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HomeMy WebLinkAbout10-4787SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F(' ~l.:~- {.,.. , Sheriff ';~ T~ ~~~„3tn ~f +Cu~bP~~~~ ~ , Jody S Smith Chief Deputy j ~ ~'~'~,•~ ~~ ~ ~ ~ .~.~ -~ ~`,'( ~ • ~ V ~ ~~ ~~~~~ ~~ ~vtr a P/~ rss- Richard WStewart ~ `' `'` Gl~ii Solicitor crce ~. ~ rxg s~sRiFF _ , ~~ F I Northwest Consumer Discount Company Case Number vs. Glenn A. Myers, III (et al.) 2010-4787 SHER FF'S RETURN OF SERVICE 07/26/2010 03:50 PM -Robert Bitner, Deput Sheriff, who being duly sworn according to law, states that on July 26, 2010 at 1550 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: on A. Myers, by making known unto Glenn A. Myers III, Husband of defendant at 398 Petersburg Ro d, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him p rsonally the said true and correct copy of the same. 07/26/2010 03:50 PM -Robert Bitner, Deput Sheriff, who being duly sworn according to law, states that on July 26, 2010 at 1550 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: lenn A. Myers III, by making known unto himself personally, at 398 Petersburg Road, Carlisle, Cum erland County, Pennsylvania 17013 its contents and at the same time handing to him personally the sa d true and correct copy of the same. II ROBE BITNER, DEPU SHERIFF COST: $49.84 July 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosofl, Inc. Northwest Consumer Discount Company, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2010-4787 Glenn A. Myers, III and l ) Lori A. Myers, CIVIL ACTION C Defendants IN MORTGAGE FORECLOSURE 5 Z 7, cry -r. .c- ' PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO -? a ANSWER AND ASSESSMENT OF DAMAGES 5;;C) G N r? rn .. tJ1 -t To the Prothonotary of Cumberland County: Kindly enter an in rem judgment in favor of the Plaintiff and against GLENN A. MYERS, III and LORI A. MYERS, Defendants for failure to file an Answer to Plaintiffs 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 $27,162.79 Interest from 07/05/10-09/09/10 $581.47 TOTAL $27,744.26 I hereby certify that (1) the address of the Defendants is 398 Petersburg Road, Carlisle, PA 17013 and (2) that notice has been given in accordance with Rule 237.1, copy attached. YOFFE & YOFFE, P.C. DATED: 13 Z ol) By A /?q/' FRE . YOFF SQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: l OTHONOTARY 0 cr-f /,?,Y/ QZ'L aqjq a '? A %-t. Northwest Consumer Discount Company, Plaintiff vs. Glenn A. Myers, III and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-4787 Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE NOTICE TO: Glenn A. Myers, III, 398 Petersburg Road, Carlisle, PA 17013 DATE: August 18, 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 OR (717) 249-3166 NOTICIA IMPORTANTE A: Glenn A. Myers, III, 398 Petersburg Road, Carlisle, PA 17013 FECHA DEL AVISO: August 18, 2010 USTED ESTA EN REBELDIA HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICIAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 OR (717) 249-3166 YOFFE & YOFFE, P.C. By JEFFREY N. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. Northwest Consumer Discount Company, Plaintiff vs. Glenn A. Myers, III and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-4787 Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE NOTICE TO: Lori A. Myers, 398 Petersburg Road, Carlisle, PA 17013 DATE: August 18, 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 OR (717) 249-3166 NOTICIA IMPORTANTE A: Lori A. Myers, 398 Petersburg Road, Carlisle, PA 17013 FECHA DEL AVISO: August 18, 2010 USTED ESTA EN REBELDIA HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICIAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 OR (717) 249-3166 By YOFFE & YOFFE, P.C. JEFFREY N. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. Northwest Consumer Discount Company, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. N0.2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF NONMILITARY SERVICE To the best of the plaintiffs and the undersigned's knowledge information and belief, defendants are not in the military service as defined and covered by 50 U.S.C.A. Section 501 et seq. DATED: q il 3 /-1 0 / o YOFFE & YOFFE, P.C. BdFYY FFE, ESQUIRE O Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 n i t n <?' .? { '< , t .? "C7 w -3 -? C: tV 1 c-n Northwest Consumer Discount Company, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary of Cumberland County: Please issue writ of execution in the above matter: Amount Due Interest from 09/15/10 to 12/08/10 [Costs to be added] Total $27,744.26 $383.10 YOFFE & YOFFE, P.C. Date: (3 TU 10 ?? .OD 84 -k ?BF 411f x.00 14.oo a .50 » " $1U.M -PO AThI 2,.00 L"00 .50 LL 0-Ki 117Z, RE U4?t4?Aad By /?') - 14 effrey . Yoffe, Esq. Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verizon.net ri c ?? ,; Arm y0 N c.,rt WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-4787 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORTHWEST CONSUMER DISCOUNT COMPANY, Plaintiff (s) From GLENN A. MYERS, III and LORI A. MYERS (l) 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 $27,744.26 L.L.$.50 Interest from 9/15/10 to 12/8/10 -- $383.10 Atty's Comm % Atty Paid $182.34 Plaintiff Paid Date: 9/14/10 (Seat) Due Prothy $2.00 Other Costs is/ C"4w h/ -Aj""' o David Buell, Pro Brld y Deputy REQUESTING PARTY: Name: JEFFREY N. YOFFE, ESQUIRE Address: YOFFE & YOFFE, PC 214 SENATE AVENUE, SUITE 404 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-975-1838 Supreme Court ID No. 52933 Northwest Consumer Discount Company, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P. 3129.1 Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 650 Dog House Road, Boiling Springs, PA 17007 and 658 Dog House Road, Boiling Springs, PA 17007, per further description attached hereto as Exhibit "A": 1. Name and address of owner(s) or reputed owner (s): NAME: ADDRESS: Glenn A. Myers, III Lori A. Myers 398 Petersburg Road Carlisle, PA 17013 N rn .. cry 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Glenn A. Myers, III Lori A. Myers 398 Petersburg Road Carlisle, PA 17013 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Dell Financial Services, LLC ATTN: Correspondence P.O. Box 81577 Austin, TX 78708-1577 c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Attn: Daniel Santucci, Esq. 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 4. Name and address of the last recorded holder of every mortgage of record: NAME: ADDRESS: Northwest Consumer Discount Company 223 Penrose Place Carlisle, PA 17013 Cumberland County Consumer Discount 227 Penrose Place Company Carlisle, PA 17013 CitiFinancial, Inc. 950 Walnut Bottom Road, Suite 16 Carlisle, PA 17015 5. Name and address of every other person who has any record lien on the property: ADDRESS Cumberland County Tax Claim Bureau 1 Courthouse Square Old Courthouse Square Carlisle, PA 17013 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: ADDRESS 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: ADDRESS Tenant/Occupant 650 Dog House Road Boiling Springs, PA 17007 Tenant/Occupant Domestic Relations Of Cumberland County PA Department Of Revenue Inheritance Tax Division Commonwealth Of Pennsylvania Department Of Welfare Commonwealth Of Pennsylvania Department Of Public Welfare Estate Recovery Program 658 Dog House Road Boiling Springs, PA 17007 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Department 280601 Harrisburg, PA 17128-0601 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 8486 Harrisburg, PA 17105-8486 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 falsification to authorities. YOFFE & YOFFE, P.C. Date: W101o By effrey . Yoffe, Esq. Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyo#?Averizon. net 650 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or formerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction 175 feet, more or less, to a point, the place of BEGINNING. For title see deed recorded in Cumberland County Record Book 177, Page 838 in the Cumberland County, Pennsylvania Recorder Of Deeds office. 658 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: On the north by land now or formerly of John T. Stull; on the east by land now or formerly of Thomas McCauslin; on the south by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 feet in width and extending approximately 465 feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Book K, Volume 33, Page 651 in the Cumberland County, Pennsylvania Recorder Of Deeds Office. EXHIBIT "A" Northwest Consumer Discount Company, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE ACT 6 AND ACT 91 CERTIFICATION The requirement of Act 6 of 1974, 41 P.S. §403 and the Homeowner Mortgage Assistance Act of 1983 (Act 91) have been complied with in this case by virtue of letters dated and mailed to defendant on June 3, 2010, containing information required by said statutes. An exact copy of said notices are attached hereto. YOFFE & YOFFE, P.C. Dar q113?2,ro By effrey . Yoffe, sq. Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe agverizon. net C r n es' ... C> t . F .?, ,4 1„ C '5 rn c.n June 3, 2010 TO: Glenn A. Myers, III FROM: Northwest Consumer Discount Company 398 Petersburg Road 223 Penrose Place Carlisle, PA 17015 Carlisle, PA 17013 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Northwest Consumer Discount Company (hereafter we, us or ours) on your properties located at 650 Doghouse Road, Boiling Springs, Cumberland County, PA and 658 Doghouse Road, Boiling Springs, Cumberland County, PA per Cumberland County Mortgage Book 1667, Page 389 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $441.69 for the months of March, April and May 2010. Late charges have also accrued to this date in the amount of $123.90. The total amount now required to cure this default, as of June 3, 2010 is $1,448.97. You may cure this default within THIRTY (30) DAYS of the date of the receipt of this letter, by paying to us the above amount of $1,448.97 plus any additional net interest, late charges and other charges which may fall due during this period. If you cure this default within THIRTY (30) DAYS of receipt of this letter, such payment must be made either by cash, cashier's check, certified check or money order, and made at Northwest Consumer Discount Company, 223 Penrose Place, Carlisle, PA 17013. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest day that such a Sheriffs sale could be held would be approximately December 8, 2010. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (717) 249-0722. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE; [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If within the aforesaid 30 day period you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. June 3, 2010 TO: Lori A. Myers FROM: Northwest Consumer Discount Company 398 Petersburg Road 223 Penrose Place Carlisle, PA 17015 Carlisle, PA 17013 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Northwest Consumer Discount Company (hereafter we, us or ours) on your properties located at 650 Doghouse Road, Boiling Springs, Cumberland County, PA and 658 Doghouse Road, Boiling Springs, Cumberland County, PA per Cumberland County Mortgage Book 1667, Page 389 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $441.69 for the months of March, April and May 2010. Late charges have also accrued to this date in the amount of $123.90. The total amount now required to cure this default, as of June 3, 2010 is $1,448.97. You may cure this default within THIRTY (30) DAYS of the date of the receipt of this letter, by paying to us the above amount of $1,448.97 plus any additional net interest, late charges and other charges which may fall due during this period. If you cure this default within THIRTY (30) DAYS of receipt of this letter, such payment must be made either by cash, cashier's check, certified check or money order, and made at Northwest Consumer Discount Company, 223 Penrose Place, Carlisle, PA 17013. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest day that such a Sheriffs sale could be held would be approximately December 8, 2010. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (717) 249-0722. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE; [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If within the aforesaid 30 day period you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. Date: June 3, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of 7 HOMEOWNER'S NAME(S): Glenn A. Myers, III and Lori A. Myers PROPERTY ADDRESS: 650 Doghouse Road, Boiling Springs, PA 17007 and 658 Doghouse Road, Boiling Springs, PA 17007. LOAN ACCT. NO.: 492-190736-3 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Northwest Consumer Discount Company Northwest Consumer Discount Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. Page 2 of 7 APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date), NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 650 Doghouse Road, Boiling Springs, PA 17007 and 658 Doghouse Road, Boiling Springs, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Page 3 of 7 March 2010, April 2010 and May 2010 monthly payment of $441.69 have not been paid, for a total of $1,325.07. Other charges (explain/itemize): Late charges in the amount of $123.90. TOTAL AMOUNT PAST DUE: $1,448.97 as of June 3, 2010. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,448.97 as of June 3, 2010, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Northwest Consumer Discount Company 223 Penrose Place Carlisle, PA 17013 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT-- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to Page 4 of 7 the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yQu still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be December 8, 2010. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: E-Mail Address: Northwest Consumer Discount Company 223 Penrose Place, Carlisle, PA 17013 (717) 249-0722 (717) 249-9622 Kara Osborn KOsborn@nwbcorp.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You (X) may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 5 of 7 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (888) 511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 PHFA 211 North Front Street Harrisburg, PA 17110 (717) 780-3940 (800) 342-2397 Marantha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PA Interfaith Community Programs Inc. 40 E. High Street Gettysburg, PA 17325 (717) 334-1518 Page 6 of 7 We'll assume the validity of this debt unless you act to dispute it, or any part thereof, within 30 days after receipt of this letter. If within the aforesaid 30 day period you notify us in writing of such a dispute (entire or partial), we'll obtain and mail to you verification of the debt or a copy of any judgment against you. If requested by you within the aforesaid 30 day period, we'll provide you with the original creditor's name and address, if different from the current creditor. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. Page 7 of 7 Northwest Consumer Discount Company, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE C = `-n NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ro n " PURSUANT TO PA. RULE OF CIVIL PROCEDURE 3129 TO: ALL PARTIES IN INTEREST AND CLAIMANTS C IV ? ; TAKE NOTICE: cs+ That the Sheriffs Sale of Real Property (real estate) will be held on December 8, 2010, at the Cumberland Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 at 10:00 a.m., prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description attached as Exhibit "A" which mainly consists of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. THE LOCATION of your property to be sold is: 650 Dog House Road, Boiling Springs, PA 17007 and 658 Dog House Road, Boiling Springs, PA 17007. THE JUDGMENT under or pursuant to which your property is being sold is docketed to: 2010-4787 in the Cumberland County, Pennsylvania Court of Common Pleas in which the Plaintiff is Northwest Consumer Discount Company located at 223 Penrose Place, Carlisle, PA 17013 (717) 249-0722. The names of the owners or reputed owners of this property are: Glenn A. Myers, III and Lori A. Myers. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff within thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, located in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a judgment against you. It may cause your property to be held or sold 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. 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 Bar Association 32 S. Bedford St. Carlisle, PA 17013 (800) 990-9108 or (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or procedure used against you. 2. After the Sheriffs sale you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs deed is delivered. 3. A petition or petitioners raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor before presentation to the Court and a proposed Order or Rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office located in the Cumberland County Courthouse at 1 Courthouse Square, Carlisle, Pennsylvania 17013, (717) 240-6200 before presentation of the petition to the Court. YOFFE & YOFFE, P.C. Date: I? (Z01 B*eIyN. offe, Esq. ey for Plantiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. 650 Dog House Road Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or formerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction 175 feet, more or less, to a point, the place of BEGINNING. For title see deed recorded in Cumberland County Record Book 177, Page 838 in the Cumberland County, Pennsylvania Recorder Of Deeds office. 658 Dog House Road Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: On the north by land now or formerly of John T. Stull; on the east by land now or formerly of Thomas McCauslin; on the south by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 feet in width and extending approximately 465 feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Book K, Volume 33, Page 651 in the Cumberland County, Pennsylvania Recorder Of Deeds Office. EXHIBIT "A" Northwest Consumer Discount Company, Plaintiff vs. Glenn A. Myers, III and Lori A. Myers, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2010-4787 CIVIL ACTION IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE The undersigned certifies that on October 5, 2010 he served a copy of the Notice of Sale attached hereto as Exhibit "1" on the entities listed below at the addresses indicated. Service was accomplished by depositing the same in the United States Mail, First Class, postage prepaid. Certificates of mailing evidencing the mailings are attached as Exhibit " 2": Glenn A. Myers, III 398 Petersburg Road Carlisle, PA 17013 Dell Financial Services, LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Attn: Daniel Santucci, Esq. 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Cumberland County Consumer Discount Company 227 Penrose Place Carlisle, PA 17013 Domestic Relations Of Cumberland County 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Tenant/Occupant 650 Dog House Road Boiling Springs, PA 17007 Cumberland County Tax Claim Bureau 1 Courthouse Square Old Courthouse Square Carlisle, PA 17013 Lori A. Myers 398 Petersburg Road Carlisle, PA 17013 ,.~ ~.=- ~: ~ ~ `' Dell Financial Services, LLC ~'-M' ~~ --~ ~,~ ATTN: Correspondence ° ~~' ~ ' ~"''°_-~' P.O. Box 81577 ~ '~` ~' Austin, TX 78708-1577 ~ ~ ~: .~~ = :-y ,,, ~ Northwest Consumer Discoun ~,,,~ t Company °~ 223 Penrose Place Carlisle, PA 17013 CitiFinancial, Inc. 950 Walnut Bottom Road, Suite 16 Carlisle, PA 17015 Tenant/Occupant 658 Dog House Road Boiling Springs, PA 17007 PA Department of Revenue Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 Commonwealth Of Pennsylvania Department Of Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth Of Pennsylvania Department Of Public Welfare Estate Recovery Program P.O. Box 8486 Harrisburg, PA 17105-8486 YOFFE & YOFFE, P.C. Date: ~ (~~301 ~U(d By f effrey . Yoffe, sq. Attorney for Plaintiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verizon. net Northwest Consumer Discount Company, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND CO[:INTY, P~SYLVANIA vs. No. 2a 14-4787 Glenn A. Myers, III and Lori A. Myers, : CIVIL ACTION Defendants : IN MORTGAGE FORECLOSURE NO'1'IGE OF SHERIFF'S SALE OF REAL PROPERTY PURSUAI'~IT TO PA. RULE OF CIVIL. PROCEDURE 3129 TO: ALL PARTIES IN INTEREST AND CLAIMANTS TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held on December $, 2010, at the Cumberland Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013 at 10:00 a.m,, prevailing local time. TFIE PROPERTY TO BE SOLD is delineated in detail in a legal description attached as Exhibit "A" which mainly consists of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land.. THE LOCATION of your property tc> be said is: 650 Dog House Road, Boiling Springs, PA 17007 and 658 Dog House Road, Bailing Springs, PA 17007. THE JUDGMENT under ar pursuant to which your property is being sold is docketed to: 2010-4787 in the Cumberland County, Pennsylvania Court of Camman Pleas in which the Plaintiff is Northwest Cansurner Discount Company located at 223 I'enrvse Place, Carlisle, PA 17413 (717) 249-4722. The names of the owners ar reputed owners of this property are: Glenn A. Myers, III and Lori A. Myers. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities ar agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheri1~' (for example, to la~~nks that hold mortgages and municipalities that are awed taxes}, will be bled by the Sheriff within thirty (30) days after the sale and distribution of the peeds of sale in accordance with this schedule wi11, in :fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed, Information about the schedule of distribution may be obtained from the Sheriff of the Court. of Common Pleas of Cumberland County, Pennsylvania, located in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 1701.3, {717) .240-6390, THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been. issued because there is a judgment against you, It may cause your EXHIBIT "1" property to be held or sold 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. YOU SHOULD TAKE THIS PAPER. TO YOUR. LAWYER AT ONCE. IF YOU DD NOT HAVE A LAWYER, GO TO qR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIDING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAUTYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WIfiH INFOR11iIATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 1701.3 (800) 990-9108 or (717) 249-3166 THE LEGAL RIGHTS YOU .MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the judgment if you have a meritorious defense against the person ar company that. has entered judgment against you. Yau may also file a petition with the same Court if you are aware of a legal defect in the obligation ar procedure used against. you. 2. After the 5herifFs sale you may file a petition with the Court of Camman Pleas of Cumberland County to set aside the sale for a grossly inadequate price ar for other proper cause. This petition must be fled before the Sheriffs deed is delivered. 3. A petition or petitioners raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. "The petition must be served on the attorney far the credztor before presentation. to the Court and a proposed Order or Rule must be at:tachecl to the petition. If a specific return date is desired, such. date must be obtained from the Court Administrator's Offxce located in the Cumberland County Courthouse at 1 Courthouse Square, Carlisle, Pennsylvania 17013, (717) 244-6200 before presentation of the petition to the Court. YFFCE & YOFFE, P.C. Date: L-~' ~ ~ ~~ I~ ~~ By r'%~%~ eEs. y N. off , q ttarney for Plantiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011. (71'7) 9'75-1838 Attorney ILl No. 52933 This communication is from a debt collector and is an attempt to collect a debt, Any information obtained from you will be used for debt collection nurooses. EXHIBIT "1" 650 Dog House Road, Boiling Springs, PA 1700?: ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGIP11~lING at a point on the easterly line of land now ar formerly of Lloyd H. Stipe and Evelyn G, Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now ar formerly of said Lloyd 1-l. Stipe and Evelyn G. Stipes his wife, in a nartheastwazdly direction 2f10 feet,. snare or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwazdly direction 281 feet, mare or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction I?5 feet, mare ar less to a paint, the place of BEGINNING. Far title see deed recorded in Cumberland County Record Book 1??, Page $38 in the Cumberland County, Pennsylvania Recorder Of Deeds office. 658 Dog House Road. Bailing Springs, PA 1?Of}7: ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: On the north by land now ar formerly of John `1'. Stull; on the east by land now or formerly of Thomas McCauslin; an the south: by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 .feet in width. and extending agproximatel}= 46S feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Boar K Volume 33, Page 65I in the Cumberland County, Pennsylvania Retarder Of Deeds Office. EXHIBIT "1" MAY fiE t~~ FOR DO~AES'itC AMID tNTERNATiONAI MAN.. DOEB MK3T PROVIDE FOR tN$URANCE-POSTlMA$TER .q y.. , R.~wa From: Yofff3 & Yaffe, P.C_ 214 Senate Avanu~ Suns ~' C~np Hiq, PA i 7Q11 ~717~ $75.1a3~ ~: Oar ~s pf o~drory eroN aadrsad fo: ~1 ~Ir'uu--~-ittl ,Se~'viCPS, La.C. ,, u. i~~ o- 't~aX 8 ~'~"-~ /~f stir , "C'X "? g'i 08 ' 151'1 PS Fam 381 T, Msr. 1988 MAY QE U~Ef FOR Dt~ilE$71C AND INTEf1NATIONAI. MAN.. DOBdi NOT PlIOM111DE FOR IM18iM1ANCE-POBTMA$TEIi R.o~wa From: YOft6 & Yaffe, P.C. ' 214 Senate Avenue. Suite 4t3~`;-` Imp Hill, PA 170i 1 Oro. P~~ of or~ry~ mill addroq~d to: Lora ~ . ~~ecs t~~ $ ~p~fS~U ~ ~.Catar~-- ~4; ~;¢y'"IiS~ ~A 1013 '`T PS fam 3817, PAru. 1989 MAY`S t1$E!M POR DOIMESTIC AND tNT191N/IT10NAl MAN.. DOEf3 NOT PROVIDE POR IN1.411RANCE-POSTMASTER rl.e.lw~a F'°'"' Yaffe a Yaffe, P.C. 214 Senate Avenue. 4Q4. ,~ ; arrlp t , ref W75~~.... ~. -~-, ;:~ Oro pMar of aMiMrr mirN sddnsf~e m: ' ` oc rr2r~ ~5t.o~.r~ ~a3 ~acr~se. ~ tc~e ~~ Ct~~~e. PA f'7o~3 P5 foMm 3817. Ma. 1988 ~~~ •x ~~. ` f±.~, ~~~~ -M+rR~-R"A tf # 4 f ~ 0 ~~ "i [i4, ~,. . +'::~ , e, 4.~, `'r. ,fir . ~ Aft tetllsr! h sups EXHIBIT "2" ', °~~. ,f MAY SE USED FOR DOMESTIC AAA INTERNA'ItONAL MAR, GOES ~+ PROVIDE FOR INSURANCE-PO$TMASTEf! ry R4- .. a.~w From' Yaffe 8 Yoffe, P.C. 214 Sena#e Avenue, ~ ~` amp I f,~PA~'T6i~~ 5r d,. pl.o. ar onlinsry msil aean.wd te: 1 >~~`~- ~O~c u. par} ;~ -r t3o-1i nq ~Qlpr~S, ~p r7ot~~1 ~' Ps Fa-„ 3st ~, ~. vase MAY 8& USEO FOR DOMESTIC /CND tNTERNA7fOAtAI MAC. DOE8 N0T PROVIpE FOR INSURANCE-POSTMASTER Rsosivad From; Yoffe &Yoffe, P.C. Camp H9!!, PA 17011 on. alse+s of ordxWry maM addhasd to: ~~ ~tA P~-~erS ~ue~ ~C)Qt~-~ r -cr fir' h S ~ , ~~ 17©!3 P8 Form 3817, Mar. t 989 MAY ttE USED FOR OOMEffi1'IC AND iNTERAiAT'IONAI MAIL. GOES NOT PROVR>E FOt3'IAISt1RANCE-POSTMASTER R~wivad Fromc Yaffe ~ Yoffe. P.C. 214 Senate Avenue, Sui~a •4~4~ 1 _~~l (717) 975-1$3£~ ~~ ~. Ons P~ of adtnsrY maN addnssad to: ~.~Y1k'1'1t~Y11w}~4i.~'~'+ L1't ~fV"1~~~~~1~- p•Q ~a~ ~!a"!S ~. Nu~rr~s~~5, Pa r~ro PS form 38t7. Mar. 1989 kMac fN AMbc fat hua in stamps EXHIBIT "2" '~` ; . ~. ,. - ;•, a ~'' r , AtRu ha Ewdti is stamps or anetK psstape and MAY BE llSEb'FOR DOM~TIt: AND iNTEANAT10NAl MAIL, GOES NOT PR{3VID8 FOR H~R4lRANCE-P~TMASTER Raorhad From: Yoffie & Yoffie, P.C. 214 Senate Avanue~ Suite 4ti4; <, y {717j 975-1333 ,~~, , :~. -'~ Om at ordkury mail addrasMd to: -- '~p1r~txr~cdCa..t .SF'•{'VKeS, l.t..C. cio')~I~'1',l~3,tt'anmiller ~~~:i51LPf'~-i~~bt~~E~.~- ~. :~ i ~'~' 5 C-,rPU~ Uc~lieci ,~a~'rw~, .,J'rri~ tao ~(,ljgiv~?rn, ~ 193x3 •.- FOrtn 3877, Mar, 1.9$9 MAY t;E U$1~i Fpt OOMQB'TIC AND IN7~lNA7'!t>r1Ai. !WALL, DOEB NOT P1tOVtDA FOR MIWRNMCE--PO8'CMMASTER R~~«a Fes: YofEe & Yaffe. P.C. 214 $ertate Avg mp 17011 ~ r,,, (717) 9fi5-~~~n Om pisca of ordinnY msN aMdnsad to: ~`-'~3 1/~t~1'1t,t.`4~ r.~T"~vt''1") ~flLtt~ +`~'- :, ~~,r t i Si.P, PA ~?~ i 5 ` ~. PS Form X17, Mar. 39$9 MAY RE ti$1Df FOR DOMi8TIC AND Ni'FERNATIONAL MALL. DOts9 NOT PROHIQE KOl1 tt!~IIRANCE-POSIMA'$THI RsaNad From: YOff+B $4 Yoffie, P.C. , -~ r~ , 2.14 Senate Ave~tue, Suite ~, (717) 975-1$33 ~ Gns pTama of aedA+ary mMi aadnsaw m: iarn~stc. Qe1~+ans ~ ~urnheric~ C.a. 13 ~(3C-1'h ~crt~vef S-i~re~- ~~ ~P,o. 3a x 3au s. Ccu~~s4., i~~ -7a~3 P8 Fa+r4t 3$17. Mar. 7888 EXHIBIT "2" Affix far hms in stamps A#fix Fas Mn in stamps __ Rfifx faa Mrs &- aternpa MAYBE U6ED Faai aOMESTiC AND INTEFtIdA'11QNA1. MJ1tt., DOES NOT °f ~~~ ~d P'RavIOE FCR fN$11MNCH-P~TAAASTER j R•a.ti.e From: Yoffie 8 Yoffie, P.C. .,,.-~,~ r 2i4 Senate Avenue Su#e p ~, 17011 ~ `~ (i17)~~IZ~-l R.~~ QY~~ a» oi•cr or odr,.ry mw .adns..a to: Gorr~mon weac~}+~ of Porn -~! it,~.. - 4'.a tea ~SU~(o =*- 'Ncursk~rg. PA -~to5-~4Y1~ F'S Fond 3817, Man. 1989 MAY eE usEa FaR DDaa~esitc at~o +thunonrr+~. Man.. aoES MD7 °"W °O"'°' '"0 fnoxroe FpR IN~7RANCE-rosnw-ss~ ~~ R~cMitrad From: Yoffie & Yoffie, P.C. Camp N7N, PA 17011 ,..~~~~~ ' '~~' +' 1~}~97f' .~ O++r pi~or of man addrasa~d to: -., Gumkaarlc~.r~d ~.E~fLSumpr' ~~W ' . . ~a~ n+ras~ P1txce ,~ AffbriM.hit~ in amps a msaer postsp~ tared FS Form :3$1.7, Maw. 1988 Mar ee [ FpR uotrc AND ~M'f~INanaMAi Man., aa~s Malt enovio~ Fos n+1~RANC~-nosrMASs+ R~eriwd Fepm: Yoffie & Yoffie, P.C. Camp HN, PA 17(31 i on. M.o. of onariay mdl sedr....a io: ~- tt-t ~' ~'e~we 1~'her ~~r,ce ~tuyc. `sy`tisioery r`~s?~ur~, P1~ ~~t28'- aG~o~ PS Form 3817, Mawr. 1889 EXHIBIT "2" ~::~ ~~~, ,, -, -5{ ~. s ~~ r'~.~. !« ,, MAY a usw IFflIt DOE1d'871C AND +NTERNATIONAL MAq., Does aor PROVIDE FOR iNl~{JRIINCE-Pt?8TMA5'f'ER R~iwp From: Y Offe $~ YOie, P.C. 214 Senate Avenue amp , PA 17011 l717,j ~7S..1g333 Onf YMc~ of o~+KY mail ~ddrawe to: -o -=--= ~ 1d C. t-~at~e`. C+~e~- a Cap" ti.Sl~ , Q A i'7p13 PS fcxm 3817. Mv. 1888 W ham. MAY eE LtSfO FOii DQwid'R7lC A11D INTL4SNATIONAL MAIL. DOES NOT PRQYIpE FO# 1N8~RANCE-F06TaAA$TBR R~oNv~d From: Yof!`e & Yoffie. P.C. A 214 Senate Avenue. Stdb~ 4Q4; ,; ~~ (fi17) 975-1a3€t °~ bM P~ of wdinrry m~ ~ddn~sal m: 1~oilittit~ S~n~.s, ~;~ s?oa-r - ~ P'S form 3817, Mir. 1988 EXHIBIT "2" M '. r _~,; ~~ . f .~' r A1lIx fey 1+~es h s SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ray . 'r Sheriff ?4k`??,• of r?aP?b r T! Z- i j'° . J r? ??G Jody S Smith 201 1 FFD _9 r. Chief Deputy Richard W Stewart I l I+o r : , YL Solicitor PE S Northwest Consumer Discount Company I Case Number vs. 2010-4787 Glenn A. Myers, III (et al.) SHERIFF'S RETURN OF SERVICE 10/14/2010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1920 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn A. & Lori A. Myers, III, located at, 650 Doghouse Road, Boiling Springs, Cumberland County, Pennsylvania according to law. 10/14/2010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to 'law, states that on 10-14-10 at 1920 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn A. & Lori A. Myers, III, located at, 658 Doghouse Road, Boiling Springs, Cumberland County, Pennsylvania according to law. 10/14/2010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1757 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lori A. Myers, by making known unto, Lori A. Myers, personally, at, 398 Petersburg Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10/19/2010 Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1757 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Glenn A. Myers, III, by making known unto, Lori A. Myers; wife of defendant, at, 398 Petersburg Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct: copy of the same. 12/08/2010 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, PA on December 8, 2010 at 10:00 a.m. He sold the same for the sum of $22,001.00 to David A. Krulac, P.O. Box 1064, Mechanicsburg, PA 17055, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $2,060.62 SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF ?d pt° da. Q .DD Pd ` Ca , 0 L- L- Pe4?syg?'g :;C.j CCii,lt,ySUito, She!^ff. iE,',.'i;50!t. In:;. J • I 7 ' SCHEDULE OF DISTRIBUTION Date Filed: 1/5/11 Writ No. 2010-4787 Civil Term Northwest Consumer Discount Company Vs Glenn A. Myers, III Lori A. Myers 650 and 658 Dog House Road Boiling Springs, PA 17007 Sale Date: Buyer: Bid Price: Real Debt: Interest: Attorney V December 8, 2010 David A. Krulac $ 22,001.00 $ 27,744.26 383.10 Jrit Costs: 182.34 Total: $ 28,309.70 DISTRIBUTION: Receipts: Cash on Account (08/17/2010): $ 2,000.00 Cash on Account (12/08/2010): 2,200.00 Cash on Account (12/15/2010): 22,270.78 Total Receipts: $ 26,470.78 r Disbursements: Sheriffs Costs $ Legal Search Transfer Tax State Transfer Tax Local Cumberland County Tax Claim Bureau Mary Murray, (Monroe Township Tax Collector) 2010 Mary Murray, (Monroe Township Tax Collector) 2011 Reflects 2010 Spring Taxes x 3 for 2011 Spring Taxes) Attorney Jeffrey Yoffe Northwest Consumer Discount Company Total Disbursements: Balance for distribution: So Answers: 'dt RV' R. Anderson Sheriff 1,460.62 600.00 714.88 714.88 911.62 844.62 533.70 (Amount 2,000.00 18,690.46 ($ 26,470.78) 00.00 Northwest Consumer Discount Company, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-4787 Glenn A. Myers, III and Lori A. Myers, CIVIL ACTION Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT UNDER PA. R.C.P. 3129.1 Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esquire, Attorney for Plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate located at 650 Dog House Road, Boiling Springs, PA 17007 and 658 Dog House Road, Boiling Springs, PA 17007, per further description attached hereto as Exhibit "A": 1. Name and address of owner(s) or reputed owner (s): NAME: ADDRESS: Glenn A. Myers, III Lori A. Myers 398 Petersburg Road Carlisle, PA 17013 2. Name and address of defendant (s) in the judgment: NAME: ADDRESS: Glenn A. Myers, III Lori A. Myers 398 Petersburg Road Carlisle, PA 17013 3. Name and address of every judgement creditor whose judgment is a record lien on the real estate to be sold: NAME: ADDRESS: Dell Financial Services, LLC ATTN: Correspondence P.O. Box 81577 Austin, TX 78708-1577 c/o Blatt, Hasemniller, Leibsker & Moore, LLC Attn: Daniel Santucci, Esq. 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 4. Name and address of the last recorded holder of every mortgage of record: NAME: ADDRESS: Northwest Consumer Discount Company 223 Penrose Place Carlisle, PA 17013 Cumberland County Consumer Discount 227 Penrose Place Company Carlisle, PA 17013 Citil'inancial, Inc. 950 Walnut Bottom Road, Suite 16 Carlisle, PA 17015 5. Name and address of every other person who has any record lien on the property: ADDRESS Cumberland County Tax Claim Bureau I Courthouse Square Old Courthouse Square Carlisle, PA 17013 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: ADDRESS 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: ADDRESS Tenant/Occupant 650 Dog House Road Boiling Springs, PA 17007 Tenant/Occupant Domestic Relations Of Cumberland County PA Department Of Revenue Inheritance Tax Division Commonwealth Of Pennsylvania Department Of Welfare Commonwealth Of Pennsylvania Department Of Public Welfare Estate Recovery Program 658 Dog House Road Boiling Springs, PA 17007 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Department 280601 Harrisburg, PA 17128-0601 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 8486 Harrisburg, PA 17105-8486 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 falsification to authorities. YOFFE & YOFFE, P.C. Date: By fl I '/ Jeffrey . Yoffe, Esq. Attorney for Plaintiff 214 Senate .Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyo ffer&verrizon. net 1 650 Dog House Road. Boiling Springs PA 17007• ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or formerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction 175 feet, more or less, to a point, the place of BEGINNING. For title see deed recorded in Cumberland County Record Book 177, Page 838 in the Cumberland County, Pennsylvania Recorder Of Deeds office. 658 Dog House Road Boiling Springs, PA 17007• ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: On the north by land now or formerly of John T. Stull; on the east by land now or formerly of Thomas McCauslin; on the south by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 feet in width and extending approximately 465 feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Book K, Volume 33, Page 651 in the Cumberland County, Pennsylvania Recorder Of Deeds Office. EXHIBIT "A" Northwest Consumer Discount Company, Plaintiff VS. Glenn A. Myers, III and Lori A. Myers, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2010-4787 : CIVIL ACTION IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PA. RULE OF CIVIL PROCEDURE 3129 TO: ALL PARTIES IN INTEREST AND CLAIMANTS TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held on December 8, 2010, at the Cumberland Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 at 10:00 a.m., prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description attached as Exhibit "A" which mainly consists of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. THE LOCATION of your property to be sold is: 650 Dog House Road, Boiling Springs, PA 17007 and 658 Dog House Road, Boiling Springs, PA 17007. THE JUDGMENT under or pursuant to which your property is being sold is docketed to: 2010-4787 in the Cumberland County, Pennsylvania Court of Common Pleas in which the Plaintiff is Northwest Consumer Discount Company located at 223 Penrose Place, Carlisle, PA 17013 (717) 249-0722. The names of the owners or reputed owners of this property are: Glenn A. Myers, III and Lori A. Myers. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff within thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, located in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a judgment against you. It may cause your property to be held or sold 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. 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 Bar Association 32 S. Bedford St. Carlisle, PA 17013 (800) 990-9108 or (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or procedure used against you. 2. After the Sheriffs sale you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs deed is delivered. 3. A petition or petitioners raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor before presentation to the Court and a proposed Order or Rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office located in the Cumberland County Courthouse at 1 Courthouse Square, Carlisle, Pennsylvania 17013, (717) 240-6200 before presentation of the petition to the Court. YOFFE & YOFFE, P.C. By frey N. offe, E q. Attorney for Plantiff 214 Senate Avenue, Suite 404 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained from you will be used for debt collection purposes. 650 Dog House Road Boiling Springs PA 17007• ? 111? ="1)3- b043 - bah ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or formerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction 175 feet, more or less, to a point, the place of BEGINNING. For title see deed recorded in Cumberland County Record Book 177, Page 838 in the Cumberland County, Pennsylvania Recorder Of Deeds office. 658 Doiz House Road Boiling Springs PA 170071 ALL THAT CERTAIN tract of land situate Pennsylvania, bounded and described as follows: ?- as - 33 - (Dbg3 -o in Monroe Township, Cumberland County, On the north by land now or formerly of John T. Stull; on the east by land now or formerly of Thomas McCauslin; on the south by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 feet in width and extending approximately 465 feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Book K, Volume 33, Page 651 in the Cumberland County, Pennsylvania Recorder Of Deeds Office. EXHIBIT "A" I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-4787 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORTHWEST CONSUMER DISCOUNT COMPANY, Plaintiff (s) From GLENN A. MYERS, III and LORI A. MYERS (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 $27,744.26 L.L.$.50 Interest from 9/15/10 to 12/8/10 -- $383.10 Atty's Comm % Due Prothy $2.00 Atty Paid $182.34 Other Costs Plaintiff Paid Date: 9/14/10 (Seal) REQUESTING PARTY: Name: JEFFREY N. YOFFE, ESQUIRE Address: YOFFE & YOFFE, PC 214 SENATE AVENUE, SUITE 404 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-975-1838 Supreme Court ID No. 52933 David uell, Prothon By Deputy On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 650 and 658 Dog House Road, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: i (Rell Estate Coordinator The Patriot-News Co: 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE atrI*ot•News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWTS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being (July sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify, this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/1:5110 Sworn to aRd's scribed ore me this 1? Notary Public 10/22/10 10/29/10 Jd-y of ember, 2010 A. D. t COMMONWEALTH OF PENNSYLVANIA, !I Notafti Seal —i, Sherrie L KLSner, Notary Public ! Lower Paxton Twp„ Dauphin County I MY Commisslon Expires Nov 26, 2011 Memtw, Pennsylvania Association of Notaries M0 4m7 CkU Term Vs G16nn JL ; Ilt Lori A. Aftr. J*" N- Y0110 650 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or fonnerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to be of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point at line of land now or formerly of said John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter WA in a westwardly direction 175 feet, more or less, to a point, the ply of BEGINNING. For title see deed recorded in Cumberland County Record Boob 177, pap 838 in the Cumberland county, Pennsylvania Recorder Of Deeds office. 658 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of laud situate in Monroe Tmoship, CuMtierlanci County, Pennsylvania, bounded and described as follows: On the north by land now or formerly of John T. Stull; on the east by land now or formerly of Thomas Mcfauslm; on the south by lands now or formerly of South Mountain Land Company; and on the west by lauds now or formerly of Andrew Pendery, and being used as a road `Said premises being 50 feet m width and extending approximately 465 feet in depth in a north-south direction. For title see -deed recorded in Cumberland County Record Book K. Volume 33, Page 651 in the Cumberland Ctwmty, Pennsylvania Recorder Of Deeds Otte. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Ufisa Marie Coyne, Fjditor SWORN TO AND SUBSCRIBED before me this 5 dU of November. 2010 Notary NOTARIAL SEAL (DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-4787 held December 8, 2010 EFFECTIVE DATE: December 8, 2010 PREMISES: 650 Dog House Road, Boiling Springs, Monroe Township, Cumberland County, Pennsylvania, Tax Parcel No. 22-33-0043-030 (the "Premises") 658 Dog House Road, Boiling Springs, Monroe Township, Cumberland County, Pennsylvania, Tax Parcel No. 22-33-0043-027 (the "Premises") RECITAL: With respect to the premises at 650 Dog House Road, Boiling Springs: being the same Premises which Glenn E. Wolf and Joan B. Wolf, by their deed dated May 21, 1998 and recorded May 22, 1998 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 177, Page 838, granted and conveyed unto Glenn A. Myers, III and Lori A. McDilda Myers. With respect to the property at 658 Dog House Road, Boiling Springs: being the same Premises which Christie A. Parr, Martha L. Szczynta and Andrew A. Szczynta, husband and wife, by their deed dated June 24, 1988 and recorded June 27, 1988 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book "K", Volume 33, Page 651, granted and conveyed unto Lori McDilda and Glenn A. Myers, IJI, as tenants in common. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: With respect to 650 Dog House, Road, Boiling Springs: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable; municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. -2- 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2010. 20. Subject to the legal operation and effect of the absence of the marital status of the Grantors noted in the deed recorded in Deed Book 177, Page 838 and the possible absence of any joinder of any spouses of the Grantors in the conveyance to Glenn A. Myers, III and Lori A. McDilda Meyers by the foregoing deed. 21. Mortgage in the amount of $37,809.00 (covering both 650 and 658 Dog House Road, Boiling Springs) from Glenn A. Myers, III and Lori A. McDilda Myers to Northwest Consumer Discount Co. dated January 24, 2001 and recorded January 31, 2001 in Mortgage Book 1667, Page 389. 22. Judgment against Glenn A. Myers, III and Lori A. Myers in the amount of $27,744.26 in favor of Northwest Consumer Discount Co. entered September 14, 2010 to No. 2010- 4787. 23. Judgment against Lori A. Myers in the amount of $2,298.09 in favor of Dell Financial Services, LLC entered May 4, 2009 to No. 2009-1598. 24. Unpaid taxes due the Tax Claim Bureau in the amount of $419.20 together with any or additional accrued interest and penalties assessed thereon. 25. Subject to the right-of-way in Deed Book "Q", Volume 22, Page 560. 26. Subject to the rights granted Met Ed in Misc. Book 118, Page 244. 27. Subject to the rights of others in and to any portion of the Premises lying within or adjoining Dog House Road. EXCEPTIONS: With respect to 658 Dog House Road, Boiling Springs: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. -3- 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. -4- 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2010. 20. Mortgage in the amount of $37,809.00 (covering both 650 and 658 Dog House Road, Boiling Springs) from Glenn A. Myers, III and Lori A. McDilda Myers to Northwest Consumer Discount Co. dated January 24, 2001 and recorded January 31, 2001 in Mortgage Book 1667, Page 389. 21. Mortgage in the amount of $15,437.00 from Lori A. McDilda and Glenn A. Myers, III to Citifinancial, Inc. dated July 16, 2003 and recorded July 21, 2003 in Mortgage Book 1823, Page 4697. 22. Judgment in the amount of $27,744.26 against Glenn A. Myers, III and Lori A. Myers in favor of Northwest Consumer Discount Co. entered September 14, 2010 to No. 2010- 4787. 23. Judgment against Lori A. Myers in the amount of $2,298.09 in favor of Dell Financial Services, LLC entered May 4, 2009 to No. 2009-1598. 24. Unpaid taxes due the Tax Claim Bureau in the amount of $486.94 together with any or additional accrued interest and penalties assessed thereon. 25. Subject to the rights of others in and to any portion of the Premises lying within or adjoining Dog House Road. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -5- Writ No. 2010-4787 Civil Northwest Consumer Discount Company VS. Glenn A. Myers, III Lori A. Myers Atty.: Jeffrey N. Yoffe 650 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land, together with the improvements thereon erected, situate in Monroe Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point on the easterly line of land now or formerly of Lloyd H. Stipe and Evelyn G. Stipe, his wife, and at line of land now or formerly of South Mountain Land Company; thence by the line of land now or formerly of said Lloyd H. Stipe and Evelyn G. Stipe, his wife, in a northeastwardly direction 200 feet, more or less, to line of land now or formerly of John Stull; thence by line of land now or formerly of said John Stull, in a southeastwardly direction 281 feet, more or less, to a point qt line of land now or formerly of e,oir, John Stull and line of land now or formerly of said South Mountain Land Company; thence by the latter land, in a westwardly direction 175 feet, more or less, to a point, the place of BEGINNING. For title see deed recorded in Cumberland County Record Book 177, Page 838 in the Cumberland County, Pennsylvania Recorder of Deeds office. 658 Dog House Road, Boiling Springs, PA 17007: ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, bounded and described as follows: On the north by land now or for- merly of John T. Stull; on the east by land now or formerly of Thomas McCauslin; on the south by lands now or formerly of South Mountain Land Company; and on the west by lands now or formerly of Andrew Pendery, and being used as a road. Said premises being 50 feet in width and extending approximately 465 feet in depth in a north-south direction. For title see deed recorded in Cumberland County Record Book K, Volume 33, Page 651 in the Cumber- land County, Pennsylvania Recorder Of Deeds Office. EXHIBIT A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Krulac, David A is the grantee the same having been sold to said grantee on the 8th day of December A.D., 2010, under and by virtue of a writ Execution issued on the 14th day of September, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 4787, at the suit of Northwest Cons Disc Co against Glenn A Myers III & Lori A Myers is duly recorded as Instrument Number 201104816. IN TESTIMONY WHEREOF, IIhhave reunto set my hand and seal of said office this / day of A.D. 07 0 4-1" of Deeds 6?i?hRo?tMo?i?. to[?M >aN