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Home My WebLink About10-4193? Y F .\ FILED-OW-CE OF THE ,'0 THCi, 0TAjq f 2010 JUN 23 PH 2: 26 CUMBS-i'I.AI- Ci UJUN y PENVSYlM" 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 GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff V. CHRISTOPHER A. BLACK TONI M. BLACK 2375 DUSTY LANE ENOLA, PA 17025-1118 Defendants File #: 242037 ATTORNEY FOR PLAINTIFF 242037 COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 16- 1-11/ 3 C U ?- fc% CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 9-fi"06 11 k a-? 9GY677 2 .-yyj74 T 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 #: 242037 I . Plaintiff is GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE, P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: CHRISTOPHER A. BLACK TONI M. BLACK 2375 DUSTY LANE ENOLA, PA 17025-1118 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/08/2008 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR AMERICAN HOME BANK, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200839623. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 02/01/2010 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 #: 242037 6. The following amounts are due on the mortgage: Principal Balance $211,286.60 Interest $6,057.85 01 /01 /2010 through 06/11/2010 (Per Diem $38.1490) Attorney's Fees $650.00 Cumulative Late Charges $799.64 12/08/2008 to 06/11/2010 Property Inspections/Property Preservations $33.75 Costs of Suit and Title Search 0.00 Subtotal $218,827.84 Escrow Credit 319.60 TOTAL $218,508.24 7. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 242037 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $218,508.24, together with interest from 06/11/2010 at the rate of $38.1490 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. HALLINAW SCHMIEG, LLP By: V ? a ence T. Phelan, Esq., d. No. 32227 ? F cis S. Hallinan, Esq., d. No. 62695 ? Daniel G. Schmieg, Es q., d. No. 62205 J?ic ? e M. Bradford, Esq., Id. No. 69849 th T. Romano, Esq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 242037 LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a stake at the corner of land of Howard Nebinger and land of Thomas Pifer, said stake being two hundred fifty (250) feet west of the center line of the Lambs Gap Road; thence along said land of Thomas Pifer, South 86 degrees 30 minutes West, three hundred (300) feet to a stake; thence along other land of Beatrice A. Henry, North 5 degrees 42 minutes East, three hundred thirty-three and twenty-four hundredths (333.24) feet to a stake; thence continuing along other land of Beatrice A. Henry, North 86 degrees 30 minutes East, three hundred (300) feet to a stake; thence along land of Howard Nebinger, South 5 degrees 42 minutes West, three hundred thirty-three and twenty-four hundredths (333.24) feet to a stake at the corner of land of Thomas Pifer, the place of BEGINNING. CONTAINING 2.265 acres of land. Property Address: 2375 DUSTY LANE, ENOLA, PA 17025-1118 Parcel Number: 10-11-3016-013 File #: 242037 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to DATE: A-Xk-Vb File #: 242037 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~~~ti~cr at ~urttbFp{~~~b ~. ~Yf ~ ~ _ .~;~ „_ _. I : r.~~ ZQIO..~~tL - I ~ ~: 36 Richard W Stewart Solicitor AFC t"E ._ ° ThE ~.;.Eair~ Ct1iv?~:; ~ ~; i r~~,~~~?~i t!! i~Vt~a~fti~ ~~!! tt/~ k GMAC Mortgage, LLC vs Case Number Christopher A. Black (et al.) 2010-4193 SHERIFF'S RETURN OF SERVICE 06/28/2010 08:52 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 2052 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christopher A. Black, by making known unto Toni M. Black, Wife of defendant at 2375 Dusty Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. ~ .. ~i"~ DEN FRY, DEP 06/28/2010 08:52 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 2052 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Toni M. Black, by making known unto herself personally, at 2375 Dusty Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 June 29, 2010 DENNI RY, DEP SO ANSWERS, .~ RON R ANDERSON, SHERIFF (ci GounrySuite Shenft. Teleosoft. Irr,. !~ r~ ~',! ._r ~,~. T~--,. 1 Z~t~i ~{l~~ t ~ ~t'~ ~~ i J CU~~'1 ~ ' ~ ; ~ L~1 ~ ,.~ ar~,~'~ t'L; , ~. 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 vJ'enine 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 GMAC MORTGAGE, LLC Plaintiff vs. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-4193 CIVIL CHRISTOPHER A. BLACK CUMBERLAND COUNTY TONI M. BLACK Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 242037 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP A~-ney for Plaintiff n By: ^ L ~ rence .Phelan, Esq Id. No. 32227 ^ F cis S. Hallinan, Esq., Id. No. 62695 ^ D iel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Ju ith T. Romano, Esq., Id. No. 58745 ^ eetal 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 Date: 7-7-10 PHS #: 242037 VERIFICATION ,may gtephar ~ lmised Slgnin9 pflicer ,hereby states that he/she is ~. `-~ 0 of, GMAC MORTGAGE, LLC, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE:~l1L~, ZO/ ~ Jeffrey Stephan ' e: Limped Signing Officer Servicer: GMAC MORTGAGE, LLC File #: 242037 Name: BLACK I r, 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 GMAC MORTGAGE, LLC Plaintiff vs. CHRISTOPHER A. BLACK TONI M. BLACK Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-4193 CIVIL CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: CHRISTOPHER A. BLACK 2375 DUSTY LANE ENOLA, PA 17025-1118 PHS #: 242037 TONI M. BLACK 2375 DUSTY LANE ENOLA, PA 17025-1118 Hallinan & Schmieg, LLP ;v for Plaintiff ~ LJ rence T. Phelan, Es ., Id. No. 32227 ^ ncis S. Hallinan, ., Id. No. 62695 ^ niel G. Schmie sq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Ju ith T. Romano, Esq., Id. No. 58745 eetal 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 Date: 7-7-10 PHS #: 242037 20!3 OCT -9 PENNSYLVANIA M 9; STYLI C UHBER�,AND ACOUNTY PHELAN HALLINAN, LLP BY: COURTENAY R. DUNN, ESQUIRE Identification No. 206779 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Courtenay.dunn@phelanhallinan.com (215) 563-7000 GMAC Mortgage, LLC • Court of Common Pleas 1100 Virginia Drive • Civil Division P.O. Box 8300 • Fort Washington, PA 19034 • Plaintiff Cumberland County • No.: 10-4193 v. • • Christopher A. Black • Toni M. Black • 2375 Dusty Lane • Enola, PA 17025-1118 • Defendants • STATEMENT OF INTENTION TO PROCEED TO THE COURT: The above-referenced foreclosure action was protected by the automatic stay provisions of the Defendant Toni M. Black Chapter 13 Bankruptcy filed on September 7, 1011 at Docket No. 1:11-06181 in the Middle District of Pennsylvania. Plaintiff intends to proceed with its above foreclosure action should the Defendant's Bankruptcy be dismissed or Plaintiff receives relief from the automatic stay. S' ( DATE: BY: Courtenay R. Dunn, Esquire Attorney for Plaintiff #909036 PHELAN HALLINAN, LLP BY: COURTENAY R. DUNN, ESQUIRE Identification No. 206779 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Courtenay.dunn@phelanhallinan.com (215) 563-7000 GMAC Mortgage, LLC • Court of Common Pleas 1100 Virginia Drive • Civil Division • P.O. Box 8300 • Fort Washington, PA 19034 Plaintiff • Cumberland County • No.: 10-4193 • v. • • Christopher A. Black Toni M. Black • • 2375 Dusty Lane • Enola, PA 17025-1118 • Defendants CERTIFICATION OF SERVICE I hereby certify a true and correct copy of Statement of Intention to Proceed was served by regular mail to the following on the date listed below: Toni M. Black Christopher A. Black 2375 Dusty Lane Enola, PA 17025-1118 DATE: k® )�l I BY: Courtenay R. Dunn, Esquire Attorney for Plaintiff #909036 • PHELAN HALLINAN, LLP i?_ }- (;+ Attorney for Plaintiff Adam H. Davis, Esq., Id. No �34�34 ►'+; �G T��, 1617 JFK Boulevard, Suite 1`0.0 One Penn Center Plaza i�':4 JAN "6 PI 10: 15 Philadelphia, PA 19103 CUt rBERLAND COUNT' Adam.Davis @PhelanHal linan.coNNS PENNSYLVANIA 215-563-7000 GMAC MORTGAGE, LLC : CUMBERLAND COUNTY vs. : COURT OF COMMON PLEAS CHRISTOPHER A. BLACK : CIVIL DIVISION_ . TONI M.BLACK .• : No. 10-4193.CIVIL . 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 CHRISTOPHER A.BLACK and TONI M.BLACK, 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 $218,508.24 Interest- 06/12/2010 to 01/02/2014 $49,631.85 • TOTAL $268,140.09 I hereby certify that (1) the Defendants' last known address is 2375 DUSTY LANE, ENOLA, PA 17025-1118, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date 1/3/79- or4rztrt-vV- e,_-- Adam H. Davis, Esq., Id. No.203034 Attorney f laint DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: .____1(6_1 I PH#735871 PROTHONOTARY o c1l1) Stl t C�L.t ►3 %04-11 735871 • .. ,- bbO.1°I '�(Au. Maa`IeJ • • • PHELAN HALLINAN,LLP Attorney for Plaintiff Adam H. Davis, Esq., Id.No.203034 1617 JFK Boulevard, Suite 1400 • One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis @PhelanHallinan.com . 215-563-7000 GMAC MORTGAGE,LLC : CUMBERLAND COUNTY : COURT OF COMMON PLEAS vs. CIVIL.DIVISION CHRISTOPHER A.BLACK TONI M.BLACK : No. 10-4193 CIVIL 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 its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant CHRISTOPHER A. BLACK is over 18 years of age and the • defendant's last known address is 2375 DUSTY LANE,ENOLA, PA 17025-1118. (c) that defendant TONI M. BLACK is over 18 years of age and the defendant's last known address is 2375 DUSTY LANE, ENOLA, PA 17025-1118. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date //,..)V Phelan Hallinan,LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 • 215-563-7000 . • 735871 • • •Department.of Defense Manpower Data • Results as of Jan-03-207412:05.37 • Center • SCRA 3.0 • Staff R ►rt Pursuant to Senliccitteictibers Civil Relief Act • Last Name: BLACK First Name: CHRISTOPHER Middle Name: A Active Duty Status As Of: Jan-03-2014 • On Active Duty On Active Duty Status Date ' Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the.Active Duty Status Date Left Active Duty Wdhin 367 Days of Active Duty Status Data Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cat-Up to Active Duty on Active Duty Status Date Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has receivedeady notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ,.w Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 • • Department of Defense Manpower Data Resutsesof Jan=03-2014,20525 • Center • SCRA 3.0 Status Report P# /want to Servrcemembers Civil Relief Act Last Name: BLACK First Name: TONI Middle Name: M Active Duty Status As Of: Jan-03-2014 On Active Duty On Active Duty Status Date • Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ' No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HistHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date: Status Service Component NA NA No NA This response reflects whether the individual'.or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. yri$L. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 • • • • • • (Rule of Civil Procedure No. 236) - Revised GMAC MORTGAGE,LLC : CUMBERLAND COUNTY vs. : COURT OF COMMON PLEAS CHRISTOPHER A.BLACK • TONI M.BLACK : CIVIL DIVISION : No. 10-4193 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on 1' 1I . By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis,Esq., Id. No.203034 • Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND 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 OF A LIEN AGAINST PROPERTY.** 735871 • • • • GMAC MORTGAGE,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CHRISTOPHER A.BLACK NO. 10-4193 CIVIL TONI M.BLACK Defendant(s) CUMBERLAND COUNTY TO: TONI M.BLACK 2375 DUSTY LANE ENOLA,PA 17025-111 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 HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. • YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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)249-3166 By: r a the : _ •rood,Esq.,Id.No.310592 • orn. fort aintiff P iel • Hal`'an,LLP 1617 t oulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#735871 • GMAC MORTGAGE,LLC COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. CHRISTOPHER A.BLACK NO. 10-4193 CIVIL TONI M.BLACK Defendant(s) CUMBERLAND COUNTY • TO: CHRISTOPHER A.BLACK 2375 DUSTY LANE ENOLA,PA 17025-1118 DATE OF NOTICE: / Jeb )1 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. • • YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 if (717)249-3166 I Agri- By:j i� :rushwood,Esq.,Id.No.310592 y Atto for Plaintiff Phelan Hallinan,LLP • 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#735871 • • • PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 GMAC MORTGAGE,LLC COURT OF COMMON PLEAS Plaintiff - : CIVIL DIVISION v. NO.: 10-4193 CIVIL CHRISTOPHER A.BLACK TONI M.BLACK Defendant(s) CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due $268,140.09 Interest from 01/07/2014 to Date of Sale $6,567.92 ($44.08 per diem) • TOTAL $274,708.01 Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff . • • Note: Please attach description of property. PH#735871 'C. , � � _, $S.? so CAF . rn :.r.--;41 l SCE`` `' MC - o., • sDA S 1. . c‘. so �(.- CIA ( 3go4nt . • • ?._ 6(3oIST) •• (t.--.{- Q • o C CO• C.-). 00 E � W � W � N N CO W a ° U .a �° Z L p v) a a 45 ■aQO ZQo b xMz oMz < U N W H N W . ;.r 0 H W W OU W o z wo Q w ar° � Z � WU O cW O O � a g row 0 • � L) � Q U � \ xx ai Z U C7 > U.E-1 a w a • • PHELAN HALLINAN, LLP Attorneys for Plaintiff •i Adam H. Davis, Esq., Id. No.203034 J THONO TA: 1617 JFK Boulevard, Suite 1400 2014 JAN _6 API 10: 16 One Penn Center Plaza Philadelphia, PA 19103 CUMBERLAND COUNTY Adam.Davis @PhelanHallinan.com PENNSYLVANIA 215-563-7000 GMAC MORTGAGE, LLC : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION v. : NO.: 10-4193 CIVIL CHRISTOPHER A. BLACK TONI M.BLACK Defendant(s) : CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: (X) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant • • ( ) Act 91 procedures have been fulfilled . • ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197,41 Pa.B. 3943 • This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: �i/ t■—■ Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff • • • •' • COURT OF COMMON PLEAS GMAC MORTGAGE,LLC t. ;F rytl �, � Plaintiff • 2O1 I JAN -6 t 10: 17 CIVIL DIVISION v. • ��if3 RLANO COUNTY • NO.: 10-4193 CIVIL CHRISTOPHER A.BLACK 'E�INSYL Y��d�A • TONI M. BLACK Defendant(s) CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 GMAC MORTGAGE,LLC,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 2375 DUSTY LANE,ENOLA,PA 17025-1118. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) CHRISTOPHER A.BLACK 2375 DUSTY LANE ENOLA,PA 17025-1118 TONI M.BLACK 2375 DUSTY LANE ENOLA,PA 17025-1118 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) • SAME AS ABOVE. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name • Address(if address cannot be reasonably ascertained,please indicate) None. PH#735871 • 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be • reasonably ascertained,please indicate) TENANT/OCCUPANT 2375 DUSTY LANE ENOLA,PA 17025-1118 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 • U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: //3/77' By: Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff • PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 • 215-563-7000 • • . PH#735871 f ��R �`O�� 11'I" : COURT OF COMMON PLEAS .GMAC MORTGAGE, LLC 01 ~IA ~6 AK 10: 7 Plaintiff : CIVIL DIVISION CUMBERLAND COUNTY vRENNSYLVANIA : NO.: 10-4193 CIVIL CHRISTOPHER A. BLACK TONI M.BLACK : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CHRISTOPHER A.BLACK TONI M.BLACK 2375 DUSTY LANE ENOLA,PA 17025-1118 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house(real estate) at 2375 DUSTY LANE,ENOLA,PA 17025-1118 is scheduled to be sold at the Sheriff's Sale on 06/04/2014 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$268,140.09 obtained by GMAC MORTGAGE,LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. • • 2. You may be able to petition the Court to.set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to.the Shedff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. • CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE • CARLISLE,PA 17013 (717) 249-3166 (800) 990-9108 • • • SHORT DESCRIPTION • • By virtue of a Writ of Execution No. 10-4193 CIVIL GMAC MORTGAGE,LLC v. CHRISTOPHER A. BLACK TONI M.BLACK owner(s) of property situate in HAMPDEN TOWNSHIP, CUMBERLAND County, Pennsylvania, being 2375 DUSTY LANE,ENOLA,PA 17025-1118 Parcel No. 10-11-3016-013 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $268,140.09 Attorneys for Plaintiff Phelan Hallinan, LLP • • • • • LEGAL DESCRIPTION ALL THAT CERTAIN tract or Parcel of land and premises,situate,lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania,more particularly described as follows: BEGINNING at a stake at the corner of land of Howard Nebinger and land of Thomas Pifer,said stake being two hundred fifty(250)feet west of the center line of the Lambs Gap Road;thence along said land of Thomas Pifer,South.86 degrees 30 minutes West,three hundred(300)feet to a stake;thence along other land of Beatrice A.Henry,North 5 degrees 42 minutes East,three hundred thirty-three and twenty-four hundredths(333.24)feet to a stake;thence continuing along other land of Beatrice A.Henry,North 86 degrees 30 minutes East,three hundred(300)feet to a stake;thence along land of Howard Nebinger,South 5 degrees 42 minutes West,three hundred thirty-three and twenty-four hundredths(333.24)feet to a stake at the corner of land of Thomas Pifer,the place of BEGINNING. CONTAINING 2.265 acres of land. TITLE TO SAID PREMISES VESTED IN Christopher A. Black and Toni M. Black from Wesley V. Cooper and Diane K. Cooper, by Deed, dated 08/23/2006 and recorded 08/31/2006 in Book 276 Page 2045. PREMISES BEING:2375 DUSTY LANE,ENOLA,PA 17025-1118 PARCEL NO. 10-11-3016-013 • • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-4193 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE,LLC Plaintiff(s) From CHRISTOPHER A. BLACK,TONI M.BLACK (I) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $268,140.09 L.L.: $.50 Interest FROM 1/7/2014 TO DATE OF SALE($44.08 PER DIEM)-$6,567.92 Atty's Comm: Due Prothy: $2.25 Atty Paid: $194.50 Other Costs: Plaintiff Paid: Date: 1/6/14 2/Az/L." David D. Buell,Prothon. a _ (Seal) B : ' Deputy REQUESTING PARTY: Name: ADAM H.DAVIS,ESQUIRE Address: PHELAN HALLINAN,LLP 1617 JFK BLVD.,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 203034 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY GMAC MORTGAGE,LLC PH#735871 DEFENDANT SERVICE TEAM/Ixh CHRISTOPHER A.BLACK COURT NO.:10-4193 CIVIL C TONI M.BLACK - �Tt r.'=t- SERVE TONI M.BLACK AT: TYPE OF ACTION f', ' '''` 2375 DUSTY LANE XX Notice of Sheriff's Sale -Z r t C� ENOLA,PA 17025-1118 SALE DATE: June 4,2014 ).., .c" -- 1,' c SERVED Served and made known to TONI M.BLACK,Defendant on the `-‘k day of P 1 ,20(y ,at _� o'clock R.M.,at 7-11s W S'T`f LAN C" ,in the manner described below: ./S Defendant personally served. -.4 �„Adult family member with whom Defendant(s)reside(s). Relationship is . _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _Other: . Description: Age 116 Height ci l Weight la° Race 1A) Sex Other I, f 6%31..1 V ,a competent adult,hereby verify that I personally handed a true and correct copy of the. Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S.Sec.4904 relating to unworn falsification to authorities. DATE: 1 H 11°1 NAME: c-‘--. . btu Mk Yh:tCZ�U PRINTED NAME: TITLE: (kl'f)CC- 3' •SC-1 GAL • NOT SERVED On the day of ,20 ,at o'clock_.M.,I, ,a competent adult hereby state that�eTendyant NOT FOUND because: • _Vacant —Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at ,• at Service Refused — Other: I understand that this statement is made subject to the penalties of, 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 AFFIDAVIT OF SERVICE * PLAINTIFF CUMBERLAND COUNTY GMAC MORTGAGE,LLC PH#735871 DEFENDANT SERVICE TEAM/lxh C*3 CHRISTOPHER A.BLACK COURT NO.:10-4193 CIVIL (-`) , TOM M.BLACK -n fit SERVE CHRISTOPHER A.BLACK AT: TYPE OF ACTION rn 1-11 ' 2375 DUSTY LANE XX Notice of Sheriff's Sale Nr ENOLA,PA 17025-1118 SALE DATE: June 4,2014 �r - t.--G .". a„ `.r.., SERVED 7 U"" Served and made known to CHRISTOPHER A.BLACK,Defendant on the \LI day of 1 1 7',20 y `- ` --?o'clock .M.,at "2-3-15 R.) 1/ - L ,in the manner described below: .-t Q -- Defendant personally served. f ` .Adult family member with whom Defendant(s)reside(s). Relationship is T01%-31 VA- (it.kOf— _Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _Other: t Description: Age • 1 v, Height / ,�N Weight%6, Race tki Sex "P. Other I, M5ts) ,a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unworn falsification to authorities. DATE: 1111 11°N NAME: " ECti PRINTED NAME: f �1 I '� TITLE: ;\1°C€. -.S. 4/4erL NOT SERVED On the day of 20_,at o'clock_.M.,I, ,a competent adult hereby state thalnandant NOT FOUND because : —Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on �f ui a at _Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 \ Ronny R Anderson. Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t OFFiC. OF NE & $E fiFF FILED -OFFICE THE. PROTHONOTARY 201' Mill 19 AIS I I : 07 CUMBERLAND COUNTY PENNSYLVANIA GMAC Mortgage, LLC vs. Christopher A. Black (et al.) Case Number 2010-4193 SHERIFF'S RETURN OF SERVICE 03/31/2014 05:31 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 2375 Dusty Lane, Hampden - Township, Enola, PA 17025, Cumberland County. 03/31/2014 05:31 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Toni Black, wife, who accepted as "Adult Person in Charge" for Christopher A. Black at 2375 Dusty Lane, Hampden Township, Enola, PA 17025, Cumberland County. 03/31/2014 05:31 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Toni M. Black at 2375 Dusty Lane, Hampden Township, Enola, PA 17025, Cumberland County. 05/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $699.02 SO ANSWERS, May 15, 2014 RONNY R ANDERSON, SHERIFF k. sri2 4--/..70.- ��z-,� 9c� yip 3e4e, (c) Co:anySuite Sheriff, Teleoscft. Inc. On January 29, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as 2375 Dusty Lane, Enola, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: January 29, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2010-4193 Civil Term GMAC Mortgage, LLC vs. Christopher A. Black Toni M. Black Atty.: Francis Hallinan By virtue of a Writ of Execution No. 10-4193 CIVIL, GMAC MORT- GAGE, LLC v. CHRISTOPHER A. BLACK, TONI M.BLACK owner(s) of property situate in HAMPDEN TOWNSHIP, CUMBERLAND Colinty, Pennsylvania, being 2375 DUSTY LANE, ENOLA, PA 17025.1118. Parcel No. 10-11-3016-013. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $268,140.09 31 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 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coy , Editor SWORN TO AND SUBSCRIBED before me this da of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE KORO., CUMBERLAND CNTY My Commission Expires Apr 28. 2018 , The Patriot -News Co. . 2020 Technology Pkwy Suite.300 • Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he patriot*News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 2010-4193 Civil Term GMAC Mortgage, LLC Vs Christopher A. Black Toni M. Black Atty: Francis Hallinan By virtue of a Writ of Execution No. 10.4193 CIVIL GMAC MORTGAGE, LLC v. CHRISTOPHER A. BLACK TONI M. BLACK owner(s) of property situate in HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, Pennsylvania, being 2375 DUSTY LANE, ENOLA, PA 17025.1118 Parcel No. 10-11-3016-013 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $268,140.09 This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 is 02 day of ay, 2014 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holy Lynn Wj rfel, Nozry Public l"Iash+rgton Twp., Dauphin County M Comms.'n Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES