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Home My WebLink About10-3218 Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 .i1'vlichele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 234359 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 v. Plaintiff DANIEL SHIELDS CONNIE SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013-2538 Defendants File #: 234359 F1~ED--f:~ -.r,~ ZO{Q f~AY { 4 Pik 3~ ~~ CUP~~ ~ ~ :~NTY '~ P-d'~ti 5 ~LL`f'~ti ~ ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. (O -30218 Ctvil~~ CUMBERLAND COUNTY ~9 a. oo PA A-rM ~~ ~soa~~ ~2,~ a ya ras NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800)990-9108 File #: 234359 Plaintiff is THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 4828 LOOP CENTRAL DRIVE HOUSTON, TX 77081-2226 2. The name(s) and last known address(es) of the Defendant(s) are: DANIEL SHIELDS CONNIE SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013-2538 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/26/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR WMC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1916, Page 3515. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 02/01 /2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 234359 6. The following amounts are due on the mortgage: Principal Balance Interest 01/01/2009 through 05/13/2010 Attorney's Fees Cumulative Late Charges 07/26/2005 to 05/13/2010 Costs of Suit and Title Search Escrow Deficit TOTAL 7. $66,711.39 $6,418.18 $650.00 $177.38 $550.00 $i2, 4 (1~ $76,748.97 Plaintiff is nQt seeking a judgment of personal liability (or an in near. ~nam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 234359 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $76,748.97, together with interest from 05/13/2010 at the rate of $14.62 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: a ence helan, Esq., Id. No. 32227 F ancis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 234359 LEGAL DESCRIPTION ALL those certain two tracts of land with the improvements thereon erected situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: TRACT A: BEGINNING at a point on the southern line of East North Street, which point is at the corner of land now or formerly of Frank T. Adams and Lester F. Adams; thence southwardly along said land 61 feet to a point in line of land now or formerly of the John Spahr Estate; thence westwardly along land of the latter 28 feet to a point in line of lot now or formerly of Dewey W. Bernheisel and Hilda Bernheisel, his wife; thence northwardly along line of lot of the said Dewey W. Bernheisel and Hilda Bernheisel, his wife, and through the center of a partition wall erected between the house built on the lot herein being conveyed and the house on the lot of the said Dewey W. Bernheisel and Hilda Bernheisel, his wife, 61 feet to a point on the southern side of East North Street; thence eastwardly along the southern side of said East North Street; 28 feet to a point, the Place of BEGINNING. BEING improved with a frame dwelling house and other improvements and known as 248 East North Street. TRACT B: ALL THAT CERTAIN lot of ground situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, and more particularly bounded and described in accordance with a Subdivision Plan prepared by Thomas A. Neff, Registered Surveyor, which said Subdivision Plan as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 36, Page 134, as follows: BOUNDED on the North by land now or formerly of Richard A. Keller and Margaret V. Keller, his wife; on the East by land now or formerly of Roy W. Shearer; on the South by land now or formerly of Clara F. Fahnestock; on the West by Lot No. 3 on the hereinabove mentioned Subdivision Plan. BEING Lot No. 4 on the hereinabove mentioned Subdivision Plan and containing 485.24 square feet. BEING the same premises which John C. Myers and Anna M. Myers, husband and wife, by deed dated June 4, ]999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 201, Page 40, granted and conveyed unto Linda J. Jumper, Grantor herein. PREMISES BEING: 248 EAST NORTH STREET PARCEL#: 02-21-0318-183 File #: 234359 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to DATE: File #: 234359 AUG 0 ~ ~p;y ~ IN THE COURT OF CONIlVION PLEAS CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005- 1 vs. DANIEL SHIELDS CONNIE SHIELDS Civil Division No. 2010-3218 cn ~' ,~- ~` ~E. ;. -t .;=_. ~ ~,'. ~_. ~ ~., ter. ORDER AND NOW, this `~ day of Gt ~~ , 2010, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendants, DANIEL SHIELDS and CONNIE SHIELDS, by: 1. Posting of the premises: 248 EAST NORTH STREET, CARLISLE, PA 17013-2538 by the Sheriff or a non-party competent adult; 2. First class mail to DANIEL SHIELDS and CONNIE SHIELDS at the last known address, PO BOX 906, CARLISLE, PA 17013-5906, and the mortgaged premises located at 248 EAST NORTH STREET, CARLISLE, PA 17013-2538; and 3. Publication in accordance with PA. R.C.P. 430. ., ~ f~ 2 It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY T O RT: J. cc: DANIEL SHIELDS and CONNIE SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013-2538 DANIEL SHIELDS and CONNIE SHIELDS PO BOX 906, CARLISLE, PA 17013-5906 PHS# 234359/ARM e~Py m.Y~ lam(, A.~ e :~,J B~N~iv ~r/l 3 OF 31 s Z14 y nag) COCO ??,?YLVlS? ,?? I'hclan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, 1,,sq., Id. No. 597,15 Shcetal R. Shah-Jani, Esq., Id. No. 81760 %/(enine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jav 11. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. 13ramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 15-563-70_00 THE BANK OF NEW YORK MEI,LON F/K/A T1 IF BANK OF NEW YORK, AS TRUSTEE FOR TI-11", HOLDERS OF TI-II; GE-WMC ASSET-BACKED PASS-THROUGH CERTIF[CA1'IS, SERIFS 2005-1 Plaintiff vs. DANIEI, SHIELDS CONNIF, SHIELDS Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 10-3218-CIVIL-TERM PRALCIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE 410 . oo P 10 A'rI l CVQg5O'7q FO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PI-MAN HALLINAN & SnIMIEG, UP fly: ? La once P Zelan, Esq. d. No. 32227 ? Fra is S. Hallman, Esq., Id. No. 62695 ? Dan el G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 . udith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. "babas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaimc McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff Date: Au?-Ltst 23, 2010 /arm, Svc Dept. File# 234359 r GF Vic . -". `-TARY 11 0 AUG 31 AM 10: 31 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PENNSYLVANIA ATTORNEYS FOR PLAINTIFF THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 Plaintiff vs. DANIEL SHIELDS CONNIE SHIELDS Defendants COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 2010-3218 AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following persons, DANIEL SHIELDS and CONNIE SHIELDS at 248 EAST NORTH STREET, CARLISLE, PA 17013-2538; PO BOX 906, CARLISLE, PA 17013-5906 on August 30, 2010, in accordance with the Order of Court dated August 3, 2010. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date: August 30, 2010 PHY`L)YN HALLINAN & SCHMIEG, LLP I aw erlce T. Phelan, Esq., Id: No. 32227 cis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Ju 'th T. Romano, Esq., Id. No. 58745 S eetal R. Shah-Jani, Esq., Id. No. 81760 /enine R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~ntr of ~~f~b~~^~, ~~' . ~-: (?rF~IGE ~' I' '~~E &r4RIRF fl(~D-4~~=r-'' t3F ~F~G Pub ~ ~~~lOTA~iYY ~~ ~;~?~ 3 i PAS I~ 07 CUM~E.~L~"1D~ /~~~~J~ ~UN'(Y [" G ~~~~~Y/'Y Y~1 The Bank of New York Mellon vs. Daniel Shields (et al.) Case Number 2010-3218 SHERIFF'S RETURN OF SERVICE 08/27/2010 11:56 AM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2010 at 1156 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Daniel Shields, pursuant to order of court by posting the premises located at 248 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. DENNIS F ,DEPUTY 08/27/2010 11:56 AM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2010 at 1156 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Connie Shields, pursuant to order of court by posting the premises located at 248 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. DENNI RY, DEPU SHERIFF COST: $61.40 August 30, 2010 SO ANSWERS, ~~^^,~ RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft. Inc. ~- f_~ ~::.. u.~ ~.. ,:.~ ~ o -'' ' u CO ~~-.,. „ ~~r ~i~ 1 Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 -Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ] 617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. DANIEL SHIELDS CONNIE SHIELDS No. 10-3218-CIVIL-TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE -~ 10 . oo P q A'1'-''1 C~ 10056!9 2#~y8588 TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHEL HALL N & SCHMIEG, LLP By: ^ Lawrence T. Ph ,Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ udith T. Romano, Esq., Id. No. 58745 [~ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff Date: September 20, 2010 /arm, Svc Dept. File# 234359 r'w'~~ FiL.~-O~FIC~ 13~ TNT F~t~TN0~i0~ARY Phelan k-Iallinan &Schmieg, LLP k~awrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 Plaintiff vs. DANIEL SHIELDS CONNIE SHIELDS Defendants ZQ10 Cl~~' 23 P+1 2~ L'~3 CiIM~ER~.AND C~l9~TY ~~~~sY~vA~ai~ ATTORNEYS FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No. 10-3218 AFFIDAVIT OF SERVICE BY PUBLICATION 1N ACCORDANCE WITH COURT ORDER ~" r ~..v I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the Court Order dated August 3, 2010 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)(1) in The Sentinal on Member 1, 2010 and The Cumberland Law Journal on September 10, 2010. Proofs of the said publications are attached hereto. 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. PHELAN HALLINAI~Br.SC~G, LLP By: Phelan Hall' Schmieg, LLP Lawren helan, Esq., Id. No. 227 Francis . Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff Date: September 22, 2010 PHS #:234359 i ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW 30URNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 ..---. is Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 10 day of September, 2010 !~ J Notary NOTARIAL 8EAl DEBORAH A COLLIN8 NoNAry- PdWk BOROtJ8F1. CtM~BERLAND CDtI111Y Mft CoA~ialo~ E~OUa AOr ~. Z81~ 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 September 10, 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. i~3~ sA~NA1s~i'! 2Vit.t 3E3~ A MJ~NflB~Q ~il~u~l Y~itnN Y`IIUQ~ itNli~ii381ulUy .Ne')tWAQB 3J81.iA ~tOS .SS aµ asuq~c3 no~t~dm~o~ ~M .. i CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTQA(iE FORECL08URE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 2010-3218 THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 vs. DANIEL SHIELDS, CONNIE SHIELDS NOTICE To DANIEL SHIELDS and CONNIE SHIELDS: You are hereby notified that on May 14, 2010, Plaintiff, THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK, AS TRUST- EE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1, filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUMBERLAND County, Pennsylvania, docketed to No. 2010-3218. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 248 EAST NORTH STREET, CAR- LISLE, PA 17013-2538 whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. NOTICE ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that ifyou fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 SERViCE5 TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 Sept. 10 If you wish to defend, you must enter a written appearance person- PROOF OF PUBLICATION State of Pennsylvania, County of C~.tmberland Tames Kleinklaus Director of Sales and MazketinQ, 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 Cazlisle, County and State aforesaid, was established December 13,1881, 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): September 1, 2010 COPY OF NOTICE OF PUBLICATION 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 character of publication are true. /~oo, ~ Sworn to and subscribed before me this ~~ ~~ WlJ `~«(-Ci+`(.~~~t-W~JI~ Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notuy Public CARLISLE 80ROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 ~ ,____ 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 13~, 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): September 1, 2010 COPY OF NOTICE OF PUBLICATION NpTI(~ tIF ACTION 1N MOATQAClE FORECL08URE iRT11E`CdURT CAF CtIMMON FLEAl3 ¢FCIiMlI~ALANQ CO!lNTY, P~NNBYLYANIA CIVIL At:71DN = LAtN THE BANK OF NEW'~'bRK ~riEL£ON ~ COURT OF COMMON RLE~AS ,,,, FAVA THE BANK OF NEW YORK, AS TRUSTEE FOta THE MOLDERS OF THE CIVIL DIVISION GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES200b=1 CUMBERLAND COUNTY ., . Vs. j N0.2010-8218 DANIEL SHIELDS CONNIE SHIELDS. NOTICE To DANIEL SHIELDS and CONNIE SHIELDS: You are he notified that on ~ TH 6 Plaintiff, THE BANK OF NEW YORK MELLON FlK/A THE BANK OF NEW Y AS TRUSTEEf R THE H LDERS OF THE QE-WMC ASSET-BAG~ICED PASS-THROUGH CERTIFICATES, SERIES 2005.1, }fled a Mortgage Foreclosure Complaint endoraed,with a Notice to Defend, aggainst you in the Court of Common Pleas of CUMBERLAND Couttty PennsyNShiM, to No. 2010-3218. . VJhephr'Alaln~ seeks to foreclose on the mortgage secured on your property IocatedEAST NORTH STREET, CCARLISLE, FA 97013-2538 whereupon your property would be-sold by.~a S11erfQ At CUMBERLAND County, ' You are hereby nolNied to plead to the above referenced Complaint on or.before 20,days from the date of this , ,publication or a Judgment wig be entered against you. NOTICE If you wish to defend, you must solar a written appearance personally or by attorney and file yyo~ur d®fenses or objections in writingwiltl the court. You are warned that H you faA to do so the ~~e~may proceed wiffiout you and a judgment maybe entered ~ you without further notice for the relief requested by the pfalntlff. You may lode money or properrttyy pprr other imppoor~taBnnt to you. - YOU SHOULD T 'THIS .}NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO"NOT HAVE A LAWYER, GO TO OR TELEPHANE THE QFFICE SET FORTH BELOW. THIS OFFICE CAN RROVIDE YOU WITH j-yFORMATION ABOUTHII;IMG A LAWYER. IF YOU ClWN01'AfFORD TO HIRE A LAWYER, THIS OFFICE MAY $E.ABLE TO PRQVIDE YOU WITH INFORMATION AEfOUT AGEAICIES THAT MAY OFFER LEGAL SERVICES TO EL IBLEI~ERSONS AT A REDUCED FEE-0R NO FEE: ~ , ., . ;CUMBEAIANQ:CdDUNTY . `~ 1;AWIFER' REFERf~AL SERVICE ` ~ CURI:AND:COUNTY'BltRtitlsf80CIATKN~I 32 SOUTH BEDPORf,IBTREET ~ ~97ARLIBLE,PA 17013' . (8t>I!} 990-9108 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 character of publication are true. A, ,-.. Sworn to and subscribed before me this ~~ ~~V ~~~ ~~ Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 " L 'En-OFFICE OTHONOTARI i Ii,J''J`_21 AM 10: 13 ERLAND COUNTY ;PENNSYLVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 V5. DANIEL SHIELDS CONNIE SHIELDS Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . No. 10-3218-CIVIL-TERM Qtwk •1y. 00 ?d a Ck *' hubwS Q??vaily tA PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DANIEL SHIELDS, and CONNIE SHIELDS, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $76,748.97 Interest - 05/14/2010 to 07/19/2011 $6,315.84 TOTAL $83,064.81 I hereby certify that (1) the Defendants' last known addresses are PO BOX 906, CARLISLE, PA 17013-5906 and the mortgaged premises 248 EAST NORTH STREET, CARLISLE, PA 17013-2538, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date 7-- ?-?C) ` { 1 Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallman, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jam, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Co enay R. Dunn, Esq., Id. No. 206779 ? ison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Schemer, Esq., Id. No. 308912 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS # 234359 PROTHONOTARY 234359 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Schemer, Esq., Id. No. 308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 VS. DANIEL SHIELDS CONNIE SHIELDS Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-3218-CIVIL-TERM 234359 AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DANIEL SHIELDS is over 18 years of age and the Defendant's last known addresses are PO BOX 906, CARLISLE, PA 17013-5906 and the mortgaged premises 248 EAST NORTH STREET, CARLISLE, PA 17013-2538. (c) that defendant CONNIE SHIELDS is over 18 years of age and the Defendant's last known addresses are PO BOX 906, CARLISLE, PA 17013-5906 and the mortgaged premises 248 EAST NORTH STREET, CARLISLE, PA 17013-2538. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date 7- o 0- Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallman, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 lison F. Wells, Esq., Id. No. 309519 YWilliam E. Miller, Esq., Id. No. 308951 ? Melissa J. Schemer, Esq., Id. No. 308912 Attorney for Plaintiff 234359 (Rule of Civil Procedure No. 236) - Revised THE BANK OF NEW YORK MELLON F/K/A CUMBERLAND COUNTY THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC COURT OF COMMON PLEAS ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 VS. DANIEL SHIELDS CONNIE SHIELDS . CIVIL DIVISION . No. 10-3218-CIVIL-TERM Notice is given that a Judgment in the above captioned matter has been entered against you on ? By: 'Mwoooooor MW If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? lison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 ? Melissa J. Schemer, Esq., Id. No. 308912 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIEN AGAINST PROPERTY." 234359 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 v. Plaintiff DANIEL SHIELDS CONNIE SHIELDS Defendant(s) TO.- CONNIE SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013-2538 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-3218-CIVIL-TERM CUMBERLAND COUNTY DATE OF NOTICE: L THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO _IVY PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. MPORTANT 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 RIGI-ITS. YOU SHOULD TAKE T14IS 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. PHS # 234359 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-316 -"rawrence 1, Phelafi?Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 6269 Daniel G. Schmieg, Esq., Id. No. 622 5 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 -'Allison F. Wells, Esq., Id. No. 308915 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 -- -- ..._o, r,. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS N 234359 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR. THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 V. Plaintiff DANIEL SHIELDS CONNIE SHIELDS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-3218-CIVIL-TERM CUMBERLAND COUNTY TO: CONNIE SHIELDS PO BOX 906 CARLISLE, PA 17013-5906 DATE OF NOTICE: R f THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL F.L ,$LQ_FQR TAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. PHS # 234359 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 1701.3-- (717 B. nce T. Phelan, Esq., Id. No. 3 27 Francis S. Hallinan, Esq., Id. No. 62 5 Daniel G. Schmieg, Esq., Id. No. 6 05 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ---;(I-Iison F. Wells, Esq., Id. No. 308915 William E. Miller, Esq., Id. No. 308951 Melissa T. SQ(ejUer, Esc., Id No 308912 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 234359 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 Plaintiff V. DANIEL, SHIELDS CONNIE SHIELDS Defendant(s) TO: DANIEL SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013-2538 COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-3218-CIVIL-TERM CUMBERLAND COUN'T'Y DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO TIE _ - ..T..__ . _. _ , PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 BFL,OW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 234359 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 1 3I (717 - 16 L-- awreffce T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 6220 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 An rew C. Bramblett, Esq., Id. No. 208375 ,,Allison F. Wells, Esq., Id. No. 308915 William E. Miller, Esq., Id. No. 308951 MPLiNsa-I,r h in r, Esq., Id No 308912 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 234359 THE BANK. OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-I Plaintiff V. DANIEL SHIELDS CONNIE SHIELDS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-3218-CIVIL-TERM CUMBERLAND COUNTY TO: DANIEL SHIELDS PO BOX 906 CARLISLE, PA 17013-5906 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE __ __ _ U IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED AT-_"" ° _. . PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE W 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 IIAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 234359 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 242.1 ; '"'' -- 4,vvv1Snce T. Phe , No. 32227 Francis S. Hallinan, Esq., Id. . 2695 Daniel G. Schmieg, Esq., Id. No. 205 Michele M. Bradford, Esq., Id. N . 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 (Allison F. Wells, Esq., Id. No. 308915 William E. Miller, Esq., Id. No. 308951 _ ._ _.,. __.. ___---- ,..?.... ._____ Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS 9 234359 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Allison F. Wells, Esquire, Id. No. 309519. s " 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza °E Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET- BACKED PASS-THROUGH CERTIFICATES, COURT OF COMMON PLEAS SERIES 2005-1 Plaintiff VS. DANIEL SHIELDS CONNIE SHIELDS Defendant To the Prothonotary: CIVIL DIVISION CUMBERLAND COUNTY No. 10-3218-CIVIL-TERM WITHDRAWAL OF APPEARANCE Kindly withdraw my appearance on behalf of Plaintiff, THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1. Phelan Hallinan & Schmieg, LLP Date: B Alliso . W uire, Id. No. 309519 r Plaintiff PHS # 234359 t? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID #309091 HARRY B. REESE, ESQUIRE - ID #310501 ANY GLASS, ESQUIRE - ID #308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH WASSALL, ESQUIRE - ID#7778 ELANA FLEHINGER, ESQUIRE - ID#209197 AGNES MOMBRUN, ESQUIRE - ID#309356 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com THE BANK OF NEW YORK MELLON :COURT OF COMMON PLEAS F/K/A THE BANK OF NEW YORK, :CIVIL DIVISION AS TRUSTEE FOR THE HOLDERS OF `CUMBERLAND County THE GE-WMC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-1 :NO. 10-3218-CIVIL-TERM Plaintiff V. DANIEL SHIELDS CONNIE SHIELDS 248 EAST NORTH STREET CARLISLE, PA 17013 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Harry B. Reese, Esquire; Elizabeth Wassall, Esquire; Elana Flehinger, Esquire; and Agnes Mombrun, Esquire on behalf of the Plaintiff, THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK, AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-1 in the above-captioned matter. UDREN LAW OFFICES, P.C. BY: KASSIA FIALKOFF, ESQUIRE PA ID 310530 11120799-1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York, as Trustee for the CIVIL DIVISION c Holders of the GE-WMC Asset-Backed CUMBERLAND County -0a Pass-Through Certificates, Series 2005-1 rn Plaintiff MORTGAGE FORECLOSURE V. r—'= --q p NO. 2010-03218 3>°, o--''..3 CONNIE SHIELDS v DANIEL SHIELDS, o Defendant(s) VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she 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 sent by certified mail and regular first class mail as follows: TO: CONNIE SHIELDS DANIEL SHIELDS 248 EAST NORTH STREET, CARLISLE, PA 17013-2538 P.O. BOX 906, CARLISLE, PA 17013-5906 DATE MAILED: March 11,2013 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:�-f�� ,2013 UDREN LAW OFFICES, P.C. BY: l Attorn for P aintiff MJU#: 11120799 CASE#: 11120799-1 Nicole LaBleftal Esquire PA ID • AUG 0 J-Z0,.q IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK,AS TRUSTEE - -- -_, FOR THE HOLDERS OF THE GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005- 1 Civil Division VS. No. 2010-3218 DANIEL SHIELDS CONNIE SHIELDS ORDER AND NOW,this day of Gt d-6_ 2010,upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of Court,it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendants,DANIEL SHIELDS and CONNIE SHIELDS, by: 1. Posting of the premises: 248 EAST NORTH STREET, CARLISLE, PA 17013-2538 by the Sheriff or a non-party competent adult; 2. First class mail to DANIEL SHIELDS and CONNIE SHIELDS at the last known address,PO BOX 906,CARLISLE, PA 17013-5906, and the mortgaged premises located at 248 EAST NORTH STREET, CARLISLE,PA 17013-2538; and 3. Publication in accordance with PA. R.C.P. 430. 2 It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY T O T: J. cc: DANIEL SHIELDS and CONNIE SHIELDS 248 EAST NORTH STREET. CARLISLE,PA 17013-2538 DANIEL SHIELDS and CONNIE SHIELDS PO BOX 906,CARLISLE,PA 17013-5906 PHS#234359/ARM Py AIA 3 LLP 00 a M a N N ce) . O r Q . t!1 � Q. M ` �C uj m O o0 c`a v► 63 tat N U __ • m m m� li m • c7 ¢c p c � �Z 2 �� = iE d :m va :v�o :U fi29G fi9Sfi 2000 Ofi9T 2TO?- fi290 fi95fi 2000 Dh9T 2'CU i UDRow 1,A►W Orple s, 01$H2$519216 WOODCREST CORRORATE CENTER i WOO CR'.NJ R 03, 06. 112 CHER 03/11/2013 pit Mailed From 08003 e r �f i � _ E US P08)THVE 3NIM .. . i 1Q�Xl�-L TO: Connie Shields 248 East North Street Carlisle,PA'170I3 h.t ¢¢ o r3 01 � • r N E3 E3 «� OD o' Q ertified Mail Pmvidet; .. U A mailing receipt E A unique identifier for your mailpieca I' ,. E ru A record of delivery kept by the Postal Service for two years g nportant Reminders: s F � � 1 E i Certified Mail may ONLY be combined with Firstivts`s�`MI 40_it P;.*Maim., CO i Certified Mail is not available for any class of international mail. ° in i NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For i. `9 g valuables,please consider Insured or Registered Mail. a For an additional fee,a Return Rece t may be requested to provide proof of t' m rLI delivery.To obtain Return Receipt service,please complete and attach a Return f. @ $ C3 Receipt(PS Form 38111 to the article and add applicable postage to cover the vi a fee.Endorse mailpiece Return Receipt Requested'.To receive a fee waiver for ' ro r @ cc C3 a duplicate return receipt,a USPSe postmark on your Certified Mail receipt is ? �t = Q required. ? d x d t3 E i For an additional fee, delivery may be restricted to the addressee or addressee's authorized a 2a�nt.Advise the clerk or mark the mallpiece with the endorsement"Restricted Detfva r 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. co 0 * MPORTANT.Save this receipt and present it when making an inquiry. N 3S Fo m 3800,August 2006(Reverse)PSN 7630-02-000-9047 = E • �. NQ Cl) cr) 00 04 �m m � m ca 2 pj t3'LS i y of .� UJ .D .� 0 CO O .d Co LL Er- ? -� C3NU cis � d a _ pp is. C�m f]� vii Q `o IL" 399 t SO.d sn £{logo Ui01:1 paliew to o w90 %M99ZHM £IOLi'6�d`ats{Iats� Is'89 8tlz WPM MUR(l :01 �� ,... J-.r,-un�.__.z��7.YC+- ter.��,i x ni,►� _ _.�...� PLACE STICKER AT TOP OF ENVELOPE TO THE RIGHT OF THE RETURN ADDRESS,FOLD AT 6O TED LINE CERTIFIED MAILrn, 1111111 IN 1111 i i oil 1 lii f i _ il v c =' .nN 00090 PN` 1111H�fA�/�+I�U31143 aXV8is",.,= 14Jom II.II.E 'OTSBOWO Mvi Nuan i } 1 i i N O N N N CD -.�..�.....w._.._.......^_._.. w N p m qq 001 00 0 Certified Mail Provides: w 0 r • A mailing receipt o E 3 1 • A unique identifier for your mailplece m S N ry p. Y Service for two years a ¢ • A record of delivery kept b the Postal important Reminders. k ., f, • g O r-3� • Certified Mail may ONLY be combfn d with Fjrg'.t-Cf�ss'•RA i4or kAifiy'MaiI,., JR 0 c❑� _n • Certified Mail is not available for any class of international mail. g Z • NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For � valuables,please consider Insured or Registered Mail a 75 > co • For an additional fee,a Return Receipt may be requested to provide proof of Ln delivery.To obtain Return Receipt service,please complete and attach a Return c Receipt(PS Form 3811)to the article and add applicable postage to cover the fee.Endorse mall 'ece'Return Receipt Requested'.To receive a fee waiver far vi ' ru a duplicate retumpreceipt,a USPSG postm postmark on your Certified Mail receipt is � � g } 0 ° required. rn = ❑❑ cc C3 • For an additional fee, delivery may be restricted to the addressee or : • ,K ¢i o addressee's authorized aggent.Advise the clerk or mark the mail piece with the � E endorsement"Restricted Delivery". C3 • 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. a r> o PS Form 3604,August 2006{Reverse)PSN 7530-02 000 9t}47 't6 � .. t • 8 W 0 N r` " m T C7 a m 0 X: W O ch E -a "C , I m S < • C) Z.0 Z0m N a p F 0)a0s r m m++ N Y d Uj N U -0 Ej• r_ 00 �' GNU oo E. r m m •- m!t= 3:Z — � � CD • 'EGrfO0 p C E U tFla r¢ i ¢ 9.. ti s0 Q ■ CV a. uj ca o= i ch N O 1 O Q N x LL �y y O o C m y us (fl O cC - m 0 m'Q m D 0 IL LLd.L'_' U m IL Tr CL �m .v mrn 1c Ea t EE mE p c m z L d:0 p lYC imp ;VI � Na a ;U i TE90 hQSh 2000 Oh9T 2TOL `CE90 hQSh 2000 Oh9T 2TOZ rLX� Vt 016H26519216 IJDREN LAW OFFICES,P.C. ` $06- 112. WOODCREST CORPORATE CENTER 03!11!2013 111 WOODCRLST ROAD Mailed From.08003 CHERRY HILL,NJ 08003 US POSTAGE TO: Connie Shields P.O.Box 906 Carlisle, PA 17013-5906 a[ -..� } i i j. �o y Q O } Z m ❑❑ v- ❑O 13 Certified Mail Provides: " m o _a • A mailing receipt • A unique identifier for your mailplece rl • A record of delivery kept by the Postal Service for two years ' m E M important Reminders: , r + , al • Certified Mail may ONLY be combined with `�rst l"a's Mack or i?riordy Mali•i v m 1:148 13 • Certified Mail is not available for any class of international mail. m • NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For' Lr) valuables,please consider Insured or Registered Mail. • For an additional fee,a Return Receipt ma be requested to provide proof of . m .m $ delivery.To obtain Return Receipt service,please complete and attach a Return I w '6 rU Receipt(PS Form 3811)to the article and add applicable postage to cover they o, } Z c C3 a fee.Endorse mailpiece'Return Receipt Requested".To receive a fee waiver for m m = 0 0 c d a duplicate return receipt,a USPS,a postmark on your Certified Mail receipt is, g required. d X ao o • For an additional fee, delivery may be restricted to the addressee or C3 addressee's authorized a ent.Advise the clerk or mark the maltplece with thq endorsement"Restricted-[Delivery" -0 • If a postmark on the Certified Mail receipt is desired,please present the art!-' m r q s? cle at the post office for postmarking. It a postmark on the Certified Mail d 0 7u receipt is not needed,detach and affix label with postage and mail. m > Q ru o rq IMPORTANT.Save this receipt and present it when making an inquiry. OE 6 � o E !' o tom! PS Farm 3800,August 2446(Reverse)PSN 7530-02-000-9047 U'in >+W O C 0 r O m0 °x' n- N v Ey CD E co in cC it v_i t? fl 0 .2 V Y 0 o cal Z � M ■ ■ ■ rn N a . �r i � y o co s rn a CO) o dm U �M p 'L - m- LL tL IL N LL m a • r �'¢ ma[ .o c is • U �c Oc N 2Z A - m rn =m I m d �¢o 'm CC 0 o mp r 'D w °[w rn M`o .0 _. . .._. ,.. _.� LT90 fi95b 2000 0fi9T 2T LT90 figgh 2000 Ofi9'C 21.02- UDkE+v,-AW OFFICES,P.C. MYCiUNNX" 016HMM216 WOODCREST wORPORATE CENTER 111 WOODCREST ROAD h $06. 110 CHERRY HILL,NJ 08003 Mailed From2 08003 r i US ruW AUC - IHMU 31-1101 U013AN330 dOl IV HEINOUS 33V-1d i fi t t t TO: Daniel Shields P.O. Box 906 Carlisle, PA 17013-5906 f j. N Y C Q Q d Z ® .. .. ... ._ ......__...._.._............. ._....._..... ❑ ❑ O 130 ❑ N C. O Certified Mail Provides: • A mailing receipt a c • A unique identifier for your mailplece E N • A record of delivery kept by the Postal Seryice for two years ' a Important Reminders: ;.' �. `* �+ � I • Y103 [� s Certified Mail may ONLY be combined with rftt-6i ss"i il'�oil Pripftty mail,&. '■ Certified Mail is not available for any class of international map. ty� • NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For U valuables,please consider insured or Registered Mail, n ru • For an additional fee,a Retum Recel t may be requested to provide proof of m I' delivery.To obtain Return Receipt service,please complete and attach a Return c Receipt(PS Form 3811 to the article and add applicable postage to cover the , fee.Endorse mailplece,-Return Receipt Requested°.To receive a fee waiver for qt = m ❑❑ O a duplicate return receipt,a USPSO postmark on your Certified Maii receipt is • required. d X W C i d' c • For an additional fee, delivery may be restricted to the addressee or S addressee's authorized agant.Advise the clerk or mark the mailplece with the endorsement"RestdctedZTelivery" o • if a postmark on the Certified Mail receipt is desired,please present the arti- m cis at the post office for postmarking. if a postmark on the Certified Mail nj receipt is not needed,detach and affix label with postage and mail. 4) a rn, oE° IMPORTANT:Save this receipt and present it when making an Inquiry. • E v o PS Form 3800,August 2006(Reverse}PSN 7534-02.040-9047 t/l OCOr to O � mN C•- — to , Y 00 13 0 ty" 'D E r Qi co t6 C � r�G3 i6 LD��-. a w $ Q .t � .ca Cl CL • A: c e_t E 'OD f R� >Itt{st Q Z w M w m i . fc g c« is o �_ " 0 pm c p L LL ca�o _to Q o d dr' ■ ■ ■ N a — — — — — 1 l THIS SECTION DELIVERY COMPLETE • ■ Complete items 1,2,and 3.Also complete A. Signature..; i � ❑Agent item 4 if Restricted Delivery is desired. X ❑Addressee ■.Print your name and address on the reverse so that we can return the card to you. D ate of Delivery ■ Attach this card to the back of the mailpiece; or on the front if space permits. D. Is delivery address different from item 1? ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No I i Daniel Shields P.O. Box 906 Carlisle, PA 17013-5906 Nservicre�T",peed M ❑Express Mail 0%W erect Return Receipt for Merchandise E3 Insured Mall ❑ •D• 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7Q12 164D DOD2 4584 X617 (!ransfer from service label) PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 IF.M."micis:00111M _ � q. Signature ❑Agent � late � C]Addressee and 3.Also comp X ■ Complete items 1,2, is desired. C. Date of Delivery Item 4 if Restricted Delivery on the reverse Printed Name) B. Received by ■ Print your name and address on to YOU- so 3 5 hem 1? 0 Yes so that we can r to ththe a k of the mailp different from ❑No ■ Attach this card to SP ace permits' p.Is delivery address address below: or on the front If YES,enter delivery 1. Article Addressed to: Connie Shields P O gox 906 7p13_5906 Service TypepressMail ,ertffied Mail�etum Receipt for Merchandise Carlisle,PA ❑Ftegutered ❑C.o.D. ❑Insured Mall ❑Yes 4. Restricted Delivery? ra Fee) 1313[1-2, 4584 13631 1640 102595A2-M 1540 2 Article Number (transfer from service label) pcmestic Return Receipt 3811, Ps Form February 2004 Name and ❑Registered Address UDREN LAW OFFICES, P.C. ❑Insured Of Sender 111 WOODCREST ROAD, SUITE 200 ❑Return Receipt for Check appropriate block for Affix stamp here if issued as Merchandise Registered Mail: certificate of mailing or for CHERRY HILL, NJ 08003 ❑COD El int'I Recorded Del. El With Postal Insurance additional copies of this bill. ATTN: Henni Crommarty ❑Certified ❑Express Mail ❑Without postal Insurance Postmark and Date of Receipt Line Article Name of Addressee Street and Post Office Address Postage Fee Handling Value d sure Due Sender R.R. S.D. S.H. Rst.Del.Fee , , Number Charge If COD Fee Fee Fee Remarks 1 2010-3218 Daniel Shields P.O. Box 906 Carlisle, PA 17013-5906 2 Connie Shields P.O. Box 906 Carlisle, PA 17013-5906 r C01 \'s 3 06/05/2013 Daniel Shields 248 East North Street �, L Carlisle, PA 17013-2538 N' 1 '.I'�, p 4 Connie Shields °; ;,p 248 East North Street = GV ~ P 10 Carlisle, PA 17013-2538 �, g= M t3, 5 c � 6 JalseH 7 8 ( �I 10 v r 11 12 13 — ----- -- 14 15 Total number of Pieces Total Numbe of Pieces Postma Per(Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail.The maximum indemnity payable for Listed by Sender Received at ost Office the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is$50,000 per piece subject to a limit of$500,000 per occurrence.The maximum indemnity payable on Express Mail merchandise is$500.The maximum indemnity payable is$25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,S913,and S921 for limitations of coverage on insured and COD mail.See International Mail Manual for limitations of—�kj 4 coverage on international mail.Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Daniel Shields and Connie Shields - MJU #11120799-1 (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 The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York, as Trustee for the CIVIL DIVISION Holders of the GE-WMC Asset-Backed Cumberland County Pass-Through Certificates, Series 2005-1 -�D 3 rn co Plaintiff NO. 2010-03218 r'' -<>CD -s. d CONNIE SHIELDS >n x' o DANIEL SHIELDS; et al o Defendant(s) � o PRAECIPE TO FILE PROOF OF PUBLICATION TO THE PROTHONOTARY: Kindly file the attached Proofs of Publication with regard to the captioned matter. Date: UDREN LAW OFFICES, P.C. BY. Attome for Plamti f Nicole LaBlefta, Esquire PA ID 202194 AUG 042019 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA THE BAND.OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK,AS TRUSTEE - -- FOR THE HOLDERS OF THE s �" GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005- 1 Civil Division 4� VS. No.2010-3218 DANIEL SHIELDS CONNIE SHIELDS GIRDER AND NOW,this - day of Lt,t' 2010,upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court,it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendants,DANIEL SHIELDS and CONNIE SHIELDS, by: 1. Posting of the premises: 248 EAST NORTH STREET,CARLISLE, PA 17013-2538 by the Sheriff or a non-party competent adult; 2. First class mail to DANIEL SHIELDS and CONNIE SHIELDS at the last known address, PO BOX 906, CARLISLE, PA 17013-5906,and the mortgaged premises located at 248 EAST NORTH STREET, CARLISLE,PA 17013-2538; and 3. Publication in accordance with PA. R.C.P. 430. 2 It is finther ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. J. i cc: DANIEL SHIELDS and CONNIE SHIELDS I 248 EAST NORTH STREET CARLISLE,PA 17013-2538 DANIEL SHIELDS and CONNIE SHIELDS PO BOX 906,CARLISLE,PA 17013-5906 PHS#234359/ARM co F7 MWL L5�c 3 i PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox,Sales Director, 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): March 23,2013 COPY OF NOTICE OF PUBLICATION ` Nt3"Ci Of ALTION W MORTGAt3E FORECLOSURE IN THE COURT.Of°COMMON PLVAS OF 4 �GoMBEliLAND G@UN ffiant further deposes that he/she is not P ero:z�aarsl� ' r 6aiNcofNaw`ForkMellonf l Theft '-,dNdtk orfc,, rw * ► 'r Qf.fh®BE-W CAsftt interested in the subject matter of the Nf-fhrbugfiGdrNf+cateA 81i "`� mss. � '"'{j$h".`� Defi� aforesaid notice or advertisement,and that t70 f ero R a Box rCrfa Pty + ► "` ;, i - all allegations in the foregoing statement as #8 Elf �,A sch�ldule�i to#e #li S§aIP. to time,place and character of publication are true. k t,Tt�T olr� a�rcasr�prmei 'fda �t Lba3terF." cloE ; ' Sworn to aipd subscribed before me this • x0111 r"Qr fibtf erry�;of M1 V #. . ran he h4r rn 1lop, 4x L bN4. Qn�h ±� whichE did au #ft.. -sc WWh1b0 r+� . e th . , �or #� at in low TITLE,'r0 ' s�rFgle' P f�fl§RAC p fxal,E zr2,t�AVlr eI N ERECTED Notary Public 4 ( Ffi4�1{fL'fELI f 1N �� ,dtborflays.forPicinldl,t#tV!tfdaesf � ? C'tl ),�St NiE Dkt 19003 .$ 54i�6 My commission expires: NGTP2ML FL,L BAMBI ANN HECKENDOfiN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY miy Cor-mission ER}7ir�.r ,ran 2014 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 March 29, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Li Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 29 day of March, 2013 Notary NOTAHIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN said land 61 feet to a point in line MORTGAGE FORECLOSURE of land now or formerly of the John Spahr Estate: thence westwardly In the Court of Common Pleas of along land of the latter 28 feet to a Cumberland County, Pennsylvania point in line of lot now or formerly of Civil Action—Law Dewey W.Bernheisel and Hilda Bern- heisel, his wife; thence northwardly NO. 2010-03218 along line of lot of the said Dewey W.Bernheisel and Hilda Bernheisel, The Bank of New York Mellon his wife, and through the center of f/k/a The Bank of New York,As a partition wall erected between the Trustee for the Holders of the GE- house built on the lot herein being WMC Asset-Backed Pass-Through conveyed and the house on the lot Certificates, Series 2005-1, of the said Dewey W.Bernheisel and Plaintiff Hilda Bernheisel,his wife,61 feet to vs. a point on the southern side of East Daniel Shields and Connie Shields, North Street;thence eastwardly along Defendant(s) the southern side of said East North Street,28 feet to a point,the Place of NOTICE OF SALE BEGINNING.BEING improved with a OF REAL PROPERTY frame dwelling house and other im- provements and known as 248 East TO: Daniel Shields and Connie North Street. TRACT B: ALL THAT Shields, Defendants, whose last CERTAIN lot of ground situate in the known addresses are P.O. Box First Ward of the Borough of Carlisle, 906,Carlisle,PA 17013-5906 and Cumberland County, Pennsylvania, 248 East North Street,Carlisle,PA and more particularly bounded and 17013-2538 described in accordance with a Sub- Your house (real estate) at 248 division Plan prepared by Thomas East North Street, Carlisle, PA A. Neff, Registered Surveyor, which 17013-2538 is scheduled to be sold Subdivision Plan as recorded in the at the Sheriff's Sale on June 5,2013 Office of the Recorder of Deeds in and at 10:00 A.M. in the Cumberland for Cumberland County in Plan Book County Courthouse,Commissioners 36,Page 134,as follows:BOUNDED Hearing Room, 2nd Fl., Carlisle, PA on the North by land now or formerly 17013,to enforce the court judgment of Richard A. Keller and Margaret V. of$83,064.81, obtained by Plaintiff Keller,his wife, on the East by land above (the mortgagee) against you. now or formerly of Roy W. Shearer; If the sale is postponed,the property on the South by land now or formerly will be relisted for the Next Available of Clara F. Fahnestock; on the West Sale. PROPERTY DESCRIPTION: by Lot No.3 on the hereinabove men- ALL those certain two tracts of land tioned Subdivision Plan. BEING Lot with the improvements thereon No.4 on the hereinabove mentioned erected situate in the First Ward of Subdivision Plan and containing the Borough of Carlisle,Cumberland 485.24 square feet.BEING the same County,Pennsylvania,bounded and premises which John C. Myers and described as follows: TRACT A: BE- Anna M. Myers, husband and wife, GINNING at a point on the southern by deed dated June 4, 1999, and line of East North Street,which point recorded in the Office of the Recorder is at the corner of land now or for- of Deeds in and for Cumberland merly of Frank T.Adams and Lester County in Deed Book 201, Page 40, F.Adams: Thence southwardly along granted and conveyed unto Linda 8 CUMBERLAND LAW JOURNAL J. Jumper, Grantor herein. BEING KNOWN AS: 248 East North Street, Carlisle, PA 17013. PROPERTY ID NO.: 02-21-0318-183. TITLE TO SAID PREMISES IS VESTED IN Dan- iel Shields and Connie Shields,h/w BY DEED FROM Linda J. Jumper, single person DATED 07/28/2005 RECORDED 07/29/2005 IN DEED BOOK 270 PAGE 772.HAVING BEEN ERECTED THEREON A SINGLE FAMIT_,Y DWELLING. UDREN LAW OFFICES, P.C. Attorneys for Plaintiff 111 Woodcrest Rd. Ste. 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Mar. 29 9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY I=IT L!-`O-IDFi tDREN LAW OPPICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 P eadin2s udren.com The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York, as Trustee for the CIVIL DIVISION Holders of the GE-WMC Asset-Backed Cumberland County Pass-Through Certificates, Series 2005-1 Plaintiff MORTGAGE FORECLOSURE V. Connie Shields Daniel Shields NO. 2010-03218 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 The Bank of New York Mellon f/k/a The Bank of New York,as Trustee for the Holders of the GE-WMC Asset=Backed Pass-Through Certificates Series 2005-1, 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: 248 East North Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Connie Shields 248 East North Street Carlisle,PA 17013 Daniel Shields. 248 East North Street Carlisle,PA 17013 2. Name and address of Defendant(s) in the judgment: Connie Shields 248 East North Street Carlisle,PA 17013 Daniel Shields 248 East North Street Carlisle,PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mers as a nominee for WMC Mortgage Corporation PO Box 2026 Flint, MI 48501-2026 4. Name and address of the last recorded holder of every mortgage of record: The Bank of New York Mellon f/k/a The Bank of New York, as Trustee for the Holders of the GE-WMC Asset-Backed Pass-Through Certificates, Series 2005-1 1661 Worthington Road,Suite 100 West Palm Beach, FL 33409 ,?f Sr Mortgage.H.olders -None Jr Mortgage Holders-None 5.Name and address of every other person who has any record lien on the property: Sr lien Holders-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: Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 248 East North Street Carlisle,PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle,PA 17013 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: Federal Tax Lien Holders-None Condo/Homeowners Association-None 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 to unsworn falsification to authorities. DATED: r , �� UDREN LAW OFFICES, P.C. Attorney for Plaintiff KASSIA FIALKOFF, ESQUIRE MJU#: 11120799 CASE#: 11120799-1 PA ID 310530 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadin2sAmdren.com The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York, as Trustee for the CIVIL DIVISION Holders of the GE-WMC Asset-Backed Cumberland County Pass-Through Certificates, Series 2005-1 Plaintiff MORTGAGE FORECLOSURE V. CONNIE SHIELDS,DANIEL SHIELDS NO. 2010-03218 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Daniel Shields 248 East North Street Carlisle, PA 17013 Your house(real estate) at 248 East North Street, Carlisle,PA 17013 is scheduled to be sold at the Sheriffs Sale on June 5,2013 at 1 0:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013,to enforce the court judgment of$83,064.81, 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 Sheriffs 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (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 pleadin2s udrenxom The Bank of New York Mellon f/k/a The COURT OF COMMON PLEAS Bank of New York, as Trustee for the CIVIL DIVISION Holders of the GE-WMC Asset-Backed Cumberland County Pass-Through Certificates, Series 20054 Plaintiff MORTGAGE FORECLOSURE. V. CONNIE SHIELDS,DANIEL SHIELDS NO. 2010-03218 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Connie Shields 248 East North Street Carlisle, PA 17013 Your house(real estate) at 248 East North Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on June.5,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce the court judgment of$83,064.81, 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 SHERIFFS SALE To prevent this Sheriffs 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. Z. 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 Sheriffs 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 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Par Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-3218 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK,AS TRUSTEE FOR THE HOLDERS OF THE GE-WMC ASSET- BACKED PASS-THROUGH CERTIFICATES,SERIES 2005-1 Plaintiff(s) From CONNIE SHIELDS,DANIEL SHIELDS (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 garnishees) 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: $83,064.81 L.L.: $.50 Interest from 7/20/2011 to Date of Sale June 5,2013 ongoing per diem of$14.62 to actual date of sale including if sale is held at a later date- $10,043.94 Atty's Comm: Due Prothy:$2.25 Atty Paid: $275.30 Other Costs: Plaintiff Paid: Date:2/4/2013 David D. Buell,Prothonot (Seal) Deputy REQUESTING PARTY: Name: KASSIA FIALKOFF,ESQUIRE Address: UDREN LAW OFFICES,P.C. 111 WOODCREST ROAD,SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 TRUE COPS FROM RECORD Supreme Court ID No.310530 In Testimony whereot ,'l here unto set my hand and the seal of said Court at Carlisle,Pa This day of 20'.E U j� Prothonotary On March 11, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as 248 East North Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 11, 2013 By: Real Estate Coordinator n� z ci S- 031 1192 CUMBERLAND LAW JOURNAL Writ No. 2010-3218 Civil subdivision plan as recorded in the Office of the Recorder of Deeds in and THE BANK OF NEW for Cumberland County in Plan Book YORK MELLON 36,Page 134,as follows: vs. BOUNDED on the north by land DANIEL SHIELDS, now or formerly of Richard A. Keller Connie Shields and Margaret V. Keller, his wife; on the east by land now or formerly of Atty.: Mark Udren Roy W.Shearer;on the south by land ALL THOSE CERTAIN two tract of now of formerly of Clara F. Fahne- land with the improvements thereon stock; on the west by Lot No. 3 on erected situate in the First Ward of the hereinabove mentioned subdivi- the Borough of Carlisle,Cumberland sion plan. County,Pennsylvania,bounded and BEING Lot No. 4 on the herein- described as follows: above mentioned subdivision pan TRACT A: BEGINNING at a point and containing 485.24 square feet. on the southern line of East North BEING the same premises which Street, which point is at the corner John C. Myers and Anna M. Myers, of land now or formerly of Frank T. husband and wife, by deed dated Adams and Lester F.Adams;thence June 4, 1999, and recorded in the southwardly along said land 61 feet Office of the Recorder of Deeds in to a point in line of land now or and for Cumberland County in Deed formerly of the John Spahr; thence Book 201, Page 40, granted and westwardly along land of the latter conveyed unto Linda J. Jumper, 28 feet to a point in line of Lot now grantor herein. or formerly of Dewey W. Bernheisel BEING KNOWN AS: 248 East and Hilda Bernheisel,his wife;thence North Street, Carlisle, PA 17013. northwardly along line of Lot of the PROPERTY ID NO.: 02-21-0318- said Dewey W. Bernheisel and Hilda 183. Bernheisel, his wife, and through TITLE TO SAID PREMISES IS the center of apartition wall erected VESTED IN Daniel Shields and between the house built on the Connie Shields, h/w by deed from lot herein being conveyed and the Linda J.Jumper,single person dated house on the lot of the said Dewey 7/28/2005 recorded 07/29/2005 in W.Bernheisel and Hilda Bernheisel, Deed Book 270 Page 772. his wife, 61 feet to a point on the southern side of East North Street; thence eastwardly along the southern side of said East North Street;28 feet to a point,the place of BEGINNING. BEING improved with a frame dwelling house and other improve- ments and known as 248 East North Street. TRACT B: All That certain lot of ground situate in the First Ward of the Borough of Carlisle,Cumberland County, Pennsylvania, and more particularly bounded and described in accordance with a subdivision plan prepared by Thomas A. Neff, Registered Surveyor, which said 69 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 12, April 19 and April 26, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r r ' L sa Marie toyne, Edit r SWORN TO AND SUBSCRIBED before me this 26 da y of April, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 _ .the Patriot-News Co. 2020 Technology Pkwy 14t atr1*otwXtws Suite 300 Mechanicsburg, PA 17050 NOW you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2010-3218 Chril -9NC THE BANK OF NEW YORK This ad ran on the date(s)shown below: MELLON y�I VS. :ESr 04/16/13 DANIEL SHIELDS :01r 04/23/13 Connie Shields d N Atty:Mark Udren . 3H 04130/13 ALL THOSE CERTAIN TWO TRACT OF rJV, LAND WITH THE IMPROVEMENTS IS S' THEREONERECTEDSITUATEINTHE dj )I( . • • • • • • • • . . . . . . . . . . . . . . . . . FIRST WARD OF THE BOROUGH OFF J CARLISLE,CUMBERLAND COUNTY,no PENNSYLVANIA, BOUNDED AND;Og Sworn to nd subscribed befor me this 13 day of May, 2013 A.D. DESCRIBED AS FOLLOWS: )S'31 TRACT A: BEGINNING AT A POINT IN9 ON THE SOUTHERN LINE OF EAST kt0 NORTH STREET, WHICH POINT IS r3B AT THE CORNER OF LAND NOW OR IdY o ary Public FORMERLY OF FRANK T. ADAMS )2It AND LESTER F. ADAMS; THENCE n SOUTHWARDLY ALONG SAID LAND 61 FEET TO A POINT IN LINE OF LAND NOW OR FORMERLY COMMONWEALTH OF PENNSYLVANIA OF THE JOHN SPAH) �NCE WESTWARDLY A NO OF Notarial Seal THE LATTER 28 FEET TO A POINT IN Holly Lynn Warfel,Notary Public LINE OF LOT NOW OR FORMERLY Washington Twp.,Dauphin County OF DEWEY W. BERNHEISEL My Commission Expires Dec.12,2016 AND HIIAA BERNHEISEL, HIS MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES WIFE; THENCE NORTHWARDLY .Z" ALONG LINE OF LOT OF THE SAID DEWEY W. BERNHEISEL AND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Holders of the GE-WMC Asset-Backed Passed-Through Cert Series 2005-1 Tr is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013,under and by virtue of a writ Execution issued on the 4th day of February, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 3218, at the suit of Holders of the GE- WMC Asset-Backed Pass-Through Cert Series 2005-1 Tr against Connie & Daniel Shields is duly recorded as Instrument Number 201324164. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 0?,3—j day of A.D. Recorder of Deeds R of ,Cumberland County,Carlisle,PA My Commission Expires the Fist Monday of Jan.2014