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HomeMy WebLinkAbout10-6815SHERIFF'S OFFICE OF CUMBERLAND Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard Al Stewart Solicitor U NTY Beneficial Consumer Discount Company Case Number vs. Harry T. Shughart (et al.) 2010-681a SHERIFF'S RETURN OF SERVICE 11/02/2010 06:00 PM - William Cline, Corporal, who being duly sworn according to law; states that on November 2, 2010 at 1800 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Harry T. Shughart, by making known unto himself personally, at 132 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania 17015 its cont nts ?rSd at the same time handing to him personally the said true and correct copy of the same. ? ?f CLINE, 11/02/2010 06:00 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 2, 2010 at 1800 hours, he served a true copy of the within Complaint in Mortgage foreclosure, upon the within named defendant, to wit: Vonda L. Shughart, by making known unto Harry T. Shughart, adult in charge at 132 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. LLIA CLINE, DEPUTY SHERIFF COST: $49.40 November 04, 2010 SO ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-6815 CV ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: rn 00 .z M r- ? CD rU c-? C) Sa "Tt C) ? fW Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 10/26/10 to 12/06/10 Total $ 218,052.61 $ 2,177.70 S 220,230.31 i` TERRENCE J. McCABE, ESQUIR MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff AND NOW, this _1Aay of -EC , 2010, Judgment is entered in favor of Plaintiff, Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, and against Defendants, Harry T. Shughart, Jr. and Vonda L. Shughart, and damages are assessed in the amount of $220,230.31, plus interest and costs. BY THE PROTHON TARY ?.? any to v, *t6 ?Jc?i McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-6815 CV AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Harry T. Shughart, Jr. and Vonda L. Shughart, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Harry T. Shughart, Jr. and Vonda L. Shughart, are over eighteen (18) years of age, and reside as follows: Harry T. Shughart, Jr. 132 Lawrence Lane Carlisle, Pennsylvania 17015 SWORN AND SUBSCRIBED BEFORE ME THIS 9`h DAY OF DECEMBER, 2010, NOTARY PUBLIC/ / ' COMMONWEALTH OF PE N5YLVANb NOTARIAL BEAL Barbara J. Moyer- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 Vonda L. Shughart 132 Lawrence Lane Carlisle, Pennsylvania 17015 L TERR UCE. McCABE, ESQ IRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE -'ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-6815 CV CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". -T?A?(. 14 t,? SWORN AND SUBSCRIBED BEFORE ME THIS 91n DAY OF DECEMBER, 2010 i NOTARY PUBLIC TERRENCE J. McCABE, ESQUIRI MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff ?7MM?f:Wc""ACTH Ch F-LNNSYI.VANI,a NOTARIAL SEAL Barbara j. Moyer- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, -- 14 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY L? COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary November 24, 2010 To: Harry T. Shughart, Jr. 132 Lawrence Lane Carlisle, Pennsylvania 17015 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS. Harry T. Shughart, Jr. Vonda L. Shughart Cumberland County Court of Common Pleas Number 10-6815 CV NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENT[-,'R A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS 1-0 THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WMIIN TEN (10) DAYS FROM THE DATE OF TI4IS NOTICE, A JUDGMENT MAY BE ENTERED AGAINSTYDUWrWOLT'AIIEAMH G'ANDYUUI- YLOS£YOURPROPERTY OR OTHER IMPORTANT' RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR,TELEPHONE THE OFFICE SET FORTH BELOW. DIIS OFFICE CAN PROVIDE YOU i litn INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY HE ABLE TO PROVIDE YOU WITH INFORMATION ABOUTAGFNCIES THATMAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FF,E. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 USTED SE ENCUENTRA EN F'STADO DE RFBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR -E.SCRITO CON FSTE TRIBUNAL-SUS DEFENSES U OBJECIONES'A LOS RECLAMOS.FORMVLADOS EWCONTRA;SVYO...AL NQ TOMAR LA ACCION'DEBIDA DENTRO DE DIF.7.(10) DIAS DE-41A FECHA t1E t35TA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED,,PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES, ' USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTL•. Sl USTED NO 116NE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA 1.0 PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO, SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DF PROPORCIONARLO CON INFORMACION ACERCA DE I.AS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGl1N HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (8000)) 9990-9108 BY: 1 . Attorneys for Plaintiff TERRENCE J. McCABE, ESQ MARC S. WEISBERG, ESQU EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE, FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE hm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ?C) Curt Long Cumberland. County Courthouse, Carlisle, Pennsylvania 17013 Prothonotary November 24, 2010 To: Vonda L. Shughart 132 Lawrence Lane Carlisle, Pennsylvania 17015 Beneficial Consumer Discount Company tla Cumberland County Beneficial Mortgage Company of Pennsylvania Court of Common Pleas VS. Harry T. Shughart, Jr. Vonda L. Shughart Number 10-6815 CV NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE. IN WRITING WITH TIIE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF T141S NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WJTHOUTA HEARINGAND YOUMAY LOSE YOUR PROPERTY OR OTHER_IMPORTANT RIGHTS, .: . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDF YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WIT14 INFORMATION ABOUTAGENCIFSTHATMAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POP NO HABER PRESENTADO UNA COMPAREC.ENCIA ESCRITA, YA SEA PERSONALMENTE 0 FOR ABOGADO Y POR NO HABER RADICADO FOR ESCRITO CON ESTE'172IBUNAL SUS DEFENSAS U OBJECIONF3 A LOS RECLAMOS FORMULADQs EN CONTRA SUYO. AL NO. TOMAR LA ACCION DEBIDA DENTRO OF DIEZ (10) DIAS DE LA FECHA PE ESTA _ NOTIFICACION, EL;.TRtBUNAL'.PODRA, SIN NmhtiDADDE COMPARECER.USTED'EM CORTE`IJ'01R PREUBA ALGUNA, DICTAR SE. TENCIAL'NSUCONTRA YUSTEDPODRIAPERDERBIENESUOTROS DERECHOSIMpoRTANTES. USTED"LE DFBE TOMAR ESTE PAPEL'A'SU`AHOGADO INAIEDIATAMENTE. SI USTED NO TIF,NE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA FXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACON ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPA7 DE PROPORCIONARLO CON INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES FN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 BY: Attorneys for Plaintiff TERRENCE J. McCABE, ES IRE -C - MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE FRANK DUBIN, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE hm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. FILE NO.: 10-6815 CV Civil Term AMOUNT DUE: $220,230.31 INTEREST: from 12/07/10 Harry T. Shughart, Jr. and Vonda L. Shughart $3,077.00 at $36.20 ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 132 Lawrence Lane, Carlisle, Pennsylvania 17015 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named gamishee(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 gamishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: December 22, 2010 . 111 q. (/U LULI fJ ?.yo 06r ga' a G IN.D0 4,7,561 84 Atf Cc# last 3av ?Wi* 453016 Signature: ? ( V Print Name: MCCABE, WEISBERG AND CONWA Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. W C . Z ' l LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST FENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A SPIKE IN THE CENTER OF TOWNSHIP ROAD #437, KNOWN AS LAWRENCE LANE, AND A LINE OF LOT NO.2 NOW OWNED BY ROGER G. LEBO AND WIFE, THENCE ALONG THE CENTER OF SAID TOWNSHIP ROAD SOUTH 62 DEGREES 00 MINUTES WEST, 167 FEET TO A SPIKE IN THE CENTER OF SAID ROAD AND A PROPOSED STREET 50 FOOT RIGHT OF WAY; THENCE ALONG PROPOSED STREET 50 FOOT RIGHT OF WAY SOUTH 28 DEGREES 00 MINUTES EAST 225.64 FEET TO A POINT TO THE CORNER OF LANDS OF MERVIN R. YINGER AND ANNA A. YINGER, HIS WIFE, THENCE ALONG THE LANDS OF YINGER NORTH 62 DEGREES 00 MINUTES EAST 134.28 FEET TO THE CORNER OF LANDS OF YINGER AND LOT NO. 2, NOW OWNED BY ROGER G. LEBO AND WIFE; THENCE ALONG LOT NO. 2, NORTH 19 DEGREES, 45 MINUTES WEST 228 FEET TO THE PLACE OF BEGINNING. CONTAINING.780 ACRES BEING LOT NO. 1 IN THE CERTAIN PLAN OF LOTS OF MERVIN R. YINGER REVISED OCTOBER 3, 1973 AND LAID OUT BY THOMAS A. NEFF, R.9. RB5678 132 Lawrence Lane, Carlisle, Pennsylvania 17015. BEING the same premises which JAY R. BEIDEL AND BEVERLY M. BEIDEL by deed dated November 19, 1998 and recorded November 19, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 189, Page 551, granted and conveyed to Harry T. Shughart, Jr. and Vonda L. Shughart. TAX MAP PARCEL NUMBER 46-08-0587-015 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-6815 CV AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 132 Lawrence Lane, Carlisle, Pennsylvania 17015, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Harry T. Shughart, Jr. Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 Vonda L. Shugart 132 Lawrence Lane Carlisle, Pennsylvania 17015 2. Name and address of Defendants in the judgment: Name Harry T. Shughart, Jr. Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 .7) r., -„ - rn ?-- `° .3 Wiz. µ „k Vonda L. Shughart 132 Lawrence Lane Carlisle, Pennsylvania 17015 3. 4. 5 6. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 81' Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U.S. Dept of Justice, Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S. Dept of Justice, Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. December 22, 2010 DATE TERRE E J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST FENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A SPIKE IN THE CENTER OF TOWNSHIP ROAD #437, KNOWN AS LAWRENCE LANE, AND A LINE OF LOT NO.2 NOW OWNED BY ROGER G. LEBO AND WIFE, THENCE ALONG THE CENTER OF SAID TOWNSHIP ROAD SOUTH 62 DEGREES 00 MINUTES WEST, 167 FEET TO A SPIKE IN THE CENTER OF SAID ROAD AND A PROPOSED STREET 50 FOOT RIGHT OF WAY; THENCE ALONG PROPOSED STREET 50 FOOT RIGHT OF WAY SOUTH 28 DEGREES 00 MINUTES EAST 225.64 FEET TO A POINT TO THE CORNER OF LANDS OF MERVIN R. YINGER AND ANNA A. YINGER, HIS WIFE, THENCE ALONG THE LANDS OF YINGER NORTH 62 DEGREES 00 MINUTES EAST 134.28 FEET TO THE CORNER OF LANDS OF YINGER AND LOT NO. 2, NOW OWNED BY ROGER G. LEBO AND WIFE; THENCE ALONG LOT NO. 2, NORTH 19 DEGREES, 45 MINUTES WEST 228 FEET TO THE PLACE OF BEGINNING. CONTAINING.780 ACRES BEING LOT NO. 1 IN THE CERTAIN PLAN OF LOTS OF MERVIN R. YINGER REVISED OCTOBER 3, 1973 AND LAID OUT BY THOMAS A. NEFF, R.9. RB5678 132 Lawrence Lane, Carlisle, Pennsylvania 17015. BEING the same premises which JAY R. BEIDEL AND BEVERLY M. BEIDEL by deed dated November 19, 1998 and recorded November 19, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 189, Page 551, granted and conveyed to Harry T. Shughart, Jr. and Vonda L. Shughart. TAX MAP PARCEL NUMBER: 46-08-0587-015 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-6815 CV AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendants are: Harry T. Shughart, Jr. Vonda L. Shughart 132 Lawrence Lane 132 Lawrence Lane Carlisle, Pennsylvania 17015 Carlisle, Pennsylvania SWORN AND SUBSC ED B OF ME THISZZn DAY OF 2010 TARY PVJBLIC OMMONWEALTH_OF PENNSYLVANIA NOTARIAL SEAL STACEY M. O'CONNELL, Notary Public City of phi ia, Phila. County 192912 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 17015 ... :... cz-D ' 'r I n ? > t n_ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania V. Hang T. Shughart, Jr. and Vonda L. Shughart Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-6815 CV NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Harry T. Shughart, Jr. Vonda L. Shughart 132 Lawrence Lane 132 Lawrence Lane Carlisle, Pennsylvania 17015 Carlisle, Pennsylvania 17015 L r* I ?1 < r*.a i /tom W -v M Your house (real estate) at 132 Lawrence Lane, Carlisle, Pennsylvania 17015 is scheduled to be sold at Sheriffs Sale on March 1, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $220,230.31 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 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 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. :> tj :3 -ry You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST FENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A SPIKE IN THE CENTER OF TOWNSHIP ROAD #437, KNOWN AS LAWRENCE LANE, AND A LINE OF LOT NO.2 NOW OWNED BY ROGER G. LEBO AND WIFE, THENCE ALONG THE CENTER OF SAID TOWNSHIP ROAD SOUTH 62 DEGREES 00 MINUTES WEST, 167 FEET TO A SPIKE IN THE CENTER OF SAID ROAD AND A PROPOSED STREET 50 FOOT RIGHT OF WAY; THENCE ALONG PROPOSED STREET 50 FOOT RIGHT OF WAY SOUTH 28 DEGREES 00 MINUTES EAST 225.64 FEET TO A POINT TO THE CORNER OF LANDS OF MERVIN R. YINGER AND ANNA A. YINGER, HIS WIFE, THENCE ALONG THE LANDS OF YINGER NORTH 62 DEGREES 00 MINUTES EAST 134.28 FEET TO THE CORNER OF LANDS OF YINGER AND LOT NO. 2, NOW OWNED BY ROGER G. LEBO AND WIFE; THENCE ALONG LOT NO. 2, NORTH 19 DEGREES, 45 MINUTES WEST 228 FEET TO THE PLACE OF BEGINNING. CONTAINING.780 ACRES BEING LOT NO. 1 IN THE CERTAIN PLAN OF LOTS OF MERVIN R. YINGER REVISED OCTOBER 3, 1973 AND LAID OUT BY THOMAS A. NEFF, R.9. RB5678 132 Lawrence Lane, Carlisle, Pennsylvania 17015. BEING the same premises which JAY R. BEIDEL AND BEVERLY M. BEIDEL by deed dated November 19, 1998 and recorded November 19, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 189, Page 551, granted and conveyed to Harry T. Shughart, Jr. and Vonda L. Shughart. TAX MAP PARCEL NUMBER: 46-08-0587-015 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6815 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 COMPANY OF PENNSYLVANIA Plaintiff (s) From HARRY T. SHUGHART, JR. AND VONDA L. SHUGHART (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 $220,230.31 L.L. $.50 Interest FROM 12/07/10 -- $3,077.00 AT $36.20 Atty's Comm % Due Prothy $2.00 Atty Paid $'I k1 o 9G? Other Costs Plaintiff Paid Date.-, 01/03/2011 D. Bugh, Prothonotary (Seal) REQUESTING PARTY: Narri0: MARC S. WEISBERG, ESQ. Address: MCCABE, WEISBERG, AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone : 215-790-1010 Supreme Court ID No. 17616 By: Deputy McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendant r' ?:J-0F ICE- ? „ p?` 'ROTHONOTAt? f Attorney for Plaintiff Li 1 2 12: {' PEN NSYLVANIA TY CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-6815 CV AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 15th day of July, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSC BEFORFi1C?jE THIS DAY OF ?f L? X120,11. Y PUBLIC McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff By: TE NC McCABE, ESQUIRE - ID # 16496 MARC S. ISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-6815 CV AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 132 Lawrence Lane, Carlisle, Pennsylvania 17015, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owners or Reputed Owners Name Harry T. Shughart, Jr. Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 Vonda L. Shugart 132 Lawrence Lane Carlisle, Pennsylvania 17015 2. Name and address of Defendants in the judgment: Name Harry T. Shughart, Jr. Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 Vonda L. Shughart 132 Lawrence Lane Carlisle, Pennsylvania 17015 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 132 Lawrence Lane Carlisle, Pennsylvania 17015 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. July 15, 2011 Attorneys for Plaintiff DATE By: M t-, TERR6WE McC BE, ESQUIRE MARC S. W SBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania Plaintiff V. Harry T. Shughart, Jr. and Vonda L. Shughart Defendants DATE: July 15, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-6815 CV NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Harry T. Shughart, Jr. and Vonda L. Shughart PROPERTY: 132 Lawrence Lane, Carlisle, Pennsylvania 17015 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. J O? Ui A W N ?+ ? H?W?3 '?] p v;w es FU> 7'6! ^C'C7 ? O b ? ? a C7 O.7CA y ? om. n ' O ?CtO .7 ?oNd? 7 f?D C.i O ? fD i "S ' Z ff Pa .Z .Z ? ?. ? M1 b G O ? R ? d ? r °fQ YxC?7CA ?]L7 A fD O c y;ebd 17 AD C ? "r,'.S7?7C?-3C A7 A bfD ? .T?'C?,? bdC? A7 A'.SC O '?7v??? A SC Off' O Y`?I,"`.?bdC7A ?'j p? O A O C??'?l A? CD N oooaon n ?' m w n - F f o Zy O y mm O c c r"m Z A ? m'z1A A 9 b B ?O ? t A ? ? a 0 •-l? ?? 7 vi ?m ti y'r0 p n ? a ca.0 = C/1C n O C'O ? O Y! O ?m ?O O O? ?' ni Q. o O R :i. k b p?d + dO k p go dcc A? C w?'rt QQ A?.bm .O.' n, =(nf-D: Cr'AS!'! L7 Nr.geD "S!A O o bWa C bCTWUOQ? bN? y d'. t11G?„? O rD C o w y ?C C S ?.+ O p ?O? .. p G Orti .+ C? O C ?00? Yf < S r..OQ'I....11CLO ' y* Cr tD O > CL Si"' C"y 0 o ? o 0 o m D Ndn N ls1"' O ?1.+Qfb t d b ?+ ?' O? . cr ? b a y y v, 777777w f fD Vi hr f C p n fp 0Q f!1 ?? N 00 O ' O F. ? O fE .ti O fA 0 °$d.. N? w N O W c A ?fp 00 p O k v y .??vOi n '. rD ?' ?' T 3 ONO d A y ?. ?+ fD W ?N D e O O 3 ' ?X C 0 ? a ?? v x w? n 5' sa ?m fsg o 0 R? R? y C'? ? W N ?+ O b 00 y z a = w? ?b h O A ? Az a? ¦0 ? ^o A y o » o m ? W o x+ va ?. a? v,??. m ? i_-.o o ? v ? e o :d g ? r.o A C? a ?•? C? a Q ?Q a o o g A o c, y'00? y a.?a m o o a y ?'? ? A . w o O `! C_ O Z+ Oq O y m "b W yyNyy G? Z1 {17 O 7 y ? ?i LI ? `3 y ,0., O b M A '? 'e a O y' ?' a' ?, y ? r... p Ir ?l n '+ ? A A y ?d eD O a O ,q „ ,? ? „ >? O A ?' CD V -j ;- ° aa$_ ° ; C?pAm 0 OCprim . o ep OLw=F o ?. A ? ? ?Q U l ( /l C A ? ? W 0 C y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff qrX>titp etu+nbrf,T? t- w r r ,, Jody S Smith Chief Deputy Richard W Stewart Solicitor Fri CE F TrF z ?iFF `? t't tiS.' j 1 ?. 5: I g Beneficial Consumer Discount Company Case Number vs. Harry T. Shughart (et al.) 2010-6815 SHERIFF'S RETURN OF SERVICE 06/23/2011 04:15 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 132 Lawrence Lane, Carlisle, PA 17015, Cumberland County. 06/23/2011 04:15 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be VONDA L. SHUGART, WIFE, who accepted as "Adult Person in Charge" for Harry T. Shughart at 132 Lawrence Lane, West Pennsboro Township, Carlisle, PA 17015, Cumberland County. 06/23/2011 04:15 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Vonda L. Shughart at 132 Lawrence Lane, West Pennsboro Township, Carlisle, PA 17015, Cumberland County. 06/28/2011 Timothy Black, Deputy Sheriff, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Vonda L. Shughart, at 132 Lawrence Lane, Carlisle, PA 17013, Cumberland County. 06/28/2011 Timothy Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Vonda L. Shughart, (wife) who accepted as "Adult Person in Charge" for Harry T. Shughart, at 132 Lawrence Lane, Carlisle, PA 17013, Cumberland County. 06/28/2011 Timothy Black, Deputy Sheriff, 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 132 Lawrence Lane, Carlisle, PA 17015, Cumberland County. 09/08/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Marc Weisberg, on behalf of, Beneficial Consumer Discount Company, of, 961 Weigel Drive, Elmhurst, IL 60126, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $885.91 SO ANSWERS, October 11, 2011 RON R ANDERSON, SHERIFF ?•4c:) PGA ' ? - ee,) Pei . CG' . S r? L lad iC CourrySuite Shenfl, Teleosoft. Inc. On May 11, 2011 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, Known and numbered as, 132 Lawrence Lane, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-6815 Civil TAX MAP PARCEL NUMBER: 46 08 0587 015. Beneficial Consumer Discount Company vs. Harry T. Shughart Vonda L. Shughart Atty.: Marc S. Weisberg ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at a spike in the cen- ter of Township Road #437, known as Lawrence Lane, and a line of Lot No. 2 now owned by Roger G. Lebo and wife, thence along the center of Said Township Road South 62 degrees 00 minutes West, 167 feet to a spike in the center of said road and a proposed street 50 foot right of way; thence along proposed street 50 foot right of way South 28 degrees 00 minutes East 225.64 feet to a point to the corner of lands of Mervin R. Yinger and Anna A. Yinger, his wife, thence along the lands of Yinger North 62 degrees 00 minutes East 134.28 feet to the corner of lands of Yinger and Lot No. 2, now owned by Roger G. Lebo and wife; thence along Lot No. 2, North 19 degrees, 45 minutes West 228 feet to the place of BEGINNING. CONTAINING .780 acres being Lot No. 1 in the certain plan of lots of Mervin R. Yinger revised October 3, 1973 and laid out by Thomas A. Neff, R.9. 132 Lawrence Lane, Carlisle, Pennsylvania 17015. BEING the same premises which JAY R. BEIDEL AND BEVERLY M. BEIDEL by deed dated November 19, 1998 and recorded November 19, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 189, Page 551, granted and conveyed to Harry T. Shughart, Jr. and Vonda L. Shughart. 60 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: July 15, July 22 and July 29, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 9 day of July, 2011 Notary NOTARI AL SEAL DEBORAH A COLLINS Notary Public FGARLIBLE BOROUGH, CUMBERLAND COUNTY ommission Expires 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 the Patti* ot 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 oetialt 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 07/15/11 07/22/11 This ad ran on the date(s) shown below: m to`and ubscri efore me s 18 aypf August, 2011 A.D. Notary Pu COMMONWEALTH OF PENNSYLVANIA NotarW Seal Sherrie L Klsner, Notary Public Lower Paxton Twp,, Dauphin County My Commission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 07129/11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 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 Consumer Discount Company D/B/A Beneifical Mortgage Company of Pennsylvania is the grantee the same having been sold to said grantee on the 7th day of September A.D., 202011, under and by virtue of a writ Execution issued on the 3rd day of Janu , A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6815, at the suit of Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Company of Pennsylvania against Harry T Shughart Jr and Vonda L. Shughart is duly recorded as Instrument Number 201128272. IN TESTIMONY WHEREOF, I have hereunto set my hand ZA- and seal of said office this _ day of A.D. _ of Deeds Aewftof DOW6, CumbeftW County, COW%PA My Cw nisew Expires the Fret Monday of Jan. 2014 2010-015 CM I Term Beneficial Consumer Discount Company Vs' Harry T. Shughart Vonda L. Shughart Atty: Marc S. Weisberg All That Certain ?Land Situate In West Pennsboro , Cumberland County, Pennsylvania, More Particularly Bounded And Described As Follow% To Wit: Beginning At A Spike In The Center Of Township Road #437, Known As Lawrence Lane, And A Line Of Lot No. 2 Now Owned By Roger G. Lebo And Wife, Thence Along The Center Of Said Township Road South 62 Degrees 00 Minutes West, 167 Feet To A Spike In The Center Of Said Road And A Proposed Street 50 Foot Right Of Way; Thence Along Proposed Street 50 Foot Right Of Way South 28 Degrees 00 Minutes East 225.64 Feet To A Point To The Comer Of Lands Of Mervin R. Yinger And Anna A. Yinger, His Wife, Thence Along The Lands Of Yinger North 62 Degrees 00 Minutes Fast 134.28 Feet To The Comer Of Lands Of Yinger And Lot No. 2, Now Owned By Roger G. Lebo And Wife; Thence Along Lot No. 2, North 19 Degrees, 45 Minutes West 228 Feet To The Place Of Beginning. Containing.780 Acres Being Lot No: 3 In The Certain Plan Of Lots Of Mervin R. Yinger Revised October 3,1973 And Laid Out By Thomas A. Neff, R.9. 132 Lawrence Lane, Carlisle, Pennsylvania 17015. Being The Same Premises Which Jay R. Beidel And Beverly M. Beidel By Deed Dated November 19,1998 And Recorded November 19,1998 In The Office Of The Recorder In And For Cumberland County In Deed Book 189, Page 551, Granted And Conveyed To Harry T. Shughart, Jr. And Vonda L.Shughart. Tax Map Parcel Number: 46 08 0587 015