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HomeMy WebLinkAbout10-4221t ~9 ~ 1 14~~IJ 'vl ri'v 1. 2~~~ Eilia ~~ ~l~ t ~ ~ ~ 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 ATTORNEY FOR PLAINTIFF 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 241325 SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE COURT OF COMMON PLEAS P.O. BOX 27767 RICHMOND, VA 23224-7767 CIVIL DIVISION Plaintiff TERM v. DALE R. BRUMBACH 208 NORTH 32ND STREET CUMBERLAND COUNTY CAMP HILL, PA 17011-2810 Defendant CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE sT~~t - av ? d "'~~ S ~k ~ r~7 yip File #: 241325 ~,/ ~ yyal Y 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 #: 241325 M 1. Plaintiff is SUNTRUST MORTGAGE, INC. 1001 SEMMES AVENUE, P.O. BOX 27767 RICHMOND, VA 23224-7767 2. The name(s) and last known address(es) of the Defendant(s) are: DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/23/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS 1ST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1793, Page 4095. By Assignment of Mortgage recorded 01/29/2003 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 693, Page 4523. 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 07/01 /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 #: 241325 6. The following amounts are due on the mortgage: Principal Balance Interest 06101 /2009 through 06/21 /2010 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 01/23/2003 to 06/21/2010 Property Inspections/Property Preservations Non Sufficient Funds Charge Costs of Suit and Title Search Escrow Deficit TOTAL 7 8 $93,910.99 $6,020.54 $650.00 $140.00 $9.00 $20.00 $550.00 862.59 $102,163.12 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 #: 241325 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $102,163.12, together with interest from 06/21 /2010 at the rate of $15.44 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. HALLINAN &/S~CHMIEG, LLP By: ^ a ence T. Phelan, Esq. Id. No. 32227 ^ r is S. Hallinan, Esq., Id. No. 62695 ^ an el G. Schmieg, Esq., Id. No. 62205 ^ hele M. Bradford, Esq., Id. No. 69849 ^ J ith 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 #: 241325 LEGAL DESCRIPTION ALL that certain lot of ground situated in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at the point of Intersection of the line of adjoiner between Lot Nos. 22 and 23, in the hereinafter mentioned Plan of Lots, and the line of the western edge of North 32nd Street, which point is also 150 feet in a northerly direction by the western line of North 32nd Street from Lincoln Street; thence south 86 degrees west, by said line of adjoiner and lands now or formerly of Ada M. Eckert, one hundred sixty (160) feet to an iron pin at the eastern line of a 15 foot alley; thence, north 4 degrees west, by the said eastern line of a 15 foot alley, for a distance of fifty (50) feet to an iron pin at the northwest corner of Lot No. 24; thence north 86 degrees east, by the southern line of Lot No. 24, for a distance of one hundred sixty (160) feet to a point on the line of the northern edge of North 32nd Street; thence, south 4 degrees east, by the western line of North 32nd Street, for a distance of fifty (50) feet to the point and place of BEGINNING. BEING Lot No. 23, on Plan of Lots of Belvoir, which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 16. HAVING thereon erected a two story brick and frame dwelling house known and numbered as 208 North 32nd Street, Camp Hill, PA 17011. Parcel No. 01-21-0273-025 File #: 241325 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 authori+~P~ DATE: ~` ~'a' ~~ Fiie #: 241325 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOi1CltOr ~QS~~titr of ~~i+c+brr~~~~ # ~ ~ ; i-. ZOfO.l~L - t ~~~ ~~ 3~ ~/r \ ~~ Suntrust Mortgage Inc Case Number vs. 2010-4221 Dale R. Brumbach SHERIFF'S RETURN OF SERVICE 06/28/2010 05:33 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 1733 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dale R. Brumbach, by making known unto himself personally, at 208 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 June 29, 2010 DENNI RY, DEP SO ANSWERS, .:. RON R ANDERSON, SHERIFF (01 GountySuite Sheriff. Teleosoft. li~c ~ "'_` r F~~~i ,~ 210 Jil~. I `L ~I~ ~~ i 2 CU~~t' .~ ~ .Ui~TY 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 SUNTRUST MORTGAGE, INC. Plaintiff vs. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.10-4221-CIVIL DALE R. BRUMBACH CUMBERLAND COUNTY Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 241325 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: /s/ Francis S. Hallinan Q~ww~ ^ Lawrence T. Phelan, Esq., Id. No. 32227n ^ Francis S. Hallinan, Esq., Id. No. 62695 t~~~~~ ^ 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 Date: 7-7-10 C~~d~ C~Op~ L~S~ u vww PHS #: 241325 i= ~ ~ ~i-~' , __ C~~Q t,~,.~u .. _'~ -- b l' :~ ~v(,- (~ Prh a •• 3~ ~ 'P,tjj , rr'v ,.. i'~_ ~ ~`~ 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 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 SUNTRUST MORTGAGE, INC. vs. DALE R. BRUMBACH Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.10-4221-CIVIL • ~ I ~.oo P~ A~ e~ qg~5~ ~* o2ylo'i3'7 I~o1•cee ~~~ v~ 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 DALE R BRUMBACH 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 $102,163.12 Interest - 06/22/2010 to 08/03/2010 $663.92 TOTAL $102,827.04 I hereby certify that (1) the Defendant's last known address is 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, EsquirE/ Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. / DATE: !~~ ~,5/ ~puc,CQ ~,5~`~~ QKB PHS # 241325 PROTHONOTARY 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 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 Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION DALE R. BRUMBACH No.10-4221-CIVIL VERIFICATION 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 DALE R. BRUMBACH is over 18 years of age and his last known residence is 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 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 Attorney for Plaintiff (Rule of Civil Procedure No. 236) -Revised SUNTRUST MORTGAGE, INC. CUMBERLAND COUNTY vs. COURT OF COMMON PLEAS DALE R. BRUMBACH CIVIL DIVISION No. 10-4221-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on By: 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 ^ 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 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 2I5-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIi~ED A DISCHARGE INBANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 'Y 4- SUNTRUST MORTGAGE, INC. v. Plaintiff DALE R. BRUMBACH Defendant(s) TO: DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 DATE OF NOTICE: July 20, 2010 COURT OF COMMON PLEAS CNIL DNISON NO. 10-4221-CNIL CUMBERLAND COUNTY 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 RECENED 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. IIVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRITTEN APPERANCE 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. PHS # 241325 ~.. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PHS # 241325 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND. COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 170 i 3 (717) 249-3166 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 Shee R. Shah-Jani, Esq., Id. No. 81760 J me 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 I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 ._I% PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 SUNTRUST MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v DALE R. BRUMBACH Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 08/04/2010 to Date of Sale ($16.90 per diem) NO. 10-4221-CIVIL CUMBERLAND COUNTY $102,827.04 $ 3,565.90 ?e f?,a 4 f'`J c? -YI TOTAL Q *d4. oo P n Am-Y 41.60 e13F- 0. 00 a.so * 174.0 0 - PO ATH 0o Nx_ 0.0 •50 LL Note: Please attach description of property. PHS # 241325 Ct 100-681 s 2t ays? Phelan Hallinan & Schmieg, LLP ? L wrence T. Phelan, Esq., Id. No. 32227 ? 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 RE LQL?j b m ? o A WL o cad ? .??-+ o 05. ?Ma ? to ?' w 00 o d U Q q° o? a oa O? VO OV O? ?W ?V v PH4 O ?a U d a? p? A a Q ? A 0 ?W W w ? 0 W as w? N t?Nwd ?S Mcn a`??Z N G o`O•o ?Z ?N?`OZZ-Z2? a'b o vim' z 6;5? b.cs?Zb o.c o Ww ccw w~ crww''?w awWW?W'WWWW oe, o > 3 o' ?c7 -21 --'A M app (?L7L7C]C]C?0DQO00L 15 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Plaintiff a 3 :? L P_ ^C^ Ph '" 4 'S NOTARY F. S • - 1 2t - f . r Attorneys for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION V. DALE R. BRUMBACH Defendant(s) CERTIFICATION : NO. 10-4221-CIVIL : CUMBERLAND COUNTY 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: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. r By: t L* `--? Atto or Pl i f Phela Hallinan & Schmieg, LLP ? L rence T. Phelan, Esq., Id. No. 32227 ? F 1 cis 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 SUNTRUST MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff ' r in - n-,!--'r7: t k? sr „ E (TA `{ CIVIL DIVISION V. NO. 10-4221-CIVIL DALE R. BRUMBACH Defendants CUMBERLAND COUNTY PHS # 241325 AFFIDAVIT PURSUANT TO RULE 3129.1 SUNTRUST MORTGAGE, INC., 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 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DALE R. BRUMBACH 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 Address (if address cannot be reasonably ascertained, please so indicate) 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) CHASE BANK USA, NA 3700 WISEMAN BOULEVARD SAN ANTONIO, TX 78251 CHASE BANK USA, NA 436 SEVENTH AVE STE 1400 C/O JAMES C. WARMBRODT, ESQUIRE PITTSBURGH, PA 15219 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MEMBERS Is'FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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. 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 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. r September 20, 2010 By: Atto Dyvfolaintiff Phelan Hallinan & Schmieg, LLP ? L rence T. Phelan, 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 SUNTRUST MORTGAGE, INC. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. DALE R. BRUMBACH : NO. 10-4221-CIVIL : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 "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 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810 is scheduled to be sold at the Sheriff's Sale on 03/02/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $102,827.04 obtained by SUNTRUST MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement.wilf?e made at said sale in compliance with Pa.R.C.P. Rule 3129.3. ` -' NOTICE OF OWNER'S RIGHTSz YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE rh? 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. 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 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 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 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 LEGAL DESCRIPTION ALL that certain lot of ground situated in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at the point of Intersection of the line of adjoiner between Lot Nos. 22 and 23, in the hereinafter mentioned Plan of Lots, and the line of the western edge of North 32nd Street, which point is also 150 feet in a northerly direction by the western line of North 32nd Street from Lincoln Street; thence south 86 degrees west, by said line of adjoiner and lands now or formerly of Ada M. Eckert, one hundred sixty (160) feet to an iron pin at the eastern line of a 15 foot alley; thence, north 4 degrees west, by the said eastern line of a 15 foot alley, for a distance of fifty (50) feet to an iron pin at the northwest corner of Lot No. 24; thence north 86 degrees east, by the southern line of Lot No. 24, for a distance of one hundred sixty (160) feet to a point on the line of the northern edge of North 32nd Street; thence, south 4 degrees east, by the western line of North 32nd Street, for a distance of fifty (50) feet to the point and place of BEGINNING. BEING Lot No. 23, on Plan of Lots of Belvoir, which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 16. HAVING thereon erected a two story brick and frame dwelling house known and numbered as 208 North 32nd Street, Camp Hill, PA 17011 TITLE TO SAID PREMISES IS VESTED IN Dale R. Brumbach, single man, by Deed from Dorothy A. Keeley, widow, dated 07/10/2001, recorded 07/12/2001 in Book 247, Page 1895. PREMISES BEING: 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810 PARCEL NO. 01-21-0273-025 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-4221 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUNTRUST MORTGAGE, INC., Plaintiff (s) From DALE R. BRUMBACH (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $102,827.04 L.L.$.50 Interest from 8/4/10 to Date of Sale ($16.90 per diem) -- $3,565.90 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Plaintiff Paid Date: 9/22/10 (Seal) REQUESTING PARTY: Other Costs Cavid D. Bue 1, Prothonotary By: Deputy Name: MICHELE M. BRADFORD, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 69849 r AFFIDAVIT 6F SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY SUNTRUST MORTGAGE, INC. PHS # 241325 DEFENDANT SERVICE TEAM/ tore DALE R. BRUMBACH COURT NO.: 10-4221-CIVIL SERVE DALE R. BRUMBACH AT: TYPE OF ACTION 208 NORTH 32ND STREET XX Notice of Shei itf's Sale CAMP HILL, PA 17011-2810 SALE DATE: 03/02/2011 SERVED 1~ > ' Served and made known to DALE R. BRUMBACH ,Defendant on the -day of &Gt °6L'R 20t --t 6 2% , o'clock/. M., at Uir Ar. Sloe( 5t. ,Awe 1h&-E9 in the manner described below: Defendant personally served. _ - Adult family member with whom Defendant(s) reside(s). m.? T Relationship is [ i Adult in charge of Defendant's residence who refused to give name or relationship. -"7 C' _ 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: Ages Height 5 Weight 176 Race U) Sex Al Other I, & N AZ4 A46 &L , a competent adult, being duly sworn according to law, depose and state 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. Sworn to and subscribed before me this ZS µday KIMBERLY CURTY of 2010 ??GU??`'V NOTARY PUBLIC ?- STATE OF NEW JERSEY Notary: Y RY COMMISSION EVIIRES MARCH 1, 2013 NOT SERVED On they o 20_, at _ o'clock _. M., Defendant NOT FOUND because: cant _ Does Not Exist - Moved - Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of M-. By: Notary: ATTORNEY FOR PLAIlVTIFF Lawra,m T. Pbdwk Faq., K No. 32227 Finis S. HaB`rt, Esq, Id. No. 62695 Daniel G. Schde& Esq, Id. No. 62265 Mk bde M. Brsdfad, Faq., Id. No. 69849 Jdith T. Romano, Esq., Id. Na 58745 Shetld R Shnh-Jard, Esq, IL No. 81760 Jeohte R. Davey, Fact, Id. Nw 87077 Looter R. Tsbae, Esq, Id. No. 93337 Vivek Siivastova, Esq., Id. No. 202331 Jay IL Jones, Esq, Id. No. 86657 Peter J. Mukaby, Esq., Id. No. 61791 Andrew L. Spivack, Esq, Id. No. 84439 Jaime McGuinness, Esq, Id. No. 90134 Chrim"do to P. FMW4 al., Id. No. 94620 Josboa 1. Gotlman, Esq., Id. No. 206047 Courtemy R. Dunn, FA;., bL No. 206779 Andrew C. Brambidy . No. M075 Oa P. Ceefer at Station 1617 John F. Kamedy Blvd, Suite 1400 Phildelp ", PA 19103.1814 1215)563-7000 SUNTRUST MORTGAGE INC., IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DALE R. BRUMBACH, DEFENDANT NO. 10-4221 CIVIL ORDER OF COURT AND NOW, this 16th day of December, 2010, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before January 6, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, - "Sheetal R. Shah-Jani, Esquire Attorney for Plaintiff ?Dale R. Brumbach Defendant bas n Ccr l £s rYtS t Lot `v` M. L. Ebert, Jr., --) , , a p -, _ CZ C:, f-.:7 i ? S c CD q X ? r+i - i a D co -FILED-OFF ICP TIDE PRQTHOtt' 2910 DEC 27 AM 10: 01 CUMBERLAND PENNSYLVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DALE R. BRUMBACH No.: 10-4221-CIVIL Defendant CERTIFICATION OF SERVICE 241325 I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of January 6, 2010 was sent to the following individual on the date indicated below. DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 z::No. Han-&. ieg, DATE: V1 ZZ410 By: e T. Phelan, sq., Id. ' c ? Francis S. Halli nan, 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 [Allison F. WeJls, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF 241325 -FILED-OFFICE OF THE PROTHONOTARY 2011 Y"I ! _ : 13: 48 CUMBE;, ' ?" ' ?'L`` r Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Court of Common Pleas Plaintiff Cavil Division V. CUMBERLAND County DALE R. BRUMBACH No.: 10-4221-CIVIL Defendant MOTION TO MAKE RULE ABSOLUTE 241325 SUNTRUST MORTGAGE, INC., by and through its attorneys, Phelan Hallinan & Schmieg, LLP, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: That it is the Plaintiff in this action. 2. A Motion to Reassess Damages was filed with the Court on December 15, 2010. 3. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on December 7, 2010 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. True and correct copies of Plaintiff s letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit "A". 4. A Rule was issued by the Honorable M.L. Ebert, Jr. on or about December 16, 2010 directing the Defendant to show cause why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit "B". 5. The Rule to Show Cause was timely served upon all parties on December 22, 2010, in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit "C". 6. Defendant failed to respond or otherwise plead by the Rule Returnable date of January 6, 2011. 241325 WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. Phelan Hallinan & S DATE: B awrence T. Pht* an, 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 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 lison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF 241325 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DALE R. BRUMBACH Defendant No.: 10-4221-CIVIL BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE 241325 A Motion to Reassess Damages was filed with the Court on December 15, 2010. A Rule was entered by the Court on or about December 17, 2010 directing the Defendant to show cause why the Motion to Reassess Damages should not be granted. The Rule to Show Cause was timely served upon all parties on December 22, 2010 in accordance with the applicable rules of civil procedure. Defendant failed to respond or otherwise plead by the Rule Returnable date of January 6, 2011. 241325 WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. Phelan DATE: ?J L ce T. Phelaq., 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 [;-Allison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF 241325 Exhibit "A" 241325 Y C% a a a w U CIO 'Q a a ¢ W x a 0 Y o ?a C oa ? L C rn ,b N L d z c ao ? ? C O F '.j v o c w v o cl 7 v ? u E C U N u u .v. ? E w o O o v # 6u c A 3 d F U T ? & ? 8 b '9 ? ' N gF H e . C ? C u O 9 w j ? ^ 1?1 . y u w ? v ? u ?' qd u O j 0! .? U ? ? N C U o v .a u a 00 p. d o m c O E. co ¢ a . ocoE?? s=e?' x ..A b?ov o ,cN rA u rn v d w vi rX 'C U Q v? ? ? Q O N ? QI P7 u c W a ? , N 4 ? w .. ° o ma 0 'O / y Fy Z ; ',. N M e u N ? ¢ x . a N M N c? Exhibit "B" 241325 SUNTRUST MORTGAGE INC., IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DALE R. BRUMBACH, DEFENDANT NO. 10-4221 CIVIL ORDER OF COURT AND NOW, this 16th day of December, 2010, upon consideration of the Plaintiffs Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before January 6, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, "Sheetal R. Shah-Jani, Esquire Attorney for Plaintiff ?Dale R. Brumbach Defendant bas CZY « i=ILet M. L. Ebert, Jr., c' a -n r n C C= ,= -? r-q Z r*I r .1 b rQ -4cs o- z ) ° ,y On yc -I o n CD M Exhibit "C" 241325 A v , 0 ?E ? Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hal linan, 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. Jenine R. Davey, Esq., Id. No. 8701 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. N(Y. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Plaintiff v. DALE R. BRUMBACII Defendant PP f an •: i 27 AM I: Ah. PENNS's ATTORNEY FOR PLAINTIFF Court of Common Pleas Civilpif'i "WAND County No,: 10-4221-CIVIL. CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of January,6,, 20vas sent to the following individual on the date indicated below. DALE R. BRUMBACH 208 NORT14 32ND STREET CAMP HILL, PA 17011-2810 Phelan DATE: By: --"'---- wrence T. Phelan, Esq., Id. No. ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ? Judith tomano, Esq., Id. No. 58745 ? She Shah-Jani, Esq., Id. No. 81760 Davey, Esq., Id. No. 87077 n R. Tabas, Esq., Id. No. 93337 ivek Srivastava, Esq., Id. No. 202331 ay 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. Fliakes, 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 RAllison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF J ,. VERIFICATION I hereby state that I am the attorney for Plaintiff in this action, that I am authorized to make this verification, and that the statements made in the foregoing Motion to Make Rule Absolute are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement herein is made subject to the sworn penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification of authorities. DATE: Phelan Hallinan &-Sc:hmim LLP L La . Pin, 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 ? drew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF 241325 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 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 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 SUNTRUST MORTGAGE, INC. Plaintiff V. DALE R. BRUMBACH Defendant ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-4221-CIVIL CERTIFICATION OF SERVICE 241325 I hereby certify that true and correct copies of Plaintiff's Motion to Make Rule Absolute and Brief in Support thereof were served upon the following individual on the date indicated below. DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 Phelan HallinanZ DATE: By: V, Lawren . 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 E?Allison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF 241325 RtED-0FFIC'•E 20 ! I JAN 14 All !'r l ." `"UMBERLA"' l C IIJ ! F L 1W 1 LVI%! ir:,?•- 2011 JON 12 PM ? 03 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, INC. Court of Common Pleas Plaintiff : Civil Division V. CUMBERLAND County DALE R. BRUMBACH No.: 10-4221 -CIVIL Defendant A ORDER AND NOW, this 13 day of -S4A , 2011, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant shall be and is hereby made absolute; and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ordered to amend the judgment and the Sheriff is ordered to amend the writ nunc pro tunc as follows: Principal Balance Interest Through March 2, 2011 Per Diem $15.44 Late Charges Legal fees Cost of Suit and Title Sheriffs Sale Costs Property Inspections/ Property Preservation Appraisal/Brokers Price Opinion Mortgage Insurance Premium / Private Mortgage Insurance Non Sufficient Funds Charge $93,910.99 $9,856.86 $326.00 $1,300.00 $595.00 $0.00 $0.00 $0.00 $0.00 $0.00 a 241325 Suspense/Misc. Credits Escrow Deficit TOTAL ($0.00) $2,965.61 $108,954.46 Plus interest from March 2, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. BY THE COURT J. 241325 /'-phelan ptLtt i r-.eXn t 1)&6rA9. LL P pale R. Brurnbach CoQ axA 241325 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, INC. Plaintiff, V. DALE R. BRUMBACH Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL. DIVISION No.: 10-4221-CIVIL = r'!) w AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 77 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth 7elr)Ao Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Vorm n and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is ttached Exhibit'As-? Date: , 1)11 U ce T. Phelan, Esq., Id. No. 3222Y F cis is 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 R-.40-dine R. Davey, Esq., Id. No. 87077 66 La muren n 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 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. r-a F r? ,J PHS # 241325 SUNTRUST MORTGAGE, INC. Plaintiff V. DALE R. BRUMBACH COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-4221-CIVIL Defendant(s) CUMBERLAND COUNTY PHS # 241325 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 SUNTRUST MORTGAGE, INC., 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 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 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) CHASE BANK USA, NA 3700 WISEMAN BOULEVARD SAN ANTONIO, TX 78251 CHASE BANK USA, NA 436 SEVENTH AVE STE 1400 C/O JAMES C. WARMBRODT, ESQUIRE PITTSBURGH, PA 15219 PENN WASTE INC 85 BRICKYARD RD PO BOX 3066 YORK, PA 17402 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MEMBERS 1sT FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 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. £ 0 L6 3000diZ WONA a311VVi OWZ £Zd3S 99ZLLZb000 `30 IM z o / - Nsod 0 /cw U - C o C r" H r ?3 ? a •s o ? o o •y?o ? ? a ? ? ? ??~ wig >, 8 A AHE,O;,. 3 3ug ?`n ?qo? v1?o wa any e < ., <?De°$iya bCq ' ? as ? •?" ? e wMw? ?? ?N??C ?Z??z ??? or0 A??? ? ? + ° ?+ ?U °, ,o a ••? o? a? a? w .9 e o A e ?•? o Q ?' a ®~•a^?? Ep4 a° vooao a0? D ? Owe aq p???W o? a o?:? o?e??? 8 aZ oT`e 8 °?'p C °•.?$ ?<?? t?? ?''??.?, g ?? d< ..x? a. -• az?NUC`?V?VU?haC?S?a??>?N?v?,?u??a9 ?oa?? a3?a ? F ?qC # zQ0 a'" N "' v h ?o o? o zI 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 None. reasonably ascertained, please indicate) 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 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 t t false state ge is herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsific ion to author' es. 4JI, !IjElap4lallinan & 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 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 rrvv ??••? o9z o- $ VU .Mwmw 1 P SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Suntrust Mortgage I vs. Dale R. Brumbach FILED-OFFICE 0 THE " 0 T'9 ON-0 T R)' '011 JUL -S PM 2: 12 CUMBERLAND COU,NTy PENNSYLVAN'I A Case Number 2010-4221 SHERIFF'S RETURN OF SERVICE 12/29/2010 09:00 F posting upon tF 03/02/2011 As dire 5/4/201 04/27/2011 As dire 07/01/2011 Ronny per Jett( I - Deputy Dennis Fry, being duly sworn according to law, states service was performed by true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, property located at 208 North 32nd Street, Camp Hill, PA 17011, Cumberland County. ad by Phelan Hallinan & Schmieg, LLP, Attorney for the Plaintiff, Sheriffs Sale Continued to :d by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/6/2011 Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", of instruction from Attorney. SHERIFF COST: $68$.42 July 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF a &C) j9/1 ('v sz r_L --,? Ir 46-* S?l? M ! SUNTRUST MGZTGAGE, INC. Plaintiff ' v. DALE R. BRUMB8CH Defendant(s) PHS # 241325 AFFIDAVIT PURSUANT TO RULE 3129.1 COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-4221-CIVIL CUMBERLAND COUNTY SUNTRUST M RTGAGE, INC., 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 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DALE R. BRU BACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 2. Name and Name of Defendant(s) in the judgment: Address (if address cannot be reasonably ascertained, please so indicate) SAME AS 3. Name and last Name CHASE BANK address of ever? judgment creditor whose judgment is a record lien on the real property to be sold: Address (if address cannot be reasonably ascertained, please indicate) NA 3700 WISEMAN BOULEVARD SAN ANTONIO, TX 78251 CHASE BANK SA, NA 436 SEVENTH AVE STE 1400 CIO JAMES C. ARMBRODT, ESQUIRE PITTSBURGH, PA 15219 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MEMBERS IT EDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 5. Name and addres 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 sale. Name of every other person who has any record interest in the property and whose interest may be affected by the Address (if address cannot be reasonably ascertained, please indicate) None. 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 thi.- sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OC6UPANT Domestic Relations of Cumberland C¢unty Commonwealth) of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Departme t of Justice U.S. Attorney f r the Middle District of PA COMMONWE LTH OF PENNSYLVANIA BUREAU OF I DIVIDUAL TAX INHERITANC TAX DIVISION DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 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. I September 20, 2010 By. kklt?? Atto y for Plaintiff Phelan Hallinan & Schmieg, LLP V rence T. Phelan, Esq., Id. No. 32227 cis S. Hallinan, Esq., Id. No. 62695 iel G. Schmieg, Esq., Id. No. 62205 hele 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 SUNTRUST MORTGAGE, INC Plaintiff VS. DALE R. BRUMB?CH Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-4221-CIVIL CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DALE R. B UMBACH 208 NORTH 32ND STREET CAMP HILL, PA 17011-2810 * *THIS FIRM IS A D BT 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 A SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (r al estate) at 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810 is scheduled to be sold at the Sheriff Sale on 03/02/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $102,827.04 obtained by SUNTRUST MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in c mpliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS VENT To prevent this Sheriffs Sale, you must take immediate action: 1. The sale w 11 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 b able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was i properly 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 s le. (See notice on page two on how to obtain an attorney.) . YOU MAY STILL BE ABLE TO SAVE YOUR EVEN IF THE SH RIIPF'S SALE DOES TAKE YOU HAVE 1. If the Sheriff s S le is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 15-563-7000. 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 Sheriff, you will remain the owner of the property as if the sale never happe ed. 5. You have the righ 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 themoney 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 un ess exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days fter the filing of the proposed schedule. 7. You may also hav? other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAI ?E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAN NOT 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 I LEGAL DESCRIPTION ALL that cert?iin lot of ground situated in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at the point of Intersection of the line of adjoiner between Lot Nos. 22 and 23, in the hereinafter mentioned Plan of Lots, and the line of the western edge of North 32nd Street, which point is also 150 feet in a northerly direction by the western line of North 32nd Street from Lincoln Street; thence south 86 degrees west, by said line of adjoiner and lands now or formerly of Ada M. Eckert, one h dred sixty (160) feet to an iron pin at the eastern line of a 15 foot alley; thence, north 4 degrees west, by the said eastern line of a 15 foot alley, for a distance of fifty (50) feet to an iron pin at the no west corner of Lot No. 24; thence north 86 degrees east, by the southern line of Lot No. 24, for a istance of one hundred sixty (160) feet to a point on the line of the northern edge of North 32nd Street; thence, south 4 degrees east, by the western line of North 32nd Street, for a distance of fi y (50) feet to the point and place of BEGINNING. BEING Lot N . 23, on Plan of Lots of Belvoir, which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 16. HAVING thereon erected a two story brick and frame dwelling house known and numbered as 208 North 32nd St eet, Camp Hill, PA 17011 i i i Lh i u Ill PREMISES 1S VESTED IN Dale R. Brumbach, single man, by Deed from Dorothy A. K eley, widow, dated 07/10/2001, recorded 07/12/2001 in Book 247, Page 1895. PREMISES BE G: 208 NORTH 32ND STREET, CAMP HILL, PA 17011-2810 PARCEL NO. 1-21-0273-025 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-4221 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUNTRUST MORTGAGE, INC., Plaintiff (s) From DALE R. BRUMBACH (1) !You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISI EE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying an 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 nd is enjoined as above stated. Amount ue $102,827.04 L.L.$.50 Interest from 8/4/10 to Date of Sale ($16.90 per diem) -- $3,565.90 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Plaintiff P ?id Date: 9/2210 i? (Seal) Other Costs Deputy REQUES Name: M Address: Attorney f Telephone Supreme ( ING PARTY: CHELE M. BRADFORD, ESQUIRE HELAN HALLINAN & SCHMIEG, LLP 617 JFK BOULEVARD, SUITE 1400 )NE PENN CENTER PLAZA HILADELPHIA, PA 19103 r: PLAINTIFF 215-563-7000 Durt ID No. 69849 zoluutploo,? tLa2I 01OZ `ZZ J3quzanoN :ajUQ -ut3j3q polviodtoout oouOnjo.z still Xq puu llim stgi gilm polo «d„ liglgxg uo poquosap XIInj QIOW `IhH dwicD 1;)ojlS PuZ£ tljtoN 8OZ `st pazagtunu pue umoulx `dd `Xlunoj puvIjaquzna `g2no.tog IItH dutLa ut povemis ?izadojd luaz all ut 4sa.talui s,luUpuajap oqj uodn patnaj jjizatlS Qqj 0 IOZ `ZZ zaqutanoN up PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMOI WEALTH OF :PENNSYLVANIA ss. COUNTY ? F CUMBERLAND. Lis 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 f r the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 28, February 4, and February 11, 2011 Affi nt further deposes that he is authorized to verify this statement by the Cumberland Law Journa, 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, ditor SWORN TO AND SUBSCRIBED before me this 11 day of February 2011 rNotary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 I CUMBERLAND LAW JOURNAL Writ Noi 2010-4221 Civil Sunt st Mortgage Inc. vs. Dal R. Brumbach Atty.: Daniel Schmieg By virtue o fa Writ of Execution NO. 10-4221-CIVIL, SUNTRUST MORT- GAGE, INC. vs. DALE R. BRUMBACH, owner(s) of property situate in the BOROUGH F CAMP HILL, Cum- berland County, Pennsylvania, being 208 NORTH 2ND STREET, CAMP HILL, PA 17011-2810. Parcel No. 01-21-0273-025. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGME TAMOUNT: $102,827- .04. i --•-r, 2'r"o''-'Yews Co. Z O 'FecFlno ogy Pkwy SU4E '300. Me,-,hatflcsbup1, PA 17050 Inquiries - 71`'-255-8213 C1JMBERLIND CO. SHERIFF=S OFFICE CUMBERLAND COUNTY COURT HOUSE atr otW,4 5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1926 Commonwealth of Pennsylvania, County of Dauph n) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and exist ng under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 -lechnolog f Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of Thf Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot DdVE?, 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 off=ice for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 260401 M11 Tsm . V*, MrrM "" 4 *49 or a °1NIIie of 11100016010 NO. ??irc?, sae. A DALE R. BRUMBACH owser(s) of property situate in the BOROUGH OF CAMP HII L fS+mbccrlasd Canty, Peylvania, being i (qty) 208 NOR H 32ND STREET CAW HILL, PA 17012-2810 Parml No. 01-21-0273-(Y1.5 (Acreage or save address) bwwoements thereoff. 1aIDE14 nAL DWMI ING JUDGhaW AMOUNT 5102,82904 Sworn to'artd subscribed before me this Notary Public .-. This ad ran on the date(s) shown below: 1/28/11 2/4/11 2/11/11 a.,0VI..... , flay of February, 2011 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie Lower L ?' Notary Public a ,Dauphin 26County M' Comm Member- °ennsvtvanla? , 2011 Assocfatron of Natarres Li rh4EPROTIf lot Z 6 4 FEB -7. A HD 10. 4 2. CI1" 3 LA,`4D:COUN` Y PENNSYLVANIA Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DALE R.BRUMBACH Defendant(s) No. 10-4221-CIVIL PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P.,2352 TO THE PROTHONOTARY: Kindly substitute FANNIE MAE("FEDERAL NATIONAL MORTGAGE ASSOCIATION") as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: FANNIE MAP,("FEDERAL NATIONAL MORTGAGE ASSOCIATION") is the current holder of the mortgage by virtue of that certain Assignment of Mortgage, which Assignment was recorded on 1.0/25/2013 in Instrument No. 201334789 of the Recorder of Deeds Office in and for CUMBERLAND County. Kindly amend the information on the docket accordingl . Date: & By: Mario J. Hanyon,Esq.,Id. No.2 993 Attorney for Plaintiff PH#735159 C U+ 3 �� �� X1373 Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE INC. Court of Common Pleas t Plaintiff Civil Division V. CUMBERLAND County DALE R.BRUMBACH Defendant(s) No. 10-4221-CIVIL PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION'), located 14523 SW MIL,LIKAN WAY SUITE 200 BEAVERTON, OR 97005 Date:_p7 PHELAN H LLINAN,LL By: Z^- Marjo J. anyon,Es Id. N . 03993 Attorney for Plaintiff PH#735159 Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE INC. Court of.Common Pleas Plaintiff Civil Division V. CUMBERLAND County DALE R.BRUMBACH Defendant(s) No. 10-4221-CIVIL ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION"). Date: PHELAN HALLINAN,LL By: ' Mario J. Hanyon,Es q/,Id.&o.26993 Attorney for Plaintiff PH#735159 Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 SUNTRUST MORTGAGE INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DALE R.BRUMBACH Defendant(s) No.10-4221-CIVIL CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Plaintiffs Praecipe to Mark Judgment to'FANNIE MAE ("FEDERAL NATIONAL MORTGAGE ASSOCIATION"), Substitution of Party Plaintiff and Entry of Appearance were served by regular mail on the person(s) on the date listed below: DALE R. BRUMBACH 208 NORTH 32ND STREET CAMP HELL,PA 1.7011-2810 Date: /Lo (l Y PHELAN HALLINAN, LLP By: Ma/61 LHanyon,Es Id.N .203993 Attorney for Plaintiff