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Home My WebLink About10-5644PLED-ORF CE CF THE PP'`" ` -NOTARY `01 PLIJ 31 PM 2: 30 PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ---- 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. 5701 East Hillsborough Avenue Tampa, Florida 33610 V. James M. Coyer 245 Pine Grove Road Gardners, Pennsylvania 17324 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 1p - 4S& q q alyi t Tem CIVIL ACTION/MORTGAGE FORECLOSURE GJ 49a. Do PO AT7-f 0 IF 119 a33 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. S1 USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRF_CER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association Court Administrator 2 Liberty Avenue I l 1-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is HSBC Mortgage Services Inc., a corporation duly organized and doing business at the above captioned address. 2. The Defendant is James M. Coyer, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 245 Pine Grove Road, Gardners, Pennsylvania 17324. 3. On March 31, 2005, James M. Coyer made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for Accredited Home Lenders Inc. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1902, Page 2027. .4. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for Accredited Home Lenders Inc. to HSBC Mortgage Services Inc., by Assignment of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland County. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 245 Pine Grove Road, Gardners, Pennsylvania 17324. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November 1, 2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. L 7. The following amounts are due on the mortgage: Principal Balance $ 44,935.33 Interest through July 19, 2010 $ 7,400.59 (Plus $11.39 per diem thereafter) Attorney's Fee $ 1,250.00 Late Charges $ 564.12 Corporate Advance $ 8,402.94 GRAND TOTAL $ 62,552.98 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands an in rem Judgment against the Defendant in the sum of $62,552.98, together with interest at the rate of $11.39 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY: ? / a z- Attorneys for PT_ntiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY,P.C. _ BY: h-a'r Attorneys for PIcCABE, tiff TERRENCE J. ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE EXHIBIT A ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED SITAUTE AT TOLAND IN THE TOWNSHIP OF DICKINSON BEING DESIGNATED ON A "PLAN OF LOTS AT TOLAND: ENTERED FOR RECORD IN THE OFFICE FOR RECORDING OF DEEDS IN PLAN BOOK 3, PAGE 68 WHICH LOT HEREIN CONVEYED IS DESIGNATED ON SAID PLAN AS LOT NO. 5 WITH DIMENSIONS AS MARKED ON THE PLAN. TOGETHER WITH THE USE OF THE COMMON NAND BETWEEN THE LOTS AND THE PUBLIC ROAD AND THE USE OF THE WELL AND PUMP ON THE COMMON LAND ALONG WITH OTHER OWNERS. TAX MAP OR PARCEL ID NO.: 08-38-2172-005 ADDRESS: 245 PINE GROVE ROAD; GARDNERS, PA 17324-8946 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor HSBC Mortgage Services, Inc. vs. James M. Coyer ?j?§119 -1111b'r,'14 Case Number 2010-5644 SHERIFF'S RETURN OF SERVICE 09/15/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: James M. Coyer, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant James M. Coyer. Request for service at 245 Pine Grove Road, Gardners, PA 17324 is vacant. The Gardners Postmaster has advised James M. Coyer's new address is 1073 Pine Street, Palmer, MA 01069. SHERIFF COST: $42.90 SO ANSWERS, September 15, 2010 RON y R ANDERSON, SHERIFF 771 -rj n . r ..• i ti S McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorneys fer "IV JD -OFFICE TARP 201011'!1119 P 12:27 CT% ,',E1_RLAN'o COUNTY r .. NSYLVANIA t°1;a CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5644 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 07/20/10 to 11/16/10 Total $ 62,552.98 $ 1,366.80 $ 63,919.78 .C/ ?WA -*- T RREN J. MCCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET CAIRO, ESQUIRE Attorneys for Plaintiff AND NOW, this fq?day of A)00 . , 2010, Judgment is entered in favor of Plaintiff, HSBC Mortgage Services Inc., and against Defendant, James M. Coyer, and damages are assessed in the amount of $63,919.78, plus interest and costs. BY THE PROTHONOTARY- 1, "") ?'kl AV-d' . cry -?Cp? t McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5644 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant, James M. Coyer, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, James M. Coyer, is over eighteen (18) years of age, and reside as follows: James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 SWORN AND SUBSCRIBED BEFORE ME THIS jo+ DAY OF VJQ'V en, t)a , 2010 NOTAR PUBLIC A L n C i` 1 , tau,ly A J d Phi' is %ounty •. IV nr1\AI A ...?. r1\. UG, 2 0'14 T RREN J. McCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff i- r McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5644 Civil Term AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 SWORN AND SUBSCRIBED BEFORE ME THIS1(0jhDAY OFV-^CWeE f*2010 mpAi?(1 NOTARY PUBLIC L Ccurty f 6, 2 0 -mk TERREN J. McCABE, ESQUIRE MARC S- WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5644 Civil Term CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS Jk& DAY OF ?%i!erf4MT , 2010 1 To" Q ? q?t NOTARY PUBLIC E; rr 11% L Public a, ' efp is County "y 71- AN, 06, 2014 TERRENC . McCABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY 5 C' ?T COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 18, 2010 To: James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 I-ISBC Mortgage Services Inc. Cumberland County Court of Common Pleas Vs. James M. Coyer Number 10-5644 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPFARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TIIE COURT YOUR DEFENSES OR OBJECTIONS TO TIM CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOt1WITHOUTAHEARING ANDYOUMAYLOSEYOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE IMF. OFFICE SEI" FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRJNG A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAW YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUTAGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED F'EF: OR NO FEE.. Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE RLDELD1A POR NO HABER PRESENTADO UNA COMPARFCENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFFNSAS 1) OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DF.BIDA DENTKO DE DIET, (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, F.I, TRIBUNAL PODRA, SIN NECESIDAD OF. COMPAREC.ER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTFD PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. LISTED LE DEBE TOMAR FiSTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TF.LEFONEA LA OFICINA MUSO ABAJO. ESTA OFICINA IA PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DF. EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGF•NCIAS QUE PUL• DEN OFRFCER LOS SERVICIOS LEGALFS A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO *I1 NINGLN 1'IONORARIO. Cumberland County Bar Association Court Administrator 2 Liberty Avenue 1 11-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9-tog -.", BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE eci VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. T"ERREN,kE J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 HSBC Mortgage Services Inc. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. James M. Coyer I No. 10-5644 Civil Term Defendant NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary Ilk?i??J X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOIO-5644 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE SERVICES INC. Plaintiff (s) From JAMES M. COYER (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$63,919.78 L.L.$.50 Interest FRON 11/17/10 TO 3/2/11 - $1,114.06 AT $10.51 Atty's Comm % Due Prothy $2.00 Atty Paid $175.40 Plaintiff Paid Other Costs Date: November 19, 2010 (Seal) REQUESTING PARTY: a_??v David uell, Prot notary By: Deputy Name Margaret Gairo, Esq. Address: McCabe, Weisberg and Conway, 123 S. Broad Street, Suite 2080, Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 34419 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION HSBC Mortgage Services Inc. V. FILE NO.: 10-5644 Civil Term Civil Term AMOUNT DUE: $63,919.78 James M. Coyer INTEREST: from 11/17/10 to 3/2/11 $1,114.06 at $10.51 ATTY' S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 245 Pine Grove Road, Gardners, Pennsylvania 17324 (More fully described as attached) PRAECIYE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: November 16, 2010 or. "7r 8 I 'x, C) 6 co 5'k f qS-. Q6 N " ?F Iv, 66 11 rY n / d- .1k, s` (3 S - 416 i4 `7 s??,o0 ?? 6 a #-.511 DU- f- 4L erd !a 772 2.,,- Signature: Ra'k Print Name: CCA , WEISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. C) M ?' ~= rn- -0 r- ;:0 ? )> C:D r-- --+o < CD z° C- _ -n o -rt :z C) ) D? N ?M N LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE AT TOLAND IN THE TOWNSHIP OF DICKINSON BEING DESIGNATED ON A "PLAN OF LOTS AT TOLAND: ENTERED FOR RECORD IN THE OFFICE FOR RECORDING OF DEEDS IN PLAN BOOK 3, PAGE 68 WHICH LOT HEREIN CONVEYED IS DESIGNATED ON SAID PLAN AS LOT NO.5 WITH DIMENSIONS AS MARKED ON THE PLAN. TOGETHER WITH THE USE OF THE COMMON LAND BETWEEN THE LOTS AND THE PUBLIC ROAD AND THE USE OF THE WELL AND PUMP ON THE COMMON LAND ALONG WITH OTHER OWNERS. RB5678 245 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DONALD C. YOST AND SUSIE A. YOST, HUSBAND AND WIFE by deed dated March 30, 2005 and recorded April 4, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 268, Page 1235, granted and conveyed to James M. Coyer in fee. TAX MAP PARCEL NUMBER: 08-38-2172-005 9 % McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 245 Pine Grove Road, Gardners, Pennsylvania 17324, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner 2. 3 4. Name and address of Defendant in the judgment: Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein FILED-OFFICE OF THE PROTHONOTARY 2010 410'.' 19 P 12:32 Attorneys for Plaintiff CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5644 Civil Term Address Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address MERS, Inc. P.O. Box 2026 Flint, Michigan 48501 Name and address of every other person who has any record lien on the property: Name Address None Name and address of every other person who has any record interest in the property which may be affected by the sale: Name none Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 245 Pine Grove Road Gardners, Pennsylvania 17324 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North P Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name none P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 16 2010 DATE T RRE E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE AT TOLAND IN THE TOWNSHIP OF DICKINSON BEING DESIGNATED ON A "PLAN OF LOTS AT TOLAND: ENTERED FOR RECORD IN THE OFFICE FOR RECORDING OF DEEDS IN PLAN BOOK 3, PAGE 68 WHICH LOT HEREIN CONVEYED IS DESIGNATED ON SAID PLAN AS LOT NO.5 WITH DIMENSIONS AS MARKED ON THE PLAN. TOGETHER WITH THE USE OF THE COMMON LAND BETWEEN THE LOTS AND THE PUBLIC ROAD AND THE USE OF THE WELL AND PUMP ON THE COMMON LAND ALONG WITH OTHER OWNERS. RB5678 245 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DONALD C. YOST AND SUSIE A. YOST, HUSBAND AND WIFE by deed dated March 30, 2005 and recorded April 4, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 268, Page 1235, granted and conveyed to James M. Coyer in fee. TAX MAP PARCEL NUMBER: 08-38-2172-005 FiLEO-OFFICE OF THE PROTHONOTARY McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID #.34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad. Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. V. James M. Coyer CIVIL ACTION LAW Attorneys for Plain#0 NOV 19 PM 12: 32 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5644 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069.. Ypur:house (real Ostate)-at 24S Pine Grove. Road, ::Gardners, Pennsylvania .17324 is'scheduled to be sold at Sheriffs Sale on March 2, 2011 at 10:00 a.ni. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $63,919.78 obtained by HSBC Mortgage Services Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to HSBC Mortgage Services Inc. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE AT TOLAND IN THE TOWNSHIP OF DICKINSON BEING DESIGNATED ON A "PLAN OF LOTS AT TOLAND: ENTERED FOR RECORD IN THE OFFICE FOR RECORDING OF DEEDS IN PLAN BOOK 3, PAGE 68 WHICH LOT HEREIN CONVEYED IS DESIGNATED ON SAID PLAN AS LOT NO.5 WITH DIMENSIONS AS MARKED ON THE PLAN. TOGETHER WITH THE USE OF THE COMMON LAND BETWEEN THE LOTS AND THE PUBLIC ROAD AND THE USE OF THE WELL AND PUMP ON THE COMMON LAND ALONG WITH OTHER OWNERS. RB5678 245 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DONALD C. YOST AND SUSIE A. YOST, HUSBAND AND WIFE by deed dated March 30, 2005 and recorded April 4, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 268, Page 1235, granted and conveyed to James M. Coyer in fee. TAX MAP PARCEL NUMBER: 08-38-2172-005 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff C_') ?.? V. -M t Number 10-5644 Civil Term James M. Coyer t ^A Defendant c_ -ta y AFFIDAVIT OF SERVICE I, the undersigned attorney for the Plaintiff in the within matter, hereby certify that on the 30th day of December, 2010, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A." Copies of the letter and certificates of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN AND SUBSCRIBED BEFORE ME THIS 3r^ DAY OF OLhu > 2011 NOTARY PUBLIC C_MM NWEALTH OF PENNSYLVANIA N13TARIAL SEAL Megan C. Peolucci -Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 06, 2014 &4Z,;C T RREN E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5644 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 245 Pine Grove Road, Gardners, Pennsylvania 17324, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner 2. 3 Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 Name and address of Defendant in the judgment: Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. 6. 7 MFRS, Inc. P.O. Box 2026 Flint, Michigan 48501 Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name none Address Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Address 245 Pine Grove Road Gardners, Pennsylvania 17324 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 81d Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601. Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address none I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 16.2010 DATE ,AA Z- '- RRE E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant DATE: December 30, 2010 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5644 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: James M. Coyer PROPERTY: 245 Pine Grove Road, Gardners, Pennsylvania 17324 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on March 2, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. 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E ? ? i C'00 L OCA CQ C y ?? . y C ??F3a?a 7 AUaU M C O V?3Nrn C 0 ?xNx C = (Y3 r . O,3 y ? V V V ? O 0 y d c G ? yy 7 .CO. u Fa i d G. w. ? o ,uo u ? z •O CN 0 _ G6 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 FRANK DUBIN, ESQUIRE - ID # 19280 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. V. James M. Coyer COURT OF COMMON PLEAS PHILADELPHIA COUNTY Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5644 Civil Term AFFIDAVIT OF SERVICE :l -- r rr, co C?)C * (73 C.. tw) ?C7 The undersigned, attorney, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief: That he is counsel for the above-named Plaintiff, That on January 17, 2011, Plaintiff served a true and correct copy of the Notice of Sale through the B&R Services, upon the Defendant, James M. Coyer, by handing the same to the Defendant's adult tamily member, Michelle Renaud, at the Defendants' last-known address of 1073 Pine Street, Palmer, MA 01069. A True and correct copy of the Return of Service is attached hereto, made a part hereof, and marked as Exhibit "A." -- - SWORN TO AND SUBSCRIBED BEFORE ME THIS ag4DAY OF Pebr ry 2011 NOTAR PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Megan C. Paolucci -Notary Public City of Fhn Phi!?delphia County h`Y Gas , JAN. 06 2014 BY. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE EXHIBIT A 235 SOUTH 13TH STRCET PHILADELPHIA, PA 19107 PHONE: (215) 546.7400 sentlcae for t+rof+loaay tac. FAX: (215) 985-0169 5(.o L.3 MW National Association of Professional Process Servers Philadelphia Association of Professional Process Servers HSBC Mortgage Services, Inc. COURT Court of Common Pleas of Pennsylvania -Vs- COUNTY r-4jX awloJCounty James M. Coyer CASE NUMBER 10-5644 Civil Term AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: B$R Control # CS081254 -1 COUNTY OF PHILADELPHIA: Reference Number 96-2283 SERVICE INFORMATION On 10 day of January, 2011 we received the Notice of Sheriff Sale for service upon James M. Coyer at 1073 Pine Street Palmer, MA 01069 Special Instructions *** r '7 Served Date Time 1 'Q?J' )Acceptad BY: 1 ¢ 1 I.1 f C> t,? ?(i. (t??rrl J i .`tl In the manner described below. Personally served. (X Adult family member. Relationship is it Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging - Agent or person in charge of office or usual place of business Other _ Description of Person Age 411 Height ?j - Weight,' ' 7 -4/ _?_ Race Sex Other IJI v't C?_?f l "r t" F-INot Served Date Time Not Served Information [7:j Moved E-] Unknown ?-] No Answer (--j Vacant Other ............... . The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information, Q)?elief. t Process Server/Sheriff - Lw- Law Firm Phone (215) 0-5964 - Alyssa Egan Attorney Outsourcing Support Services, Inc. 123 S. Broad Street Suite 2040 Philadelphia, PA 19109 ORIGINAL Sworn to and subscribed before me this Notary Public out lk- !R(0)13 cKA` ServeBy Date 3/2/211 4wy Ila Filed Date Wa My Commission Expire s Sale Date 2/2/2 t(t, June 16, 2016 D10VC McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 307169 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendant Attorney for Plaintiff c CO M rTj M T.- ? ?=- CUMBERLAND COUNTY ?- 01 COURT OF COMMON PLEAS r-" :.-Tj a? ?C) Number 10-5644 Civil Term r . -t a AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 1 st day of March, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS ar?j DAY OF Hac-c h , 2011 Np AnRIkPUBLIC COMMONWEALTH OF PENNSYLVANIA N?TARiAL BEAL Megan C. Faolucci -Notary Public C"y of Philn:c!-hii,!1hiladelphia County I ; , ( rI'? uS !AN, 06; 2014 McCABE, VY,EJ&BFLtG & CONWAY, P.C. By: TERR CE cCABE, ESQUIRE - ID # 16496 MAR S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 307169 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN McQUAIL, ESQUIRE-ID # 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendants Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5644 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 245 Pine Grove Road, Gardners, Pennsylvania 17324, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 2. Name and address of Defendants in the judgment: Name Address James M. Coyer 1073 Pine Street Palmer, Massachusetts 01069 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein MERS, Inc. Mortgage Electronic Registration Systems, Inc. as nominee for Accredited Home Lenders Mortgage Electronic PO Box 2026 Registration Systems, Inc. Flint, MI 48501 as nominee for Accredited Home Lenders 5 6 Name and address of every other person who has any record lien on the property: Name None Address P.O. Box 2026 Flint, Michigan 48501 15090 AVENUE OF SCIENCE SAN DIEGO, CA 92128 Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name none Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 245 Pine Grove Road Gardners, Pennsylvania 17324 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U.S. Dept of Justice, Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S. Dept of Justice, Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address none I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. McCABE, W P + RG & CONWAY, P.C. March 1, 2011 Attorneys DATE r P tntiff By: TERR E J. McCABE, ESQUIRE MAR S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN McQUAIL, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Services Inc. Plaintiff V. James M. Coyer Defendants DATE: March 1, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5644 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: James M. Coyer PROPERTY: 245 Pine Grove Road, Gardners, Pennsylvania 17324 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on April 6, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. N N o 0 z ?S??1Mt1 0 r v V a x w; Q?U W a° U ? V ti Y M h rA L o L s o ?oz I-oo Ov ? fi ? •C L?IN •G L x?N d €d ?oao? u C uOd +L+dW u C u •+z+d O ? L? V .. O ^ L C O \p 6 '? W4,?GJ v Ww.ry? y N ^ € G? C> z ??od ?UUC] W odo oQo G UOOOO? CC rI U) ICi RSW ZI r.+ u ap u C "" ? oy 0 U °0 d a E a r ? z ; L > ,. ca 3 N O O ' ° 9 O y ? V ? v ] v C p V 1 Q bA dVO .: Vl7N0?' ?M fj q. C u a.-- o? ? L C y V F ^" O 4d " L Cr O d ash cc .0 dz V z? w cc u H N Nr Z ..ad a 64 F¦a N Us