The URL can be used to link to this page

Home My WebLink About10-5951RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) t t: i}i i t 'n ' U1,13ERL {ND cOU 1' CMS a., IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) 2929 Walden Avenue Depew, NY 14043 V. Norman D. Kuhn 42 West South Street Carlisle, PA 17013 Civil Action Number: 10-5951 Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION Kindly substitute the verification for the above complaint which was filed on SEPTEMBER 16, 2010 with the enclosed verification. STERN AND EISENBERG BY: STEVE ^. EISENBERG, ESQ. Attorne for Plaintiff JAAngela\Praecipe to substitute verification\Cumberland\HSBC.Kuhn.09.10.doc VERIFICATION is the y__P of HSBC Mortgage Corporation (USA) and is authorized to sign this Verification on behalf of same, and states that he/she verifies the foregoing Civil Action-Mortgage Foreclosure against Norman D. Kuhn and avers the statements of fact therein contained are made subject to the penalties of I8 PA C. S. §4904 relating to the unsworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief ort a ge Corporation (USA) Kevin J Elliott DATE:cc -??' J P. Admin Services H77v.-, Loan #7357810 J:Vess\Complaints\Cumberland\Kuhn, Norman.doc SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff titttit of +,,,r,trrf?f 0;1 4,E QF'HE $-EWF S r tj nnt-} r `- ? ,4 l , ILI ?? . ?at-RL h ate i. t ? ?? S 1 (P, '? t ? Jody S Smith Chief Deputy Richard W Stewart Solicitor HSBC Mortgage Corporation (USA) V& Norman D. Kuhn Case Number 2010-5951 SHERIFF'S RETURN OF SERVICE 09/22/2010 04:51 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2010 at 1651 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Norman D. Kuhn, by making known unto Crystal Russell, adult in charge at 42 W. South Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 September 23, 2010 DENNI FRY, DEPT o SO ANSWERS, RON R ANDERSON, SHERIFF %oi camtysuite Shenf}. T"eteosoft_ Inc.. RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKIN"I'OWN, PENNSYLVANIA 19046 TELEPHONE: (215)572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) ~~ E-~'.~ ; ~1W ~~~r .'i t i . r/ ~// } j ~ V + ~ 1 ti ~/ FI F~ 1 I~~l 1 ~fl IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhn Civil Action Number: 10-5951 Civil Term Defendant(s) MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Norman D. Kuhn, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE .......................................................$105,366.78 INTEREST accrued thru 09/03/2010 of ...............................$6,286.80 Interest after 09/03/2010 shall accrue at the per diem rate of $18.60.) LATE CHARGES accrued thru 09/03/2010 of .....................$333.72 Late charges after 09/03/2010 shall accrue at the monthly rate of $37.08.) ESCROW ADVANCES ........................................................$2,520.82 ~ t~,op Pap1'Y`I CL~a2131o(0 1~~i~ee Ma~-~ J:\Supriya\Sales\Cumberland\IiSBC.Kuhn.10.10. doc FEES BILLED .......................................................................$125.00 LEGAL COSTS .....................................................................300.00 ATTORNEY'S FEE ..............................................................$5,300.00 Sub-Total Through Date of Complaint ............................$120,233.12 ACCRUED INTEREST after 09/03/2010 shall accrue at the per diem rate of $18.60 to October 27, 2010 ........................................$1,004.40 ACCRUED LATE CHARGES Late charges after 09/03/2010 accruing at the monthly rate of $37.08 through October 27, 2010 ..........................................$74.16 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT ................................................................ ,311.68 STERN AND EISE~BERG LLP BY: RICHA F. STERN, ESQUIRE STEVE K. EISENBERG, ESQUIRE KEV P. DISKIN, ESQUIRE Date: October 27, 2010 Attorney for Plaintiff J:\Supriya\Sales\Cumberland\I-ISBC.Kuhn.10.10. doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIItE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVII.ION 261 OLD YoRx ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) Civil Action: 10-5951 Civil Term v. Norman D. Kuhn MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': Last-known address is 42 West South Street, Carlisle, PA 17013 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the Soldiers' Civil Religf Act of 1940, as amended. STERN AD,I~ EISENBERG LLP BY: SY~VEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff Sworn tosubscribed before me thi ~ 'Day of ~~ , 2010. Notary PUb11C~ EALTH OF FE.~N~ ~` '-~ MONW NO~ DANE J. TU . nh.,~.,,- „~~~ COMNIONWEAI'JH OF PENNSYLVANIA ~enklnl0`?'j0 ~' f ~' NOTARIAL SEAL ~ miys,on ExG~~' ~~ __ *lniary 4 ubt;c M Com DIANE J. TURANt, Jenkintown 6oro., ~res Ocrober 312014 M Commission Exp J:\Supriya\Sales\Cumberland\IISBC.Kuhn.10.10. doc RICHARD F. STERN, ESQUIItE STEVEN K. ELSENBERG, ESQUIItE KEVIN P. DISKIN, EsQWtE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUTTE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhn Civil Action: 10-5951 Civil Term Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten- day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. STERN ISENBERG LLP BY: S N K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya~.Sa(eslCumberland~l ISBC.Kuhn.10.10. doc STERN AND EISENBERG LLP TxE PAVILION 261 OLD YORx ROAD, SUrrE 410 JENxINTOwrr, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) (Plaintiff) Docket #: 10-5951 Civil Term v. Norman D. Kuhn TEN DAY NOTICE (Defendant(s NOTICE PURSUANT TO Pa.R.C.P. 237.1 TO: Norman D. Kuhn 42 West South Street Carlisle, PA 17013 Date of Notice: Wednesday, October 13, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIviPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 By: Attorney for Plaintiff STERN & EISE ERG, LP r' `~ ~ '°._ ,f`_ J:Vess\10 Day Letters\Cumberland\ICuhn, Norman 10.10.doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVII,ION 261 OLD YORK ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhn Defendant(s) Civil Action: 10-5951 Civil Term MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. STE EISENBERG LLP STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\IISBC.Kuhn.10. l0.doc RICHARD F. STERN, ESQUIItE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVII.ION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhn Civil Action: 10-5951 Civil Term Defendant(s) MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: HSBC 2929 Walden Avenue Depew, NY 14043 (Plaintiff) Norman D. Kuhn 42 West South Street Carlisle, PA 17013 (Defendant(s)) STERN AND,1~ISENBERG LLP STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\IISBC.Kuhn.10.10. doc r YN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ~" ~~-~~~~~~ ~~ Ts`~ ,w ; ~-~~d~T~RY PRAECIPE FOR WRIT OF EXECUTION C~ ~ ~ F.,,,,,} _ ~ ~;LLj ~; ~ ~ Caption: ( )Confessed Judgmeni~" ~ ~; " '.~°~~ ~c, -'''~ ~ Y f~ .l~ ca Yal HSBC Mortgage:. Corporation (USA) ~ (~) Other File No. 10-5951 Civil Term vs. Amount Due ~ 121.311.68 Norman D. Kuhn Interest from 10/28/10 at the per diem rate of $18.60 until judgment is paid in full. Atty's Comm Costs TO THE PROTHONOTARY OF THE 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. Issue writ of 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) Norman D. Kuhn, owner 33 Parsonage Street, Newville~ PA 1771x1 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of 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 re estate of the defendant(s) described in the attached exhibit. Bate 10/27/2010 Signature: s Steven K. Eisenberg ~a~.oc pA AT'rY Print Name: 261 o=~Te-~--~e-~ 33.¢0 CBF Address: The Pavilion Suite 410 4a.oo en n own, ~,~. ~ a,~ N ~ ~ (0 5.90 ' P~ AMY ~~a~~ Q,~ aso5~o ~a.oo Due l.o •50 LL ~~~ Attorney for: Plaintiff Telephone: (215) 572-8111 Supreme Court ID No.: 75736 (aver) ALL THAT CERTAIN lot of ground situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Parsonage Street; on the West by property formerly of Mrs. Bertie Snyder, now or formerly at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of George Way, now or formerly of Clarence P. Hollenbaugh et ux. CONTAINING forty (40) feet in front on said Parsonage Street and extending in depth one hundred eighty (180} feet to said Glebe Alley. Property commonly known as: 33 Parsonage Street, Newville, PA 17241 BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn aJk/a Norman D. Kuhn, Jr., in fee. PARCEL N0.2?-20-1754-079. J:\Supriya\Sales\CumberlandU ISBC.Kuhn. l0. l0.doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SurrE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) L~ Ti.."~. ~~~,~€~3~i~~0~~~TAR`t t~l.r i~~._..f~~_r~.ia,J ~~i IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhn Defendant(s) Civil Action: 10-5951 Civil Term MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 33 Parsonage Street, Newville, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Norman D. Kuhn 42 West South Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Norman D. Kuhn 42 West South Street Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: LVNV Funding, LLC C/o Wolpoff & Abramson, L.L.P. 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 J:\Supriya\Sales\Cumberland\IISBC.Kuhn.10. l O.doc 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 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: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 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: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 Occupant 3 3 Parsonage Street Newville, PA 17241 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. Date: October 27, 2010 STERN AND E~ENBERG LLP BY: K. EISENBERG Sworr~~fZli subscribed before me thi~ Day of ~, 2010. otary Public RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff ALTN OF PENNgYLVANIA ~ COMMONVJE N0T AR ~ ~.~ SE~A~.~, Puhiic DIANE ~~ TURA county nkintown, Monty ,tuber 31, 2014 ~D~~~grE ~ ices Oc J:\Supriya\Sales\Cumberland\HSBC.Kuhn.10.10. doc R1C11ARD F. STERN, EsQIJrRE STEVEN K. EISENBERG, ESQUIItE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUrrE 410 7ENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIIvin.E: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Norman D. Kuhri Defendant(s) Civil Action: 10-5951 Civil Term MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Norman D. Kuhn 42 West South Street Carlisle, PA 17013 Your real estate at 33 Parsonage Street, Newville, PA is scheduled to be sold at Sheriff s Sale on Wednesday, March 2, 2011 at 10:00 A.M., at Sheriff s Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $121,311.68 obtained by HSBC 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 Stern and Eisenberg, LLP the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and Eisenberg LLP, telephone (215) 572-8111. 2. You maybe 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 ar~orney 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.) J:1Supriya\Sales\Cumberland\IiSBC.Kuhn. l0. l0.doc YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN 1F THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111. 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 Stern and Eisenberg LLP, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriff s Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Supriya\Sales\Cumberland\HSBC.Kuhn.10.10. doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIIZE STERN AND EISENBERG LLP THE PAVII,ION 2b 1 OLD YoRx ROAD, SuTiE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAWTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) v. Civil Action: 10-5951 Civil Term Norman D. Kuhn Defendant(s) MORTGAGE FORECLOSURE RE• PREMISES: 33 Parsonage Street, Newville, PA Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, March 2, 2011 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $121,311.68 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. October 27, 2010 STERN AND BERG LLP BY• STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:1Supriya\Sales\Cumberland\HSBC. Kuhn.10.10. doc ALL THAT CERTAIN lot of ground situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Parsonage Street; on the West by property formerly of Mrs. Bertie Snyder, now or formerly at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of George Way, now or formerly of Clarence P. Hollenbaugh et ux. CONTAINING forty (44) feet in front on said Parsonage Street and extending in depth one hundred eighty (180) feet to said Glebe Alley. Property commonly known as: 33 Parsonage Street, Newville, PA 17241 BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn aik/a Norman D. Kuhn, Jr., in fee. PARCEL N0.27-20-1754-079. J:\Supriya\Sales\Cumberland\EISBC.Kuhn.10.10. doc WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5951 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 NORMAN D. KUHN (1) You are directed to lery 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 $121,311.68 L.L.$.50 Interest from 10/28!10 at the per diem rate of $18.60 until judgment is paid in full Atty's Comm % Due Prothy $2.00 Atty Paid $165.90 Plaintir"~ Paid Date: • 11/1/YA S` ` -- - -(Set11) REQU)r'STING PARTY: Other Costs d D. Bu 1, Prothonotary By: Deputy Name: STEVEN K. EISENBERG, ESQUIRE Address: STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 75736 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG LLP The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 HSBC Mortgage Corporation (USA) V. Norman D. Kuhn Civil Action Number: Term C-) c N n o -'? ? ' ;:O v> o C) - r- E LZ 0 ?_n 5 -t? C :)-n zc) -yc 10-595 1 Civil MORTGAGE FORECLOSURE s CERTIFICATE OF SERVICE I, STEVEN K. EISENBERG, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested on December 30, 2010. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on December 30, 2010, as evidenced by copy of certificates of mailing attached. STERN AND EISENBERG LLP BY: EN K. EISENBERG Attorney for Plaintiff 12/30/10 { 9460 E699 0000 0492 0 L 1 0 w ti c? a C7 ?+ W ? WG:d II y u CO 'ItC w zda W"dm- 21P 00307 AILED 9v i / a U' 0 a _M x 00 O a Q ca U Q M a 0 ? w ?, a U ai u ° o a U ° N ? ? o o W o U ° ° O a V a ? > N ^ Z '- ?.,• ° U a? a° o 4 ?- U cu U y . O a 3 o „ o cu t U ° U o U U o a v o o CIS N cd w 0. 9. w a w ? E? c Q U > • > o z; z a Q O H a ? ?? Y ¢z aT p N M ? v) pp pll O • -+ N M ? v) Z C ? U .a F 0. 4?vz?es post O PITNEY BOWES $ 002.10° 782 DEC 30 2010 ROM ZIP CODE 19 046 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor HSBC Mortgage Corporation (USA) vs. Norman D. Kuhn 00, r: . OFF s !''' li t sib 'y 2Ui 1 APR 11 AM 10:37 rUMBERLA2 COUNTY PEHNSYLVAMA Case Number 2010-5951 SHERIFF'S RETURN OF SERVICE 01/06/2011 11:57 AM - Deputy Shawn Gutshall, 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 33 Parsonage Street, Newville, PA 17241, Cumberland County. 01/07/2011 Timothy Black, Deputy Sheriff, 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 Crystal Russel, Girlfriend, who accepted as "Adult Person in Charge" for Norman D. Kuhn, at 42 W. South Street, Carlisle, 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 Steven Eisenberg, on behalf of HSBC Mortgage Corporation (USA), 2929 Walden Avenue, Depew, NY 14043 being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $802.76 April 08, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 'f-79- d-?:cA? • a vU ?CL - ej .70 ?CL Ilk- ek4 glg3 V Bpi Coun*.ySuite Shenft. 7eieosott. Inc. A RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP TBE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSWILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) V. Civil Action: 10-5951 Civil Term Norman D. Kuhn Defendant(s) MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 33 Parsonage Street, Newville, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Norman D. Kuhn 42 West South Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Norman D. Kuhn 42 West South Street Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: LVNV Funding, LLC C/o Wolpoff & Abramson, L.L.P. 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 J:\Supriya\Sales\Cumberland\HSBC. Kuhn.10.10. doc A 4. Name_ and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: N/A 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: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 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: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 Occupant 33 Parsonage Street Newville, PA 17241 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. Date: October 27, 2010 Swo subscribed before me thi0 T of 2010. Notary Public STERN AND FAENBERG LLP BY: -STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff OWgFALTH OF PENNSYLVANIA COMM N<TARIA! SEAL DIANE J. TURANO ' nary Puhlic mery County Jenk .ion ?cQ rfestOctober 31, 2014 J: \Supriya\Sales\Cumbedand\HS BC. Kuhn. 10. 10.doc RICHARD F. ST) RN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSUAILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) V. Civil Action: 10-5951 Civil Term Norman D. Kuhn Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Norman D. Kuhn 42 West South Street Carlisle, PA 17013 Your real estate at 33 Parsonage Street, Newville, PA is scheduled to be sold at Sheriffs Sale on Wednesday, March 2, 2011 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $121,311.68 obtained by HSBC 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 Stern and Eisenberg, LLP the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and Eisenberg LLP, telephone (215) 572-8111. 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.) J:\Supriya\Sales\Cumberland\HSBC.Kuhn.10.10.doc 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111. 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 Stern and Eisenberg LLP, telephone (215) 572-8111. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date. 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 date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Supriya\Sales\Cumberland\HSBC.Kuhn.10.10. doc RICHARD F. STERN, Es6UIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FAcsiNIILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Mortgage Corporation (USA) V. Civil Action: 10-5951 Civil Term Norman D. Kuhn Defendant(s) MORTGAGE FORECLOSURE RE: PREMISES: 33 Parsonage Street, Newville, PA Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, March 2, 2011 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $121,311.68 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. October 27, 2010 STERN AND BERG LLP BY• STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC.Kuhn. 10. 10.doc ALL THAT CERTAIN lot of ground situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Parsonage Street; on the West by property formerly of Mrs. Bertie Snyder, now or formerly at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of George Way, now or formerly of Clarence P. Hollenbaugh et ux. CONTAINING forty (40) feet in front on said Parsonage Street and extending in depth one hundred eighty (180) feet to said Glebe Alley. Property commonly known as: 33 Parsonage Street, Newville, PA 17241 BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn a/k/a Norman D. Kuhn, Jr., in fee. PARCEL NO. 27-20-1754-079. J:\Supriya\Sales\Cumberland\HSBC.Kuhn.10.10. doc ALL THAT CERTAIN lot of ground situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Parsonage Street; on the West by property formerly of Mrs. Bertie Snyder, now or formerly at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of George Way, now or formerly of Clarence P. Hollenbaugh et ux. CONTAINING forty (40) feet in front on said Parsonage Street and extending in depth one hundred eighty (180) feet to said Glebe Alley. Property commonly known as: 33 Parsonage Street, Newville, PA 17241 BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn a/k/a Norman D. Kuhn, Jr., in fee. PARCEL NO. 27-20-1754-079. J: \Supriya\Sales\Cumberland\HSBC.Kuhn.10.10.doc • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-5951 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE CORPORATION, USA, Plaintiff (s) From NORMAN D. KUHN (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 u, fo, the account of the defendant (s) and from delivei ing any property of the defendattt (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 $121,311.68 L.L.$.50 Interest from 10/28/10 at the per diem rate of $18.60 until judgment is paid in full Atty's Comm % Due Prothy $2.00 Arty Paid $165.90 Other Costs Plaintiff Paid Date: 11/1/10 . 4Dd David D. Buell, Pr thonotary (Seal) By: Deputy REQUESTING PARTY: Name: STEVEN K. EISENBERG, ESQUIRE Address: STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-572-8111 TRUE COPY FROM RECORD In Tbaftony Mweot, I has onto set my hand 74 #* Md at saki' Court at cwflaa, 8a. ca- L/. Proftno" I"- Supreme Court ID No. 75736 On November 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA, Known and numbered as 33 Parsonage Street, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 22, 2010 By: um,t -- (R?, / Real Estate Coordinator 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. e isa Marie Coy e, Editor SWORN TO AND SUBSCRIBED before me this da of February Notary NOTARIAL EA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-5951 Civil HSBC Mortgage Corporation (USA) VS. Norman D. Kuhn Atty.: Steven Eisenberg ALL THAT CERTAIN lot of ground situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Par- sonage Street; on the West by prop- erty formerly of Mrs. Bertie Snyder, now or formerly at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of George Way, now or formerly of Clarence P. Hollenbaugh et ux. CONTAINING forty (40) feet in front on said Parsonage Street and extending in depth one hundred eighty (180) feet to said Glebe Alley. Property commonly known as: 33 Parsonage Street, Newville, PA 17241 BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn a/k/a Norman D. Kuhn, Jr., in fee. PARCEL NO. 27-20-1754-079. 33 The Patriot-News Co. 2020 Technology Pkwy • Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c?,c hpatriot4ews Now you know 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. Pt1Rt ICATION COPY This ad ran on the date(s) shown below: 2010.5951 Clvll Term HS13C Mortgage Corporation 1128/11 (USA) Vs 2/4/11 Norman D. Kuhn 2/11/11 Atty: Steven Eisenberg ALL THAT CERTAIN lot of ground situate in the Borough of Newville Cumberland E { , County, Pennsylvania, bounded and described as follows: BEGINNING on the South by Parsonage t b f l St t th W t 2011 A D to`anO subscribed berme me this 22 day Of February Sworn ; on es y proper ormer y ree e y of Mrs. Berrie Snyder, now or formerly . . , . . \ f at Steven L. Gordon et ux; on the North by Glebe Alley, formerly Chapel Alley; and on the East by property formerly of ?? - - - Notar Public George Way, now or formerly of Clarence y P. Hollenbaugh et us. CONTAINING forty (40) feet in front COMMONWEALTH OF PENNSYLVANIA on said Parsonage Street and extending in ( Notarial Seal depth one hundred eighty (180) feet to said ! Sherrie L Klsrw, Notary Public Glebe Alley. ` older Paxton Twp., Dauphin County Property commonly known as: 33 Parsonage i M Commission Expires Nov. 26, 2011 Street, Newville, PA 17241 Mem'er Pennsv!wanla Association of Notaries BEING the same premises which Susan A. Colorado by Deed dated March 4, 2010 and recorded March 16, 2010 in the Office of the Recorder of Deeds in and for Cumberland County as Instrument Number 201006592, granted and conveyed unto Norman D. Kuhn a/k/a Norman D. Kuhn, Jr., in fee. PARCEL NO.27-20-1754-079. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which HSBC Mortgage Corp (USA) is the grantee the same having been sold to said grantee on the 2nd day of March A.D., 2011, under and by virtue of a writ Execution issued on the 1 st day of November, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 5951, at the suit of HSBC Mortgage Corp (USA) against Norman D Kuhn is duly recorded as Instrument Number 201110688. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D.? h Recorder of Deeds NVCamal "ErisMhoFAM1W"djM2M