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Home My WebLink About10-5944PLED- E. pENN;,YLVANA 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 SPIVAK, ESQUIRE - ID # 74770 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Corporation (USA) 2929 Walden Avenue Depew, New York 14043 V. Angela M. Orchowski 235 Pine Grove Road Dickinson, Pennsylvania 17324 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10 - 5g44 Oi.,- J 1 ej1K CIVIL ACTION/MORTGAGE FORECLOSURE p #ga.00 PO AITY a*146759 0 a q&V(1 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 courtyour 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 1 I 1-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias 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 corte 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 continuar 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. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTEDNO 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. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is HSBC Mortgage Corporation (USA), a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Angela M. Orchowski, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 235 Pine Grove Road, Dickinson, Pennsylvania 17324. 3. On July 24, 2007, Angela M. Orchowski made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for HSBC Mortgage Corporation (USA) which mortgage is recorded in the Office of the Recorder of Cumberland County in Instrument 200730002. 4. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for HSBC Mortgage Corporation (USA) to HSBC Mortgage Corporation (USA), 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 235 Pine Grove Road, Dickinson, Pennsylvania 17324. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due May 1, 2010 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. 7. The following amounts are due on the mortgage: Principal Balance Interest through August 28, 2010 (Plus $13.89 per diem thereafter) Attorney's Fee Late Charges Corporate Advance Escrow Advance $ 64,388.34 $ 2,065.28 $ 1,300.00 $ 146.14 $ 299.50 $ 1,258.77 GRAND TOTAL $ 69,458.03 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 $69,458.03, together with interest at the rate of $13.89 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISB BY: CONWAY,P.C. Attorneys forTlaintiff TERRENCE J. McC E, E UIRE MARC S. WEISB G, E UIRE EDWARD D. CON , ESQUIRE MARGARET GAIRO, ESQUIRE FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI SPIVAK, 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. WEISI3gYG>AND CONWAY,P.C. BY: `/ Attorneys for Plaintiff TERRENCE J. McCABE, ES E MARC S. WEISBERG, ES DIRE EDWARD D. CONWAY, MARGARET GAIRO, ESQUIRE FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI SPIVAK, ESQUIRE (Page 19 of 20) E x h'l'b'l't A ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. i i Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~ti,,~atr a~ 4urtr~~,~,~~~~ ~~ z=z ~FFF~4E~=~-? c.~HRIPF ()F fi€~E~~ D-O~FfCE ~ ~~~~~~~~A~~' ~~1(l ~~T I $ F,~f t ~ 23 ~;~r~>~nCf~~Ai~1t~ ~t7~TY HSBC Mortgage Corporation (USA) vs. Case Number Angela M. Orchowski 2010-5944 SHERIFF'S RETURN OF SERVICE 10/14/2010 08:42 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 14, 2010 at 2042 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Angela M. Orchowski, by making known unto herself personally, at 235 Pine Grove Road, Gardners, Cumberland County, Pennsylvania 17324 its ntents and at the same time handing to her personally the said true and correct copy of the same. AWN UT LL, DEPU SHERIFF COST: $57.70 October 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;ci CountySuite Sherff, Teleosoft. Inc. ^ a '~ W~pr~xt dC~~u,re~~yr F~o~r. Protho}}notpry Use Onlly.,: ' ,,. ~ .w w ~w. W ~ y , y. h _ 4 pF~ , .,L '<i*CJ 6 f 'F ~Tv F *~~ '~.~s r.= s3 w i a -~~ keY ,~~ f a> , ~"f'+ ( r The information collected on this form is used solely jor court administration purposes. This form does not .cunnlement nr replace the ~IInQ nru~l.cervice nf'nlendinvc nr nthor nnnvrc nc remiirod by Imu nr r:iloc nl'rmirJ ;~.;. 5=~' ~,. E;., T ~: ,,~,:_ p, O: N._.- A Commencement of Action: ® Complaint ^ Writ of Summons ^ Petition ^ Notice of Appeal ^ Transfer from Another Jurisdiction Lead Plaintiff's Name: HSBG Mortgage Corporation (USA) Lead Defendant's Name: Angela M. Orchowski ^ Check here if you fire aSelf-Represented (Pro Se) Litigant Name of Plaintiff/Appellant's Attorney: McCabe. Weisbere and Conwav. P.C. Are money damages requested? : ^ Yes ~No Dollar Amount Requested: within arbitration limits (Check one) outside arbitration limits Is this a Class Action Suit? ^ Yes ® No Nature otthe Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider-most important.: ~~ TORT (do not include Mass Tort) ^ Intentional ^ Malicious Prosecution ^ Motor Vehicle ^ Nuisance ^ Premises Liability ^ Product Liability (does not include mass tort) S n Slander/Libel/ Defamation ' E: ' ^ Other: C,:.. : ° T I' ; ; O ~ ^ Asbestos N ^ Tobacco ^ Toxic Tort -DES B ^ Toxic Tort -Implant ^ Toxic Waste ^ Other: __ PROFESSIONAL LIABLITY ^ Dental ^ Legal ^ Medical ^ Other Professional: CONTRACT (do not include Judgments) CIVIL APPEALS ^ Buyer Plaintiff Administrative Agencies ^ Debt Collection: Credit Card ^ Board of Assessment ^ Debt Collection: Other ^ Board of Elections ^ Dept. of Transportation ^ Zoning Board ^ Statutory Appeal: Other ^ Employment Dispute: Discrimination ^ Employment Dispute: Other Judicial Appeals ^ MDJ - Landlord/Tenant ^ MDJ -Money Judgment ^ Other: ^ Other: MISCELLANEOUS ^ Common Law/Statutory Arbitration ^ Declaratory Judgment ^ Mandamus ^ Non-Domestic Relations Restraining Order ^ Quo Warranto ^ Replevin ^ Other: P~elt~~+~-1~~~1E^I~~a F'~ ~ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff 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 SPIVAK, ESQUIRE - ID # 74770 t "m~ South Broad Street, Suite 2080 t~kus~~ar~i~~~~hia, Pennsylvania 19109 ~+; ; 9tp-Y 010 1-f~~~st~' aior~gage Corporation (USA) Cumberland County ~'~~ ~~~ ~~a9den Avenue Court of Common Pleas- <a:. ; , Ty e v~~ York 14043 v. ~`~.: e <;~~ 4 a t~rl. Orchowski a ~ ~'inc Grove Road ~:~~R~;i:~nson, Pennsylvania 17324 Number ~~ ~~y4 ~CV ~ i'~~ CML ACTION/MORTGAGE FORECLOSURE ntu~ cc~ r~~~ ~~'_ ~ _ atCa~+rN..Pa. 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 ifyou 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. Cusni~c.~~land County Bar Association Court administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800)990-9108 AVISO Le hen demandado a usted en la corte. Si usted quiere defenderse de ester demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace fella asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defenses 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 lodes las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPU50 ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON TNFORMATION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN H.ONORARIO REDUCED"O NI NINGUN HONORARIO. Cumberland County Bar Association Court Administrator 2 Liberty Avenue 111-117 Baltimore Street Carlisle, Pennsylvania 17013 (800)990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is HSBC Mortgage Corporation (USA), a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Angela M. Orchowski, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 235 Pine Grove Road, Dickinson, Pennsylvania 17324. 3. On July 24, 2007, Angela M. Orchowski made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for HSBC ?~~lortgage Corporation (USA) which mortgage is recorded in the Office of the Recorder of Cumberland county in Instrument 200730002. =1. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration ~vsteins, ]nc., as nominee for HSBC Mortgage Corporation (USA) to HSBC Mortgage Corporation (USA), ~~~, ~ ++_n~nent of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland ~"ounty. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 235 Pine Grove Road, Dickinson, Pennsylvania 17324. 5. The mortgage is in default because monthly payments of principal and interest upon said rs E ~rtgage due May 1, 2010 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. 7. The following amounts are due on the mortgage: Principal Balance $ 64,388.34 Interest through August 28, 2010 $ 2,065.28 (Plus $13.89 per diem thereafter) Attorney's Fee $ 1,300.00 Late Charges $ 146.14 Corporate Advance $ 299.50 Escrow Advance $ 1,258.77 GRAND TOTAL $ 69,458.03 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 °;, i°P; a ;;et-tificate of mailing and by certified mail, return receipt requested. W'l1EREFORE, Plaintiff demands an in rem Judgment against the Defendant in the sum of +:; ~q.4 ~ ~ .03, together with interest at the rate of $13.89 per diem and other costs and charges collectible under., :ire trs:~rtgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBER~i~fi' D CONWAY,P.C. BY: Q MARGARET GAIRO, ESQUIRE FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI SPIVAK, ESQUIRE TERRENCE J. McC E, E UIRE MARC S. WEISB G, E UIRE EDWARD D. CON ES UIRE 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, CONWAY,P.C. BY:~~_ / Attorneys for Plaintiff TERRENCE J. McCABE, ES MARC S. WEISBERG, ES DIRE EDWARD D. CONWAY, MARGARET GAIRO, ESQUIRE FRANK DUB]N, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI SPIVAK, ESQUIRE i (Page 19 of 20) ~ ~ hibit A ALL THAT CERTAIN lot of ground with the buildings and. improvements I' ~ thereon erected situated at Toland in the Townshi of Dicki n unt f p nso , Co y o Cumberland, Nennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as mazked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. Exhibit "A" 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 Corporation (USA) Plaintiff V. Angela M. Orchowski Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5944 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: W r ? r M i F? w ¢.. 7 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 08/29/10 to 11/16/10 Total $ 69,458.03 $ 1,111.20 $ 70,569.23 ar? ?- ? W TERRENCE J. McCABE, ESQUERI% MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff AND NOW, this ?ay of , 2010, Judgment is entered in favor of Plaintiff, HSBC Mortgage Corporation (USA), and against Defendant, Angela M.Orchowski, and damages are assessed in the amount of $70,569.23, plus interest and costs. BY THE PROTHONOTARY: ?? 160 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 Corporation (USA) Plaintiff V. Angela M.Orchowski Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5944 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Angela M.Orchowski, 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, Angela M.Orchowski, is over eighteen (18) years of age, and reside as follows: Angela M. Orchowski 235 Pine Grove Road Dickinson, Pennsylvania 17324 SWORN AND SUBSCRIBED BEFORE ME THIS _15" _ DAY OF November-, 2010 . RyAl ARY LI QUMM0N WEALTH OF PENNSYLVANIA TE NCE J. McCABE, ES IRE MARC S. WEISBERG, ESQ IRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff NOTARIAL SEAL STACEY M. O'CONNELL, Notary pubic City of ia, Phis. Courdy My Common Eow July 10, 2012 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 Corporation (USA) Plaintiff V. Angela M. Orchowski Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5944 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 15" _ DAY OF November-, 2010 1 4dTA-RY P LIC [:,R,;NC`TAPJAL TE NCE J. MCCABE, ESQUiR? MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 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 unworn falsification to authorities. TERRENCE J. McCAB , ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff C--, j(D (D2 OFFICE OF THE PROTHONOTARY p COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary November 4, 2010 To: Angela M.Orchowski 235 Pine Grove Road ?-- Dickinson, Pennsylvania 17324 HSBC Mortgage Corporation (USA) Cumberland County vs. Court of Common Pleas Angela M.Orchowski Number 10-5944 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 VWITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT AHEARINO ANDYOU MAYLOSEYOURPROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOURLAWYERAT ONCE. IF YOU DO NOT HAVE A LAWYER, .00 TO.QR TEWHOM THE OFFICKSET' FORTH BELOW. THIS OFFIC9.CAN PROVIDE. YOU WITH.INFORMAT O14-MOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIREA LAWYER, THIS OFFICE MAYBE ABLE TOFRQVMYQUWtMMFORMATIONABO,UrPGEN.CIFS'I•t1 tMAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO PEE. Cumbedand County Bar Association Court Administrator 2 Liberty Avenue 111.117 Baltimore Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIf ACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMSN E O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NIICESIDAD DE COMPARECER USTED EN CORTE U 01R PREUBA ALGUNA, DICTAR . SENTENCIA EN SU COifMYUSMPODRIAPERDERBBsM U aMOS DEREOHOS•IMPORTANIES: LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIM A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPVSO ABA10. )WA OFICINA LO PUEDE PROPORCIONAR CON WORMAC16N ACERCA DE P.MPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCJONAR PARR EMPLEAR UN AwGADO, ESTA OFICINA PUEDE SER CAPAZ DE MOPORC1014ARL40 CON INFORMAC16N ACERCA DE LAS AG04CIAS QUEPUEDEN OFRECERLOS SERVICIOS LEGALES A PERSONAS ELEOIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association Court Administrator 2 Liberty Avenac 111-11 Itimore Street C c cnnsYlvania 17013 BY: TERRENCE J. McCABE, E UI MARC S. WEISBERG, ES EDWARD D. CONWAY, ES MARGARET GAIRO, ESQUIRE mmo 1 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC Mortgage Corporation (USA) V. Angela M.Orchowski FILE NO.: 10-5944 Civil Term C o 0 -i x AMOUNT DUE: $70,569.23 =rrI { M, INTEREST: from 11/17/10 > ? C $1.160.00 at $11.60 r v -0 ATTY' S COMM.: > o :X Z n .? _ ?m COSTS: rn D o 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) 235 Pine Grove Road Gardners, Pennsylvania 17324 (More fully described as attached) PRAECIPE 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 22, 2010 .0.2q.00 ?c.L A4414 57.10 - Q?.UV - h ?c 1'? .VV - ri rc .7. S C? - tr cr 140. Signature: Aa?c &44z6" Print Name: MCCA E, ISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. clot' jaea2a A-W ZrA-1 y . , V LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of the Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DAVID S. LIVELSBERGER AND CARRIE L. LIVELSBERGER, HUSBAND AND WIFE by deed dated July 24, 2007 and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County in Deed Book InstrumentNo. 200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38-2172-010 I 'F'ILED-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 GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Corporation (USA) Plaintiff V. Angela M. Orchowski Defendant 2010 NOV 29 PM 1: 51 Attorneys for Plaintiff CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5944 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: 235 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. Name and address of Owner or Reputed Owner Name Address Angela M. Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 2. Name and address of Defendant in the judgment: Name Address Angela M. Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. 5 6. 7 Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 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 Address 235 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 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 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: Sheriffs 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 Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name none 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 unworn falsification to authorities. November 22.2010 DATE - P&Z'?c TTER]iEN)ft J. McCABE, ESQUIRE MARC SVWEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of the Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DAVID S. LIVELSBERGER AND CARRIE L. LIVELSBERGER, HUSBAND AND WIFE by deed dated July 24, 2007 and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County in Deed Book InstrumentNo. 200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38-2172-010 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 Corporation (USA) Plaintiff V. Angela M. Orchowski Defendant fILED-0rFFICE Attorney0forTAM610 TNONO TA R Y 1010 NOV 29 PM 1: 51 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5944 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: Angela M. Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF )2010 - YA a r LZZ44:?X_ T E 'E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff NOTARY PUBLIC `FILED-OFFICE Or 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 GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW HSBC Mortgage Corporation (USA) V. Angela M.Orchowski Attorneys for RAMNOV 29 PM 1: 51 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5944 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Angela M.Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 Your house (real estate) at 235 Pine Grove Road, Gardners, Pennsylvania 17324 is scheduled to be sold at 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, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $70,569.23 obtained by HSBC Mortgage Corporation (USA) 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: 1. The sale will be canceled if you pay to HSBC Mortgage Corporation (USA) 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 . t LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of the Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DAVID S. LIVELSBERGER AND CARRIE L. LIVELSBERGER, HUSBAND AND WIFE by deed dated July 24, 2007 and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County in Deed Book InstrumentNo. 200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38-2172-010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5944 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE CORPORATION (USA) Plaintiff (s) From ANGELA M. ORCHOWSKI (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 $70,569.23 Interest FROM 11/17/10 $1,160.00 AT $11.60 Atty's Comm % Atty Paid $190.20 Plaintiff Paid Date: NOVEMBER 29, 2010 (Seal) REQUESTING PARTY: Name MA-AGARET GAIRO, ESQ. L.L. $.50 Due Prothy $2.00 Other Costs D vid D. Buell, Prothonotary "Jay- A???7-r -4?:) Deputy Address: MCCA.$E, WEISBERG AND COMPANY 123 S. BRAOD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Corporation (USA) Plaintiff V. Angela M.Orchowski Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5944 AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 c? f'T s ?rJ _J r l1 N C7 r '.71 ril tv The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 3rd day of January, 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 L1 }? _ DAY OF J?j r) , 2011 -"6 tkIes r, c L uGu NOTAR PUBLIC rNOTARIAL WEALTH Of PENNSYLVANIA SEAL C. Nolucci -Notary Public hiladelphia, Philadelphia County it il'""? "RIRES JAN, 05, 2014 McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff By: TERRENC . McCABE, ESQUIRE - ID # 16496 MARC S. EISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 O ?o --4 p = - ?n / VJ :xy p o r,,.f D 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC Mortgage Corporation (USA) Plaintiff V. Angela M.Orchowski Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5944 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 235 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. Name and address of Owner or Reputed Owner Name Address Angela M.Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 2. Name and address of Defendant in the judgment: Name Address Angela M.Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 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 Name and address of the last recorded holder of every mortgage of record: Name Address 5. 6 Plaintiff herein 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 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 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 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Address 235 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 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America 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 U.S. Dept. of Justice Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 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 950 Pennsylvania Avenue NW Room 4400 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. McCABE, WEISBERG & CONWAY, P.C. January 3, 2011 Attorneys for Plaintiff DATE By: nta?t &e'e? TERRENCE J. cCABE, ESQUIRE MARC S. WEI BERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET CAIRO, 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 Corporation (USA) Plaintiff V. Angela M.Orchowski Defendant DATE: January 3, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5944 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Angela M.Orchowski PROPERTY: 235 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. 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. 00 ?l O? C? A W N 1.r r ?. x ? o o x s 0 ° C" Y >.7.C77?C7 ?'"OC77 C7 o; a xbg??o o-? r? xC7?-b7C? O ,? nOC/1..' (7 8&0 Yx;tibdC?f? ° C,?Ny ?;ti v p? 7 ° n.?Cd C O V?-'?p 0 w Cq ..O A? O *0 a t 3v ??y rA A ?0? O p ?O/ b?tn C n CD tiCD O D ?? OO CK0w N Op okp?1ID 'S OOCD '..dw O p• ?°° fD.. cD ° fD C o ° o 9° d.! 0"fD ° ???' ° -• C ? ro'? ; O?OO O ?0`G O 0 "?KHd? A7 00 y? N CD1 ~ ? ?O? 0 0 ??p ?b to h < , .0 V1x ?ro?=,5 CCD.O 7Q w 0 ON - ?, V]? 0 .+O'C • ?.. 4 E3 OQ 00 aOC °,r Y z O °? C'"dO go A ? d O 91 N C w n ON „? y..-. (roD O .??, !y n n go w"' 0 N G y 00 V1 A CD N 00 . C. ,, N O r< `? :? C O n O C A . y 00 .Q A7 w p p<i O r ??;? OAS N N CD w s I A? A7 O A p7 00 O ? A N W ? fD O ? CD r. N p r-. O ° o N UN a Fn o 0 o Z7 CO T1 cjq A O O I N azo m ° t.?t I O r. y y. ? C a? A? A ? O 7 „y A b A ? C n ? A C d b fD O ? O Q b n ? A y 0 < (A. 0 N0p n WC?O 0 ro ?00 - eD = O d; (D C ^ ' .O ' A d 1.1 d . ? fD d d ~ y y' O. ° y w, a A Q+ I/ ? O d d ' A 7 eD A ? lQ A O "8 R ?• 7 eD A • R D 7 ^' a s t/1 C C' M O "Z' g O tD T?O rD O ft ? k n ? eD A W S A m. N n O m y ° O R y eD y "1 C Z ^rrQ ^ G? bw > w O ?A? R' er Z ? ,h f D ^ Vl ? C eD Vi y V1 I O > :z MeD A G fD C < A CD eD ep y .? = y? ? 3 ? y C ? N S _? N ? ? ? et > eD ft eD cm "1 00 . eD > [ O 7 R n c O O p .. O j ° ?. OO A p ° O eaD = A. . O. n. O sy O e O ° A w O eD N d > y A < `< C A C d n o ° n ° Z bC va to rA w o a y y SD rQ a 04 c c C ? e?+ W O C eD McCABE, WEISBERG AND CONWAY, P.C. BY: Andrew L. Markowitz, Esq. Attorney ID # 28009 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 HSBC MORTGAGE CORPORATION (USA) Plaintiff V. ANGELA M. ORCHOWSKI Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5944 CIVIL TERM C') C N p C? mm rn-n r -am cNa ?c rx --4o a. x c!) " C7 O R D E R -ZZ 7,11 AND NOW, this day of M v J , 2011, upon petition of plaintiff pursuant to Rule 3132 Pa. R. C. P., to vacate and set aside the Sheriff s Sale of Real Property located at 235 Pine Grove Road, Gardners, PA 17324 held on March 2, 2011, it is hereby ORDERED and DECREED that the Petition is hereby GRANTED and the said Sheriff s Sale is hereby vacated and set aside. IT IS FURTHER ORDERED that the underlying mortgage herein, recorded on August 1, 2007, as Instrument 200730002 shall remain an open and valid lien on the subject property and such mortgage shall not otherwise be affected or diminished by the sheriff's sale held on March 2, 2011, which sale is hereby ordered as vacated and set aside. Argelo- M. brehoU--'S 'iomoaaJ . luelsh , ?. VtUMb Co. Z% k ?n bah ies mw" - C? !1 3A a8 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIF'F'S OFFICE OF CUMBERLAND COUNTY ?ugr?rp/494 FILED-OFFICE OF THE PrOTHONTAa ZQII MAR 28 P11 2. C? CUMBERLA14O COUNTY FEIN` YLVANIA HSBC Mortgage Corporation (USA) vs. Case Number Angela M. Orchowski 2010-5944 SHERIFF'S RETURN OF SERVICE 01/03/2011 08:43 PM - Deputy Tim Black, 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 235 Pine Grove Road, Gardners, PA 17324, Cumberland County. 01/03/2011 08:43 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Mark S. Philips, Sr., Live in Boyfriend, who accepted as "Adult Person in Charge" for Angela M. Orchowski at 235 Pine Grove Road, Dickinson Township, Gardners, PA 17324, Cumberland County. 03/02/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA, on March 2, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Margaret Gairo, on behalf of HSBC Mortgage Corporation, (USA), being the buyer in this execution, paid to the Sheriff the sum of $ 03/28/2011 Order of Court to vacate and set aside Sheriffs Sale of Real Property dated 3/22/11 received in Sheriffs Office on 3/24/11. cab 03/28/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per Order of Court to Vacate and Set Aside dated 3/22/11 by Judge J. Wesley Oler, Jr. SHERIFF COST: $689.54 SO ANSWERS, March 28, 2011 4RON ANDERSON, SHERIFF - :_? . GAD pd. (o S_t) L.L F/'' .. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff 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 Corporation (USA) Plaintiff V. Angela M. Orchowski Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5944 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: 235 Pine Grove Road, Gardners, Pennsylvania 17324, as of the -late the Praecipe, for the Writ of Execution was filed. A copy of the description of said property being attached hereto. L Name and address of.Qwner or Reputed Owner . Name Address Angela M. Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 2. Name and address of Defendant in the judgment: Name Address Angela M. Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 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 r 4. 5 6 Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 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 Address none 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale:. . Name Address Tenants/Occupants 235 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 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 811 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 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance 8. United States of America 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 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 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 N.W. Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 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 unworn falsification to authorities. November 22, 2010 TERREN J. Mc Q CABE, ES RE DATE MARC EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff y LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of the Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DAVID S. LIVELSBERGER AND CARRIE L. LIVELSBERGER, HUSBAND AND WIFE by deed dated July 24, 2007 and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County in Deed Book InstrumentNo. 200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38-2172-010 . ?. R M McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff 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 CIVIL ACTION LAW HSBC Mortgage Corporation (USA) I COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Angela M.Orchowski Number 10-5944 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Angela M.Orchowski 235 Pine Grove Road Gardners, Pennsylvania 17324 Your house. (real. esthte)At 235 Pine Grove Road,. Gardners, Pennsylvania 17324 is. scheduled to be sold at 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, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $70,569.23 obtained by HSBC Mortgage Corporation (USA) 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: 1. The sale will be canceled if you pay to HSBC Mortgage Corporation (USA) 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. 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 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 buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of the Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which DAVID S. LIVELSBERGER AND CARRIE L. LIVELSBERGER, HUSBAND AND WIFE by deed dated July 24, 2007 and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County in Deed Book InstrumentNo. 200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38-2172-010 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 28, February 4, and February 11, 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. Li Marie Coyne, Ed' or- SWORN TO AND SUBSCRIBED before me this 11 day of February 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-5944 Civil HSBC Mortgage Corporation (USA) vs. Angela M. Orchowski Atty.: Margaret Gairo ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at To- land," entered for record in the Office of Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and condi- tions that may apply to the afore- described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which David S. Liveisberger and Carrie L. Liveisberger, husband and wife, by deed dated July 24, 2007, and recorded August 1, 2007 in the of- fice of the Recorder in and for Cum- berland County with instrument #200730001, granted and conveyed to Angela M. Orchowski in fee. TAX MAP PARCEL NUMBER: 08- 38-2172-010. 46 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 4? Zhe Patr10tWXvWS 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 Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of 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-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that -all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2010-5914 CWH Term tmBC Mortgage Corporation (USA) Vs Angela M. Orchowskl Atty: Margaret Galro ALL THAT CERTAIN lot of ground with the buildings and improvements thereon erected, situated at Toland, in the Township of Dickinson, County of Cumberland, Pennsylvania, being designated on a "Plan of Lots at Toland," entered for record in the Office of Recorder of Deeds in Plan Book 3, Page 68, which lot herein conveyed is designated on said Plan of Lots as Lot No. 10, which dimension as marked on the Plan. Together with the use of the common land between the lots and the public road, along with other lot owners. SUBJECT, HOWEVER, to such easements, restrictions, and conditions that may apply to the afore-described tract of land, recorded or unrecorded. RB5678 235 Pine Grove Road, Gardners, Pennsylvania 17324. BEING the same premises which David S. Liveisberger and Came L. Liveisberger, husband and wife, by deed dated July 24, 2007, and recorded August 1, 2007 in the office of the Recorder in and for Cumberland County with instrument #200730001, granted and conveyed to Angela M.Orchowski in fee. TAX MAP PARCEL NUMBER: 08-38- 1179J110 This ad ran on the date(s) shown below: 1128/11 : .? \,.. k.??_ ..,'r _>?<'.. to .....: t.. `1 . ?. \s 21-. l ' ? l Sworn to anc subscribed before-me this 22,/day of February, 2011 A.D. Notary Public COM MONWEALT11 OF PENNSYLVANIA Notarial Seal St;errte L. ittsner, Notary Public ewer Aaxton rwp., Dauphin County I _ WMv Commission Fx?lre5 NOv, 2 , 2011 r??mh-.r a^nnsv!vanta R{9dci ftnh if NAtarlau 2/4111 2/11/11