t0, O m o- m ? ,D a o- 0 w d ???? N m? CD ?o m? ? a m I = a 'a 0 0 Z aro a ??ro3 ° m? 00 c o a."R 0 0). 77 M ' 4s N G Q C n F o n C co m (7O N D; ?7% r ?j x ? tD3 CL O n •oo° 3 O In N `? m O1 o a rn rn co O SO. N TN CO N (D N ? IN T b (m R cc I • Only; Coverage Provided) M Ln Postage $ r r-- Cenified Fee ! Postmark -` Return Receipt Fee Here J ? O (Endorsement Required) lit - ?i 0 - 3C2 E 7.14 Restricted Delivery Fee r. -* o G7 (Endorsement Required) rn CO J Total Postage & Fees $ ?D 1 rq Sent To LJenn?e N. Heller C3 wii ii, Ajit. ww st High Street, Room 213 or PO Box No. PA 17013 Cary, State, ZIP+d r 4 1+ r CC) It no r r_ w ?? C3 C] Z ul C7 U1 O Postage $ r:l Certified Fee , s C] C] C] O Return Receipt Fee (Endorsement Required) 30 Postmark Here w O C] Restricted Delivery Fee C] C] (Endorsement Required) CO CO Total Postage & Fees $ i ..t cO . cc ° sent o Jennifer N. Heller a r- ( r_ street, dpCriro 102 West High Street, Room 213 or P0 Box ft. Carlisle, PA 17013 City State, ZIP.r r-- Z te . v ¢ " a (D 0- h c? ?J 0 Ui C-) D[ H -n LU- 0 Z CL UA ??Qi ? 1 ??ryp! ?0 ?. dt ? LU?-i W cr U T .Q N I T Z m 03 3 rr T n 2 m o ? I n "J C3 C3 W Y Oz W O 0 C7 G7 Y n w Ui Y N . N = n' D D c CD o?m w ro co O O J N i W ? mI ?? m a ?? s 7 a y r r • y o wo T ? m z0wca? O ?. CL W y' m ? ; M 3 0 a O N 005 " (D a 5 C, O a awo m O? $ '' ' N m I rr a a z a 3 n ?? ?? { O y O Cp? q +? c l j?aisem for.two years t-Class Malls or Priority Mail. 'emational mail. ) with Certified Mail. For i Mail. 'equested to proyide proof of complete and attach a Return plicable postage to cover the j'. To receive a fee waiver for your Certified Mail receipt is cted to the addressee or mark the mailpiece with the -ed, please present the arti- mark on the Certified Mail postage and mail. hen making an inquiry. 7 IS W z dLJ 0LU o uJI F' uU".o?z vCCL 0Gi ZU)?Cr uu u! w /c` T T r-I N O W W? N ?-I N N ?-I r-I JJ r-I CIS ' t31 ? • •r-t - zx 4-I a? _j . v a r, h H H SHERIFF'S OFFICE OF CUMBERLAND, COUNTY Ronny R Anderson C; 1 t/ Sheriff ,r ti F Jody S Smith Chief Deputy Richard W Stewart Solicitor PNC Mortgage vs. Brian M. Heller (et al.) 26 1 vU???ilLhil? LU?3? ? t1 PEMSYLYAtd'(A Case Number 2010-3026 SHERIFF'S RETURN OF SERVICE 12/29/2011 03:45 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1875 Douglas Drive, Carlisle, Cumberland County, PA 17013. 01/18/2012 Affidavit of Service to Lien holders Filed in Sheriffs Office 03/16/2012 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, CumberlandCounty, Pennsylvania on March 7, 2012 at 10:00 AM. He sold the same for the sum of $84,000.00 to Jeremy Hess on behalf of CJD Group, LLC. CJD Group, LLC at 1770 Oregon Pike, Lancaster, PA 17601, being the buyer in this execution, paid to the Sheriff the sum of $88,608.00. SHERIFF COST: $2,818.68 April 10, 2012 SO ANSWERS, r RON R ANDERSON, SHERIFF 7 ?/ .? G' 01 Proposed Schedule of Distribution Date Posted - March 23, 2012 PNC Bank Mortgage, a division of PNC Bank NA VS Brian M. Heller and Jennifer N. Heller 1875 Douglas Drive Carlisle, PA 17013 Sale Date: March 7, 2012 Bid Price: $84,000.00 Buyer: CJD Group, LLC 1770 Oregon Pike, Lancaster, PA 17601 Real Debt: $118,305.61 Interest: $ 9,797.63 Atty Paid: $ 1,058.39 Total: $129,161.63 RECEIPTS: Received on November 15, 2011 (check 18124) $ 1,500.00 Received on March 7, 2012 (check 1000080872) $ 3,330.00 Received on March 7, 2012 (check 1000080874) $ 5,000.00 Received on March 7, 2012 (check 1910) $ 70.00 Received on March 15, 2012 (check 1000087396) $ 80,208.00 TOTAL RECEIPTS $ 90,108.00 DISTRIBUTION: Sheriff's Costs: $ 2,818.68 State Transfer Tax: $ 1,314.00 Local Transfer Tax: $ 1,314.00 Robin Sollenberger - Local Tax Collector: $ 391.18 North Middleton Authority - Water & Sewer $ 168.72 Refund of advance costs to Attorney Mark Udren $ 1,500.00 Paid to PNC Bank Mortgage (writ no. 2010-3026 Civil Term) $82,601.42 Total Distribution: ($90,108.00) Balance 0.00 S sw r Ronny R. Anderson Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-3026 Held March 7, 2012 EFFECTIVE DATE: March 7, 2012 PREMISES: 1875 Douglas Drive, North Middleton Township, Cumberland County, Pennsylvania, Tax Parcel No. 29-16-1094-359 (the "Premises") RECITAL: Being the same Premises which Ahmad Bayat and Hosniah Bayat, his wife, by their deed dated September 28, 2005 and recorded September 30, 2005 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 271, Page 1101, granted and conveyed unto Brian M. Heller and Jennifer N. Heller, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal.. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2012. 20. Mortgage in the amount of $95,750.00 from Brian M. Heller and Jennifer N. Heller to National City Mortgage Co. dated September 28, 2005 and recorded September 30, 2005 in Mortgage Book 1925, Page 598. -2- 21. Mortgage in the amount of $10,000.00 from Brian M. Heller and Jennifer N. Heller to National City Bank dated October 23, 2006 and recorded November 15, 2006 in Mortgage Book 1972, Page 4802. 22. Judgment against Brian M. Heller and Jennifer N. Heller in the amount of $101,728.09 entered February 9, 2009 in favor of National City Mortgage entered to No. 2008-7355. 23. Judgment against Brian M. Heller and Jennifer N. Heller in the amount of $118,305.61 entered August 30, 2010 in favor of PNC Bank, NA to No. 2010-3026. 24. Judgment against Jennifer Heller, John Laverty and Safe Harbour in the amount of $2,070.25 entered June 28, 2010 in favor of Seneca Street Partnership to No. 2010-4249. 25. Subject to all setback lines, easements, notes and all other matters appearing on the plan of Section No. 12 of Noll Manor recorded in Plan Book 39, Page 30. 26. Subject to the Declaration recorded in Misc. Book 283, Page 310. 27. Subject to the rights granted Keystone Pipeline Company in Misc. Book 67, Page 60. 28. Subject to the rights granted PPL in Misc. Book 115, Page 202, Misc. Book 244, Page 490 and Misc. Book 287, Page 317. 29. Subject to the rights granted PPL and Bell or Bell of PA in Misc. Book 209, Page 203 and Misc. Book 266, Page 292. 30. Subject to the rights granted United Telephone Company of Pennsylvania in Misc. Book 270, Page 562 and Misc. Book 317, Page 626. 31. Subject to the Grant Agreement in Misc. Book 697, Page 3525. 32. Subject to the rights of others in and to any portion of the Premises adjoining Douglas Drive. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: IL?\-? Keith O. Brenneman -3- Writ No. 2010-3026 Civil Term PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller and Jennifer N. Heller Atty.: Paige Bellino ALL THAT CERTAIN tract of parcel of land and premises situate, lying and being in North Middleton eTn Town- ship, Cumberland County, P vania, bounded and described as follows: BEING Lot No. 103 on the resub- division plan of Section 12 of Noll Manor, as recorded in the office of the Recorder of Deeds for Cumber- land County in Plan Book 39, Page 30; containing 148.42 feet along the north along Lot No. 102, Section 12, containing 47.503 feet along the east 8; contain along Noll Manor, Section the south along contain- ing 148.94 feet along and Lot No. 104, Section 12*1 the west along ing 47.50 feet along Douglas Drive as shown on the Plan lent CONTAINING 7,062 square and being improved with a town- house Drive, Carlisle, Penn- 1875 Douglas . sylvania BEING KNOWN AS: 1875 Douglas Drive, Carlisle, PA 170129 16-1094- PROPERTY ID NO.: 359. TITLE TO SAID PREMISES IS VESTED IN Brian M. deed from Ahura. Heller and wife Bayat, hmad Bay his wife dated 9/28/2005 recorded 9/30/2005 in Deed Book 271 Page 1101. EXHIBIT A SHERIFF'S OFFICE OF CUMBERLAND COUNTY .Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor' PNC Mortgage vs. Brian M. Heller (et al.) Case Number 2010-3026 SHERIFF'S RETURN OF SERVICE 12/29/2011 03:45 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1875 Douglas Drive, Carlisle, Cumberland County, PA 17013. 01/18/2012 Affidavit of Service to Lien holders Filed in Sheriffs Office 03/16/2012 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, CumberlandCounty, Pennsylvania on March 7, 2012 at 10:00 AM. He sold the same for the sum of $84,000.00 to Jeremy Hess on behalf of CJD Group, LLC. CJD Group, LLC at 1770 Oregon Pike, Lancaster, PA 17601, being the buyer in this execution, paid to the Sheriff the sum of $88,608.00. SHERIFF COST: $2,818.68 March 16, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF Sipe of Tofle'-atT I'ic UDREN•LAW OFFitES, 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 Bank Mortgage, a division :COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller -:NO. 10-3026 Jennifer N. Heller Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank Mortgage, a division of PNC Bank NA, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1875 Douglas Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Jennifer N. Heller 107 West Hig] Carlisle, PA 1875 Douglas Carlisle, PA 2. Name and address of Defendant(s) in the Name Address SAME AS #1 ABOVE z Street, Room 213 17013 Drive 17013 judgment: 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address h Seneca Street Partnership P.O. Box 337 Shippensburg, PA 17257 4. Name and address of the last recorded holder of every mortgage of.record: Name Address PNC Bank Mortgage, a division 3232 Newmark Drive of PNC Bank NA Miamisburg, OH 45342 National City Bank 6750 Miller Road Brecksville, OH 44141 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 Address 1875 Douglas Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating unsworn falsification to authorities. NZ? v? 14) DATED: 9s*? a -- , 2011 UDREN LAW OFFICES, P.C. BY: - A orney for Plaintiff ? ("'-k - 1 Courthouse Square Carlisle, PA 17013 13 N. Hanover 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 IN 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 Bank Mortgage, a division ::COURT OF COMMON PLEAS of PNC Bank NA :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Brian M. Heller -:NO. 10-3026 Jennifer N. Heller Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Brian M. Heller 1875 Douglas Drive Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN. LAW *OFF'ICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank Mortgage, a division of PNC Bank NA Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Brian M. Heller Jennifer N. Heller Defendant(s) NO. 10-3026 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jennifer N. Heller 107 West High Street, Room 213 Carlisle, PA 17013 Your house (real estate) at 1875 Douglas Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriff's Sale on March 7, 2012, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $118,305.61, 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 canceled 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 tc 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 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRACT OF PARCEL OF LAND AND PREMISES SITUATE, LYrING AND BEING IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 103 ON THE RESUBDIVISION PLAN OF SECTION 12 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 39, PAGE 30; CONTAINING 148.42 FEET ALONG THE NORTH ALONG LOT NO. 102, SECTION 12, CONTAINING 47.503 FEET ALONG THE EAST ALONG NOLL MANOR, SECTION 8; CONTAINING 148.94 FEET ALONG THE SOUTH ALONG LOT NO. 104, SECTION 12; AND CONTAINING 47.50 FEET ALONG THE WEST ALONG DOUGLAS DRIVE AS SHOWN ON THE PLAN. CONTAINING 7,062 SQUARE FEET AND BEING IMPROVED WITH A TOWNHOUSE KNOWN AS AND NUMBERED 1875 DOUGLAS DRIVE, CARLISLE, PENNSYLVANIA. BEING KNOWN AS: 1875 DOUGLAS DRIVE CARLISLE, PA 17013 PROPERTY ID NO.: 29-16-1094-359 TITLE TO SAID PREMISES IS VESTED IN BRIAN M. HELLER AND JENNIFER N. HELLER, HIS WIFE BY DEED FROM AHMAD BAYAT AND HOSNIAH BAYAT, HIS WIFE DATED 9/28/2005 RECORDED 9/30/2005 IN DEED BOOK 271 PAGE 1101. WRIT OT EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-3026 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK MORTGAGE, A DIVISION OF PNC BANK NA, Plaintiff (s) From BRIAN M. HELLER, 1875 DOUGLAS DRIVE, CARLISLE, PA 17013 AND JENNIFER N. HELLER, 107 WEST HIGH STREET, ROOM 213, CARLISLE, PA 17013 (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: $118,305.61 L.L.: Interest from 8829/10 to Date of Sale March 7, 2012 ongoing per diem of $17.59 - $9,797.63 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $1,058.39 Other Costs: Plaintiff Paid: Date: 11/8/11 --' ? IL David D. Buell, Prothonotary (Seal) ?Y ?.p ?C?.QiLt Deputy REQUESTING PARTY: Name: PAIGE M. BELLING, ESQUIRE Address: UDREN LAW OFFICES, P.C. TRUE COPT FROM RECORD In Testimony ,vheraof' l here unto set my hand WOODCREST CORPORATE CENTER and the al of said Court at Carlisle, Pa. 111 WOODCREST ROAD, SUITE 200 This day °f ?' 201"-- Prothonotary CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 309091 On November 15, 2011 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 1875 Douglas Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date November 15, 2011 By: Rea Estate Coordinator 0 1 :3 V b - AN 1101 CUMBERLAND LAW JOURNAL Writ No. 2010-3026 Civil Term PNC Bank Mortgage, a division of PNC Bank NA VS. Brian M. Heller and Jennifer N. Heller Atty.: Paige Bellino ALL THAT CERTAIN tract of parcel of land and premises situate, lying and being in North Middleton Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEING Lot No. 103 on the resub- division plan of Section 12 of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumber- land County in Plan Book 39, Page 30; containing 148.42 feet along the north along Lot No. 102, Section 12, containing 47.503 feet along the east along Noll Manor, Section 8; contain- ing 148.94 feet along the south along Lot No. 104, Section 12; and contain- ing 47.50 feet along the west along Douglas Drive as shown on the plan. CONTAINING 7,062 square feet and being improved with a town- house known as and numbered 1875 Douglas Drive, Carlisle, Penn- sylvania. BEING KNOWN AS: 1875 Douglas Drive, Carlisle, PA 17013. PROPERTY ID NO.: 29-16-1094- 359. TITLE TO SAID PREMISES IS VESTED IN Brian M. Heller and Jen- nifer N. Heller, his wife by deed from Ahmad Bayat and Hosniah Bayat, his wife dated 9/28/2005 recorded 9/30/2005 in Deed Book 271 Page 1101. 43 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 27, February 3, and February 10, 2012 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. a'- sa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 10 da of Februg 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 AO- The Patriot-News Co. 2020 Teciinclogy Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Z4( ?latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: Sworn to a"bscribed b or tl}* 24 of ?ebbruary, 2012 A.D 'T C .? ?- -? Notarv Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2015 01/27/12 02/03/12 02/10/12 MEMBER. 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Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which CJD Group LLC is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 8 day of November, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 3026, at the suit of PNC Bank Mortgage against Brian M. Heller and Jennifer N. Heller is duly recorded as Instrument Number 201212107. IN TESTIMONY WHEREOF, I have hereunto set my hand ZZI and seal of said office this cs day of A.D. 07© 46ReCorder of Deeds lend taoui? t?nllele, PA My U FM rdondq, olden. 2m4