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Home My WebLink About10-6345RICHARD 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 7ENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) ~~ ~t~l£~P~~Jfl~~OPd4TAFtY' ZOIQ QCT 15 ~~ I I ~ 24 ~~~~~~lr~~ CQ~~~~ P~PsAfSYI,V~:~:1~, IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania 2929 Walden Avenue Depew, NY 14043 Civil Action Number: 10-6345 v. Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION Kindly substitute the verification for the above complaint which was filed on October 6, 2010 with the enclosed verification. STERN AND EISENBERG BY: /1 STE N K. EISENBERG, ESQ. Attorney for Plaintiff K:\Angela\Praecipe to substitute verification\Cumberland\HSBC.Stazewski.l0.l0.doc VERIFICATION is the of Beneficial Consumer Discount Company, d/b/a Bene ial Mortgage . of Pennsylvania and is authorized to sign this Verification on behalf of same, and states that he/she verifies the foregoing Civil Action-Mortgage Foreclosure against Lonnie L. Stazewski and avers the statements of fact therein contained are made subject to the penalties of 18 PA C.S. §4904 relating to the unsworn falsification to authorities, and that same are true upon the signer's personal lrnowledge or information and belief. Ole-O`--' ~/~c.~ Beneficial onsumer Discount Company, a Beneficial Mortgage Co. of Pennsylvania DATE: Loan #179648793 J:Vess\Complaints\Cumbedand\Stazewski, Lonnie.dce SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~,~~tii~r pt ~~url~~~,f~~~ ~s ',~ ~, (y~fiGE " r "~E S'"ERtFF Qti THE P~~T?~0N TgR4 Jody S Smith Chief Deputy Richard W Stewart SOllCItOr CUMBERLA~dD COUN~'`~' ~~~~~Y~4/A~l~ Beneficial Consumer Discount Company I Case Number vs. f{ 2010-6345 Lonnie L. Stazewski SHERIFF'S RETURN OF SERVICE 10/11/2010 06:29 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2010 at 1829 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lonnie L. Stazewski, by making known unto himself personally, at 175 N. Enola Road, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. AMANDA COBAUGH, PUTY SHERIFF COST: $41.50 October 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c} CountySuite Shentf. TeleosaR, Inc. RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQuntE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIhm,E: (215) 572-5025 (COUNSEL FOR PLAINTIFF) OF THE PROTONOTARY 2010 NOV 16 PM 1: 05 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Civil Action Number: 10-6345 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), Lonnie L. Stazewski, for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE .......................................................$91,607.46 INTEREST accrued thru 09/27/2010 of ...............................$5,954.42 Interest after 09/27/2010 shall accrue at the per diem rate of $28.22.) LATE CHARGES accrued thru 09/27/2010 of .....................$250.20 Late charges after 09/27/2010 shall accrue at the monthly rate of $50.08.) ESCROW ADVANCES ................................................. ?`/yad ?7c? ..$582.86 Ce, RA,-?S'1aeL Jl 4itF-rvtu? g J:\Supriya\Sales\Cumberland\HSBC. Stazewski.11.10. doe LEGAL COSTS .....................................................................300.00 ATTORNEY'S FEE ..............................................................$4,600.00 Sub-Total Through Date of Complaint ............................$103,294.94 ACCRUED INTEREST after 09/27/2010 shall accrue at the per diem rate of $28.22 to November 11, 2010 ....................................$1,269.90 ACCRUED LATE CHARGES Late charges after 09/27/2010 accruing at the monthly rate of $50.08 through November 11, 2010 ......................................$50.08 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT .................................................................$104,614.92 STERN AND EISENBERG LLP BY: CUARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Date: November 11, 2010 Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC. Stazewski.11.10. doc RICHARD F. STERN, ESQUIRE 1I.EI)`OFFICE STEVEN K. EISENBERG, ESQUIRE F " flE THE PROOFFICE AR`r KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP THEPAvILION 2010 NOV 16 PM 1: 05 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 CUMBERLAND COUNTY TELEPHONE: (215) 572-8111 PENNSYLVANIA FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania Civil Action: 10-6345 Civil Term v. Lonnie L. Stazewski Defendant(s) MORTGAGE FORECLOSURE 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 175 North Enola Road Enola, PA 17025 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 Relief Act of 1940, as amended. ,, AiApNWEALT~ OF PENN:YLV?IA L:n ?aR'a?SEAL publ'+c AN? No??ry ry Co 2014 ,res October 31, ExP STERN AN BERG LLP BY: VEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Sworn to d subscribed before me this ?Yay of JcNJ , 2010. Notary Public Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC. Stazewski.11.10. doc RICHARD F. STERN, 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) 'FILED-OFFICE OF THE PROTHONOTARY 2010 NOV 16 PM 1: 05 CU PENN YLVAN A COUNTY IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 Civil Term 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 h reto. STERN ISENBERG LLP BY: S VEN K. EISENB G RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC.Stazewski. 11. 10.doc STERN AND EISENBERG LLP THE PAVILION 26101 D 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 CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania (Plaintiff) V. Lonnie L. Stazewski Docket #: 10-6345 Civil Term TEN DAY NOTICE NOTICE PURSUANT TO Pa.R.C.P. 237. TO Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 Date of Notice: Monday, November 1, 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 IMPORTANT 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 STERN & EISENBERG, LLP By:`.. f Attorney for Plaintiff J:\Michele\10 Day Notice\Cumberland\STAZEWSKI Lonnie 1101 2010.doc RICHARD F. STERN, 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) FILED-OFFICE OF THE PROTHONOTARY 2010 NOY 16 PM 1: 05 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 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. STERN 0??E_ISENBERG LLP EVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\IISBC. Stamwski.11.10. doc RICHARD F. STERN, 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) FILED-OFFICE OF THE PROTHONOTAR? 1010 NOV 16 PM 1:05 CUMBERLASYNLDVAN COUNTY IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 Civil Term MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Beneficial 2929 Walden Avenue Depew, NY 14043 (Plaintiff) Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 (Defendant(s)) STERN BERG LLP BY: _ EVE K. EISENB ERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\IISBC.Stazewski.11.10.doe IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILED-OFFICE PRAECIPE FOR WRIT OF EXECUTION OF THE PROTHONOTARY 2010 NOV 16 PM 1:05 Caption: ( ) Confessed JudgMPkERLANO COUNTY Beneficial Consumer Discount Company, d/b/a ) Other PENNSYLVANIA Beneficial Mortgage Co. of Pennsylvania File No. 10-6345 Civil Term vs. Amount Due 104, 614.92 Lonnie L. Stazewski Interest from 11/12/2010 at the per diem rare of $28.22 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) 175 North Enola Road, Enola. PA 17085 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 agains al estate of the defendant(s) described in the attached exhibit. Date Signature: day. 00 - c_(_. 44- 9.1. a0 - <, /Y . vu -- a r r Print Name: $.2.00 Co Address: 41. X-0 kt" Attorney for: Telephone: Supreme Court ID No.: C K4 28(-36 lh` a 8,6 (over) ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. J: \Supriya\Sales\Cumberland\HSBC. Stazewski. 11. 10. doc WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6345 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, DB/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff (s) From LONNIE L. STAZEWSKI (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 $104,614.92 L.L. $.50 Interest FROM 11/12/2010 AT THE PER DIEM RATE OF $28.22 UNTIL JUDGMENT IS PAID IN FULL Atty's Comm % Due Prothy $2.00 Atty Paid Plaintiff Paid $174.00 Date: NUVEMSlr'R 16, 2010 (Seal) REQUESTING PAR'iY: Name RICHARD-F. STERN, ESQ. Address: STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Other Costs T David . Bu , Pro notary By: Deputy Telephone: 215-572-8111 Supreme Court ID No. 3315 ti RICHARD F. STERN, 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 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) FILED-OFFICE OF THE PROTHONOTARY 2010 NOV 16 PM 1: 05 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 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 175 North Enola Road, Enola, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/A 4. Name and address of the last recorded holder of every mortgage of record: J:\Supriya\Sales\Cumberland\HSBC. Stazewski. 11. 10. doc ti 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 Occupant 175 North Enola Road Enola, PA 17025 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 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: November 11 OF 00 GoM?N?a"?Np ?P?p,N? Ngp° ery 30? ??q O,pNE 9°?O "M° es p°W Je°k?n<? ?°E ic STERN AND BERG LLP B _ ST EN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Sw1d subscribed before me thi Day of 2010. Notary Public Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC. Stazewski.11.10. doc RICHARD F. STERN, ESQumE FILED-OFFICE STEVEN K. EISENBERG, ESQumE O THE PROTHONOTARY KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP 2010 NO V 16 PM 1: 06 THE PAVILION 261 OLD YORK ROAD, SurrE410 CUMBERLAND COUNTY JENKwTowN, PENNsYLvANIA 19046 PENNSYLVANIA TELEPHONE: (215) 572-8111 FACSuvflLE: (215) 572-5025 (COUNSEL FOR PLAMW) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania Civil Action: 10-6345 Civil Term V. Lonnie L. Stazewski Defendant(s) MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 Your real estate at 175 North Enola Road, Enola, 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 $104,614.92 obtained by Beneficial 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 Stem 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.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. J:\Supriya\Sales\Cumberland\HSBC.Sta xmki.11.10.doc 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 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.Stazewski.1 1. 10.doc RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG LLP TIM PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSnvME: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 Civil Term MORTGAGE FORECLOSURE RE: PREMISES: 175 Noah Enola Road, Enola, 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 $104,614.92 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 Sheriff s 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. November 11, 2010 STERN AND ISENBERG LLP BY: N K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff J:\Supriya\Sales\Cumberland\HSBC.Stazewski. 11.10.doc ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. J:1Supriya\.SaleslCumberlandMBC.Stazewslri.11.10.doc 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 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Civil Action Number: Term ('7 N D f r'1 L:J f J W 10-634 1 Ci it MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE C) rnF Urn a° C)O ? -n C :)-n o __4 _c 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 STEVEN K. EISENBERG Attorney for Plaintiff 12/30/10 r - f E m t+? Cd cd C-4 0 C) a0a 0 a?W 7a ;z z iN :a o ?m m;m ;m jino;C 'C960 E699 0000 OZ9T OTOZ It$ P%. O C 0 ce a W F ? ?aQ w ?a y C `TJ ? C ? w c F o ? V] N h ii 'LS y, ? L y Cd 'O w zQo . z 02 1 P 00030 8 „ MAILED v .? i 0 o_ M V 00 O ? N M a ° ? Q 4 a. U U 00 v O 00 N k O a l u v) o o E z _ a? U a w ? b U '? i ?Ecl O ? ? w T cn ° ? ca ? z U U U w v c k .., a o N n E m ° Q „ U a z > E k U W U z a Q F? O ? H? * -7F -)E ,?, 3F dE iF dF dE 7E iE jF * -1F ->F * * 3E dF dF -IE 3F dE jF ?" ? a? ? * * dE dE -)E * * iF dF 9F iF dF iF iE IF 3F iE dE iE iF iF iF -1F 'd * , N ¢z op E N N M ?t vl ?O I-- 00 O? O rq N M r 'IT ? vl U ? U C _U .a F 4 ri 11 PITNEY BOWES $ 001.68° 782 DEC 30 2010 FROM ZIP CODE 19046 €LED-O F1CE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COi j4AN -9 PM I: 42 CIVIL ACTION-LAW CUMBERLAND COUNTY STEVEN K. EISENBERG, ESQUIRE PENNSYLVANIA STERN AND EISENBERG I5t.0 PC The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Civil Action: 10-6345 Civil Lonnie L. Stazewski Defendant(s) MORTGAGE FORECLOSURE 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 January 6, 2012. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on January 6, 2012, as evidenced by copy of certificates of mailing attached. STERN AND EISENBERG Ian' PC 1/06/12 % o n N r, g 6 4 ? ? o I T4, W N ~ S -A: * * * * * * * * ?c o O 'q• ?N I(Z' R3?„ 0 9 N 9406 3CJ0? IZZg SL0?000 4 O Z Z LOZ 90_?O ? G oZ z .nNl{d . rn r,ftnc,9 N w c? cn ? _ ? 7? O k?1 at "O 0o A? to ca '* O+ •-d two y a ? o s o N? us o p p r•? J O ,r '''' C? ? O p9 <o j o n ? C`1 ? y ? o N CAD j v' rd O W r^` J O r-' W 110? 9 - ro? ;Ilk ,W .. ?h. _AC (Domestic Mail Only; No losurance Coverage ..0 RJ For delivery intormation visit our website at www.uspsx0m cc C F I C I A L !,f r-I m Postage $ r- Certified Fee w? f y? C3 Retum Receipt Fee `v12 rp OO (Endorsement Required) V1 Here b Restricted Delivery Fee. p (Endorsement Required) C3 LISPS 0 Total Postage & Fees ru r9 Sent To s`tmef,:ipr Wo: - P c s?.i ....................... --------- C3 r•- or PO Box No, -/7 J r f _ -/! - nQl odd cny, ware, zrw?a ----?°-_= -n o la /'fi / 7710ad 5 3800, Aucjum 0r. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?t1? at <:Uj"b(,j4"14 FIL ED -,OFF; Ci-_ iii H H,'OTHGIf j -j.1[jy 2??2lPv -4 AM c: 5 CL°MBBLAND CouN TY f t,INSYLYA,INIA Beneficial Consumer Discount Company I Case Number vs. 2010-6345 Lonnie L. Stazewski SHERIFF'S RETURN OF SERVICE 01/05/2012 06:21 PM - Deputy Michael Barrick, 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 175 North Enola Drive, Enola, Cumberland County, PA 17025. 01/05/2012 06:21 PM - Deputy Michael Barrick, 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: Lonnie L. Stazewski at 175 N. Enola Road, East Pennsboro Township, Enola, Cumberland County, PA 17025. 03/21/2012 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, Pennsylvania on March 07, 2012 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Eisenbery, on behalf of Beneficial Consumer Discount Company at 2929 Walden Avenue, Depew, New York, 14043. Beneficial Consumer Discount Company, being the buyer in this execution, paid to the Sheriff the sum of $874.84. 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. SHERIFF COST: $874.84 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 60 'j '&0 ? -2400 y_ ^,o:;rlty`iu':?6 Sheri", TeIeCSCfL 1:5. r RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) THOMAS E. SHEA, ESQUIRE (64384) JOSEPH K. REJENT, ESQUIRE (59621) STERN & EISENBERG, PC THE PAVILION 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 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Lonnie L. Stazewski Defendant(s) Civil Action: 10-6345 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 175 North Enola Road, Enola, PA. 1. Name and address of Owner(s) or Reputed Owner(s): Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: N/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 Occupant 175 North Enola Road Enola, PA 17025 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: October 13, 2011 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL l'?c DIANE J. TURANO, Notary Pub Jenkintown Boro., Montgomery County M Commission Expires October 31, 2014 STER!;EVEN & EISE BERG PC BY: K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff Sworn end subs ibe before me this Day of L , 2011. Notary Public I RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) THOMAS E. SHEA, ESQUIRE (64384) JOSEPH K. REJENT, ESQUIRE (59621) STERN & EISENBERG, PC THE PAVILION 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 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania Civil Action: 10-6345 Civil Term V. Lonnie L. Stazewski MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 Your real estate at 175 North Enola Road, Enola, PA is scheduled to be sold at Sheriffs Sale on Wednesday, March 7, 2012 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $104,614.92 obtained by Beneficial 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. I 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 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 I RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) THOMAS E. SHEA, ESQUIRE (64384) JOSEPH K. REJENT, ESQUIRE (59621) STERN & EISENBERG, PC THE PAVILION 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 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania V. Civil Action: 10-6345 Civil Term Lonnie L. Stazewski Defendant(s) MORTGAGE FORECLOSURE RE: PREMISES: 175 North Enola Road, Enola, 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 $104,614.92 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 13, 2011 STERN & ENBERG PC BY: STEVEN K. EISENBERG RICHARD F. STERN KEVIN P. DISKIN Attorney for Plaintiff A ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) THOMAS E. SHEA, ESQUIRE (64384) JOSEPH K. REJENT, ESQUIRE (59621) STERN & EISENBERG, PC THE PAVILION 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 Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania Civil Action: 10-6345 Civil Term V. Lonnie L. Stazewski MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Lonnie L. Stazewski 175 North Enola Road Enola, PA 17025 Your real estate at 175 North Enola Road, Enola, PA is scheduled to be sold at Sheriffs Sale on Wednesday, March 7, 2012 at 10:00 A.M., at Sheriff s Office, Cumberland County Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $104,614.92 obtained by Beneficial 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.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 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 ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. PARCEL NO. 09-14-0832-274A. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6345 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, d/b/a BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, Plaintiff (s) From LONNIE L. STAZEWSKI (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: $104,614.92 L.L.: Interest from 11/12/10 @ the per diem rate of $28.22 until judgment is paid in full Atty's Comm: % Atty Paid: $950.32 Plaintiff Paid: Date: 10/17/11 (Seal) REQUESTING PARTY: Due Prothy: $2.00 Other Costs: vi . Buell Prothonotary By: Deputy Name: STEVEN K. EISENBERG, ESQUIRE Address: STERN & EISENBERG, PC THE PAVILION 261 OLD YORK ROAD, SUTIE 410 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF TRUE COPY FROM RECORD In Testlrnony whereof, I here unto set my hand and tha seal of said ;t?auR st isle, Pa. This +IW?t. (? , ? protttonotary f Telephone: 215-572-8111 Supreme Court ID No. 75736 On October 27, 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, 175 Enola Road, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date October 27, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-6345 Civil Term granted and conveyed unto Lonnie L. Stazewski, Single Individual, in fee. Beneficial Consumer Discount PARCEL NO. 09-14-0832-274A. Company, d/b/a Beneficial Mortgage Co. of Pennsylvania VS. Lonnie L. Stazewski Atty.: Steven Eisenberg ALL THAT CERTAIN tract or Par- cel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured South- wardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connect- ing the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, South 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Penn- sylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, 77 a 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 27, February 3, and February 10, 2012 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, E for SWORN TO AND SUBSCRIBED before me this 0 da of Februas 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public Fr-ARLIYSLIoCARLISLE BOROUGH. CUMBERLAND COUNTY mmissionExpires Apr 28, 2014 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 t4tPatriot News 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. PUBLICATION COPY This ad ran on the date(s) shown below: 01127/12 02/03/12 02/10/12 Sworn to a su ribed b e this 24 da of ebruiry, 2012 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public Lower Paxton Twp., Dauphin county My commission F.xpkes Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 20104345 Civil Term Baneflclsl Consumer Discount Company, d/b/a Beneficial Mortgage Co. of Pennsylvania VS Lonnie L. Stazewskl Atty. Steven Eisenberg ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point in the Westerly line of Enola Road at the distance of 60 feet measured Southwardly along the Westerly line of said Enola Road from the Southerly extremity of the arc or curve connecting the Southerly side of Dauphin Street with the Westerly side of Enola Road, and extending thence along the Westerly side of the said Enola Road, 6outh 5 degrees 9 minutes 30 seconds West, 30 seconds West, 30 feet to a point at the center line of the partition wall between houses known as Nos. 173 and 175 Enola Road; thence North 84 degrees 50 minutes 30 seconds West along the centerline of said partition wall and beyond 150 feet to a point; thence North 5 degrees 9 minutes 30 seconds East, 30 feet to a point and thence South 84 degrees 50 minutes 30 seconds East, 150 feet to the Place of BEGINNING. HAVING THEREON ERECTED the Northern half of a double two story frame dwelling house, and known as No. 175 Enola Road, Enola, Pennsylvania. BEING the same premises which Robert K. Steele and Cathy A. Steele, Husband and Wife, by Deed dated March 25, 2002 and recorded April 1, 2002 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 251 Page 60, gri ted a conveyed unto Lonnie I_ Staze 1 S Ile Individual, in fee. P"CEL NO.09-14-0832-274A ehe Patriot-Xemis Now you know 2020 Technology Parkway Mechanicsburg, PA (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL 01/27/12 02/03/12 02/10/12 Of Ad Sheriff Sale 6345 7.34 $12.00 $ 88.08 Sheriff Sale 6345 7.34 $12.00 $ 88.08 Sheriff Sale 6345 7.34 $12.00 $ 88.08 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 269.24 JLC 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 Beneficial Cons Disc Co is the grantee the same having been sold to said grantee on the 7th day of March A.D., 2012, under and by virtue of a writ Execution issued on the 17th day of October, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6345, at the suit of Beneficial Cons Disc Co dba Beneficial Mtg Co of Pa against Lonnie L Stazewski is duly recorded as Instrument Number 201213207. IN TESTIMONY WHEREOF, I have ereunto set my hand and seal of said office this?_ day of A.D. QC _ Recorder of Deeds Reoo&W d DN* QVWXd t=?, CVW p? My Comrm Ww Expires the first Ivor * d den. 2014