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Home My WebLink About10-6341SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~ d~-~~-fir d' d~~ Sheriff t ~~ ~ ~ ~ ; ~ , ~. ~ , , ~~~~,-, o~ ~U21~1ip~~~~ Jody S Smith ~~ ~~ ~~`~'~~' _~ ~~ d ~ F d Chief Deputy - Richard W Stewart ' ~~-)4~~~_!~d_~-~'.~~~ 3 f;i~?;j~~ j ' Solicitor , n ._ - ~.~c.~a c~~F E ,.:.:._ ,. ~~~~r ~° c ~ , ~.° ~, • ~ a ,„. Citimortgage, Inc Case Number vs. 2010-6341 James F. Paroda, II (et al.) SHERIFF'S RETURN OF SERVICE 10/25/2010 08:08 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2010 at 2008 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Cathy C. Bachert, by making known unto herself personally, at 217 W. Locust Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. AMANDA COBAUGH, DEPU 10/29/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: James F. Paroda II, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant James F. Paroda II. Deputies were advised James F. Paroda II does not reside at 217 W. Locust Street, Enola, PA 17025. However, The Enola Postmaster is still delivering his mail to this address. SHERIFF COST: $89.50 October 29, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF ,cr Coi.m•;Sui[F Sheriff. Te!eosoft l«c Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Plaintiff vs. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : CUMBERLAND COUNTY JAMES F. PARODA, II No. 10-6341-CIVIL TERM CATHY C. BACHERT THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE 1w OLW,j ?, a TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. & SCHMIEG, LLP - . By: I I Lawrence T. Phe sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 dith T. Romano, Esq., Id. No. 58745 Veetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff Date: November 9, 2010 /arm, Svc Dept. File# 248231 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND. COUNTY ILED-OFFICE. C"r THE PR0TH"N0TIAI%" c10 DEC 10 PM 1C3 C UMBERLAP,@ CIDLl! Y PENN5YL` A11141;'111 Citimortgage, Inc vs. James F. Paroda, II (et al.) Case Number 2010-6341 SHERIFF'S RETURN OF SERVICE 12/08/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: James F. Paroda II, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant James F. Paroda II. Request for service at 425 S. York Street, Mechanicsburg, Pennsylvania 17055 does not exist. SHERIFF COST: $55.50 SO ANSWERS, December 08, 2010 RONNY R ANDERSON, SHERIFF FILED-OFFICE OF TIFF PROTHONOTARY 2010 DEC 21 PM 1: 06 "UMBERLAND COUN" PENNSYLVANIA Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. : Plaintiff vs. JAMES F. PARODA, II CATHY C.13ACHERT ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY : No. 10-634 1 -CIVIL TERM THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE Ea Alk TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHU,AN HALLINAN & SCHMIEG, LLP By: (/ylt "V?VVLVV V - - ? Lawrence 't'. Phelan, ?sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff Date: December 20, 2010 /arm, Svc Dept. File# 248231 s PLAINTIFF CITIMORTGAGE, INC. AFFIDAVIT OF SERVICE (FNMA) CUMBERLAND COUNTY DEFENDANT JAMES F. PARODA, II CATHY C. BACHERT THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA AT: MAIN JUSTICE BUILDING 950 PENNSYLVANIA AVENUE, N.W. WASHINGTON, DC 20530 PHS # 248231 C -C7 Z rw t? wm-1 -z" SERVICE TEAM/ arm Zrm>? o -y ? `,rl COURT NO.: 10-6341-CIVIL TEI r. c`? -.D r ; ' - 3 U a° TYPE OF ACTION CZ) XX Mortgage Foreclosure m, XX Civil Action C'' SERVED Served and made known to THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA , Defendant on the I=y/$ay of ND QQ . , 20LL)-, at 12--0 o'clock *.,M., at 1AA? fls } Oc , in the manner described below: - Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). t- Agent or person in charge of Defendant's office or usual place of business. /Pos/EL7 MIZ /19-S,. C4-6-?1Z an officer of said Defendant's company. Other: Description: Age a Height 10 U Weight /(a 6 Race Sex M_ Other a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. -a...au__ Sworn to and subsc 'bed before me this day of 20jQ. No W , By: • aEd NDi7J?1N ~ NOT SERVED the f , 20 , at o'clock M., Defendant NOT FOUN se. *Pa:? _ Vacan _ Does Not Exist _ Moved _ Does Not Reside, S? No Answer on at at IAt. Service Refused Other: Sworn to and subscribed before me this day of By: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mukahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalank P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courlenay R. Dunn, Esq., Id. No. 206779 Andrew C. Br aublett, Fsq., Id. No. 208375 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103.1814 (215)563.7000 SHERIFF'S OFFICE OF CUMBERLAND COUNTY, Ronny R Anderson ?- w Sheriff Jody S Smith ?IA Chief Deputy 2?,0 C,13 Richard W Stewart Solicitor Citimortgage, Inc Case Number vs. 2010-6341 James F. Paroda, II (et al.) SHERIFF'S RETURN OF SERVICE 12/22/2010 06:35 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 22, 2010 at 1835 hours, he served a true copy of the within Compla' t 'n Mortgage Foreclosure, upon the within named defendant, to wit: James F. Paroda II, by a ing known unto himself personally, at 426 S. York Street, Mechanicsburg, Cumberland Count /?e n ylv nia 17055 its contents and at the same time handing to him personally the said true and corr?ct? of a same. WN HARM-SON, DEPUTY SHERIFF COST: $37.00 December 27, 2010 SO ANSWERS, RON Y R ANDERSON, SHERIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-6341 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE INC. Plaintiff (s) From JAMES F. PARODA, II and CATHY C. BACHERT (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 $152,042.48 L.L.$.50 Interest FROM 01/27/2011 to Date of Sale ($24.99 per diem) Atty's Comm % Due Prothy $2.00 Atty Paid $:3Tq. 50 Plaintiff Paid Date: 2/23/11 (Seal). Other Costs David D. Bu , Prothonot -(? 2 ??' 'o P Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CITIMORTGAGE, INC. Plaintiff v JAMES F. PARODA, II CATHY C. BACHERT Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due D Interest from 01/27/2011 to Date of Sale ($24.99 per diem) TOTAL ga.oo "? 16 , (gyp tt ?i lo? av k? 4. Do S 5. bO 1.50 Stu it sv. so 'pd a Note: Please attach description of property. PHS # 248231 ? a.oo due L`o. & sgc?? Ct* )0!5 COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-6341-CIVIL TERM CUMBERLAND COUNTY Zrn ? art-` ir N cJ c s ,. ?C3 $152,042.48 5_? C) CD -rl $3.148..4 01 $155,191.22 Attorney for Plaintiff Phelan Hallinan-L-E awrence T. Phelan, Esq., Id. No. 2227 ? Francis S. Hallinan, Esq., Id. No. 695 ? Daniel G. Schmieg, Esq., Id. No 62205 ? Michele M. Bradford, Esq., Id: o. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 20233 i ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courte y R. Dunn, Esq., Id. No. 206779 ew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 IZ if X55692 s .l ssue?l n.+ &? 12 v ° .o W o w c? ? p?Q ?Ha FN H?o Q?c7 A in ` R ai 0<0 ? ? ? Oo U < 3 cz:?¢ UvFi? T ? U W a O O N to to '.OD C? O\ ON t- pp W NO\O?,r,[? M CI?pO? V1 I? U (NI ?ON?O ,, C?[-M QI (r] MNN I??t- O??f ,app h? z W lei ?? C? OMN t_- tyN GO O N z o?0 0? N ,r O C O Z O M W Qti O d z o adz-d?b ZZZ0 %O o`°ozbWbb?zb U u N? V;4 ;E! ° o'2 duo ry".6"-0 O ?W_ ° „ ww-ow•°N'?? ° ?'w:?ww ? °"w eat 8-5 O a ? aU ? W ° ?v????aA?'w o?•a ?C7 `? rw v ao, U Oa ?y A `'" a?x 0 c 45 - +4 U ti u a w ???????????????? ? CIT4MORTGAGE, INC. Plaintiff V. JAMES F. PARODA, II CATHY C. BACHERT Defendant(s) FILED-OFFICE ,? ti OF THE PROTHONOTAR 2041 FEB 23 AM I I *-G6 CUPENNSYLVAN A T COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-6341-CIVIL TERM CUMBERLAND COUNTY PHS # 248231 AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 217 WEST LOCUST STREET, ENOLA, PA 17025-3042. Name and address of Owner(s) or reputed Owner(s): Name JAMES F. PARODA, II CATHY C. BACHERT 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 426 SOUTH YORK STREET MECHANICSBURG, PA 17055-6406 217 WEST LOCUST STREET ENOLA, PA 17025-3042 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) LOCUST WOODS HOMEOWNERS ASSOCIATION LOCUST WOODS HOMEOWNERS ASSOCIATION C/O DAVID A. FITZSIMONS, ESQ. LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS, ESQ. LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS, ESQ. CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. C/O BURTON NEIL, ESQ. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 340 EAST PENN DRIVE, P.O. BOX 212 ENOLA, PA 17025 10 EAST HIGH STREET CARLISLE, PA 17013 10 EAST HIGH STREET CARLISLE, PA 17013 213 MARKET ST 3RD FL HARRISBURG, PA 17101 701 EAST 60TH STREET NORTH SIOUX FALLS, SD 57117 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 4. ;lame and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JANUS REAL ESTATE ASSOCIATION, LLC 2301 CLARIDGE COURT ENOLA, PA 17025 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) DEPARTMENT OF THE TREASURY - Internal ROAD 808,1000 Liberty Avenue Revenue Service, PITTSBURGH OFFICE Pittsburgh, PA 15222 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA JAMES F. PARODA, H & CATHY C. BACHERT C/O NATHAN C. WOLF, ESQ. LOCUST WOODS HOMES I verify that the statements made in this affidavit are true and correct to the best of my statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unpworn-l Date: t 217 WEST LOCUST STREET ENOLA, PA 17025-3042 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 10 WEST HIGH STREET CARLISLE, PA 17013 340 E. PENN DR. P.O. BOX 212 ENOLA, PA 17025 By: information and belief. I understand that false ,PINTan Hallinan & Sc mieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 6220 ? Michele M. Bradford, Esq., Id. No. 849 ? Judith T. Romano, Esq., Id. No,.52 745 ? Sheetal R. Shah-Jani, Esq., ld.' No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? w C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 CITIMORTGAGE, INC. HUED-O a O R'1 : COURT OF COMMON PLEAS 3 l : G Plaintiff CIVIL DIVISION 't 11FEB2 VS. ,U??$ERL ptMO C A1\( NO.: 10-6341-CIVIL TERM JAMES F. PARODA, II . CATHY C. BACHERT CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JAMES F. PARODA, II CATHY C. BACHERT 426 SOUTH YORK STREET 217 WEST LOCUST STREET MECHANICSBURG, PA 17055-6406 ENOLA, PA 17025-3042 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 is scheduled to be sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $152,042.48 obtained by CITIMORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and rr-q-;onable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-6341-CIVIL TERM CITIMORTGAGE, INC. vs. JAMES F. PARODA, II CATHY C. BACHERT owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being (Municipality) 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 Parcel No. 09-16-1051-037-UB3 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $152,042.48 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL that certain Unit, being Unit No. B-3 (the 'Unit'), of Locust Woods, A Condominium (the 'Condominium'), located in East Pennsboro Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium for Locust Woods, a Condominium (the 'Declaration'), dated June 19, 2002 recorded June 21, 2002, in the Office of the Recorder of Deeds Cumberland County, Pennsylvania, in Miscellaneous Book 688, Page 655, as amended by First Amendment to Declaration dated August 21, 2002 recorded August 30, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 689, Page 4396, as further amended by Second Amendment to Declaration dated October 24, 2002 recorded October 25, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 691, Page 1417, and as shown on the Plats and Plans attached to the Second Amendment to Declaration as Exhibit D-2. Said Unit having a street address of 217 West Locust Street, Enola, Pennsylvania. '? FOGETHER with an undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the Declaration, as the same may be amended from time to time. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herewith, pursuant to the Declaration and the Plat and Plans, as amended from time to time. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. TITLE TO SAID PREMISES IS VESTED IN James F. Paroda, II, single person and Cathy C. Bachert, single person, as joint tenants with the right of survivorship, by Deed from James F. Paroda, II, single person, dated 12/30/2004, recorded 03/03/2005 in Book 267, Page 4019. PREMISES BEING: 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 PARCEL NO.09-16-1051-037-UB3 LEGAL DESCRIPTION ALL that certain Unit, being Unit No. B-3 (the 'Unit'), of Locust Woods, A Condominium (the 'Condominium'), located in East Pennsboro Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium for Locust Woods, a Condominium (the 'Declaration'), dated June 19, 2002 recorded June 21, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 688, Page 655, as amended by First Amendment to Declaration dated August 21, 2002 recorded August 30, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 689, Page 4396, as further amended by Second Amendment to Declaration dated October 24, 2002 recorded October 25, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 691, Page 1417, and as shown on the Plats and Plans attached to the Second Amendment to Declaration as Exhibit D-2. Said Unit having a street address of 217 West Locust Street, Enola, Pennsylvania. TOGETHER with an undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the Declaration, as the same may be amended from time to time. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herewith, pursuant to the Declaration and the Plat and Plans, as amended from time to time. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. TITLE TO SAID PREMISES IS VESTED IN James F. Paroda, II, single person and Cathy C. Bachert, single person, as joint tenants with the right of survivorship, by Deed from James F. Paroda, II, single person, dated 12/30/2004, recorded 03/03/2005 in Book 267, Page 4019. PREMISES BEING: 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 PARCEL NO.09-16-1051-037-UB3 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Plaintiff V. JAMES F. PARODA, II CATHY C. BACHERT Defendant(s) iLl~0-Ol: flu or TtlE FROTHMNOTAR ,. 2311 VE6 23 011 ` 00 CUI Q SN5YLV AN'A ` PE CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 10-6341-CIVIL TERM : CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 622051" ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? A w C. Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 CITIMORTGAGE, INC., PLAINTIFF V. JAMES F. PARODA, II CATHY C. BACHERT THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY: FOR THE MIDDLE DISTRICT OF PA, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 10-6341 CIVIL TERM C c 3 ro ? ?m z? ' r- ? cn r --- ca Q ? C =-n =o a ? C= ORDER OF COURT AND NOW, this /2 day of April, 2011, a hearing on the within motion to reassess damages shall commence at 3:00 p.m., Thursday, June 16, 2011, in Courtroom Number 5, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, :saa /Allison F: lnlells, PH+S / duy?es F. FbxCC4 Albert H. Masland, J. NO, 1 P E-?OTHONOTAR 'MI I PR, 20 AV, 11: 33 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County JAMES F. PARODA, II CATHY C. BACHERT No.: 10-6341-CIVIL TERM THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendants CERTIFICATION OF SERVICE 248231 I hereby certify that a true and correct copy of the Order of Court Dated April 12, 2011, scheduling Rule Returnable on Plaintiff's Motion to Reassess Damages on June 16, 2011 at 3:00 pm was sent to the following individuals on the date indicated below. JAMES F. PARODA, II JAMES F. PARODA, II 426 SOUTH YORK STREET CATHY C. BACHERT MECHANICSBURG, PA 17055-6406 217 WEST LOCUST STREET ENOLA, PA 17025-3042 Phelan Hallinan & Schmieg, LLP q N DATE: 1 By: ? Lawrence T. P el sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 IN th T. Romano, Esq., Id. No. 58745 heetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq.., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 248231 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIMORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION JAMES F. PARODA, II = CATHY C. BACHERT No.: 10-6341-CIVIL TERM THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE ? - C;j - DISTRICT OF PA Defendant(s) T + AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 3>c-) -, COMMONWEALTH OF PENNSYLVANIA PHILADELPHIA COUNTY ) SS: =? cr _n As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Ce ' d Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exh' t "A". Date: 4-7 / I 1 ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 [ aniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 248231 a r ^c. i C C i V E -, ao a° d ? K O Ca CL w 9 '.oa'o I\ u y W z"Oo 0 6 3000diz woad a3 1VW <<oz zzead 9selat' 2 ?? 000 M z o ?ZS`ZO j AN, 0 1-2 gat rl O d ?? ppp pp •? N O O q '? h p" sa r. as W o z n ' .a a O F C a o ' ? o 0 4z ? b eQ o Q w ""W F ?? Ew '?" fY, ? ? U ? - as ?•s ? F ? 0 Arl All. 40 ? a 15 N VO 0 W F O d' W d 'PU b F a+ 0. 1 00 x a M .? h ??•" ??. ZAW ° A 04 - WO?N U f- WWo ... N OaN a. Adb`1 3 E" o o?v?.+ '° e ?zW3? H W wz? e W ? ?' A< xg°? ?G7. 0A~ irEg ? dad. A" ? ? w o p? V p pp ?? G9 p4 F, .? rn d o ?i °? pFp??moo IAA? .? E" W rpp?aC 04 fzc " d z c ?s z ? EEO ?r ? OoU N " " -? ?sz d ? ? U ? O -- $ z VG? oo? ti W W O -• M ??C?..U . 41 a? z .? N M et Vi ?O P 00 O? ° •r N M tl' Y1 ??70 a° a° v on d ? o ,;d ?d ?o?a co a??a t C ? y b N C/) za0 a £ o L 6 L 3Ooo cgz woa -A clmltlW w L 0Z ZZ93d 99Z , LLZbooo , Wl Zo -? y iro Qoz ? O nx ssnx pw?= + $ YY 1 1 r .. a?. 8 r8 a O O "' ? s ? eS i y I N , ? a b O O O O s s s s O d O O 0 o N W W w z W m ., w ?C v? 3 3 Fa+ as ?.. CF/JN d °/ = E •ia ?m " ; X0? war QW 00 o w c P wn o aw~ .'-: Q ? aE. A.? 0 w ° ?.? a e a.e+? ' . . pSw wi? n ° uN ? e? ?, vC °e? `o? a.,,h 'aL'? p v?Ainv M a" p??' M ??F? " M obi W o p4., v??Fn n AQ ? QG~ Q?T+"?d d ??'A ; A pOp?? ?. 'o 0 ? U a ? 0 >o a?U e,?a a o 3 '" +? ohdiL ? n >-+ udd w ? `o Y," a?''• a?d p' a v E A o O? oa; A y• O ;nd ?a A y.. 0 p;d ?G7a' E•'? ' o V' pG v?? ;, ? d 04 r?: g3 H so p d a a 22 ?.. It , , ' E A! 3 F N ? 3 ? 3m DD $ T y ? Zf?1 d30 ?z oar Y ° $ o.m M: e E w E aA•? a ?o L a ° ?'a? ?$Q MC e o °e Ad ?3•? i w 0p vEj vF ?? 00 i A? 0° U O"d'? o 'n U Uti? o ly[xs' WD `. .d, ? z? Z. N W ? Q d uo ° 00FLN??"i ?i W r i?.OaU U?U «?s OUNG? .,o ? V1 ' ? a H a a V # i*i # k i 3 U o? 6 O . •K N M ?! ? z FW w i ao a a ? o a?i ^-? PG U xw? a ?O O t •? N a? z¢o d yy8 ? 0 l6 L 3000 dl?_ W021A (131 IM aye.: 5 - „ 1402 ozad'v 99ZLLZZOOOO SjM09 A3NLk1 G r? ? E c a? 1y V H U W .• dye 1%,' 4Sod 5 = . ?D T A s G ? •v0 O' q y ? y a E v e 5p y U ?' •oo u y ,o ` '4 r a o v o . o v, 7 A O ..N. C ?j ?$ v O y V O ? „?, a °a w c.? w o ?' o ° w ? V O Y1 ? t+1 V ? s Fwa?x M Q Vi as H z z d Q ? c o o ? o 0-0 a 01 b zx ?z o? ? a .S Ed ? o ° as a 8 a „?„ a a ? '" F'o EraF„d a y wc?a W?WwWa a L:4 ? W ??? o0 v ?? ?d ? ? ti z p q ? z ? ???x ?° a a cx ? - i U y O ? v ~' a .w N M ? V1 10 l- 00 O .? N M el z rl ? 0 G4 U H o °? a F. a ai .{4' CITfMORTGAGE, INC. ` Plaintiff CATHY C. BACHERT CIVIL DIVISION V. JAMES F. PARODA, II CATHY C. BACHERT Defendant(s) CUMBERLAND COUNTY PHS # 248231 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 217 WEST LOCUST STREET, ENOLA, PA 17025-3042. Name and address of Owner(s) or reputed Owner(s): Name JAMES F. PARODA, II 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE COURT OF COMMON PLEAS NO.: 10-6341-CIVIL TERM Address (if address cannot be reasonably ascertained, please so indicate) 426 SOUTH YORK STREET MECHANICSBURG, PA 17055-6406 217 WEST LOCUST STREET ENOLA, PA 17025-3042 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) LOCUST WOODS HOMEOWNERS ASSOCIATION LOCUST WOODS HOMEOWNERS ASSOCIATION C/O DAVID A. FITZSIMONS, ESQ. LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS, ESQ. LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS, ESQ. CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. C/O BURTON NEIL, ESQ. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 340 EAST PENN DRIVE, P.O. BOX 212 ENOLA, PA 17025 10 EAST HIGH STREET CARLISLE, PA 17013 10 EAST HIGH STREET CARLISLE, PA 17013 213 MARKET ST 3RD FL HARRISBURG, PA 17101 701 EAST 60TH STREET NORTH SIOUX FALLS, SD 57117 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JANUS REAL ESTATE ASSOCIATION, LLC 2301 CLARIDGE COURT ENOLA, PA 17025 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) DEPARTMENT OF THE TREASURY - Internal Revenue Service, PITTSBURGH OFFICE ROAD 808, 1000 Liberty Avenue Pittsburgh, PA 15222 UNEMPLOYMENT COMPENSATION FUND UNEMPLOYMENT COMPENSATION FUND UI PAYMENT SERVICES L & I BUILDING, 16M FLOOR HARRISBURG, PA 17121 651 BOAS STREET, 5TH FLOOR HARRISBURG, PA 17121-0750 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 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 TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA JAMES F. PARODA, II & CATHY C. BACHERT C/O NATHAN C. WOLF, ESQ. LOCUST WOODS HOMES Address (if address cannot be reasonably ascertained, please indicate) 217 WEST LOCUST STREET ENOLA, PA 17025-3042 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 10 WEST HIGH STREET CARLISLE, PA 17013 340 E. PENN DR. P.O. BOX 212 ENOLA, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to ities. Date: ?7 u By: Attorney or Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? F cis S. Hallinan, Esq., Id. No. 62695 [iel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 C -0Z to r" L C r v -mti y J y\ Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ATTORNEY FOR PLAINTIFF CITIMORTGAGE, INC. Plaintiff Court of Common Pleas Civil Division vs. CUMBERLAND County JAMES F. PARODA, II ; CATHY C. BACHERT No.: 10-6341-CIVIL TERM THE UNITED STATES OF AMERICA CIO THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendants PRAECIPE TO WITHDRAW MOTION TO REASSESS DAMAGES TO THE PROTHONOTARY: M. =; -? r C'a lf.. `M__ Plaintiff hereby withdraws its Motion to Reassess Damages, filed on April 7, 2011 in the above referenced action. P?el H Ili & Schmieg, LLP DATE: By; Lawrence T. elan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 248231 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? W liam E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 248231 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Plaintiff vs. JAMES F. PARODA, II CATHY C. BACHERT THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-6341-CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Withdraw its Motion to Reassess Damages was served upon the following interested parties on the date indicated below. JAMES F. PARODA, II 426 SOUTH YORK STREET MECHANICSBURG, PA 17055-6406 JAMES F. PARODA, II CATHY C. BACHERT 217 WEST LOCUST STREET ENOLA, PA 17025-3042 248231 Phela Hal inan & Schmieg, LLP DATE: B : A Y ence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 elssa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 248231 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy PPI 2: Richard W Stewart -C 'M E R L D r Solicitor P E t' S y L' iii :' x s Citimortgage, Inc vs. Case Number James F. Paroda, II (et al.) 2010-6341 SHERIFF'S RETURN OF SERVICE 03/09/2011 05:07 PM - Deputy Shawn Harrison, 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 MICHELLE CLAYTON - GIRLFRIEND, who accepted as "Adult Person in Charge" for James F. Paroda, II at 426 S. York Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 03/15/2011 04:32 PM - Deputy Ryan Burgett, 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 the Defendant, to wit: Cathy C. Bachert at 217 W. Locust Street, East Pennsboro Township, Enola, PA 17025, Cumberland County. 03/15/2011 04:32 PM - Deputy Ryan Burgett, 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 217 West Locust Street, Enola, PA 17025, Cumberland County. 06/01/2011 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, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Atty Daniel Schmieg, on behalf of Federal National Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $782.67 August 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF s? Z A-fw j & ci Gcun.ySuilc? She..`f. Iple",- inc, CalMORTGAGE, INC. Plaintiff V JAMES F. PARODA, II CATHY C. BACHERT Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-6341-CIVIL TERM CUMBERLAND COUNTY PHS # 248231 AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 217 WEST LOCUST STREET, ENOLA, PA 17025-3042. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JAMES F. PARODA, II 426 SOUTH YORK STREET MECHANICSBURG, PA 17055-6406 CATHY C. BACHERT 217 WEST LOCUST STREET ENOLA, PA 17025-3042 2• Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably SAME AS ABOVE ascertained, please so indicate) 3• Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) LOCUST WOODS HOMEOWNERS ASSOCIATION 340 EAST PENN DRIVE, P.O. BOX 212 - ENOLA, PA 17025 LOCUST WOODS HOMEOWNERS ASSOCIATION 10 EAST HIGH STREET C/O DAVID A. FITZSIMONS, ESQ. CARLISLE, PA 17013 LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS ESQ 10 EAST HIGH STREET CA , . RLISLE, PA 17013 LOCUST WOODS HOMEOWNERS ASSOCIATION C/O JACOB M. THEIS ESQ 213 MARKET ST 3RD FL H , . ARRISBURG, PA 17101 CITIBANK (SOUTH DAKOTA) N.A. 701 EAST 60TH STREET NORTH SIOUX FALLS, SD 57117 CITIBANK (SOUTH DAKOTA) N.A. C/O BURTON NEIL ESQ. 1060 ANDREW DRIVE, SUITE 170 , WEST CHESTER, PA 19380 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC 8201 GREENSBORO DRIVE, SUITE 350 , . MCLEAN, VA 22102 . ' Name and address of last recorded holder of every mortgage of record: Name + Address (if address cannot be reasonably ascertained, please indicate) JANUS REAL ESTATE ASSOCIATION, LLC 2301 CLARIDGE COURT ENOLA, PA 17025 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) DEPARTMENT OF THE TREASURY - Internal ROAD 808, 1000 Liberty Avenue Revenue Service, PITTSBURGH OFFICE Pittsburgh, PA 15222 6. Name and address of every other person who has any record interest in the property and whose interest maybe affec tf?(j a. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the properh hit,,-, may oe red by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 217 WEST LOCUST STREET ENOLA, PA 17025-3042 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA JAMES F. PARODA, II & CATHY C. BACHERT C/O NATHAN C. WOLF, ESQ. LOCUST WOODS HOMES P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 10 WEST HIGH STREET CARLISLE, PA 17013 340 E. PENN DR. P.O. BOX 212 ENOLA, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to 11$worn`I Date: By: ? *? meAtto` v..fAr•Pt'a7?? information and belief. I understand that false P t-lan Hallinan & Sc?+mieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 El Daniel G. Schmieg, Esq., Id. No. 6220 El Michele M. Bradford, Esq., Id. No. 849 ? Judith T. Romano, Esq., Id. No-, 745 ? Sheetal R. Shah-Jam, Esq., Id: No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? w C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 CITIMORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. NO.: 10-6341-CIVIL TERM JAMES F. PARODA, II CATHY C. BACHERT CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY 'I J. JAMES F. PARODA, II CATHY C. BACHERT 426 SOUTH YORK STREET 217 WEST LOCUST STREET MECHANICSBURG, PA 17055-6406 ENOLA, PA 17025-3042 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 is scheduled to be sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $152,042.48 obtained by CITIMORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-6341-CIVIL TERM CITIMORTGAGE, INC. vs. JAMES F. PARODA, II CATHY C. BACHERT owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being (Municipality) 217 WEST LOCUST STREET ENOLA PA 17025-3042 Parcel No. 09-16-1051-037-UB3 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING K( TDGMENT AMOUNT: $152,042.48 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL that certain Unit, being Unit No. B-3 (the 'Unit'), of Locust Woods, A Condominium (the 'Condominium'), located in East Pennsboro Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium for Locust Woods, a Condominium (the 'Declaration'), dated June 19, 2002 recorded June 21, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 688, Page 655, as amended by First Amendment to Declaration dated August 21, 2002 recorded August 30, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 689, Page 4396, as further amended by Second Amendment to Declaration dated October 24, 2002 recorded October 25, 2002, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 691, Page 1417, and as shown on the Plats and Plans attached to the Second Amendment to Declaration as Exhibit D-2. Said Unit having a street address of 217 West Locust Street, Enola, Pennsylvania. "TOGETHER with an undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the Declaration, as the same may be amended from time to time. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herewith, pursuant to the Declaration and the Plat and Plans, as amended from time to time. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. TITLE TO SAID PREMISES IS VESTED IN James F. Paroda, II, single person and Cathy C. Bachert, single person, as joint tenants with the right of survivorship, by Deed from James F. Paroda, II, single person, dated 12/30/2004, recorded 03/03/2005 in Book 267, Page 4019. PREMISES BEING: 217 WEST LOCUST STREET, ENOLA, PA 17025-3042 PARCEL NO. 09-16-1051-037-UB3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-6341 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE INC. Plaintiff (s) From JAMES F. PARODA, II and CATHY C. BACHERT (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 $152,042.48 L.L.$.50 Interest FROM 01/27/2011 to Date of Sale ($24.99 per diem) Atty's Comm % Due Prothy $2.00 Atty Paid S334 Sp Other Costs Plaintiff Paid Date: 2/23/11 DBu , Prothonot : !?7 (Seal) Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 TRUE COPY FROM RECORD M Testimony why W- I hero Ur4* het"h.W OW the seal of S" Court st + . p? T?-.?s?.drlvg0 ?? On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 217 West Locust Street, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate_Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-6341 Civil Citimortgage, Inc. vs. James F. Paroda, II Cathy C. Bachert Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 10-6341-CIVIL TERM, CITIMORTGAGE, INC. vs. JAMES F. PARODA, II, CATHY C. BACHERT, owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being 217 WEST LOCUST STREET, ENOLA, PA 17025-3042. Parcel No. 09-16-1051-037-UB:3. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $152,042- .48. 62 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: April 22, April 29, and May 6, 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. Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this da of May, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 1e r atriot-Mews Co. 20 20 'Technology Pkwy Suite :300 Me,.hanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Zhe?latriotNews Now you know 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. PUBLICATION COPY This ad ran on the date(s) shown below: ? ? 1Me?n 04/22/11 Oar, Me 04/29/11 vas 9 pwo" a 05/06/11 gy vute of a WJ*af ExautioO NO. -- 1(Nb6341-e1Wx'RRM - CrnMOMA? INC. Sworn to and bscribed b e th/Is 2 d of May, 2011 A. D. V& JAMFaS r PA?f RDA, II CATHY C.BACLiEW own(s)O'propaty*udeatbe Notary Public ?.. _ Cumb,1W County, pAngWama, bft 217WMT L000STSTRFE BNOLA; __'?oMMOIyW PA 17025.3042 ?'ENNSYLV,gI L4 Parcel Na 09-16-1051-037-UB3 Sherrie L. Kisser, Seal (Am w or street ad?dim) w Pd1tOn PuNk Wereon. R?ENI3AL MY Comm T"-, ? in Co n Memh°` 'buns sY 26 2ty JUDO MM AMOUNT. 515204? 48 lvanla Nov, 1 ssociation of Nees 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 Federal National Mortgage Association is the grantee the same having been sold to said grantee on the I day of June A.D., 202011, under and by virtue of a writ Execution issued on the 23 day of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6341, at the suit of CITIMORTGAGE, Inc against lames F. Paroda II and Cathy C. Bachert is duly recorded as Instrument Number 201121376. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 21 day of CIA A.D. l -dt;r of Daeds, cA c,aaorde of Dee s ;. , rrlssian Expires the Fk9 Monday of Jan. 2014