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HomeMy WebLinkAbout10-5782Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 RLED-PFIrCE Francis S. Hallinan, Esq., Id. No. 62695 O- Tf? ? OF Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 P C _ 8 PM 2; l Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 ( UNV ? Jenine R. Davey, Esq., Id. No. 87077 -' Nl'+1SYLVrll A Lauren R. Tabas, Esq., Id. No. 93337 pE Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 248356 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. 4000 HORIZON WAY IRVING, TX 75063 Plaintiff V. ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. /6 CUMBERLAND COUNTY ?'9?.oo?cL C K-? ?6ao8s? ? aY7Q? File k: 248356 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 248356 Plaintiff is METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. 4000 HORIZON WAY IRVING, TX 75063 2. The name(s) and last known address(es) of the Defendant(s) are: ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/19/2007 ELIZABETH EFFENBERGER made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR FIRST HORIZON HOME LOANS, A DIVISION OF FIRST TENNESSEE BANK, N.A which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200730023. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(8); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 248356 6. The following amounts are due on the mortgage: Principal Balance Interest 04/01/2010 through 08/13/2010 (Per Diem $38.12) Attorney's Fees Late Charges through 08/13/2010 Mortgage Insurance Premium / Private Mortgage Insurance Costs of Suit and Title Search TOTAL 7. 9 $207,156.58 $5,032.19 $650.00 $205.29 $30.00 550.00 $213,624.06 Plaintiff is not seeking a judgment of personal liability (or an in ners? onam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 91 of 1983 because the mortgage premises is not the principal residence of Defendant(s). File #: 248356 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $213,624.06, together with interest from 08/13/2010 at the rate of $38.12 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. AN & SCHMIEG, LLP NII By: Y 11 f r??r VA ? Lawrence T. Phelan, Esq., Id. No. 32227 ?? F ancis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 248356 LEGAL DESCRIPTION ALL the following described real estate lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a pin at the southwest corner of land now or formerly of George Wasson and the inside pavement line on the northerly side of Brenton Street; thence along said lands now or formerly of Wasson, North 43 degrees 45 minutes West 150 feet to corner of lots now or formerly of William Naugle; thence by lots now or formerly of Naugle, South 46 degrees 15 minutes West 100 feet to corner of land now or formerly of Frank E. Hollar Jr., and Janet M. Hollar, his wife; thence by lands now or formerly of Hollar, South 43 degrees 45 minutes East 150 feet to a stake on the inside pavement line of Brenton Street; thence along the inside pavement line of Brenton Street, North 46 degrees 15 minutes East 100 feet to a pin, the place of beginning. BEING Lots 29 and 30, Block F, on plan of lots known as Hallwood Heights per survey of John H. Atherton, RE., duly recorded in Cumberland County, Pa., Plan Book 5, Page 60 THE above-described real estate is the same which Frank E. Hollar, Jr., and Janet M. Hollar, his wife, by deed dated March 24, 1958, recorded in Cumberland County, Pa., Deed Book I, Volume 18, Page 158, conveyed to George Kaluger and Meriem F. Kaluger, his wife. The said Merien F. Kaluger died July 6, 2006, thus vesting complete title in George Kaluger, the Grantor decedent. PROPERTY ADDRESS: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 PARCEL # 32-34-2413-247 File #: 248356 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: -q I w4l? tte for aintiff File #: 248356 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff Vs. ELIZABETH EFFENBERGER Defendant(s) r4 er"' ..-_. ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 10-5782-CIVIL TERM CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 248356 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: -? -17 I- ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenme R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ndrew C. Bramblett, Esq., Id. No. 208375 Date: 9-24-10 PHS #: 248356 f , - t. VERIFICATION Mike Fisher Limited Vice President hereby states that he/she is of, METLIFE HOME LOANS, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 0 File #: 248356 Name: Mike Fishef Title: Limited Vice President Servicer: METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Name:EFFENBERGER Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff VS. ELIZABETH EFFENBERGER Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION NO. 10-5782-CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: PHS #: 248356 ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 Phelan Hallinan & Schmieg, LLP Attorney for Plamtif By: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 2Andrew C. Bramblett, Esq., Id. No. 208375 Date: 9-24-10 PHS #: 248356 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~oa~,tr cf ~u~t~fiAry~7~ :•~- , '/.• ¢FF'IGE ~F'ti: SHERIFF Metlife Home Loans vs. Elizabeth Ellenberger Case Number 2010-5782 SHERIFF'S RETURN OF SERVICE 09/27/2010 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: Elizabeth Ellenberger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Elizabeth Ellenberger. Request for service at 625 Brenton Street, Shippensburg, PA 17257 is vacant. The Shippensburg Postmaster has confirmed Elizabeth Effenberger's new address is 120 Randal Avenue, Mine Hill, NJ 07803. SHERIFF COST: $51.00 September 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~°~ ~ ~„ ~ ~ _~ _ ~; c ~ ~ -'~ ~~~_~ ~ ~~ ~;, r sv :~> : ~ -~ y ~ ~ rm ~ ~ r.a (c) CounSySuite Sheriff. TeleosoiT Inc. AFFIDAVIT OF SERVICE (FNMA) )PLAINTIFF CUMBERLAND COUNTY T_LR4E HOME LOANS, A DIVISION OF METLIFE BANK, N.A. PHS # 248356 C C:5 DEFENDANT SERVICE TEAM/ cdf -0z C .-{ ELIZABETH EFFENBERGER COURT NO.: 10-5782-CIVIL Tl, p 5..n 2 r?9 r - SERVE ELIZABETH EFFENBERGER AT: TYPE OF ACTION Gnr- ?M , Q 120 RANDALL AVENUE XX Mortgage Foreclosure "CZ' C4 p MINE HILL, NJ 07803-2414 XX Civil Action Q a Z SERVED z 7u J>? O 276 S rved and made known to ETH EFFE ERGER ,Defendant on the day of , 2@,,4 Z. clocl. M., at 1? J Cr , in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is 7C . _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. >2 Other: w"'l t CQ '441 Descriptign:: nAge ? Height S Weight I W" Race jl Sex f Other I, S• l f vl , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed fore me I Ll ? 4 day of ?pU? J. SM ? Not i'11N118 OF 6t? J ?IOn Expires 4/93 OT SERVED On the day of It _ o'clock _. M., Defendant NOT FOUND because: Vacant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) UZNo Answer on/A/O-..,'(J at "a"I'11-Ci at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmleg, Esq, Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano' Esq, Id. No. 58745 Sheetal R. Shah•Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren IL Tabas, Esq., Id. No. 93337 V Nek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq, Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliskos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenny R. own, Esq., Id. No. 206779 Andrew C. Bramblett, Fap, d. No. 208375 One Penn Center at Subu n Station 1617 John F. Kennedy Blvd, Suite 1400 Philadelphia, PA 19103.1814 (215) 563-7000 SCOTT R. HILDEBRAND 81 RIDGE DR. NEW PROVIDENCE NJ 07974 9 0-60c 0 e6 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 z Jaime McGuinness, Esq., Id. No. 90134 :7p-r n rr" rn - Chrisovalante P. Fliakos, Esq., Id. No. 94620 c - r i Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ci r Allison F. Wells, Esq., Id. No. 30951 9 , 1617 JFK Boulevard, Suite 1400 ? One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION CUMBERLAND COUNTY OF METLIFE BANK, N.A. VS. ELIZABETH EFFENBERGER : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-5782-CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ELIZABETH EFFENBERGER, Defendant(s) 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 Plaintiff's damages as follows: J614 Db ?-t> At Ri Pip Ck* a4b6 ao0 Okicx2 (QL6L c? As set forth in Complaint $213,624.06 Interest - 08/14/2010 to 12/14/2010 $4,688.76 TOTAL $218,312.82 I hereby certify that (1) the Defendant's last known address is 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414, and mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 1 n n , „ / Lj Lawrence T. Phelan, Esq., Id. No. 32227 ? F ancis S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 19• 15-1 PHS # 248356 PROTHONOTARY?? U £ LL. 248356 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. 4000 HORIZON WAY IRVING, TX 75063 VS. ELIZABETH EFFENBERGER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-5782-CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. 248356 (b) that defendant ELIZABETH EFFENBERGER is over 18 years of age and last known address is 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414, and mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . _ %, December 14, 2010 LJ"L ice T. Phelan, Esq., Id. No. 32227 ' Y:ichiele cis S. Hallinan, Esq., Id. No. 62695 el G. Schmieg, Esq., Id. No. 62205 M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff 248356 (Rule of Civil Procedure No. 236) - Revised METLIFE HOME LOANS, A DIVISION CUMBERLAND COUNTY OF METLIFE BANK, N.A. COURT OF COMMON PLEAS VS. ELIZABETH EFFENBERGER : CIVIL DIVISION : No. 10-5782-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on 0 - t5 -10 By. "DAtat-) 7 j,O-?iLL KO T N TA Ry If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? F is S. Hallinan, Esq., Id. No. 62695 ? l G. Sc hmieg, Esq., Id. No. 62205 ele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 "THIS FIRMISA DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 248356 METLIFE HOME LOANS, A DIVISION OF COURT OF COMMON PLEAS METLIFE BANK, N.A. CIVIL DIVISON V. CUMBERLAND COUNTY ELIZABETH EFFENBERGER Defendant(s) TO: ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 Plaintiff NO. 10-5782-CIVIL TERM DATE OF NOTICE: December 2, 2010 I I THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE. PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 248356 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrenc T. P'elan, Esq., I . No. 32227 Francis/S. Hal nan, Esq., . No. 62695 Daniel G. Sc e, E Id. No. 62205 Michele M. Brad g ord, Esq., Id. No. `69849 ., .,. L Judith T. Romano, Esq., Id. No. 58745r ,. wm Sheetal R. Shah-Jani, Esq.; Id. NO'. 81760 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 , ,... Vivek Srivastava, Esq., Id: No °202331.. . Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ?sovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Couftenay R.` Dunn, Esq. 'Id. No 206779 Andrew C. Bramblett, Esq., Id. N9.,208375 Allison F. Wells, Esq., Id. No. 309519 Phelan Hallinan & Schmieg, LLP _... _...,y 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza _ .r. ,._ . Philadelphia, PA 19103 S PHS # 248356 METLIFE HOME LOANS, A DIVISION OF COURT OF COMMON PLEAS METLIFE BANK, N.A. CIVIL DIVISON Plaintiff NO. 10-5782-CIVIL TERM V. CUMBERLAND COUNTY ELIZABETH EFFENBERGER Defendant(s) TO: ELIZABETH EFFENBERGER 625 BRENTON STREET SHIPPENSBURG PA 17257-2113. DATE OF NOTICE: December 2, 2010 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT ADEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION. OBTAINED FROM YOU ;WILL BE USED FOR THAT PURPOSE.IF ,YOU..HAVE,PREVIOUSLY.„ItF EU ED ArDISCHARGE:IN -BANKRUPTCY THIS CORRESPONDENCE IS NOT AND ' SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT- A DEBT, BUT ONLY AS `ENFORCEMENT OF LIEN AGAINST PROPERTY. _.., . IMPORTANYNOTI(T YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE .PERSONALLY OR?,BY,;-ATTORNEY AND,.,FILE-4IN,,WRITING WITH ,THE ,.COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED . , AGAINST YOU : WITHOUT. A HEARING AND YOU MAY LOSE . YOUR PROPERTY OR OTHER .. IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. PHS # 248356 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: F?r w re e L-Phelan, Es , Id: No. 32227 an 's S. an, Es d. No. 62695 D el G. eg, q. Id. No. 62205 Michele Mrd, Esq., Id. No. 69849 :.Judith T. Romano E Id. No, 58745: :._ :.., ?"" ' ` Sheetal R: `Shah=Jani, Esq 'Id: No "81760 " - Jenine R. Davey, Esq , Id. No.'87077 Tabas Td. X3'37 Srivastava, Esq., Id. No. 202331 - ,? ?. JayB. s Jones, Esq.' Id. No; 86657`x'?" Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 hrispyalante P. Fliakos, Esq, Id. No. 94620 Joshua I Goldman, Esq., Id No 205047 Coiirtenay R: Dunn, Esq., Id.'Nd. 206779 .-.Andrew C. Bramblett, Esq., Id-No. 208375 . . Allison F. Wells, Esq., Id. No 309519 r? ,? ???-Phl lan Ha Ilinan &.Schmieg, LLPx*+^a; s?a,.w'?o-+a*atae .? 16 << JFK Boulevard, Suite 1400. ?...One Penn Center Plaza'""."? Philadelphia, PA 19103 .?- -,es 'ate ., .,p .sue-•,?''?°_f5i"?<`i s,:?"'.nh. ,3 .-gip .;-o s .,.,,,.=o x?e°r,•«q«.,tw .?vKe+??ar '?p".$?,"y°?,y,`°' PHS # 248356 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5782 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff (s) From ELIZABETH EFFENBERGER (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 $218,312.82 L.L.$.50 Interest FROM 12/15/2010 TO DATE OF SALE ($35.89 PER DIEM) -- $6,065.41 Atty's Comm % Due Prothy $2.00 Atty Paid $183.50 Other Costs Plaintiff Paid Date: 111041 id D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name: COURTENAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 206779 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v ELIZABETH EFFENBERGER Defendant(s) NO.: 10-5782-CIVIL TERM CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 12/15/2010 to Date of Sale ($35.89 per diem) TOTAL 51 60 9a- 1N. Div 0 ?• 56 _6ual C1 5F U It Pd A4y a? &V ??. C?# leytlcol as?? Note: Please attach description of property. PHS # 248356 CZ - $218,312.82 c rT $6,065.41 A; $224,378.23 omey for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. )ones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 J7 -?i >, ?wv m cc w? o? a Oa O? O? O? UW ?U d z PQ W a H 0 0 O ?a H W Q4 q w? pq a W ? ?A a W z 0 Pro w w a w wQo w x¢z ?i azx o? Q W?? O N O ? N V',, - 0?0 ? ? O? b? 00 N ??DN?et?t?l?M ttMi o? NO? M?? C? OMN ??001Z"ON G? wz o oZ oZo?oo o ob c oZ° ZZbZ•o 6 c o? oZZ ^ZZb a?;o? ^ ?ZZZOH-6 qb?~z W y y W C"W ~~ ^z ~ y N? m? W AW aOw^q ov"qb gWW;'?WW ? G" 19 c W W ?W ° H w W v 79 v 511 a F4xva °? ?? o o?iG03 `? E-+ a, o 10000000000000ons6o LEGAL DESCRIPTION ALL those certain two lots of ground situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more fully bounded and described as follows: BEGINNING at a pin at the Southwest corner of land of George Wasson and the inside pavement line on the Northerly side of Brenton Street; thence along the said Wasson land North 43 degrees 45 minutes West 150 feet to corner of lots of William Naugle; thence by lots of William Naugle South 46 degrees 15 minutes West 100 feet to corner of land of the Grantors herein; thence by the said Grantors' lots South 43 degrees 45 minutes East 150 feet to a stake on the inside pavement line of Brenton Street; thence along the inside pavement line of Brenton Street North 46 degrees 15 minutes East 100 feet to a pin, the place of BEGINNING. BEING Lots Nos. 29 and 30 in Block'F' of a Plan of Lots known as Hallwood Heights per survey of John H. Atherton, R.E., and duly recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book No. 5, Page 60. UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions, and rights of record to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES IS VESTED IN Elizabeth M. Effenberger, by Deed from Orrstown Bank, Executor of the Estate of George Kaluger, deceased and The Shippensburg University Foundation, a Pennsylvania not-for-profit organization, dated 07/19/2007, recorded 08/01/2007 in Instrument Number 200730022. PREMISES BEING: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 PARCEL NO. 32-34-2413-247 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff V. ELIZABETH EFFENBERGER Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION NO.: 10-5782-CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. ?? ? ;off o _J U_ ?_. C-'J ?.. ?? By: A ey for Plamtiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ?oshua L Goldman, Esq., Id. No. 205047 ourtenay R. Dunn, Esq., Id. No. 206779 0 Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff V. ELIZABETH EFFENBERGER Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5782-CIVIL TERM CUMBERLAND COUNTY PHS # 248356 AFFIDAVIT PURSUANT TO RULE 3129.1 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) ELIZABETH EFFENBERGER 120 RANDALL AVENUE ' ' F111> ?D MINE HILL, NJ 07803-2414 .= , ?- 2. Name and address of Defendant(s) in the judgment: v r . Name Address (if address cannot be reasonably O ascertained, please so indicate) a. SAME AS ABOVE ?TM .. c-> 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real proper"o b old: Name Address (if address cannot be _' reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Department of Public Welfare TPL Casualty Unit Estate Recovery Program Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept 280601 Harrisburg, PA 17128 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. January 4, 2011 By: orney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, COURT OF COMMON PLEAS N.A. CIVIL DIVISION Plaintiff NO.: 10-5782-CIVIL TERM VS. ELIZABETH EFFENBERGER CUMBERLAND CqUNTY,M ,.Defendant(s)-: i n c"? c... :ago NOTICE OF SHERIFF'S SALE OF REAL PROPERTY , ?- TO: ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 7! c.7 "THIS *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY." Your house (real estate) at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 is scheduled to be sold at the Sheriff s Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $218,312.82 obtained by METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-5782-CIVIL TERM METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. VS. ELIZABETH EFFENBERGER owner(s) of property situate in the TOWNSHIP OF DICKINSON, Cumberland County, Pennsylvania, being (Municipality) 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 Parcel No. 32-34-2413-247 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $218,312.82 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL those certain two lots of ground situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more fully bounded and described as follows: BEGINNING at a pin at the Southwest corner of land of George Wasson and the inside pavement line on the Northerly side of Brenton Street; thence along the said Wasson land North 43 degrees 45 minutes West 150 feet to corner of lots of William Naugle; thence by lots of William Naugle South 46 degrees 15 minutes West 100 feet to corner of land of the Grantors herein; thence by the said Grantors' lots South 43 degrees 45 minutes East 150 feet to a stake on the inside pavement line of Brenton Street; thence along the inside pavement line of Brenton Street North 46 degrees 15 minutes East 100 feet to a pin, the place of BEGINNING. BEING Lots Nos. 29 and 30 in Block'F' of a Plan of Lots known as Hallwood Heights per survey of John H. Atherton, R.E., and duly recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book No. 5, Page 60. UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions, and rights of record to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES IS VESTED IN Elizabeth M. Effenberger, by Deed from Orrstown Bank, Executor of the Estate of George Kaluger, deceased and The Shippensburg University Foundation, a Pennsylvania not-for-profit organization, dated 07/19/2007, recorded 08/01/2007 in Instrument Number 200730022. PREMISES BEING: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 PARCEL NO. 32-34-2413-247 R l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Civil Division VS. No. 10-5782-CIVIL TERM ELIZABETH EFFENBERGER a Zi; r ORDER AND NOW, this day of R-Nrtsrl? 2011, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendant. I'l,I7.ABETH EFFENBERGER, by: 1. Posting of the premises: 625 BRENTON STRITIA', SHIPPENSBURG, PA 17257-2113. 2. First class mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414, and the mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113; and 3. Certified mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414 and the mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113; and 4. Publication in accordance with PA. R.C.P. 430. BY TlIE' COURT: Lauren I aka9, ,,i&.4 IDS, .rte A 21--.11 2 2483 56-KXC Cc: ELIZABETH EFFENBERGER 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 C, METLIFE HOME LOANS, IN THE COURT OF COMMON PLEAS OF A DIVISION OF METLIFE BANK, N.A., CUMBERLAND COUNTY, PENNSYLVANIA im -v rn- PLAINTIFF 2 -Vrn > ov V. ?? CD' ELIZABETH EFFENBERGER, C: co rat DEFENDANT NO. 10-5782 CIVIL ORDER OF COURT AND NOW, this 12th day of April, 2011, upon consideration of the Plaintiff' s Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendants will file an answer on or before May 3, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendants file an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, 'Y` ? AA M. L. Ebert, Jr., J. `Allison F. Wells, Esquire Attorney for Plaintiff Elizabeth Effenberger IV/ Defendant P bas 2'11 IPR 20 A 11: 3 1-11?"'BERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff V. ELIZABETH EFFENBERGER Defendant ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-5782-CIVIL TERM CERTIFICATION OF SERVICE 248356 I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a Rule Return date of May 3, 2011 was sent to the following individual on the date indicated below. ELIZABETH EFFENBERGER ELIZABETH EFFENBERGER 120 RANDALL AVENUE 625 BRENTON STREET MINE HILL, NJ 07803-2414 SHIPPENSBURG, PA 17257-2113 ELIZABETH EFFENBERGER 707 BRENTON ST SHIPPENSBURG, PA 17257-2115 Phelan Hallinan & Schmieg, LLP DATE: By: 5l? ? Lawrence T. P sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? J th T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 248356 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia PA 19103 215-563,7090 METLIF8 HOME LOANS, A DIVISION OF METLIFE BANK, N.A. CUMBERLAND COUNTY Plaintiff, V. ELIZABETH EFFENBERGER COURT OF COMMON PLEAS sw-_ CIVIL DIVISION s 4 NO. 10-5782-CIVIL TER11?i* Defendant(s).° AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 rv I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to ELIZABETH EFFENBERGER on MARCH 24, 2011 in accordance with the Order of Court dated MARCH 17, 2011. The property was posted on MARCH 27, 2011. Publication was advertised in CUMNRLAND LAW JOURNAL on APRIL, 1, 2011 and in THE SENTINEL on MARCH 25, 2011. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unsworn falsification to authorities. PHELAN HALLINAN & SCHMIEG, LLP By: - - Phelan Hallinan & Schmiegg, LLP Lawrence 'l'. Phelan, Esq., Id. No. 32227 Francis S. Iallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Espy., Id. No. 62205 Michele M. Bradford, Es ., Id. No. 69849 Judith T. Romano, Esq,1-d. No. 58745 Sheetal R. Shah-Jani, EsqNo Id. No. 81760 Jenine R. Davey, Esq., Id. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq'&o.' IdNo. 202331 Jay B. Jones, Esq. Id. 86657 eter J. Mulcahy, sq , Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq, Id. No. 94620 Joshua L Goldman, Esq., Id. No. 205047 Courtenayy R. Dunn, Esc., Id. No. 206779 Andrew C 13ramblett, Esqq , Id. No. 208375 Allison Wells, Esq., Id. No. 309519 Attorneys for Plaintiff CD Dated: - ('j . IN THE COURT OF COMMON PLEAS CUNMERLAND COUNTY, PENNSYLVANIA METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. vs. ELIZABETH EFFENBERGER Civil Division No. 10-5782-CIVIL TERM ORDER AND NOW, this 11+4 day of_Nara_ , 2011, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale and all future pleadings on Defendant, ELIZABETH EFFENBERGER, by: 1. Posting of the premises: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. 2. First class mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414, and the mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113; and 3. Certified mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414 and the mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113; and 4. Publication in accordance with PA. R.C.P. 430. BY 1'Hl COURT: of ?? 14110-1 J. 2 248356-KXC Cc: ELIZABLgH EFFENBERGER 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 W ba z cn A w N 0. ? ? O ? u- O ^ w tr1 ro ?? ax 9 ° C1 0 C j 00 o ?? a 1 , r ?l ? to A W N C x?r ?or z ? cox rx c?rA O yM aItl m y?z -1 0zz N W ?^ c i a y b O PSIS PO CD 4 e® E ER 'o2Ir? 0 000427725 6 MAR MAILED FROM ZIP CO v, ?' a m y m d ul °x a biz bar > w= z C R° A? a G eD Ci7 A O O 7178 2417 6099 0078 Wil 4 / LXH RESTRICTED DELIVERY ELIZABETH EFFENBERGER 625 BRENTON STREET SHIPPENSBURG, PA 17257-0000 --fold here (regular) -- fold here (60) --fold here (regular) USPS - Track & Confirm Page 1 of 1 Home I HelD I ® Sign In _ Track & Confirm FA Qs Track & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0078 0631 Expected Delivery Date: March 28, 2011 Class: First-Class Mail® Service(s): Return Receipt Electronic Status: Delivered Your item was delivered at 10:44 am on April 04, 2011 in PHILADELPHIA, PA 19103. Detailed Results: • Delivered, April 04,2011,10:44 am, PHILADELPHIA, PA 19103 • Notice Left (No Authorized Recipient Available), April 04, 2011, 7:42 am, PHILADELPHIA, PA 19103 • Arrival at Unit, April 02, 2011, 9:24 am, PHILADELPHIA, PA 19104 • Processed through Sort Facility, March 31, 2011, 11:35 pm, PHILADELPHIA, PA 19176 • Vacant, March 29, 2011, 8:02 am, SHIPPENSBURG, PA • Acceptance, March 24, 2011, 6:01 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, March 24, 2011 liatificadon Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. ' 66> Return Receipt (Electronic) Verify who signed for your item by email. Go> t"tia:*'i a Site a Customer Service Forms Gov't Services Caren Copyright© 2010 USPS. All Rights Reserved. No FEAR Act EEO Data Track & Confirm Enter Label/Receipt Number. 1 rms of Use Business Customer Gateway http://trkcnfrm 1. smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do?strOrigTrackNum=7... 4/13/2011 7178 2417 6099 0078 06'-)l 4 / LXH RESTRICTED DELIVERY ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-0000 --fold here (regular) -- fold here (60) --fold here (regular) USPS - Track & Confirm Page 1 of 1 Home lHelD I Janusz. Sian In Track & Confirm FAQs Track & Confirm Search Results Label/Receipt Number: 7178 2417 6099 0078 0624 Expected Delivery Date: March 28, 2011 Class: First-Class MaWD Service(s): Return Receipt Electronic Status: Unclaimed Your item was returned to the sender on April 11, 2011 because it was not claimed by the addressee. Detailed Results: • Unclaimed, April 11, 2011, 11:08 am, DOVER, NJ • Notice Left, April 06, 2011, 1:08 pm, DOVER, NJ 07802 • Notice Left, March 26, 2011, 10:37 am, MINE HILL, NJ 07803 • Arrival at Unit, March 26, 2011, 6:09 am, DOVER, NJ 07801 • Acceptance, March 24, 2011, 6:01 pm, PHILADELPHIA, PA 19102 • Electronic Shipping Info Received, March 24, 2011 NotifecaGon Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go > _ Site Mau Customer Service Forms Gov't Services Copyright© 2010 USPS. All Rights Reserved. No FEAR Act EEO D sk? Irack & Confirm Enter Label/Receipt Number. 80> ,P _nns of Use Business Customer Gateway w http://trkcnfrm 1. smi.usps.comIPTSIntemetWebllnterLabell nquiry. do?strOrigTrackNum=7... 4/13/2011 AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY METLIFE HOME LOANS, A DIVISION OF METLiFE BANK, N.A. PHS # 248356 DEFENDANT ELIZABETH EFFENBERGER SERVE ELIZABETH EFFENBERGER AT: 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 **PLEASE POST PROPERTY IN ACCORDANCE WITH THE COURT ORDER**PLEASE RUSH POSTING ** SERVED SERVICE TEAM/ lac COURT NO.: 10-5782-CIVIL TERM TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: 06101/2011 Served and made known to ELIZABETH EFFENBERGER , Defendant on the ;r7 day of C- (4, 20 L1_ at Z o , o'clock. M., at 69-T B Ql:NTO N ST -Ak r , in the manner described below: Defendant personally served. 5 01 PPFou5BJQG, P4-1 - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an offi of said Defendant's company. Other: d 57,rDiQ00F-"! Description: Age Height Weight Race Sex Other _ I, 4 a competent adult, being duly sworn according to law, depose and state that 1 personally N)T/-F-D ban" a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this ?7-#day of ___,A4jP..it-20 n. Notary: Y NOT SERVED On the o 20 , at - o'clock _. M., Defendant NOT FOUND Because: Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer an at at Service Refused Other: Sworn to and subscribed before me this day of 0=. By: Notary: KIMBERLY CURTY 9 NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES MARCH 7, 2013 -------------- ATTORNEY FOR PLAINTIFF Lawrence T. Phdan, Eaq, Id. W 32227 Fnn" S. Ilanum, Esq, Id. N& 6269s DOM G. Sdaeiq, Esq., Id. No. 62205 Mkbde M. Bradyad, Eaq, bL Na 69849 Jadkh T. Baas, Esq, bL N& 59745 SheeW B. SLahdsd, Esq, ld. Na 81760 Jeake X Davey, Esq., Id. Na vwn Lauren B. Tabs, Fsq, hL Na 93337 Vivek Srivstna, Esq, Id. Na 2012331 Joy B. Jana, Fiq., LL Na 86657 Pder1. Mnkahy, Esq., Id. Na 61791 Andrew L. Spivadc, Fsq, Id. Na 84439 ehrbanknie P. Flinkas, Esq., Id. Na 94620 Johm L Geldsa, Esq, Id. Na 203047 Conrtmay IL Dann, Esq., Id. Na 206779 Andrew G BrasbkK Eaq, Id. Na 208375 AMm F. Wdh, Esq,1d. Na M"19 VAWhaE.Muter.Fa hl.Na388951 OnePmGa6a it?abnrtaeShBae 1617 JWW F. Kasady ShC Sldte 1400 Pb&Wk4d ia, PA 19103-1814 (215)563.7000 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 1, 2011 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. isa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 1 day of April, 2011 Notary NOTARIAL A DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County, Pennsylvania NO. 10-5782-CIVIL TERM METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. VS. ELIZABETH EFFENBERGER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: ELIZABETH EFFEN- BERGER Being Premises: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. Being in SHIPPENSBURG Town- ship, County of CUMBERLAND, Commonwealth of Pennsylvania. 32-34-2413-247. Improvements consist of residen- tial property. Sold as the property of ELIZA- BETH EFFENBERGER. Your house (real estate) at 625 BRENTON STREET, SHIPPENS- BURG, PA 17257-2113 is scheduled to be sold at the Sheriff's Sale on JUNE 1, 2011 at 10:00 A.M., at the CUMBERLAND County Courthouse to enforce the Court Judgment of $218,312.82 obtained by, METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. (the mort- gagee), against the above premises. PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Apr. 1 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Retail Sales Manaei; of The Sentinel, of the Cotulty and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December k 31h, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 25, 2011 COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10.5782-CIVIL TERM METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A VS. ELIZABETH EFFENBERGER NOTICE TO: ELIZABETH EFFENBERGER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" Being Premises: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 Being in SHIPPENSBURG Township, County of CUMBERLAND Commonwealth of Pennsylvania 32-34-2413-247 Improvements consist of residential property. Sold as the property of ELIZABETH EFFENBERGER Your house (real estate) at 625 BRENTON STREET, SHIPPENSBURG, RA 17257-2113 is scheduled to be sold at the Sheriff's Sale on JUNE 1 2011 at 10:00 AM, at the CUMBERLAND County Courthouse to enforce the Court Judgment of $218.312.82 obtained by, METLIFE HOME LOANS A DIVISION OF METLIFE BANK. N.A. (the mortgagee), against the above premises. PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are, rue. _ r 1?1 1? V Sworn to and s Is-14W vt My commission expires: NOTARIAL SEAL BAMBI ANN HECKENOORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 Notary Public J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff, V. ELIZABETH EFFENBERGER Defendant(s) L-) CUMBERLAND COUNTY ro -? co COURT OF COMMON P? CIVIL DIVISION rte- -C No.: 10-5782-CIVIL TERO' S -41 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: tiry W As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set fo on the Affidavit and as amended if applicable. A copy of the Certificate of Mailinj (Fo 817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is ttactlecy hereto Exhibit -q Iml , , Date: ?(J 6rwence T. Phelan, Esq., Id. Ng„22227 ?? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? S etal R. Shah-Jani, Esq., Id. No. 81760 enine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 1. "T C:) A IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 248356 soc a w j lz b3QOo d1z WObd 0371b Oft- o 9SZLLZb00p IM SOO q g o, ? 3 E3? u E .: A tll w L yS?o a w r4 o ? o e ? w O jflE? a U •o a ? W '?' Q pq w go C M ' w m A', J U °. c ,o "" tgi op W ti m ?? ca = sr r? s. 9 EYi Ja. a o," a a °° o fz1 v? cyzW! ?, a v ,n `' a,w o :Nti a,0 a to dE"•?00 "a.°.`? a a y,eryw w nv? aN o::a '~a a.a W aa'>'e4 °' 3Q Ux ° 0?$3 C ° I. Q c eu°'""p; oa+ °.. o oIZ CW x . 5 0 eGFJ4 a ae oE9 °?a a .b?,a o?,a'g F 3a w.. s o'. a?° y 5 ao d el4a vN a .a a ar ?Go ? d a 0 3 W ?i s. ?? ?. w 02 a 45 w o ?v o °8N°... as°? o. Ogaa ?, o ?n -ate ?a ?0 a a o a a N., - L d L U w 3, ?, rl. 6WZZ88Z ?? 'C60, ?, c+. I w3a os. s99gqi°'C s°,`.?°?.a'[?.xFe ° aM a ° ? pgv?v3•SN ? ?a!!p=" O ti N M el 3 tn \0 F • 'ter 3 priJ TA Ali 8, '-u M ENNSYL ANIAr ` Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff vs. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County ELIZABETH EFFENBERGER No.: 10-5782-CIVIL TERM Defendant PRAECIPE TO WITHDRAW MOTION TO REASSESS DAMAGES TO THE PROTHONOTARY: Plaintiff hereby withdraws its Motion to Reassess Damages, filed on April 7, 2011 in the above referenced action. DATE: Phelan Hal t an & Scum LLP U Lawrence elan, Esq., Id. No. 3222 ancis inan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 248356 A ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 4'Alison drew C. Bramblett, Esq., Id. No. 208375 F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 248356 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff vs. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County ELIZABETH EFFENBERGER No.: 10-5782-CIVIL TERM Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Withdraw its Motion to Reassess Damages was served upon the following interested party on the date indicated below. ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 ELIZABETH EFFENBERGER 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 ELIZABETH EFFENBERGER 707 BRENTON ST SHIPPENSBURG, PA 17257-2115 248356 Phelan Hal ' Zg, LLP DATE: ? Lawrence . o. 32227 ran ' allinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? And . ainblett, Esq., Id. No. 208375 lison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 248356 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff vs ELIZABETH EFFENBERGER Defendant PRAECIPE TO THE PROTHONOTARY: Attorney For Plaintiff : I Court of Common n ? Civil Division r"-.i • ? n CUMBERLAND C Z No. 10-5782-CIVIL TLRN Please mark the in rem judgment satisfied and the action discon Date: PHELAN HAN HMIEG, LLP By: Lawrence T. Phel q., . No. Francis S. nan, Esq., Id. No. 6269 Daniel G. Schmieg, Esq., Id. No. 62 5 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ,,<Ilison F. Wells, Esq., Id. No. 309519 PHS# 248356 Attorneys for Plaintiff d. ern C)° -j° a-n oC' A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F! F ? o Sheriff r, t ttt,j afi 4rrrra(i?? Th` P ?O, Jody S Smith° 1j?s e Chief Deputy l N "I Richard W Stewart CUMBERLAeX C-I Solicitor PEMNS YLVA r41;1; Metlife Home Loans vs. Case Number Elizabeth Effenberger 2010-5782 SHERIFF'S RETURN OF SERVICE 03/18/2011 02:44 PM - Ddputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 625 Brenton Street, Shippensburg, PA 17257, Cumberland County. 04/04/2011 Sheriff Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice and Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the;action by certified mail, return receipt requested, to the within named Defendant, to wit: Elizabeth Effebberger at 120 Randall Avenue, Mine Hill, New Jersey, The return receipt card was signed by Elizabeth Effenberger on 3/18/11 and returned to the Cumberland County Sheriffs Office. 05/20/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $3,135.25 SO ANSWERS, July 29, 2011 RON R ANDERSON, SHERIFF D (_'?p M -ce, LL 1,H, ?-# S? {o} Coun?vSuto Shenft Teleoaofl hu:. METLIFE HOME LEANS, A DIVISION OF METLIFE BANK, N.A: Plaintiff V. ELIZABETH EFFENOERGER Defendant(s) CUMBERLAND COUNTY PHS # 248356 AFFIDAVIT PURSUANT TO RULE 3129.1 METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. 1. Name and address of;Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) ELIZABETH EFFiNBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale; Name Address (if address cannot be reasonably ascertained, please indicate) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5782-CIVIL TERM TENANT/OCCUPANT 625 BRENTON STREET SHIPPENSBURG, PA 17257-2113 Domestic Relations'of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department !of Justice U.S. Attorney for; the Middle District of PA Department of P4Iblic Welfare TPL Casualty Unit Estate Recovery Program Commonwealth otPennsylvania Bureau of Individual Tax Inheritance Tax Division 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 6`h Floor, Strawberry Sq., Dept 280601 Harrisburg, PA 17128 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904; relating to unsworn falsification to authorities. Januga 4 2011 By. rney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 f s'i METLIFE DOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff VS. ELIZABETH EFFENBtRGER COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-5782-CIVIL TERM : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ELIZABETH EFFENBERGER 120 RANDALL AVENUE MINE HILL, NJ 07803-2414 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAI PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real est6te) at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 is scheduled to be sold at the Sheriff's Sale bn 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, I,A 17013 to enforce the courtjudgment of $218,312.82 obtained by METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Salle, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees die. To find out how much you must pay, you may call: 215-563-7000 x1230 2. You maybe able jo stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be 4ble to stop the sale through other legal proceedings. You may need an attdrney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriff's Sale is not Mopped, your property will be sold to the highest bidder. You ma find out price bid by calling 215-563J000. Y the o 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your,properky. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to )remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to, a share of the money which was paid for your house. A proposed schedule of distribution of the money (bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shill be kept on file with the sheriff and will be made available for inspection in his office. This schedule will; state who will be receiving that money. The money will be paid out in accordance with this schedule unless Exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT" AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHEREYOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-5782-CIVIL TERM METLIFE HON IE LOANS, A DIVISION OF METLIFE BANK, N.A. vs. ELIZABETH E1 FENBERGER owner(s) of propefty situate in the ,Cumberland County, Pennsylvania, being (Municipality) rarcei 1yo. 32-34-413-247 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $218,312.82 Phelan Hallinan & ScOmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103' 215-563-7000 LEGAL DESCRIPTION ALL those certain two lots of ground situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more Olly bounded and described as follows: BEGINNING at a pile at the Southwest comer of land of George Wasson and the inside pavement line on the Northerly side of Br$nton Street; thence along the said Wasson land North 43 degrees 45 minutes West 150 feet to corner of lots 'of William Naugle; thence by lots of William Naugle South 46 degrees 15 minutes West 100 feet to corner of nand of the Grantors herein; thence by the said Grantors' lots South 43 degrees 45 minutes East 150 feet to a stake on the inside pavement line of Brenton Street; thence along the inside pavement line of Brej ton Street North 46 degrees 15 minutes East 100 feet to a pin, the place of BEGINNING. BEING Lots Nos. 29 and 30 in Block'F' of a Plan of Lots known as Hallwood Heights per survey of John H. Atherton, R.E., and dilly recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book No. 5, Pagle 60. UNDER AND SUBJ$CT to existing covenants, agreements, conditions, easements, restrictions, and rights of record to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PUMISES IS VESTED IN Elizabeth M. Effenberger, by Deed from Orrstown Bank, Executor of the Est* of George Kaluger, deceased and The Shippensburg University Foundation, a Pennsylvania not-for-profit organization, dated 07/19/2007, recorded 08/01/2007 in Instrument Number 200730022. PREMISES BEING: 05 BRENTON STREET, SHIPPENSBURG, PA 17257-2113 PARCEL NO. 32-34-21413-247 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-5782-CIVIL TERM METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. vs. ELIZABETH EFFENBERGER owner(s) of propelrty situate in the TOWNSHIP OF DICKINSON, Cumberland County, Pennsylvania, beiirg (Municipality) 41(1 3_247 (Acreage or street address) 7257 Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $218,312.82 Phelan Hallinan & S¢hmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5782 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. Plaintiff (s) From ELIZABETH EFFENBERGER (1) You Ore directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE($) 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 otherthan 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 $? 18,312.82 L.L.$.50 Interest FROM 12/15/2010 TO DATE OF SALE ($35.89 PER DIEM) -- $6,065.41 Atty's Comm % Due Prothy $2.00 Atty Paid $181,50 Other Costs Plaintiff Paid Date: 1/10/11 D. Buell, ?rothonotary (Seal) By: Deputy REQUESTING PARTY: Name: COURThNAY R. DUNN, ESQUIRE Address: PHELAN HALLINAN AND SCHMIEG 1617 JVK BLVD, SUITE 1400 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-?63-7000 Supreme Court Il) No. 206779 TRUE COPY FROM RECORD In Testi,nony whererf, I here unto set my hand and the of said 0 at Carnets, Pa. This _L_ __day of ?kln 201( ' J On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA, Known and numbered as, 625 Brenton Street, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: y _ UOLUU Real Estate Coordinator 'hel ISchmieg, LLP_ 617__ ard, Suite 1400 METLIFE HOME LOANS, A DIVISION OF METLIFE : BANK-, N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, V. ELIZABETH EFFENBERGER CIVIL DIVISION NO. 10-5782-CIVIL TERM Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to ELIZABETH EFFENBERGER on MARCH 24, 2011 in accordance with the Order of Court dated MARCH 17, 2011. The property was posted on MARCH 27, 2011. Publication was advertised in CUVINRLAND LAW JOURNAL on APRIL 1, 2011 and in THE SENTINEL on MARCH 25, 201.1. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unsworn falsification to authorities. PHELAN HALLINAN & SCHMIEG, LLP Phelan Hallman & Schmiegg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmiee, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq , Id. No. 58745 Sheetal R. Shah-Jani, Esq. Id. No. 81760 Jemne R. Davey, Es q., Id. CIO. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq. Id. fio. 86657 -Peter J. Mulcahy, Is Id. No. 61791 Andrew L. Spivack, Lq., Id. No. 84439 Jaime McGuinness; Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq ? Id. No. 94620 Joshua L Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison Wells, Esq., Id. No. 309519 Attorneys for Plaintiff Dated: 4 . (3 - (( M ? WW"'" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA METLIFE HO LOANS, A DIVISION OF ETLIFE BANK, N.A. Civil Division No. 10-57 82-CIVIL TERM ELIZABETH E; v ?ENBERGER ORDER AND NO?, this 1144, day of- Ma ,& 2011, upon consideration of laintiff s Motion for Service Pursuant to Special Order of Court, it is hereby ORDERS and DECREED that said Motion is GRANTED. It ii further ORDERED and DECREED that Plaintiff may obtain service of the Notice of Sale lind all future pleadings on Defendant, ILIZABETH EFFENBERGER, by- I 1. Posting of the premises: 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113. 2. First class mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVEN E, MINE HILL, NJ 07803-2414, and the mortgaged premises located at 625 BRENTON STREET, SHIPPENSBURG, PA 17257-2113; and 3. Certified mail to ELIZABETH EFFENBERGER at the last known address, 120 RANDALL AVENUE, MINE HILL, NJ 07803-2414 and the mortgaged premises located at 625 BRE TON STREET, SHIPPENSBURG, PA 17257-2113; and 4. Publicat on in accordance with PA. R.C.P. 430. BY THE COURT: ,f - J. 2 CUMBERLAND LAW JOURNAL Writ No. 201q-5782 Civil Metlife Horme Loans vs.? Elizabeth Eienberger Atty.: Daniel J Schmieg By virtue of a Virit of Execution NO. 10-5782-CIVIL PERM, METLIFE HOME LOANS, A DIVISION OF METLIFE BANK, N.A. vs. ELIZABETH EFFENBERGER, ow1ner(s) of property situate in the Boro4gh of Shippens- burg, Cumberland County, Pennsyl- vania, being 625 BR?NTON STREET, SHIPPENSBURG, P? 17257-2113. Parcel No. 32-34x2413-247. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $218,312- .82. 18 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 Ma; ie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, tieing 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 fallowing dates, 29, and May 6, 2011 Affiant filrther 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 dime, place and character of publication are true. ULisa Marie Coyne /Editor SWORN TO AND SUBSCRIBED before me this 6 da of Ma 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 ?.. The Patriot-News Co. 2020 Technology Pkwy Suite-300 Mechanicsburg, PA 17050 Inquiries - 717-255+8213 the Patti* ot News Now you know CUMBERLAND Co. ;SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff AccoOntant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania!, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County 0 Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-Newsy and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been dontinuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community] Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the suoject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character bf 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 directprs 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: 04/22/11 04/29/11 W A ty 00" J By VOW of a Wrk of Envitioe N0. IQ3182t?L141ERM MEnJFE HOW LOANS, ADW SiON OF I14Eii-1FE BANK, NA. E ACBETH ER"WOIE'R Dupes) of propeil I*Aales wft Be r&* .of rg, a mbm#nd,Cou*, P ama, being 625 BRINMN SIREEL SIiS PPEC JAU, ?A 17257-2113 P"W No. 32-34.2413-247 (AwwW oc 4nd adetim) Iwovemab aca m: RH6BwnALv rr Sworn to and subs rjbed before me this 3 y y, 2011 A.D. r Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal wShhreme L Klaw Notary Pubik Axton TWp., Dauphin County ELO'1yC=M1S90n80WNov.26,2011 Memberr,ni Association n of Notaries 05/06/11 R7DGMEKf AMOUNT.. $218312.82