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HomeMy WebLinkAbout10-4699SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~ptr o~ ~utu9b~~/~~~ ~ ~ *'~ oFf~f ~F TH£ $K~RI~IF ~~ ~ ~1: -t. a:~ 7 ~ ..` ~~{1i¢~ ip'N? ll ~ N S t ~; ~~; ~, ,:r~. First Horizon Home Loans vs. Bradleh M. Martz (et al.) Case Number 2010-4699 SHERIFF'S RETURN OF SERVICE 07/27/2010 08:11 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 27, 2010 at 2011 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradleh M. Martz, by making known unto Molly Martz, Wife of defendant at' 843 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. AMANDA COBAUGH, DEPUTY 07/27/2010 08:11 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 27, 2010 at 2011 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Molly M. Martz, by making known unto herself personally, at 843 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 July 28, 2010 AMA DA COBAUGH, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySui[e Sheriff. Teleosoft, Inc. PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants -O i' IC E - eTFA rr' Y CUM[ Pi., 1, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment by Default in favor of Plaintiff, First Horizon Home Loans, a division of First Tennessee Bank National Association and against Defendants, Bradleh M. Martz and Molly M. Martz, for failure to file an Answer on Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $170,839.77 Interest @ $807.53 per month 08/01/10 to 09/30/10 $1,615.06 Late Charges $55.60 Escrow Advances $1,697.56 Pro Rata MIP/PMI Premium $107.01 -inspection Fees $90.00 Corporation Advance $1,908.25 TOTAL $176,313.25 Together with interest at the contract rate after the date of judgment, and costs. 414.00 Pa AIT-/ Cr a 13547 0.1g81093 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT IN MORTGAGE FORECLOSURE AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT IN MORTGAGE FORECLOSURE. I hereby certify that the attached Notices of Intention to Take Default were forwarded to Defendants more than ten (10) days ago. PA R McCAY P.A. By: Christine A. Pinto, Esquire Three Greentree Centre 7001 Lincoln Drive West P.O. Box 974 Marlton, NJ 08053-0974 Date: September 1, 2010 2 0 0 File No. 14027-0196 Law Offices PARKER McCAY P.A. By: Mary Wu, Esquire Attorney I.D. #209171 Three Greentree Centre, Suite 401 7001 Lincoln Drive West P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorneys for Plaintiff First Horizon Home Loans, a division of First Tennessee Bank National Association 4000 Horizon Way Suite 150 Irving, TX 75063 COURT OF COMMON PLEAS CUMBERLAND COUNTY JULY TERM 2010 NO. 10-4699 Plaintiff, V. CIVIL ACTION MORTGAGE FORECLOSURE Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants. NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: Bradleh M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 DATE OF NOTICE: August 17, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE 0 0 COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PA A P.A. 7 BY: Nary Wu Attorney or Plaintiff DATE: August 17, 2010 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL (n 3 S 3 i W 7160 3401 9846 78316 4857 w ¢, 5) 0 o C ?I CD n oz itj TO:Bradleh Martz x 0 o s - I 843 West Foxcroft Drive r °* o k r n So I~1. m Camp Hill, PA 17011 o c 3„° r O N 9? h n n ?0 ^ >n . s Z P O f? = a ?T? y n m ?? od ?Tnm CC) Fj r0 =d. ., CD N 3- l SENDER: Deanna w < 1 REFERENCE1I Days B. Martz o (D N w n cr n (D l PS Form 3800. January 2005 RETURN Postage Nk RECEIPT Certified Fee 0.00 y a SERVICE Return Receipt Fee 0.00 Restricted Delivery 0.00 {iy Total Postage & Fees I US POSTAGE POSTMARKARt P?rE _ i $01.15 Receipt for WHed From 08053 Certified Mail d ?'??•' `?.' 03" 0 i la 031 AO OOS 180085 No kmraaa coamp Ptalda0 C?Q) Do Not um to Milan ww" w • File No. 14027-0196 Law Offices PARKER McCAY P.A. By: Mary Wu, Esquire Attorney I. D. #209171 Three Greentree Centre, Suite 401 7001 Lincoln Drive West P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorneys for Plaintiff First Horizon Home Loans, a division of First Tennessee Bank National Association 4000 Horizon Way Suite 150 Irving, TX 75063 is COURT OF COMMON PLEAS CUMBERLAND COUNTY JULY TERM 2010 NO. 10-4699 Plaintiff, V. CIVIL ACTION MORTGAGE FORECLOSURE Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants. NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 DATE OF NOTICE: August 17, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY: ary W7rPlaintiff AttorneDATE: August 17, 2010 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL 7360 3%1 1846 7836 4964 TO;Molly M. Martz n 3 w o 3 J? 843 West Foxcroli Drive w 0 O o sv n o n (? Camp Hill, PA 17011 x CD SENDER: Deanna REFERENCE10 Days Molly Martz RETURN Postage RECEIPT Certified Fee 0.00 SERVICE Return Receipt Fee - 0.00 Restricted Delivery 0.00 Total Postage & Fees u $wvw POSTM 1)8 ?TE ? Receipt for ? ? Certified Mail ?4M No Itt/IRa"c ft*A d C $o 00 Nat Um for YNNr1"CI 'UM - 0 (D o i > X I J n 3 n n r ? 1 .= I o N ?4 0 n aj ? ,? 1 ?. co m C ' co a w Fj ro „ 3 d R1 , C - o J (D rt a ? nl : ? v i ,r N rj 2 s 3 OSTAGE 01 15 . Mailed From 08053 08117/2010 031A 0005180085 c c f 1 rL PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : CIVIL ACTION : MORTGAGE FORECLOSURE VERIFICATION OF NON-MILITARY SERVICE I, Christine A. Pinto, Esquire, hereby certify that I represent Plaintiff in the above entitled case; that I am authorized to make this Verification on behalf of Plaintiff; that the above-named Defendants are over 18 years of age; that the address of the Defendants, Bradleh M. Martz and Molly M. Martz is 843 West Foxcroft Drive, Camp Hill, PA 17011; that the occupations of the Defendants are unknown; and that the Defendants are not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I also certify that the address of the Plaintiff is 4000 Horizon Way, Irving, TX 75063 st ., I understand that the statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. PA R MCCAY, A. By: Christine A. Pinto, Esquire Date: September 1, 2010 2 PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney IN 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : CIVIL ACTION : MORTGAGE FORECLOSURE CERTIFICATION I, Christine A. Pinto, Esquire, do hereby certify that the Defendants, Bradleh M. Martz and Molly M. Martz were served with the Complaint in Mortgage Foreclosure in this action, by the Cumberland County Sheriff on July 27, 2010. A true and correct copy of the Cumberland County Sheriffs Return of Service is attached hereto as Exhibit "A". PARKER CCAY, P.A. By: Christine A. Pinto, Esquire Three Greentree Centre 7001 Lincoln Drive West P.O. Box 974 Marlton, NJ 08053-0974 Date: September 1, 2010 t)(ANI,IIT A SHERIFROFFICE OF CUMBERLA COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OF'CE OF 7;-,E First Horizon Home Loans vs. Bradleh M. Martz (et al.) Case Number 2010-4699 SHERIFF'S RETURN OF SERVICE 07/27/2010 08:11 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 27, 2010 at 2011 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradleh M. Martz, by making known unto Molly Martz, Wife of defendant al- 843 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. AMANDA COBAUGH, DEPUTY 07/27/2010 08:11 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 27, 2010 at 2011 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Molly M. Martz, by making known unto herself personally, at 843 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 July 28, 2010 Arifidl AMANDA COBAUGH, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c CourtySuae Sheriff, Teieosoft, trc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants JULY TERM, 2010 DOCKET NO. 10-4699 CIVIL ACTION MORTGAGE FORECLOSURE. s ?= G1 PRAECIPE FOR WRIT OF EXECUTION -; (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: C) c (!? r? w GJ t` r..? -n C`) ?T1 7Z3 Kindly issue writ of execution in the above matter directed to the Sheriff of Cumberland County. Kindly index this Writ against the Defendants as follows: Bradleh M. Martz and Molly M. Martz. Real Property involved: 843 West Foxcroft Drr've, Camp Hill, PA 17011. p1,? 001 s Amount due pQ?e,Saie $176,313.25 O Interest from 10/01 / 10 to ltt3t740 (at the monthly rate of $807.53 Costs Total a?4.ob paxwq $2,422.59 57.50 C13F 0. Do 14. oo $ " a.50 oo - ao n-M $ 0- CHRISTINE A. PINTO, ESQUIRE '50 LL Attorney for Plaintiff, First Horizon Home Loans, a division of First Tennessee Bank N.A Date: September 1, 2010 e* alarm & a481o93 RE Wt 6 No. 2010-4699 July Term, 2010 First Horizon Home Loans, a division of First Tennessee Bank N.A. Plaintiff VS Bradleh M. Martz and Molly M. Martz Defendant PRAECIPE FOR WRIT OF EXECUTION Dated: September 1, 2010 Attorney(s) for Plaintiff(s) PARKER MCCAY P.A. CHRISTINE A. PINTO, ESQUIRE Three Greentree Centre 7001 Lincoln Drive P.O. Box 974 Marlton, NJ 08053 (856) 810-5815 1J ` E t F sti,; ! iiL11M EAR i PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants il0SEP 23 P 3:22 '11 N L N} U cau v s ;, J'EH 11 SYL.`,ANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 First Horizon Home Loans, a division of First Tennessee Bank National Association, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 843 West Foxcroft Drive, Camp Hill, PA 17011: Name 1. Name and address of Owner(s) or Reputed Owner(s): Address (if address cannot be reasonably ascertained, please so indicate) Bradleh M. Martz 843 West Foxcroft Drive Cam Hill, PA 17011 Molly M. Martz 843 West Foxcroft Drive Cam HPA 17011 2. Name and address of Defendants in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Bradleh M. Martz 843 West Foxcroft Drive Cam Hill, PA 17011 Molly M. Martz 843 West Foxcroft Drive Cam Hill, PA 17011 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 so indicate) First Horizon Home Loans, a division of First Tennessee Bank N.A. 4000 Horizon Way Irving, TX 75063 Mortgage Electronic Registration Systems, Inc. as PO Box 2026 nominee for First Horizon Home Loans, a Division Flint, MI 48501 of First Tennessee Bank, NA 4000 Horizon Way Irving, TX 75063 Borough of Wormleysburg c/o Gary W. Berresford, Solicitor 20 Market Street Wormle sbur , PA 17043 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) First Horizon Home Loans, a division of First Tennessee Bank N.A. 4000 Horizon Way Irving, TX 75063 Mortgage Electronic Registration Systems, Inc. as PO Box 2026 nominee for First Horizon Home Loans, a Division Flint, MI 48501 of First Tennessee Bank, NA 4000 Horizon Way Irving, TX 75063 5. Name and address of every other person who has any record lien on the property: Name ONLY THOSE LISTED ABOVE. Address (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland Valley School District c/o Alma Berresford 20 Market Street Wormle sbur , PA 17043 Wormleysburg Borough Tax Collector c/o Alma Berresford 20 Market Street Wormle sbur , PA 17043 Wormleysburg Borough Water PA American Water 800 W Hersheypark Drive Hershey, PA 17033 Wormleysburg Borough Sewer/Trash 20 Market Street Wormle sbur , PA 17043 Lehigh County Treasurer 1 Courthouse Square Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 N. Hanover St. P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania 333 Health and Welfare Building Department of Welfare Harrisburg, PA 17105 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 ONLY THOSE LISTED ABOVE. Address (if address cannot be reasonably ascertained, please so indicate) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn Wfalsiflicon to authorities. V \6?k_ CHRISTINE A. PINTO, ESQUIRE Attorney for Plaintiff, First Horizon Home Loans, a division of First Tennessee Bank National Association Date: September 1, 2010 E.. i PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants 91010 SE 2? 1'f3:2' CUMBERLAND COUNTT _ "EHNSYLV NIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE CERTIFICATION I, CHRISTINE A. PINTO, Esquire, hereby certify that an Act 91 Notice was provided to the above-named Defendants by letter dated April 26, 2010. This certification is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. CHRISTINE A. PINTO, ESQUIRE Dated: September 1, 2010 t?.., `. ICE PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants 2 C1t0 SwF 23 Pelo 23* c2 CUMBERLAND COUNTY 1_1 r : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN ADDRESS STATE OF NEW JERSEY COUNTY OF BURLINGTON : . SS. BEFORE ME, the undersigned authority, a Notary Public in and for the said County and State, personally appeared CHRISTINE A. PINTO, ESQUIRE, attorney for the Plaintiff, who being duly sworn according to law, deposes and says that to the best of his knowledge, information and belief that the owners of the property located at 843 West Foxcroft Drive, Camp Hill, PA, are Defendants, Bradleh M. Martz and Molly M. Martz who reside at 843 West Foxcroft Drive, Camp Hill, PA. Sworn to and subscribe to IS Wreemb is 15` day f 2 10 PUBLIC C .............. V L 0Z ' L t IsnOny " s9jidx3 uoissrwwoo AN tiaslar MON }o 9181S '31,14nd hjeloN L9b88BZ N"uoissiwwoo S3tlbQlyfl3 V CHRISTINE A. PINTO, ESQUIRE ii F1 j CrE T PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants G? Ii .? - 23 d? • c2 it YL VANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SALE TO LIENHOLDERS OWNERS: Bradleh M. Martz and Molly M. Martz PROPERTY: 843 West Foxcroft Drive, Camp Hill, PA 17011 IMPROVEMENTS: Residential Single Family Dwelling PARCEL ID NO. CONTROL NO.: 47-18-1302-122 47000132 Please be advised that the undersigned office represents, First Horizon Home Loans, a division of First Tennessee Bank National Association, in a mortgage foreclosure. The above- captioned property is scheduled to be sold by the Sheriff of Cumberland County on December 8, 2010 at 10:00 a.m., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) Our records indicate that you may hold a mortgage or judgment lien on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. CHRISTINE A. PINTO, ESQUIRE Attorney for Plaintiff, First Horizon Home Loans, a division of First Tennessee Bank National Association Date: September 1, 2010 LONG LEGAL DESCRIPTION SEIZED AND TAKEN IN EXECUTION AS THE PROPERTY OF BRADLEH M. MARTZ AND MOLLY M. MARTZ ALL THAT CERTAIN lot situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, on the Plan of Lots of Riverview, as recorded in the Recorder's Office of Cumberland County, in Plan Book 11, Page 9, and being subject to utility easements and building and use conditions and restrictions of record, described as follows: BEGINNING at a point on the northeasterly line of West Foxcroft Drive, where the dividing line between Lots Nos. 19 and 20 intersects with the northeasterly side of West Foxcroft Drive; thence North 49 degrees 31 minutes 51 seconds East along the division line between Lots Nos. 19 and 20, a distance of 136.88 feet to a point; thence South 36 degrees 30 minutes East along the division line between Lots Nos. 26, 28 and 19, a distance of 86.15 feet to a point; thence South 51 degrees 14 minutes 54 seconds West along the division line between Lots Nos. 18 and 19, a distance of 132.21 feet to a point; thence in a northwesterly direction, in an arc to the left created by a 2,735.46 foot radius, along the northeasterly side of West Foxcroft Drive, a distance of 82.00 feet to a point, the place of BEGINNING. BEING Lot No. 19, Section 'D' on said Plan. PARCEL IDENTIFICATION NO: 47-18-1302-122, CONTROL #: 47000132 HAVING THEREON ERECTED a brick and frame dwelling known and numbered as 843 W. Foxcroft Drive, Camp Hill, Pennsylvania. BEING THE SAME PREMISES which Robert D. Lobel and Gwen S. Lobel, his wife, by Deed dated August 31, 1978, and recorded September 1, 1978, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book A, Volume 28, Page 356, granted and conveyed unto Robert A. Banks, Jr. and Margaret R. Banks, his wife. The said Margaret R. Banks died December 24, 1996, thereby vesting sole title unto Robert A. Banks, Jr., widower, Grantor herein. TITLE TO SAID PREMISES IS VESTED IN Bradleh M. Martz and Molly M. Martz, h/w, by Deed from Robert A. Banks, Jr., widower, dated 03/28/2008, recorded 04/01/2008 in Instrument Number 200809817. EXHIBIT "A" { THONOTAR" PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 {-F1,YLVAN1A First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Bradleh M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 The real estate located at 843 West Foxcroft Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at 10:00 a.m., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $176,313.25 plus fees, costs and other charges obtained by First Horizon Home Loans, a division of First Tennessee Bank National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Christine A. Pinto, Esquire, Three Greentree Centre, 7001 Lincoln Drive, P.O. Box 974, Marlton, NJ 08053. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that you may have the right to prevent or delay the Sheriff's Sale by filing, before this sale, a petition with the Court to open or strike the judgment against you or to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Civil Action Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend, or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. In addition, you may have the right to petition to set aside the sale for: (1) grossly inadequate price; (2) lack of competitive bidding by agreement; (3) irregularities in sale; or (4) fraud. To exercise this right you should file a petition with the Court after the sale and before the Sheriff has delivered his deed to the property. 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants X10 f+ ^3 n.. 22 C UIMSEryEr{ 1D COUNITY : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 The real estate located at 843 West Foxcroft Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on December 8. 2010 at 10:00 a.m., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $176,313.25 plus fees, costs and other charges obtained by First Horizon Home Loans, a division of First Tennessee Bank National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Christine A. Pinto, Esquire, Three Greentree Centre, 7001 Lincoln Drive, P.O. Box 974, Marlton, NJ 08053. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4tn Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that you may have the right to prevent or delay the Sheriff's Sale by filing, before this sale, a petition with the Court to open or strike the judgment against you or to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Civil Action Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend, or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. In addition, you may have the right to petition to set aside the sale for: (1) grossly inadequate price; (2) lack of competitive bidding by agreement; (3) irregularities in sale; or (4) fraud. To exercise this right you should file a petition with the Court after the sale and before the Sheriff has delivered his deed to the property. 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. Court Administrator Cumberland County Courthouse 4`h Floor Carlisle, PA 17013 (717) 240-6200 PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 20 110 S. P 23 P 3: 22 "1,.3 a£ ERLA D C 0 U N T Y LVANIA First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 : CIVIL ACTION : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: POSTING 843 West Foxcroft Drive Camp Hill, PA 17011 The real estate located at 843 West Foxcroft Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at 10:00 a.m., in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $176,313.25 plus fees, costs and other charges obtained by First Horizon Home Loans, a division of First Tennessee Bank National Association against you. NOTICE OV OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Christine A. Pinto, Esquire, Three Greentree Centre, 7001 Lincoln Drive, P.O. Box 974, Marlton, NJ 08053. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house 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, 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. Court Administrator Cumberland County Courthouse 4`h Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants : CIVIL ACTION : MORTGAGE FORECLOSURE WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that you may have the right to prevent or delay the Sheriff's Sale by filing, before this sale, a petition with the Court to open or strike the judgment against you or to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint in Civil Action Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened if you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriff s Sale would ordinarily be delayed pending a trial of the issue whether the plaintiff has a valid claim to foreclose the mortgage or judgment. You may also have the righf to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend, or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right you would have to file a petition to strike the judgment. In addition, you may have the right to petition to set aside the sale for: (1) grossly inadequate price; (2) lack of competitive bidding by agreement; (3) irregularities in sale; or (4) fraud. To exercise this right you should file a petition with the Court after the sale and before the Sheriff has delivered his deed to the property. 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-4699 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST HORIZON HOME LOANS, a division of FIRST TENNESSEE BANK, NATIONAL ASSOCIATION, Plaintiff (s) From BRADLEH M. MARTZ and MOLLY M. MARTZ (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 $176,313.25 L.L.$.50 Interest from 10/1/10 to Date of Sale (at monthly rate of $807.53) -- $2,422.59 Atty's Comm % Due Prothy $2.00 Atty Paid $190.00 Other Costs Plaintiff Paid Date: 9/23/10 i D. Buell, Prothonotary (Seal) By: REQUESTING PARTY: Name: CHRISTINE A. PINTO, ESQUIRE Address: PARKER McCAY, PA THREE GREENTREE CENTRE 7001 LINCOLN DRIVE WEST, PO BOX 974 MARLTON, NJ 08053-0974 Attorney for: PLAINTIFF Telephone: 856-810-5815 Deputy Supreme Court ID No. 205622 PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive Suite 300, P.O. Box 5054 Mount Laurel, NJ 08054 (856) 596-8900 Attorney for Plaintiff File #:14027-0196 First Horizon Home Loans, a division of First Tennessee Bank, National Association 4000 Horizon Way, Suite 150 Irving, TX 75063 Plaintiff, V. Bradleh M. Martz and Molly M. Martz 843 West Foxcroft Drive Camp Hill, PA 17011 Defendants. F11 ED-OFFICE. y THE PROTIHONOTAM tott JUN 24 PM t: 31 CUPENNSYLVaN A TY : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : JULY TERM, 2010 : DOCKET NO. 10-4699 CIVIL ACTION : MORTGAGE FORECLOSURE PRAECIPE TO SETTLE DISCONTINUE AND SATISFY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw Plaintiffs Complaint for Mortgage Foreclosure and mark same satisfied and dismissed. Please, also withdraw Plaintiffs Judgment by Default and mark same satisfied and dismissed without prejudice. PARKER MCCAY, PA Dated: June 21, 2011 Chandra M. Arkema, Esquire Attorney for Plaintiff