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10-7033
} a To: oc" MILSTEAD & ASSOCIATES, LLC ]BY: Mary L. Harbert-Bell, Esquire ID No. 80763 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (;856) 482-1400 ]Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania 636 Grand Regency Boulevard Brandon, FL 33510, Plaintiff, Vs. Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, PA 17013, and Ricky Wilcox, Original Mortgagor 627 N. West Street Carlisle, PA 17013, Defendants You are hereby notified I file,p written response to CJ - i twenty (26) days from th or a judgment may be en Attorney for Plaintiff Attorney for Pla File: 22.12760 COURT OF CON CUMBERLAND No.:?U--7o3 CIVIL ACTION 9 0 he enclosed within service hereof red against you. ON PLEAS )LINTY NOTICE You have been sued in court. If you wish to defend agains the following pages, you must take action within twen complaint and notice are served, by entering a written apl by attorney and filing in writing with the Court your defense claims set forth against you. You are warned that if you fail proceed without you and a judgment may be entered ag without further notice for any money claimed in the com claim or relief requested by the plaintiff. You may lose moni rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU C Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 the claims set forth in V (20) days after this ?earance personally or )s or objections to the to do so the case may inst you by the court Taint or for any other ?y or property or other ICE. IF YOU DO NOT R TELEPHONE THE GET LEGAL HELP. 7 .._ ...............--- -------- NOTICE PURSUANT TO FAIR DEBT COLLECTION P CTICES ACT 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assume to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our office will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices, MILSTEAD & ASSOCIATES, LLC BY: Mary L. Harbert-Bell, Esquire ID No. 80763 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Beneficial' Consumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania 636 Grand Regency Boulevard Brandon, FL 33510, Plaintiff, Vs. Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, PA 17013, and Ricky Wilcox, Original Mortgagor 627 N. West Street Carlisle, PA 17013, Defendants Attorney for COURT OF COM ` ON PLEAS CUMBERLAND COUNTY i No.. CIVIL ACTION MORTGAGE FORECLOSURE I . Plaintiff, Beneficial. Consumer Discount Company D/B/A Pennsylvania (the "Plaintiff'), is a corporation registered to conduct Commonwealth of Pennsylvania and having an office and place of Regency Boulevard, Brandon, FL 33510. 2. Defendants, Robin L. Wilcox, Original Mortgagor and Real Original Mortgagor, (collectively, the "Defendants"), are adult individ Wilcox is the real owner of the premises hereinafter described by virtue icial Mortgage Co of :ss in the s at 636 Grand ier and Ricky Wilcox, Defendant Robin L. a Deed dated July 28, 2 006 .and recorded August 15, 2006 in Deed Book 276, Page 851. 3. Robin L. Wilcox, Original Mortgagor and Real Owner, Del ndant, resides at 627 N. West Street, Carlisle, PA 1;7013. Ricky Wilcox, Original Mortgagor, Defendant, resides at 627 N. West Street, Carlisle, PA 17013. 4. On March 25, 2008, in consideration of a loan in the principal amount of $130,759.76, the Defendants executed and delivered to Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania a note (the "Note") with interest thereon at 5.250 percent per annum, payable as to the principal and interest in equal mo tlily installments of $786.00 commencing May 1, 2008. 5. To secure the obligations under the Note, the Defendants ex?cuted'and delivered to Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Clo of Pennsylvania a mortgage (the "Mortgage") dated March 25, 2008, recorded on March 7, 2008 in the Department of Records in and for the County of Cumberland under Mgrt?,Ya2e Instrument Number 200809331. See Mortgage attached. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is :incorporated herein by reference. 6. The Mortgage secures the following real property (the "Mortgaged Premises"): 627 N. West Street, Carlisle, PA 17013. A legal description of the Mortgaged Premises is attached hereto as Exhibit "A" and made a part hereof. 7. The Defendants are in default of their obligations pursuant to the Note and Mortgage because payments of principal and interest due November 1, 2009, and monthly thereafter are due and have not been paid, whereby the whole balance of principal anc all interest due thereon have become due and payable forthwith together with late charges, escr?w deficit (if any) and costs of collection including tittle search fees and reasonable attorney's i 8. The following amounts are due on the Mortgage and Note: EXHIBIT A ALL THAT CERTAIN( LOT OF GROUND SITUATED IN THE BOROUGH OF CARLISLE, COUNTY" OF CUMBERLAND AND STATE OF PNNSYLVANIA BOUNDED AND DESCRIBED AS FOLLOWS TO WIT: ON THE WEST BY NORTH WEST STREET; ON THE NORT BY PROPERTY NOW OR FORMERLY OF MRS. EMMA NEUSBAUM; ON THE EAST BY A 16 FOOT ALLEY; AND ON THE SOUTH BY PROPERTY NOW R FORMERLY OF JOHN LISZMAN. CONTAINING 20 FEET IN FRONT ON SAID NORTH WEST STREET AND IN DEPTH A LIKE WIDTH 190 FEET TO SAID ALLEY. TAX MAP OR PARCEL ID NO.: 06-20-1798-•019 ,TA MAP OR PARCEL ID NO.: 06-20-1798-019 ADDRESS: 627 N. WEST STREET; CARLISLE, PA 17013-1967 Balance of Principal ................................$127,200.29 Accrued but Unpaid Interest from 10/1/09 to 11/4/10 5.250% per armum ($18.29 per diem.) ........................... .............$7,316.00 Corporate Advance ......................... .............$3,445.49 Extension Interest Due .......:............ .............$1,688.58 Title Search Fees ............................ ................$350.00 Reasonable Attorney's Fees ........... .............$1,250.00 TOTAL as of 11/04/2010 ........................$141;250.36 Plus, the following amounts accrued after November 4, Interest at the Rate of 5.250 per cent per annum ($18 Late Charges per month if applcable 9. Plaintiff has complied fully with Act No. 91 (35 P. SA of the General Assembly ("Act 91") of the Commonwealth of Pennsy Defendants at: 627 N. West Street, Carlisle, PA 17013 as well as to ac .listed in paragraph 3 of this document on May 12, 2010, the notice pu 91, and the applicable time periods therein have expired. WHEREFORE, Plaintiff demands an in rem judgment against foreclosure and sale of the Mortgaged Premises in the amount due as namely, $141,250.36, plus the following amounts accruing after N 0: per diem); 1(c) of the 1983 Session by mailing to the of residences as to § 403-C of Act Defendants for forth in paragraph 8, 4, 2010, to the date of judgment: (a) interest of $18.29 per day, (b) late charges per month if applicable, (c) plus interest at the legal rate allowed on judgments after the date of judgmen?, (d) additional attorney's fees (if any) hereafter incurred, (e) and costs of suit. MILSTEA?D_ & ASSOCIA7S, LLC Mary L. Harbert-Bell, Attorney for Plaintiff VERIFICATION I, Mary L. Harbert-Bell, hereby certify that I am an Attorney for Plain iff and am authorized to make this verification on Plaintiff's behalf I make this verification o behalf of the Plaintiff because Plaintiff is outside the jurisdiction of the Court. I verify that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure have been obtained from the Plaintiff, and are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties: of 18 Pa. C.S. '4904, relating to unsworn falsification to authorities. Name: Mary L. Harbert-1 Title: Attorney Esquire io This instrument was prepared by. 3ANINE M. SHEAFFER (Name) 983 WAYNE AVENUE, CHAMBERSBURG, PA 17201 Address Return To: Records Processing Services 577 Lamont Road Elmhurst,IL 60126 (800) 547-8776 UPI# 06-20-1798-019 711716 MORTGAGE IF BOX IS CHECKED,' THIS MORTGAGE IS AN OPEN-E D MORTGAGE AND SECURES FUTURE AIDVANCES. THIS MORTGAGE is made this day 25TH of MARCH 2008 , between the Mortgagor, ROB I N L. W I LCOX, S I NGLE C `2 ? t L ;{ C U' herein" borrower") and Mortgagee BENEF I C I AL CONSUMER D I SCOUNT OMPANY D/B/ A BENEFICIAL MORTGAGE CO OF,PENNSYLYANIA a corporation organized and existing under the laws of PENNSYLVANIA hose address is 983 WAYNE AVENUE, LHAMBERSSURG, PA 17201 t-__r _nt < n .__. The following paragraph preceded by a checked box is applicable X WHEREAS, Borrower is indebted to Lender in the principal sum of 9 evidenced by Borrower's Loan Repayment and Security Agreement or Se Agreement dated MARCH ,2r, 2008 and any extensions or "Note"), providing for monthly installments of principal and interest, includir amount of payments or the contract rate if that rate is variable, with the balan not sooner paid, due and payable- on.MMCN 2r 2033 WHEREAS, Borrower is indebted to Lender in the principal sum of $ or so much thereof as may be advanced pursuant to Borrower's Revolving and extensions and renewals thereof therein monthly installments; and :interest at the rate and under the terms specified it adjustments in the interest rate if that rate is variable, and providing for a c principal suns above and an initial advance of $ TO SECURE to Lender the repayment of (1) the indebtedness evids interest thereon, including any increases if the contract rate is variable; (2) fu Revolving Loan Agreement; (3) the payment of all other sums, with intere accordance herewith to protect the security of this Mortgage; and (4) the perfo: and agreements of Borrower herein contained, Borrower does hereby mortga Lender and Lender's successors and assigns the following described property 1 CUMBERLAND COUNTY Commonwealth of Per SEE EXHIBIT A-LEGAL DESCRIPTION 1111 1111?lll 1111111(1111911111??III?1l IIIIIi??ll It<III1111)1{Iiliil?llillllll?[Ilillllll ?IIII ?Vl84775044P98MM8000PA001301FKNI LCOX * FILE COPY 11-11-05 MTG enewals thereof (here=in any adjustments to the - of the indebtedness, if Note"), providing for the Note, including any edit limit stated in the ed by the Nose, 1.vit y!: e ad?jances under an thereon, advanced in ance of the covenants gr2nt and convey to Lted in the County of yivania; PA001301 -2- TOGETHER with all the improvements now or hereafter erected easements, rights, appurtenances and rents, all of which shall be deemed to property covered by this Mortgage; and all of the foregoing, together wi leasehold estate if this Mortgage is on a leasehold) are hereinafter referred to ass Borrower covenants that Borrower is lawfully seised of the estate her right to mortgage, grant and convey the Property, and that the property is encumbrances of record. Borrower covenants that Borrower warrants and will. to the Property against all claims and demands, subject to encumbrances of r UNIFORM COVENANTS. Borrower and Lender covenant and agree as £ 1. Payment of Principal, Interest, Escrow Items, Prepayment Cha Borrower shall pay when due the principal of, and interest (including any vari from changes in the Contract Rate that may be specified in the Note) on, the d and any prepayment charges and late charges due under the Note. Borrower Escrow Items pursuant to Section 3. Payments due under the Note and this e be shade in U.S. currency. However, if any check or other instrument receiv under the Note or this Security Instrument is returned to Lender unpaid, Lend all subsequent payments due under the Note and this Security Instrument be following forms, as selected by Lender: (a) cash; (b) money order; (c) cer treasurer's check or cashier's check, provided any such check is drawn u deposits are insured by a foleral agency, instrumentality, or entity; or (d) Elect Payments are deemed received by Lender when received at the location d such other location as ma,y be designated by Lender in accordance with the no 12. Lender may return any payment or partial payment if the payment insufficient to bring the Loan current. Lender may accept any payment or pa to bring the Loan current, without waiver of any rights hereunder or prejud such payment or partial payments in the future, but Lender is not obligated t the time such payments are accepted. If each Periodic Payment is applied as then Lender need not pale interest on unapplied funds. Lender may hold st Borrower makes payment to bring the Loan current. If Borrower does not d period of time, Lender shall either apply such funds or return them to Borro such funds will be applied to the outstanding principal balance under the N foreclosure. No offset or claim which Borrower might have now or in the f relieve Borrower from making payments due under the Note and this performing the, covenants and agreements secured by this Security Instrument 2. Application of Payments or Proceeds. Except as otherwise descri may be required,by the Note and/or applicable law, all payments accepted and applied in the following order of priority: (a) interest due under the Note; (b, Note; (c)';amounts due under Section 3. Such payments shall be applied to eac order in which it became due. Any remaining amounts shall be. applied first any other amounts due under this Security Instrument, and then to reduce th Note. If Lender receives a payment from Borrower for a delinquent Periodic PI sufficient amount to pay any late charge due, the payment may be applied tq n the property, and all and remain a part of the h said property (or the the "Property." )y conveyed and has the nencumbered, except for defend generally the title ;es, and Late Charges. :ions in interest resulting bt evidenced by the Note shall also pay funds for ecurity Instrument shall d by Lender as payment r may require that any or ide in one or more of the ified check, bank check, 3n an institution whose DOIc Funds Transfer. ,ignated in the Note or at ice provisions inSection )r partial payments are tial payment insufficient ,e to its rights to refuse apply such payments at f its scheduled due date, ;h unappiied funds until o so within a reasonable or. If not applied earlier, to immediately prior to ;ure against Lender shall Security Instrument or 3 in this Section 2 or as plied by Lender shall be principal due under the Periodic Payment in the late charges, second to principal balance of the yment which includes a the delinquent payment 11-11-05 MTG PA001302 1 1111111111f 111111111111V 11111111111111111 IN IN 11011 oil IN 10111111111111111111111 oil 1111111111111111111111111111 *w94775044P08T0G8000PA001302FX*WILCOX X FILE COPY -3- and the late charge- If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, an to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied o any late charges due. Volunatary prepayments shall be applied first to any prepayment charges an then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day eridic Payments are due under the Note, until the l.Iote is paid in full, a sum (the "Funds" ) to provide for payment of amounts due for. (a) taxes and assessments and other items which. can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless nder waives Borrower's obligation to pay the Funds for any or all Escrow Items, Lender may waive orrower's obligation to pay to Lender Funds for a y or all Escrow Items at any time-Any such waive may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where paya le, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's` obligation to make such payments and to provide receipts shall fol all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 7. If Borrower is obligated to pay Escrow Item directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 7 and pay such amount and Borrower shall then be obligated under Section `7 to repay to Lender any such amount. Lender may revoke the waiver as :to any or all Escrow Items at any time by a notice given in accordance with Section 12 and, upon such revocation, Borrow shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under the Real Estate Settlement Procedures Act (12 U.S.C. 'ection 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 35000, as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this security instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" 'even if the loan does not qualify as a "fcderally related mortgage loan" under RESPA. Lender shall estimate the amount of F nds due on the basis of current data and reasonable estimates of expenditures of future Escrow terns or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insure by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose eposits are so insured) 11-11-05 MTG PA001303 111(Il 11 11 Hill 1111111111111 36W84775044P98MTI,BOOOPA001203FK)(Wf.COX W FILE COPY -4- or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow It = s, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid o the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. B' rrower and Lender can agree in writing, however, that interest shall be paid on the Funds, Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA, If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required b RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in ?scrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower] shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument Lender shall promptly refund to Borrower any Funds held by Lender. 4. Prior Mortgages and Deed of Trust; Charges; Liens. Borrow shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenants to make paym nts when due. Borrower shall pay or cause to be paid all taxes, assessments, and other charges, fines and impositions attributable to the Property which may attain a priority over this Mortgage, and leaseh id payments or ground rents, if any. 5. Hazard Insurance:. Borrower shall keep the improvements now existir g or hereafter erected on the Property insured agavvst loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard ` mortgage clause in favor of and in a form acceptable to Lender. Lender shall have the right to hold he policies and renewals thereof, subject to the terms of any mortgage, deed',of trust or other security agr went with a lien which has priority over this Mortgage. In the event, of loss, Borrower shall give prompt notice to the insurance ca 'er and Lender. Lender may make proof of loss if not made promptlyby Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from 'the date notice is mailed by Lender.to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender 'is authorized: to collect'and apply the insurance pro eeds at Lender's option either to restoration orxepa,ir of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Cando iuiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not 3ommit waste or permit impairment or deterioration of the Property and 'shall comply with the provi ions of any lease if this Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or 11-11-05 MTG PAGO1304 f III II?N III III 1[[I(?III VIII III Illll lill[? II VIII IIIIIN IIII I?? VIII III I[CI IIIIIII I[fl III VIII XW04775D44P38hlT0E000PA001304FXXWI'LCGX ? FILE COPY -S- governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents. 7. Protection of Lender's Security. If Borrower fails to perform the covenants and agreements contained in this Mortgage:, or if any action or proceeding is commenced which aterially affects Lender's interest in the Property, then Lender, at Lender's option, upon notice to B5?rrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take s' h action as is necessaryto protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Mortgage. Unless' Borrower and Lender °agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any acii on hereunder. 8. Inspection. Lender may take or cause to be made reasonable entries u n and inspections of the Property, provided that bender shall give Borrower notice prior to any s ch inspection specifying reasonable cause therefor related to Lender's interest in the Property, 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender, subject to the terms of any mortgage, deed of trust or othersecurity agreement with a lien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in interest. Lender shall not be required t commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's successors in interest. Any forbearance by Lender`in exercising any right or remedy ` hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any s ch right or remedy: It. Successors and Assigns Bound; Joint and Several Liability; Co-signers- The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph Whereof. All covenants and agreements of Borrower shall be,joint and several. Any Borrower who co-signs th's Mortgage, but does not execute the Note, (a) is co.-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage, (b) is not per, nally liable on the' Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accommodations with regard to the terms of is Mortgage or the Note without that Borrower's consent and without releasing that Borrower or modifyin this Mortgage as to that Borrower's interest in the Property, 12. Notice_ Except for any notice required under applicable law to begiven i another manner, (a) any notice to Borrower provides: for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender when given in the manner designated herein. 13. Governing Law; Severability.TheapplicableJawcontained intheNot shall control. Where no applicable law i(sjcontain ejd'tfiereein, the statee and local laws applicable to this Mortgage shall be'the laws of thejurisdiction lij llpl which the. t111I?n t Ilimit llthle applicability ?Il?ll?i?i11IIIli ?ii??ill llt lllll l(l??iiulilIiiiiillW?il?Iii?lll[Ill?i?ilshall 11-11-05 1VlTG III IIIIll1I?IlI ?1lllllf! PAOU1305 V$4775D44P48Mf38D00'PA001305FNKWfLCOX * FILE COPY i -6- of Federal law to this Nortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and t this end the provisions of this Mortgage and the Note are declared to be severable. As used herein. "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable aw or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgageat the ti me of execution or after recordation hereof. . 15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender.' Lender, at Lender's option, may require Borrower to execute and del ver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property. 16. Transfer of the Property. If Borrower sells or transfers all or y part of the Property or an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon th death of a joint tenant, (c) the :grant of any leasehold interest of three years or less not containing a option to purchase, (d) the creation of a purchase money security interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f) a transfer where the spouse or children of the Borrower become' an owner of the property, (g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement,, or from an incidental property settlement agreement, by which the spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by the Federal Home Loan Bank Board, Borrower shall ause to be submitted information required by Lender to evaluate the transferee as if a new loan were being made to the transferee- Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such sale or transfer, Lender may declare al of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such op ion to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 ereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the surns declared due. If Borrower fails to pay such sums rior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Acceleration; Remedies. Except as provided in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying: (I1) the breach; (2) the action. required to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, lby which such breach must be cured; and (4) that failure to cure such breach on or before the, date specified in the notice may result in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sal of the Property. The 11-11-05 MTG PA001306 Ilil1lIII?I{(I1?111f1!ll?lll?l?llllf?llll?l[l?lill111?111i?lillillllill?lill?lrlll[Iflll?lll?I) IIlIIIIIII?Illllltlllll *W84775044P9BWTGB000PA001306FM)IWILCOX FILE COPY -- notice shall further inform Borrower of the 7 right to reinstate aft r acceleration and the right to assert in the foreclosure proceeding the nonexistence of 4 default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's option, may eeclare all of the sums secured by this Mortgage to be immediately due and payable witho t further demand and may foreclose this Mortgage by judicial proceeding. Lender shall b-. entitled to collect in such proceeding all expenses of foreclosure, including, but not nited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's accele 'tion of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of 'judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then due 'under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches o any other covenants or agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and agreements of Bor owes contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action a Lender may reasonably require to assure that the, lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpai -ed. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby slpa11 remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and retain such rents as they beome due and payable. Upon acceleration under paragraph 7 hereof or abandonment of the P perty, Lender shall be entitled to have a receiver appointed by a court to enter upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver shall be applied first to, payment of the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually received. 20. Release. Upon payment of all sums secured by this Mortgage, ender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of hom tead exemption in the Property under state or Federal law. 22. Interest Rate After Judgment. Borrower agrees the interest. rate payable after a judgment is entered on the Note or i;n an action of mortgage foreclosure shall be the rate stated in the Note, 23. Arbitration Rider to Note_ The Arbitration Rider attached to and made a part of the Note is hereby incorporated by reference and made a part of this Mortgage,, 11-11-05 1MTG IINUIIIN 11111111NIIIiNNNI1I11IN111111I11111IIIIMIE111IIIl11I?II1?{(II1?8I?IIII NINI?IIIII?IIIINII? PA001307 W84775D44P98MTG8000PA001307FXXWILCOX X FILE COPY -a- REQUEST FOR NOTICE OF DEFAULT -AND FORECLOSURE UNDER SUPERIO MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or c lien which has priority over this Mortgage to give Notice to Lender, at Len( page one of this Mortgage, of any default under the superior encumbrance foreclosure action. 0 1 I hereby certify that the precise address of the Lender (Mortgagee) is: - AVENUE, CHAMBERSBURG, PA 17201 On behalf of the Lender. By: JANINE M. SHEAFFER COMMONWEALTH OF PENNSYLVANIA, ]MEERLAND I, JEANINE D. LEEPER a Notary Public in and for said co certify that ROBIN L. WILCOX,:`•:S1NG-LE ANAt.'RXCKY WILCO personally known to me or proven satisfactorily to be the same persons 4 subscribed to the foregoing instrument, appeared before me this day in pers t hey signed and delivered the said instrument as THEIR OWN act, for the uses and purposes therein set forth. Given under my hand and official seal, this 25th day of MAR COMMONWEALTH OFPENNSYt_ rAN;I; a1 Seal My Commission expires: Jeanine ?_ L Leepeeper, Notary Public Greene T"., Franklin Counly N a3-v 9 My +ssion( ?`Gra Piers May 23, 200 ? // Member, Pennsylvania Assocint; COMMONWEALTH OF PENNSYLVANIA, I, a Notary Public in and for said co certify that personally known to me or proven satisfactorily to be the same persons v subscribed to the foregoing instrument, appeared before me this dad: in perst he signed and delivered the said instrument as act, for the uses and, purposes therein set forth. Given under my hand and official seal, this day of My Commission expires: 11-11-05 MTG encumbrance with a address set forth on of any sale or other WILCOX - 983`WAYNE SALES ASSIST NT -County ss: ty and state, do hereby se nametsj are and acknowledge that free voluntary 20 08 County ss: and state, do hereby and acknowledge that free voluntary 20 . FA001308 1111 ll 11181111?I? I81IiiII(II111111l1111olll111111111111(110111118(1111111????fI?1II118?11?(Illltilll(I81Ill *W84775044P98h1TG8OD0PA00130OF3011 LCOX )E FILE COPY -9- (Space Below This Line Reserved For Lender and 11-11-05 MTG llll?(IlllfllllllllN(11111(JIIIIIIIIIIIIII(?I?(I?!<?illllll?Illflll(IIIllilllll{IIIIII?IIIINI?I!!I? 484775D44P98MTOBODOPA00130SFNXWILUX * FILE COPY PAGO1309 EXHIBIT A (PAGE 1) ALL THAT CERTAIN PROPERTY SITUATED IN THEBOROUGH OF CARLISLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEIING MORE FULLY DESCRIBED IN A DEED DATED 07128/2006 AND RECORDED 08/15/2006, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 276 AND PAGE 851, TAX MAP OR PARCEL ID NO.; 06-20-1798-0191 111111 Ell IN 1111111111111111111111111111111111 ul 11101111 IN 11 Hill III W84775044P9&W OB000PA001300F)EKWILCOX * FILE COPY ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200809331 Recorded On 3/27/2008 At 11:49:18 AM x Instrument Type - MORTGAGE Invoice Number - 17283 User ID - JM * Mortgagor - WILCOX, ROBIN L x Mortgagee - BENEFICIAL CONS DISC CO x Customer - RECORDS ADMINISTRATIONS * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $23.50 RECORDER OF DEEDS AF'F'ORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 I Total Pages -11 Certific Lion Page DO NOT DETACH This page is now part of this lee al document. I Certify this to be r?corde4 in Cumberland Coultty PA a RECORDER AIMS MS ?rso - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. Q00l.:32 fli II!!II!!!!!li{IIIIN !1 ?!I SHERIFF'S OFFICE OF CUMBERLAND COUNTY- -,:;Ronny R Anderson Sheriff , .?- C) T -Z q Jody S Smith Chief Deputy Richard W Stewart QIrr, Solicitor ? Beneficial Consumer Discount Company Case Number vs. 2010-7033 Ricky Wilcox (et al.) SHERIFF'S RETURN OF SERVICE 11/24/2010 02:50 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 24, 2010 at 1450 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robin L. Wilcox, by making known unto herself personally, at 627 N. West Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. TEPHE BENDER, DEPUTY 12/08/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ricky Wilcox, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Ricky Wilcox. Request for service at 627 N. West Street, Carlisle, Pennsylvania 17013 the defendant was not found. The Carlisle Postmaster has confirmed, Ricky Wilcox's new address is 1561 Waggoners Gap Road, Carlisle, Pennsylvania 17013. However, The Complaint in Mortgage Foreclosure has expired before service could be attempted. SHERIFF COST: $59.80 December 08, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of Pennsylvania, Plaintiff, Vs. i lr PR%0 T Jr?ec• iAN 14 Pt9 f: ? ` Attorney for 4 L A N ll L ',' File No. 22.1276 rho ;'? COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 10-07033 Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor, Defendants. Praecipe to Reinstate Complaint in Mortgage Foreclosure TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure for the above captioned matter. MILSTEAD & ASSOCIATES, LLC Pa ner, Esquire Attorney o.203145 0 .016. 66 C-twlf cam' X0783 ?.? a s37.28 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff fir. THE PROTHONOTARY Jody S Smith 44 Chief Deputy 2011 JAN 24 PM 2: 41 1 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Beneficial Consumer Discount Company vs. Case Number Ricky Wilcox (et al.) 2010-7033 SHERIFF'S RETURN OF SERVICE 01/20/2011 03:21 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 20, 2011 at 2021 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ricky Wilcox, by making known unto himself personally, at 320 Mountainview Road, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct cop "f the same. WN ALL, DEPUTY SHERIFF COST: $39.70 January 21, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF noun*,+Suit? 5^c:nfl_ Telr osofT. lrr. MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No.: 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No.: 22.12760 Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of Pennsylvania, Plaintiff, Vs. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants. C7 G .a3 corn 2 ?r r? ,CO ZCv G 3;0Z COURT OF COMMON PLEASC CUMBERLAND COUNTY No.: 10-07033 CIVIL ACTION MORTGAGE FORECLOSURE ENTRYIWITHDRAW OF APPEARANCE TO THE PROTHONOTARY: 0 w 3 Kindly withdraw the appearance of Mary L. Harbert-Bell, Esquire as counsel for Plaintiff, and enter my appearance on behalf of the Plaintiff, Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania, in the above captioned matter. MILSTEAD & ASSOCIATES, LLC MARY?LWAFb3t?-BELL, Q . Withdrawing Attorney MILSTEAD & ASSOCIATES, LLC BY PA G --1 rnr m t7'ti1 CDc' . __4 3> {00528128} 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 BRIAN T. LAMANNA ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-7033 ENTRY OF APPEARANCE TO THE PROTHONOTARY: 3 = -4 ?D 'j QC a ,CO "v -+Q - c: =C:1 s o r? tv o ~< -,s c Kindly enter the appearance of McCabe, Weisberg & Conway, P.C., as co-counsel for Plaintiff, in the above captioned matter. DATE: December 22, 2011 (/' 'I'r - J/, /' - Z' TE CE J. McCABE, S UIRE 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 Attorneys for Plaintiff BRIAN T. LAMANNA ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-101.0 Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania Cumberland County Court of Common Pleas Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Number 10-7033 CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff, hereby certifies that a true and correct copy of the within Entry of Appearance was served on the below parties on the 22nd day of December, 2011, by the United States mail, first class: Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, Pennsylvania 17013 Ricky Wilcox, Original Mortgagor 627 N. West Street Carlisle, Pennsylvania 17013 Date: December 22, 2011 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, Pennsylvania 17013 Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 10-7033 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default - Money Judgment - Judgment in Replevin I - Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania Plaintiff v Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 10-7033 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default - Money Judgment w - Judgment in Replevin - Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 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 Benefical Mortgage Co of Pennsylvania Attorneys for Plaintiff C--) N w rn 3W t- -v V • Z 'U ai C) , 3, -? - 4 C? CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. Number 10-7033 Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: 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 11/05/10 to 01/16/12 $ 141,250.36 $ 8,011.02 Total $ 149,261.38 VIL ? ? / &a' , r TERREN E J. McCABE, ESQUIRE - ? ArH # ??0 MARC S. EISBERG, ESQUIRE • EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ?#a?grJ(p(p KEVIN T. McQUAIL, ESQUIRE MARISA J. COHEN, ESQUIRE Attorneys for Plaintiff AND NOW, this & day of \jUarq 2012, Judgment is entered in favor of Plaintiff, Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co of Pennsylvania, and against Defendants, Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor, and damages are assessed in the amount of $149,261.38, plus interest and costs. BY THE PROTHONOTAR 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 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 DB/A Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-7033 AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. 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: Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, Pennsylvania 17013 SWORN AND SUBSC E BEFO E THIS ?r OF '- Y? - . 20126 NOTARY PUBLIC ' Mh'. N®' I: Barbara J. , y CKy of Philader Phii d ., Gaanly MY COMMISSIC?N DpiREJS JAN, 14 2014 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 &Z "r- ,Lt! T RRE CE J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET CAIRO, ESQUIRE KEVIN T. McQUAIL, ESQUIRE MARISA J. COHEN, 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 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 DB/A Benefical Mortgage Co of Pennsylvania Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. No. 10-7033 Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants AFFIDAVIT AS TO MILITARY SERVICE Fransheska Gonzalez-Torrres, being of lawful age and being first duly sworn on oath, states and deposes as follows: I am a Legal Assistant at McCabe, Weisberg & Conway P.C. 2. On the 13th day of January 2012, I personally conducted an online search through the Department of Defense Manpower Data Center at has://www.dmdc.osd.mil/scra/owa/home, which indicated that the defendant, Ricky Wilcox, Original Mortgagor, was not in the military service of the United States as of the date I conducted the search. A true and accurate copy of the printout of the online search results from the Department of Defense Manpower Data Center is attached hereto. To my knowledge, defendant, Ricky Wilcox, Original Mortgagor, is not an infant or an incompetent. I affirm, under the penalties for perjury, that the foregoing representations are true. SWORN AND SUBSCRIBED By: BEFORE ME THIS I/- DAY ?'?Jw , 2012 4TARY PUBLIC OMMONWEALTM OF?NN YLVA to N93TARIAL SEAL Rmanda M. Cappelletti • Notary Public City of Philadelphia, PhUdelphia County MY COMM3SION EMRES O( 28, 2015 Name: Fransheska Gonzalez- Torres T'i ? d;'t a McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUA1L, 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 DB/A Benefical Mortgage Co of Pennsylvania Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. No. 10-7033 Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants AFFIDAVIT AS TO MILITARY SERVICE Fransheska Gonzalez-Torrres, being of lawful age and being first duly sworn on oath, states and deposes as follows: I am a Legal Assistant at McCabe, Weisberg & Conway P.C. On the 13th day of January 2012, I personally conducted an online search through the Department of Defense Manpower Data Center at https://www.dmdc.osd.mil/scra/owa/home, which indicated that the defendant, Robin L. Wilcox, Original Mortgagor and Real Owner, was not in the military service of the United States as of the date I conducted the search. A true and accurate copy of the printout of the online search results from the Department of Defense Manpower Data Center is attached hereto. To my knowledge, defendant, Robin L. Wilcox, Original Mortgagor and Real Owner, is not an infant or an incompetent. I affirm, under the penalties for perjury, that the foregoing representations are true. -A"01 SWORN AND SUBSCRIBED By:? BEFORE ME THIS _/& DAY ?-,-tiv , 2012 Name: Fransheska Gonzalez- Torres NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Amanda M. Cappelletti - Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES OCT. 28, 2015 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Dec-21-2011 06:59:28 Last Name First1Allicidle Begin Date -Active Duty Status Active Duty End Date Service Agency WILCOX ROBIN Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). y6t Irill. jo"i - 0 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.m3l/fan/ois/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the https://www.dmdc.osd.mil/appj,:icr;i/poprepon.do[12/21/2011 9:59:38 AM] Request for Military Status President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard°RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:32096M'ESVF https://www.dmdc.osd.mil/appjl!icra/popreport.do[12/21/2011 9:59:38 AM] Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Dec-21-2011 07:00:18 -< Last Name Pilr?stOMddie ' (Begin Date' Active Duty Status Active Duty End Date Service WILCOX RICKY Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). iA jj0jt4_ - In. 4419?_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for, military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 el seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.m6l/faq/pis/PC09SLDR.htmi. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the https://www.dmdc.osd.mil/appj,'scra/popreport.do[12/21/2011 10:00:27 AM] Request for Military Status President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:DQGFFA4673 https://www.dmdc.osd.mil/appj/;cra/popreport.do[12/21/2011 10:00:27 AM] 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 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 DB/A Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-7033 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". SWORN AND SUBSCIjBff?f BEFO E THIS jj?' OF x , 2012 f- OTA PUBLIC G? TERRE CE J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN T. McQUAIL, ESQUIRE MARISA J. COHEN, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary January 4, 2012 To: Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, Pennsylvania 17013 Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co of Pennsylvania VS. Robin L. Wilcox, Original Mortgagor and Real Owner Ricky Wilcox, Original Mortgagor Cumberland County Court of Common Pleas Number 10-7033 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A 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 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 PROV IDE 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, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECI[A DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO T1ENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINON HONORARIO. Cumberland County Bar Association 32 Sou Bedfor treet aarlie'?e Pe 1 ania 17013 BY: //J ? /-? v Attorneys for Plaintiff - TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE hm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary January 4, 2012 To: Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania vs. Robin L. Wilcox, Original Mortgagor and Real Owner Ricky Wilcox, Original Mortgagor Cumberland County Court of Common Pleas Number 10-7033 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A 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 LOSEYOUR 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 PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA sm. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FFCHA DE F,STA 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. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICBJA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. SI USTEDNO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SEA CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 Southe ford e t C?AisleCP' an' 17013 BY: (- % (? Attorneys or Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE hm VERIFICATION The undersigned attorney hereby certifies that he is the Attorney for the Plaintiff in the within action, and that he 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 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 unswom falsification to authorities. - A??c ijx'o_'X? TERRE E J. McCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN T. McQUAIL, ESQUIRE MARISA J. COHEN, ESQUIRE Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7033 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania, Plaintiff (s) From Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor (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: $149,261.38 L.L.: $.50 Interest from 1/17/2012 -- $3,474.74 at $24.47 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $249.00 Other Costs: Plaintiff Paid: Date: 2i 17/12 David D. Buell, Prothonotani (Seal) Deputy REQUESTING PARTY: Name: Marc S. Weisberg, Esquire 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. 16717 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co of Pennsylvania V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor FILE NO.: 10-7033 Civil Term AMOUNT DUE: $149,261.38 INTEREST: from 1/17/2012 $3,474.74 at $24.47 ATTY'S COMM.: C mGU XM z? ?D r- x Dn X c?j D ?- N 0 r? 'T1 M co F _Url C cI r -tcD X -*t C,7 -r' X F; COSTS: _.J N) -j 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 oI' 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) 627 North West Street, Carlisle, Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: February 13, 2012 18.5-0 pd R f? 5q• ,?d c8p 31. 70 q'g.0o lo. 00 rl Signature: ? J((vl? Print Name: MARC S. WEISBERG, ESQ IRE Firm: MCCABE, WEISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16717 oo Pd Af ;z 01a e Co e- -s - / -9-7 Pff - a7/22D )2 e- V11-1 -/- o i rx 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 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 Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-7033 AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. c-a C roa rn03 xrn c»? Tom' t-s Z? -4 ra a r.a _n rn cry 'tT N 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: Robin L. Wilcox, Original Mortgagor and Real Owner 627 N. West Street Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF y 2012 NOTAXY NOTARIAL 8, Brendan Raftery-Notary C.q of Ph WWPhia, Philadelp t Ca my comm Ss pfPlR?7, 2 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 TERRENCE J. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. McQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorney for Plaintiff y j -s r?rt 'V r" CJ -r1 CD CDC) rn 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 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 Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-7033 AFFIDAVIT PURSUANT TO RULE 3129 G N =' C? ?` M .c " M rx? -vm t ?.. MC) CZ I r- '-q © ' )> C:7 rl T,, ? rv _..,? r*t The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 627 North West Street, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owners or Reputed Owners Name Robin L. Wilcox, Original Mortgagor and Real Owner Address 627 N. West Street Carlisle, Pennsylvania 17031 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 Name and address of Defendants in the judgment: Name Robin L. Wilcox, Original Mortgagor and Real Owner Address 627 N. West Street Carlisle, Pennsylvania 17013 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 3 4 5 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address 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 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 627 North West Street Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name None Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 1 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. February 13, 2012 TERRENCE J. McCABE, ESQUIRE DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. McQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situated in the Borough of Carlisle, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: ON the west by North West Street; on the north by property now or formerly of Mrs. Emma Neusbaum; on the east by a 16 foot alley; and on the south by property now or formerly of John Liszman; containing 20 feet in front on said North West Street, and in depth a like width, 190 feet to said alley. HAVING THEREON ERECTED a two-story brick dwelling house with frame back buildings known and numbered as 627 N. West Street, Carlisle, Pennsylvania BEING 627 North West Street, Carlisle, Pennsylvania 17013. BEING the same premises which JANICE L. AUSTIN, SINGLE WOMAN, AND TAMARA C. STOREY, SINGLE WOMAN by deed dated July 28, 2006 and recorded August 15, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 276, Page 851, granted and conveyed to Robin L. Wilcox, single woman.. TAX MAP PARCEL NUMBER: 06-20-1798-019 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 r MARISA J. COHEN, ESQUIRE - ID # 87830 r-nW M -n rn rt r - KEVIN T. McQUAIL, ESQUIRE - ID # 307169 = ? p Q r -0,r, CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 n+- t - C ' BRIAN T. LaMANNA, ESQUIRE - ID # 310321 3r' 2 J -t ? 123 South Broad Street, Suite 2080 C? -v Philadelphia, Pennsylvania 19109 c-? C") ?c :, (215) 790-1010 N - -?` CIVIL ACTION LAW Beneficial Consumer Discount Company D/B/A COURT OF COMMON PLEAS Benefical Mortgage Co of Pennsylvania CUMBERLAND COUNTY V. Robin L. Wilcox, Original Mortgagor and Real Owner Number 10-7033 and Ricky Wilcox, Original Mortgagor NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robin L. Wilcox, Original Mortgagor and Real Ricky Wilcox, Original Mortgagor Owner 320 Mountainview Road 627 N. West Street Mount Holly Springs, Pennsylvania 17065 Carlisle, Pennsylvania 17013 Your house (real estate) at 627 North West Street, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on June 6, 2012 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 $149,261.38 obtained by Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co 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: The sale will be canceled if you pay to Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co 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. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE L 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situated in the Borough of Carlisle, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: ON the west by North West Street; on the north by property now or formerly of Mrs. Emma Neusbaum; on the east by a 16 foot alley; and on the south by property now or formerly of John Liszman; containing 20 feet in front on said North West Street, and in depth a like width, 190 feet to said alley. HAVING THEREON ERECTED a two-story brick dwelling house with frame back buildings known and numbered as 627 N. West Street, Carlisle, Pennsylvania BEING 627 North West Street, Carlisle, Pennsylvania 17013 BEING the same premises which JANICE L. AUSTIN, SINGLE WOMAN, AND TAMARA C. STOREY, SINGLE WOMAN by deed dated July 28, 2006 and recorded August 15, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 276, Page 851, granted and conveyed to Robin L. Wilcox, single woman.. TAX MAP PARCEL NUMBER: 06-20-1798-019 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 Benefical Mortgage Co of Pennsylvania Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-7033 AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 x°ara y -Y'; -p p? f V - -v n Q P The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 1 1 th day of April, 2012, 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 BEFO; MET IS AY OF /!. ..412 NOTARY PUBLIC Barbary, J C'tiy of Philad?;r`? -, w,.,w ,panty MY COMMISSION E?1'IRRS JRN.12, 2014 McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff By: TENWSBERG, CABE, ESQUIRE - ID # 16496 MAESQUIRE - 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 Attorney for Plaintiff Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company D/B/A Benefical Mortgage Co of Pennsylvania Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-7033 V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants 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 627 North West Street, Carlisle, Pennsylvania 17013, 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 Robin L. Wilcox, Original Mortgagor and Real Owner Address 627 N. West Street Carlisle, Pennsylvania 17031 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 Name and address of Defendants in the judgment: Name Robin L. Wilcox, Original Mortgagor and Real Owner Address 627 N. West Street Carlisle, Pennsylvania 17013 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address 4 5 Plaintiff herein 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 Address 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 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 627 North West Street Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c" o Atty General of the United States Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept. of Justice, Rm. 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept. of Justice, Rm. 4400 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 unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. April 11, 2012 Attorneys for Plaintiff DATE 11 By: TERRENCE . McCABE, ESQUIRE MARC S. ISBERG, 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 Benefical Mortgage Co of Pennsylvania COURT OF COMMON PLEAS Plaintiff V. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants DATE: April 11, 2012 TO: ALL PARTIES IN INTEREST AND CLAIMANTS CUMBERLAND COUNTY Number 10-7033 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor PROPERTY: 627 North West Street, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on June 6, 2012 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. 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TY Our File nmevcat Uonsumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania, Plaintiff, Vs. Robin L. Wilcox, Original Mortgagor and Real Owner Ricky Wilcox, Original Mortgagor, Defendants COURT OF COMMON PL CUMBERLAND COUNTY No.: 10-07033 Withdrawal of A©©earance WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Plaintiff, Beneficial Consumer Company D/B/A Beneficial Mortgage Co of Pennsylvania. MILSTEAD & ASSOCIATES, LLC DATED: BY: PA S ESQ Attorney ID No. 314 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,- t_' ~ r ' ;_ ~ ~ i ,; r~ Sheriff I ~~E tJ n .~) t P t ~ ~,} ~' ; , I ;. ;_ at ~~„r,t~~~. ~~~~x l`''td ^r. Jody S Smith <<, t ~ ~~Q ~ ~ ~ PPS ~: Chief Deputy Richard W Stewart "~~~E~~-A~`+U t;t~(~~~~'°~ solicitor ~~~~~ PENNY Yi.VA!~IA Beneficial Consumer Discount Company Case Number vs. 2010-7033 Ricky Wilcox (et al.) SHERIFF'S RETURN OF SERVICE 03/26/2012 04:48 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 627 N. West Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 03/27/2012 07:34 PM -Deputy Robert Bitner, 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 ELIZABETH HAMILLA-GIRLFRIEND RB, who accepted as "Adult Person in Charge" for Ricky Wilcox at 320 Mountainview Road, South Middleton Township, Mount Holly Springs, PA 17065, Cumberland County. 03/28/2012 11:53 AM -Deputy Gerald Worthington, 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 Joyce Nicholson - lives at address with Robin, who accepted as "Adult Person in Charge" for Robin L. Wilcox at 627 N. West Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 05/31/2012 As directed by Mary L. Harbert-Bell, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/8/2012 07!26/2012 As directed by Mary L. Harbert-Bell, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/3/2012 10/03/2012 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, Carlise, PA on October 3, 2012 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Terrance McCabe, on behalf of Beneficial Consumer Discount Company, D/B/A Beneficial Mortgage Co of Pennsylvania, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $827.14 SO ANSWERS, ~~ -°- w. November 20, 2012 RON R ANDERSON, SHERIFF ~l~ ~ D6 pal . sa ~,~. ~- County9uite Shrri;7, 7~crsoa. Inc ~ ~ ~~ McCABE; WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 ' MARC S. WEISBERG, ESQUIItE - 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 - m # 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 Attorneys for Plaintiff Beneficial Consumer Discount Company DB/A CUMBERLAND COUNTY Benefical Mortgage Co of Pennsylvania COURT OF COMMON PLEAS Plaintiff NO: 10-7033 v. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Defendants AFFIDAVTT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 627 North West Street, Carlisle, Pennsylvania 17013, 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 Address Robin L. Wilcox, Original Mortgagor 627 N. West Street and Real Owner Carlisle, Pennsylvania 17031 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 2. Name and address of Defendants in the judgment: Name Address Robin L. Wilcox, Original Mortgagor 627 N. West Street and Real Owner Carlisle, Pennsylvania 17013 Ricky Wilcox, Original Mortgagor 320 Mountainview Road Mount Holly Springs, Pennsylvania 17065 ~. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address 4 5 Plaintiff herein 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 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 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 627 North West Street Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sates United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 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 unsworn falsification to authorities. ~;~V February 13.2012 TERRENCE J. McCAB , E QUIRE DATE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. McQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BYc TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIltE - 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 Attorneys for Plaintiff CIVIL ACTION LAW Beneficial Consumer Discount Company DB/A Benefical Mortgage Co of Pennsylvania COURT OF COMMON PLEAS CUMBERLAND COUNTY v. Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor Number 10-7033 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Robin L. Wilcox, Original Mortgagor and Real Ricky Wilcox, Original Mortgagor Owner 320 Mountainview Road 627 N. West Street Mount Holly Springs, Pennsylvania 17065 Carlisle, Pennsylvania 17013 Your house (real estate) at 627 North West Street, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on June 6, 2012 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 $149,261.38 obtained by Beneficial Consumer Discount Company DBlA Benefical Mortgage Co 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: The sale will be canceled if you pay to Beneficial Consumer Discount Company DB/A Benefical Mortgage Co 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. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To fmd 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situated in the Borough of Carlisle, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: ON the west by North West Street; on the north by property now or formerly of Mrs. Emma Neusbaum; on the east by a 16 foot alley; and on the south by properly now or formerly of John Liszman; containing 20 feet in front on said North West Street, and in depth a like width, l 90 feet to said alley. HAVING THEREON ERECTED atwo-story brick dwelling house with frame back buildings known and numbered as 627 N. West Street, Carlisle, Pennsylvania BEING 627 North West Street, Carlisle, Pennsylvania 17013. BEING the same premises which JANICE L. AUSTIN, SINGLE WOMAN, AND TAMARA C. STOREY, SINGLE WOMAN by deed dated July 28, 2006 and recorded August 15, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 276, Page 851, granted and conveyed to Robin L. Wilcox, single woman.. TAX MAP PARCEL NUMBER: 06-20-1798-019 ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-7033 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Beneficial Consumer Discount Company DB/A $enefical Mortgage Co of Pennsylvania, Plaintiff (s) From Robin L. Wilcox, Original Mortgagor and Real Owner and Ricky Wilcox, Original Mortgagor (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: $149,2b1.38 Interest from 1/17/2012 -- $3,474.74 at $24.47 Atty's Comm: Atty Paid: $249.00 Plaintiff Paid: Date: 2/17/12 L.L.: $.50 Due Prothy: $2.25 Other Costs: David D. Buell, Prothono (Seal) Deputy REQUESTING PARTY: Name: Marc S. Weisberg, Esquire 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. 16717 TRUE COPY FROM RECORD In Testimony whereof, l here unto set my hand and the se of saki Court st slo, Pe. This ~ day d _, 20 Prothonotary s~~e ~~~ On March 2, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland CQUn y, PA, known and numbered 627 N. west Street, Carlisle, PA 17Q13 more fully described on Exhibit"A" filed with t-his writ and by this reference incorporated herein. Date: March 2, 2012 For Claudia Brew~al~er, Real Estate Coordinator ba:x..;, ,. s . G. _ ..._._... g.l~~.g~.~'~, ~..~_~ ~~,~ ~I~~ ~~.;:ro z 3 Writ No. 2010-7033 Civil Term Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania vs. Robin L. Wilcox, Original Morgagor and Real Owner and Ricky Wilcox, Original Morgagor Atty.: Marc S. Weisberg ALL THAT CERTAIN lot of ground situated in the Borough of Carlisle, County of Cumberland, and State of Pennsylvania, bounded and de- scribed as follows, to wit: ON the west by North W est Street; on the north by property now or for- merly of Mrs. Emma Neusbaum; on the east by a 16 foot alley; and on the south by property now or formerly of John Liszman; containing 20 feet in front on said North West Street, and in depth a like width, 190 feet to said alley. HAVING THEREON ERECTED a two-story brick dwelling house with frame back buildings known and numbered as 627 N. West Street, Carlisle, Pennsylvania BEING 627 North West Street, Carlisle, Pennsylvania 17013. BEING the same premises which JANTCE L. AUSTIN, SINGLE WOM- AN, AND TAMARA C. STOREY, SIN- GLE WOMAN by deed dated July 28, 2006 and recorded August 15, 2006 in the office of the Recorder in and for Cumberland County in Deed Book 276, Page 851, granted and conveyed to Robin L. Wilcox, single woman. TAX MAP PARCEL NUMBER: 06- 20-1798-019 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 27, May 4, and May 11, 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. --._._ Lis arie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 1 da of Ma 2012 ~/. Notary ~~i~ NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE 80ROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 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 Beneficial Mortga eg Co of Pennsylvania is the grantee the same having been sold to said grantee on the 3rd day of October A.D., 2012, under and by virtue of a writ Execution issued on the 17th day of February, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7033, at the suit of Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of Pennsylvania against Robin L. Wilcox and Ricky Wilcox is duly recorded as Instrument Number 201236018. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ D day of _, A.D. ~- U ~ a. Rec er of Deeds Recorder d Deeds, dRnberlsnd Cwk~r, t~Asle, AA My ~ Expres ttte Fist ~londgi of Jen. 2D14 '~ .~. ~ M g o`°o~t~°OO~o~£~roO c."~ ~v~S'Z ~•° S~~"~ B ~~~~ ~ ;;~ ~ ~ 0 ., c{ ~ CC~c ~ ~ ~ A Q O O ~ '_A, _ c~ ~~T _ ro ~ °' ry go. (~ ~ `° ~ Z ~- ~ c o` ~, d ~o .~ a ~.~ f"1 A p '9 ~ m o Mn ~..~ g~ o °~, nQ~ Ci7' y~~, w a. ~ C7 ~a'. ~ ~.~ w o 0 0 ~ ~ a. S ~ ~ X21 ~ ~ Y' 7y ~ fn' ~ .~ Z E,` n~ ce w ~ a ty < ~ la m ~ O " 'L c 5 rn ° 6 ~ry3 ~u z~o ~~~~ g ~~,~.~_~ ~ ~ ~ M 4--- - - m I O i ~ Q p ! ~ p N -7 ~ K ~ 40~~ o -~ n 3mro ~ 6 1 Tl V ~ U ~`~ ~ (~ > ~ z~ °c' ° ~ r±s z ~ ~ ~ ~ z o w ' °` o c -4 z ev c CT p3~. r o+ ~~ O 7 Q N 7 Q C ~' N ~'. ni ~-, _.. Q _ 6 ,. ~-_ •- _y, ~,,......._ . ~ •~ .: ~~._.~: to .r~~-~_'.% N ' N . ;r, ~c o ill N O ' N ~_ N a o~ 0 7 S f9 a d US N S ~i'he Patriot-Nevus 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 ~latriot-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 faw, 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. pi Ri iCATION COPY This ad ran on the date(s) shown below: . 'I ~ 04/27/12 05/04/12 '~ °~ 05/11/12 ~{ I~ ~~ -- ~ i i ........ ,. Sworn t s scribed b fore m thi 2 d f iMay, 2012 A.D. ~. nu, - -- d ~ _~ >> i ,', ~{ _ _ _~~, C1N ~` '~ ~ ~ ~ ~ ~ Notary Public ., ~rM" : ' >`~ ~ ~ COMMONWERL7`M pF PENNSYLVANIA Notarial Seal Sherrie L. OvrenS, Notary Public i per. Lower Paton Twp., Dauphin County ~. Y ~ My Commission Expires Nov. 26, 2015 ~I iii ~, MEMBER, PENNSY~'JANIA ASSOCIATION OF NOTARIES