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HomeMy WebLinkAbout10-7560Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 It rancis S. Hallinan, Esq., Id. No. 62695 ~~~, ~~` Q~ F ~ ~ ~ Daniel G. Schmieg, Esq., Id. No. 62205 ~ ~ ~ ~ E }~ ~ Q~ ~ ~ ~~ ~ ~~ ~.~ Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 2~ (~ ~E~ "$ A~ ~Q~ ~} Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ~L-MBERL~fidD C~t1NTY Lauren R. Tabas, Esq., Id. No. 93337 ~E~~rY~V~~~A Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 245254 GMAC MORTGAGE LLC, S/UI TO GMAC MORTGAGE CORPORATION 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 v. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ~ (~ --~ S CD U TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF CUMBERLAND COUNTY WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 7887 KUHN ROAD GREENCASTLE, PA 17225 WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 Defendants CIVIL ACTION -LAW ~ ~ ~p Q~ COMPLAINT IN MORTGAGE FORECLOSURE Q~~ yGt~~s~~, .~YJ3 File #: 245254 C~~a ~ a,, (s NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 File #: 245254 1. Plaintiff is GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 7887 KUHN ROAD GREENCASTLE, PA 17225 WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIl'PENSBURG, PA 17257-9648 who is/are the real owner(s) of the property hereinafter described. 3. On 10/06/1995 WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. and JANET M. MILLHOUSE made, executed and delivered a mortgage upon the premises hereinafter described to PHH MORTGAGE SERVICES CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1287, Page 1053. By Assignment of Mortgage recorded 07/07/1999 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 618, Page 431. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with File #: 245254 Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach 4. 5. 6. documents to pleadings if those documents are of public record. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01 /2010 and each month thereafter aze due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon aze collectible forthwith. The following amounts aze due on the mortgage: Principal Balance $47,720.90 Interest $1,439.91 03/01/2010 through 07/17/2010 (Per Diem $10.6046) Attorney's Fees $650.00 Late Charges through 07/17/2010 $186.32 Property Inspections/Property Preservations $45.00 Costs of Suit and Title Seazch 550.00 Subtotal $50,592.13 Suspense Credit ($420.16) Escrow Credit 1 472.37 TOTAL $48,699.60 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a dischazge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability dischazged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 245254 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. By virtue of the death of JANET M. MILLHOUSE on 07/26/08, WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. became the sole owner of the mortgaged premises as surviving tenant by the entireties. 10. Mortgagor WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. died on 12/16/09 and upon information and belief, his surviving heir(s) are TONYA S. MILLHOUSE and WENDELL E. MILLHOUSE, JR. 11. Plaintiff contacted the Register of Wills of Cumberland County and was informed as of 11/10/10 no estate has been raised on behalf of the decedent mortgagor. 12. Plaintiff hereby releases WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. and JANET M. MILLHOUSE from liability for the debt secured by the mortgage. 13. Plaintiff does not hold the named Defendant(s), TONYA S. MILLHOUSE and WENDELL E. MILLHOUSE, JR., personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendant(s) in the aforesaid real estate only, and the Defendant(s) have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa C.S.A. § 301(b). File #: 245254 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $48,699.60, together with interest from 07/17/2010 at the rate of $10.6046 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALE G, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff File #: 245254 LEGAL DESCRIPTION ALL that certain tract of land situate in the Village of Lees Cross Roads, Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows, to-wit: ON the West by land now or formerly of Elmer Black; on the East by land now or formerly of Casimer J. Gadomski and Olga J. Gadomski; on the South by a fourteen (14) foot wide alley; and on the North by the Walnut Bottom Road. Containing in front on said Walnut Bottom Road fifty (50) feet and extending in depth to the said alley two hundred forty-seven (247) feet, more or less, and having thereon erected atwo-story frame dwelling house and other buildings, and being known as 626 Walnut Bottom Road. PROPERTY ADDRESS: 626 WALNUT BOTTOM ROAD, SffiPPENSBURG, PA 17257- 9648 PARCEL # 39-33-1883-042 File #: 245254 VERIFICATION '~'~'"~' ,hereby states that he/she is. GMAC MORTGAGE, LLC, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsificatic~rrt~uthorities. DATE: 1 File #: 245254 /l j N111 Vi _ ~ ~. Title:~~~~~~~ ~~~~ ~~~'J~.~ Servicer: GMAC MORTGAGE, LLC Name: MILLHOUSE M N C) SHERIFF'S OFFICE OF CUMBERLAND COUNTY, Ronny R Anderson " ` - M- Sheriffr ? Jody S Smith 4,01111 Chief Deputy z a o? Richard W Stewart - x c? Solicitor- r't GMAC Mortgage, LLC vs Case Number . Wendell E. Millhouse, Jr. (et al.) 2010-7560 SHERIFF'S RETURN OF SERVICE 12/10/2010 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: Tonya S. Millhouse, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/14/2010 06:15 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on December 14, 2010 at 1615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Wendell E. Millhouse Jr., by making known unto himself personally, at 626 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. STEPHE ENDER, DEPUTY 12/15/2010 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: Unknown Heirs, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Unknown Heirs. Request for service at 626 Walnut Bottom Road, Shippensburg, Pennsylvania 17257 is only occupied by current owner, Wendell E. Millhouse Jr. 12/28/2010 01:00 PM - Franklin County Return: And now December 28, 2010 at 1300 hours I, Dane Anthony, Sheriff of Franklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Tonya S. Millhouse by making known unto Deborah Deshong, adult in charge at 7887 Kuhn Road, Greencastle, Pennnsylvania 17225 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $92.00 January 11, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ,1' CountySu-te She'd Iete^so'i. Ire. SHERIFF'S RETURN - REGULAR CASE NO: 2010-00305 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN GMAC MORTGAGE LLC ET AL VS TONYA S MILLHOUSE WILLIAM M KAUFFMAN , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon MILLHOUSE TONYA S the DEFENDANT , at 1300:00 Hour, on the 28th day of December , 2010 at 7887 KUHN ROAD GREENCASTLE, PA 17225 by handing to DEBORAH DESHONG (CAREGIVER) a true and attested copy of COMP MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge .00 So Answers: .00 WILLIAM /M KAUFFMAN .00 .00 By .00 Deputy Sheriff .00 01/06/2011 PHELAN HALLINAN AND SCHMIEG Sworn and Subscribed to before me this day of (Jowvzz °2&tt A.D. A - . / COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL RICHARD D. McCARTY, Notary Public Chambersburg Boro., Franklin County My Commission Expires Jan. 29, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor $ it H, ] I I I"P R,, -33 l? I 'J BEtI L ' i,10 GMAC Mortgage, LLC Case Number vs. Wendell E. Millhouse, Jr. (et al.) 2010-7560 SHERIFF'S RETURN OF SERVICE 02/28/2011 07:28 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, tes that on February 28, 2011 at 1928 hours, he served a true copy of the within Complaint in age Foreclosure, upon the within named defendant, to wit: Unknown Heirs, pursuant to order of cou by osting the premises located at 626 Walnut Bottom Road, Shippensburg, Cumberlan ount , Pe nsylvania 17257 with a true and correct copy according to law. SH N HARRISON, DEPUTY SHERIFF COST: $52.00 March 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF -ruFFICE 2511 MAR I I APB 9- 53 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq. Id No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/M TO GMAC MORTGAGE CORPORATION Plaintiff CUMBERLAND COUNT'k PENNSYLVANIA ATTORNEYS FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED : CUMBERLAND COUNTY NO. 10-7560 W- ) 0 'UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following persons, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED at 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257; on MARCH 10, 2011, in accordance with the Order of Court dated FEBRUARY 7, 2011. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to uns rrfa,),sification to authorities. Date: March 10, 2011 PHELAN AN & SCH 41EG, LLP By: PHS# 245254 Lawrence T. X0, Esq., Id. No. 32227 Francis S. 1 ' an, Esq., Id. No. 62695 Daniel G. ieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 8443 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq. Id No. 309519 William E. Miller, Esq., Id. No. 308951 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells Esq., Id No. 309519 William E. Miller, Esq., Id No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC Mortgage LLC, S/M To GMAC Mortgage Corporation Plaintiff VS. Tony S, Millhouse, In Her Capacity as Heir of Wendell E. Millhouse A/K/A Wendell E. Millhouse, Sr. Deceased Wendell E. Millhouse, Jr. In His Capacity as Heir of Wendell E. Millhouse A/K/A Wendell E. Millhouse, Sr. Deceased Unknown Heirs, Successors, Assigns, and All Persons, Firms, or Associations Claiming Right, Title or Interest From or Under Wendell E. Millhouse A/K/A Wendell E. Millhouse, Sr. Deceased Defendants I CL r [°L pf'r, t ?IONOTAR ,{ { ia,tl 2 AM COWM PENNSYLVANIA ATTORNEYS FOR PLAINTIFF Court of Common Pleas : Civil Division : Cumberland County : No. 10-7560 AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the Court Order dated February 7, 2011 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)(1) in The Sentinel on March 12, 2011 and Cumberland Law Journal on March 18, 2011. Proofs of the said publications are attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. PHELAN HALLINAN & SCHMIEG, LLP By: Phe Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 20677 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq., Id No. 309519 William E. Miller, Esq., Id No. 308951 Attorneys for Plaintiff Date: March 24, 2011 PHS # 245254 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general - circulation in the Borough of Carlisle, County and State aforesaid, was established December 13tb,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 12, 2011 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are e. i Sworn to and subscribed before me this &u qjc? Lk 2-0 l ?1o Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tackie Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): March 12, 2011 COPY OF NOTICE OF PUBLICATION A z a J Y (4 z z S6 0 Z O J D WO U LLa O¢< Cal WmJ W:)0 zwV ZOa Za, F Wj 0 Ha a0 Oz UV OIL Z0 I.- 0 v W S 1- z a w a r z z O D g O ? 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W Q ¢W w c" 0 ¢gYCOr °v C W J 0«m UU Q W W 0 C5 cc 7 J¢0?O O W V ae J 0c ?m m m E n W w U w oHm OLL m J oam¢ ¢ ? Oa ? i E+ ? 0 W tt 0 U ? F-O LL O 0 ZpCF a 0 -OW Cm0 = ?-- O x m-'« a- LL .- W U) O" -'wBWJ KW WE)o o ' Z ¢c a o Q) 10 c>, ? 33 O m m¢ F¢°m C6 LU z Z C=1 ma ° ` ° JO W2 U}Z?U ( '.) (A? m 40C - M m m - g 11 a 0 C 7m TF 3a C«0 a Cl) a 0 o :2 ? V 0 a m 8? C 7 O H J H co Wm ¢ ) a3 pW 0m i E "'TO cc a W a O 0 ?LL ? LLZ-0 L J a 0 ~, WW j OW WW E C U =z U A? oa _ T '-L ?- co 7 < l UW U ¢ CC(WL 0- °. 0, ?'; A- W aZw wO Np L) < LL i ? - UH 22 (mo «amOT ac O0 Y .E W ErnOSlLLi3¢?Z (AZ '00- 0 0 0 vrn 0-0 °om=FOJIOO Cr CC CL (De 0 sWW .Om« 0 C0 ° ?tm«Fw?pOW 11 2 ZJ¢ 3 U ja 2,0., a mD 0zMzPQ v= °rnm°'S=Q2W ph ZF-o LOEon L? w pm=WjUffj Zx _ ma[00 M? 3; a(nJJU0o LLW ? 0¢m U` r°?L o n i.5 E.OFa ?m Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 March 18, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 18 day of March, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 10-7560 GMAC MORTGAGE LLC, s/i/i TO GMAC MORTGAGE CORPORATION VS. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED NOTICE TO UNKNOWN HEIRS, SUCCES- SORS, ASSIGNS, AND ALL PER- SONS, FIRMS, OR ASSOCIA- TIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED: You are hereby notified that on DECEMBER 8, 2010, Plaintiff, GMAC MORTGAGE LLC, s/i/i TO GMAC MORTGAGE CORPORA- TION, filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUMBERLAND County, Pennsylvania, docketed to No. 10-7560. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 626 WALNUT BOTTOM ROAD, SHIP- PENSBURG, PA 17257 whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 Mar. 18 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 .-- t. W - Andrew L. Spivack, Esq., Id. No. 84439 gam . . Chrisovalante P. Fliakos, Esq., Id. No. 94620 err' f'?-- Joshua I. Goldman, Esq., Id. No. 205047 Z;7 ` Courtenay R. Dunn, Esq., Id. No. 206779 - _ Andrew C. Bramblett, Esq., Id. No. 208375 c) -n Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 r 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION VS. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-7560 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED, WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR oty,} 314.00 ?-A a*y 1A0313 245254 k,680'11 's'11 e?i ee ?AQ?.\ed OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED, and UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $48,699.60 Interest - 07/18/2010 to 04/19/2011 $2,926.87 TOTAL $51,626.47 I hereby certify that (1) the Defendants' last known address is 7887 KUHN RD, GREENCASTLE, PA 17225-9774, and mortgaged premises located at 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-9648, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date R I t ? La c T. Phelan, sq., Id. No. 32227 ? Fra cis . Hallinan, 96q., Id. No. 62695 ? D niel . Schmie sq., Id. No. 62205 ? Michele ord, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. F liakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ` ?? tt DATE: `?i o?D' I PHS # 245254 PROTHONOT RY CC: TERRY WEIGLE, ESQUIRE 126 EAST KING STREET, SHIPPENSBURG, PA 17257 245254 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION : CUMBERLAND COUNTY : COURT OF COMMON PLEAS VS. : CIVIL DIVISION TONYA S. MILLHOUSE, IN HER CAPACITY No. 10-7560 AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: 245254 (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant TONYA S. MILLHOUSE is over 18 years of age and last known address is 7887 KUHN RD, GREENCASTLE, PA 17225-9774, and mortgaged premises located at 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-9648. (c) that defendant WENDELL E. MILLHOUSE, JR is over 18 years of age and resides at 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-9648. (d) that Plaintiff is without information sufficient to determine whether the defendant(s) UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; and (e) that Plaintiff is without information sufficient to determine whether defendant UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED is over 18 years of age and resides at 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257- 9648. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date L LJ Lawr4 e T. Phelan, sq., Id. No. 32227 ? Fra cis S. allinan, sq., Id. No. 62695 ? Daniel G. hmi ,Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 245254 (Rule of Civil Procedure No. 236) - Revised GMAC MORTGAGE LLC, S/I/I TO GMAC : CUMBERLAND COUNTY MORTGAGE CORPORATION VS. COURT OF COMMON PLEAS TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., CIVIL DIVISION DECEASED WENDELL E. MILLHOUSE, JR, IN HIS No. 10-7560 CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED . UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Notice is given that a Judgment in the above captioned matter has been entered against you on Y By: If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? ndrew L. Spivack, Esq., Id. No. 84439 RChrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS ISNOTAND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY" 245254 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7560 CUMBERLAND COUNTY TO: TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 7887 KUHN RD GREENCASTLE, PA 17225-9774 DATE OF NOTICE: April 8, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 245254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARENCE 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 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 ----Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 245254 GMAC MORTGAGE LLC, S/1/1 TO GMAC MORTGAGE CORPORATION Plaintiff V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7560 CUMBERLAND COUNTY TO: TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED C/O JERRY WEIGLE, ESQUIRE 126 E KING ST SHIPPENSBURG, PA 17257 DATE OF NOTICE: April 8, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 245254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARENCE 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 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 ,-rr-ancis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 245254 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7560 CUMBERLAND COUNTY TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 DATE OF NOTICE: April 8, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 245254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARENCE 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 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: rence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 245254 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7560 CUMBERLAND COUNTY TO: WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 DATE OF NOTICE: April 8, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 245254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARENCE 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 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 --Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 245254 GMAC MORTGAGE LLC, S/111 TO GMAC MORTGAGE CORPORATION Plaintiff V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7560 CUMBERLAND COUNTY TO: TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 DATE OF NOTICE: April 8, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 245254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARENCE 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 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 'Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Brambiett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 245254 AFFIDAVIT OF SERVICE (FHLMQ PLAINTIFF CUMBERLAND COUNTY GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION PHS # 245254 = r? r? DEFENDANT SERVICE TEAM/ Ixh x' -• TONYA S. MILLHOUSE COURT NO.: 10-7560 M ?- WENDELL I. MILLHOUSE, JR -urn UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL O f. " PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. C r MILLHOUSE, DECEASED SERVE WENDELL E. MILLHOUSE, JR AT: TYPE OF ACTION 626 WALNUT BOTTOM ROAD XX Notice of Sheriffs Sale ' SHIPPENSBURG, PA 17257-9648 SALE DATE: 09/07/2011 SERVED Served and made known to WENDELL E. MILLHOUSE, JR , Defendant on the vlf day of , 20 -L( , at 9 3 q o'clock A. M., at &U tit O-Nu'r 9077VM ZAP, in the manner described below: Defendant personally served. 50-1 pp&N%130A&,YI-, - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age 'JDs Height / Weight 15-0 Race W Sex M Other 1, _R 1V?-t?D t.L , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: NAME: PRINTED NAME: 2dNa /V?Q L L TITLE: Nick !; 6,r--A W, NOT SERVED On the day of , 20-, at - o'clock _. M., Defendant NOT FOUND because: _ Vacant . _ Does Not Exist - Moved _ Does Not Reside (Not Vacant) _ No Answer on at , Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 One Penn Center at Suburban Station OPWI AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY GMAC MORTGAGE LLC, S/M TO GMAC MORTGAGE -? CORPORATION PHS # 245254 fTI DEFENDANT SERVICE TEAM/ lxh -C? ? Q TONYA S. MILLHOUSE COURT NO.: 10-7560 WENDELL E. MILLHOUSE, JR NN UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL Y' 9a T PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, C- TITLE OR INTEREST FROM OR UNDER WENDELL E. ,? c Wy MILLHOUSE, DECEASED SERVE TONYA S. MILLHOUSE AT: TYPE OF ACTION 7887 KUHN ROAD XX Notice of Sheriffs Sale GREENCASTLE, PA 17225-9774 SALE DATE: 09/07/2011 SERVED erved and mad known to TONYA S.PKIj HCUS efendant on th? day of 20 ff at o'clock . M., at "e manner descr>ib bel efendant rsonally erved. 'F eP P Ca 5 t l dult family membe with hom Defendants resides . N (? ? "e rL N e Relationship is -A'USLOO CO'K z ? _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Des tion: Age --+---r-Ileigh eight Race Sex Other ?a ?pbt t, hereby verify that I personally handed a true and correct copy of the 'e tul Notice of Sheriffs Sale in the manner as set forth herein, issued m th ptioned case on the date and at th ddress indicated above. understand that this statement is made subject t e ti s of 18 Pa. C.S. c. 4 r ati to unsworn falsific ionn to thorities. DATE: r1C? // N PRINTE IvT TITLE: r` o, 5 e NOT SERVED On the __ day of , 20_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Schemer, Esq., Id. No. 308912 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 GMAC MORTGAGE LLC, S/I/I to GMAC MORTGAGE CORPORATION PLAINTIFF V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED, WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, SR., DECEASED, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-7560 CIVIL ORDER OF COURT I4] ry ? ice") --•-• 4 fi Cnr- W -iar, J i-. .? 4r' r. la's Cs AND NOW, this 24th day of June, 2011, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendants will file an answer on or before July 14, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendants file an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, M. L. Ebert, Jr., J. ""William Miller, Esquire I Attorney for Plaintiff 00pies Jerry Weigle, Esquire ?/, /0 bas T -;l ED-OFFICE W I HL PROTHONOTARY 2011 JUL I I AM 9: 28 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Court of Common Pleas Civil Division CUMBERLAND County No.: 10-7560 Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's June 24, 2011 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. 245254 TONYA S. MILLHOUSE 7887 KUHN ROAD GREENCASTLE, PA 17225-9774 TONYA S. MILLHOUSE 126 E KING STREET SHIPPENSBURG, PA 17257-1326 DATE: j By: TONYA S. MILLHOUSE WENDELL E. MILLHOUSE, JR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 Phelan Hallinan No. 32227 U Francis S. Halli/Esq., o. 62695 ? Daniel G. Schmo. 62205 Michele M. BraNo. 69849 ? Judith T. Roman. 58745 ? Sheetal R. Shah No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andre amblett, Esq., Id. No. 208375 ison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 245254 t Phelan Hallin & Schtnie LLP 1617 JFK Boule ard, Suite X00 ppn Peen Center Plaza Philadelphia PA 19103 215-563-7040 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff, V. TONYA S. MILL OUSE, IN HER CAPACITY AS HEIR OF WEND LL E. MILLHOUSE, A/K/A WENDELL E. M LLHOUSE, SR., DECEASED WENDELL E. M LLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WE DELL E. MILLHOUSE, A/K/A WENDELL E. M LLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WEND LL E. MILLHOUSE A/K/A WENDELL E. M LLHOUSE, SR., DECEASED Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-7560 c? c? rnM Xx cn ? Y 1 2a• C *.3 c-? s ---r? rnr I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail to UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED on MAY 23, 2011 in accordance with the Order of Court dated FEBRUARY 7, 2011. The property was posted on MAY 28, 2011. Publication was advertised in CUMBERLAND LAW JOURNAL on JUNE 10, 2011 & in THE SENTINEL on JUNE 3, 2011. The undetsigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unsworn falsification to authorities. P el Hallinan & Schmieg, LLP DATE: By: ? Lawrence T. Phelan, Esq., . No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF v ?w Ay? RIN ,,IBS FILE copy POSERJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION V. COURT OF COMMON PLEAS CIVIL DIVISION TONYA S. MI? LHOUSE, IN HER CAPACITY AS HEIR OF WE DELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED ET AL. ORDER NO.: 10-7560 CUMBERLAND COUNTY AND NOW, this day of ?-eb , 2011, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint and all future pleadings on the UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER WENDELI, E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED by publication of the complaint in accordance with Pa. R.C.P. 430(b)(1); and by mailing a true and correct copy of t e complaint by Regular mail; and by posting the mortgaged premises at 626 Walnut Bottom Load, Shippensburg, PA 17257-9648. r It is f u kher ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of ser*ice with the Prothonotary's office to assure compliance with this court order. OY THE COURT: J. a° a° ? M g o aqi b I1 ? b c0 ~ N N zao 4 rF'.s lr ? V ? ?. ? g ed? 1 " t ? K i F y C Y -? vox x Q ?.? 6 ant z3 3I.., i ww 0 a ao ??} ,y. u ' Z dw d , tiw a 0 ii A ? 00 c a cx r vi u ? Z y a 2 CIO= o 1 N? ?U .. - ova a,?? °';,•s`'"'t ?? ? td ..A ?' od rsltn ? i pG 3 $`O ^ ?'3 "' ^ V a t a ea o er ^ ZC7 Z Qw w E u?d IL p, s.°La' o 04 e 6? `r?i ° a $' oa, s c o CC a a d?-? a ae ?3,? 4. I o o a ?; a o °? ? 8 w° °?° (?° a qcG ? t U 3 ?a w z o?3Qw a w ? i * * * * * * _"...__.......?. __ _.....__ .. : .i I M ' •0' V I 00 z AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY GMAC MORTGAGE LLC, S/UI TO GMAC MORTGAGE CGRPORATION PHS # 245254 DEFENDANT SERVICE TEAM/ lxh TONYA S. MILLH SE COURT NO.: 10.7560 WENDELL E. MIL OUSE, JR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, R ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTE T FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED SERVE UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL TYPE OF ACTION PERSONS, FIRMS, R ASSOCIATIONS CLAE IING RIGHT, XX Notice of Sheriff's Sale TITLE OR INTEREST FROM OR UNDER WENDELL E. SALE DATE: 09/07/2011 MILLHOUSE, DEC ASED AT: 626 WALNUT BO M ROAD SHIPPENSBURG, P 17257-9648 **Please post proper per court order** SERVED Served and made kn?wn to UNKNOWN HEIRS. SUCCESSORS. ASSIGNS, AND ALL PERSONS. FIRMS OR DECEASED , Defer dant on the 2?8"flay of /144 J- 20 11, at =3O'clockh. M, at &U WALNUT I 7YoM J?Aqp , in the manner described below: - Defendant personally served. SkIPPENS60-4, Qq, - Adult family member with whom Defendant(s) reside(s). Relationship s - Adult in charge o Defendant's residence who refused to give name or relationship. - Manager/Clerk o place of lodging in which Defendant(s) reside(s). _ Agent or person i charge of Defendant's office or usual place of business. an officer of said Defendant's company. -Other: )?aSfi*p_-?" P2d;QP../t7`y Desc?.kon: Age Height Weight -Race_ Other 1, X/ D W69, L- , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs S le in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to allies of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: t NAME: PRINTED NAME: P-vNkc-D ! AO ( L- TITLE: f iI?,O?sS ??d? NOT SERVED On the day of , 20_, at - o'clock - M., Defendant NOT FOUND because: _ Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at _ Service Refused Other: I understand that th?s statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to author ties. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 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 M State aforesaid,t Journal, a legal r was established periodical for the issued weekly in exactly the same Journal on the fo Viz June 10, ie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and Bing duly sworn, according to law, deposes and says that the Cumberland Law ;riodical published in the Borough of Carlisle in the County and State aforesaid, anuary 2, 1952, and designated by the local courts as the official legal publication of all legal notices, and has, since January 2, 1952, been regularly :he said County, and that the printed notice or publication attached hereto is as was printed in the regular editions and issues of the said Cumberland Law lowing dates, Oil 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 afor said notice or advertisement, and that all allegations in the foregoing statements as to t me, place and character of publication are true. i a Marie Coyne, Edi I SWORN TO AND SUBSCRIBED before me this 10 day of June, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County, Pennsylvania NO. 10-7560 GMAC MORTGAGE LLC s/i/i TO GMAC MORTGAGE CORPORATION VS. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED &WENDELL E. MILLHOUSE, JR., IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED & UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR AS- SOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILL- HOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED Being Premises: 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-9648. Being in SOUTHAMPTON Town- ship, County of CUMBERLAND, Commonwealth of Pennsylvania. 39-33-1883-042. Improvements consist of residen- tial property. Sold as the property of TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE a/k/a WENDELL E. MILLHOUSE, SR., DECEASED & WENDELL E. MILLHOUSE, JR., IN HIS CAPACITY AS HEIR OF WENDELL E. MILL- HOUSE a/k/a WENDELL E. MILL- HOUSE, SR., DECEASED Your house (real estate) at 626 WALNUT BOTTOM ROAD, SHIP- PENSBURG, PA 17257-9648 is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 7, 2011 at 10:00 A.M., at the CUMBERLAND County Courthouse to enforce the Court Judgment of $51,626.47 ob- tained by GMAC MORTGAGE LLC s/i/i TO GMAC MORTGAGE COR- PORATION (the mortgagee), against the above premises. PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff June 10 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th ,1881, since which to THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in he regular editions and issues of THE SENTINEL on the following day(s): June 3, 2011 COPY OF NOTICE OF PUBLICATION CiR Yllli?A GMAC Mf RT4AGE LLC, SM To MAC 'MORTGAGE CORPORATION vs. TOINYA HfA C PACITY A3F? tR OF W E. Al ? ? ?#?Y IiOU$Ii? BR.. WCEN t 'EArr 3' 9MIMPlRq@? PFA Z7 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication a tr ue. Sworn t and I1??7h.I a 9C?tMl My commission expires: before me this J, ZD I I Notary Public NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27. 2014 1 i tKUIHUNU1AR 2011 AUG -4 AM 10: ? 0 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASEED WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Defendants ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-7560 MOTION TO MAKE RULE ABSOLUTE GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 245254 A Motion to Reassess Damages was filed with the Court on June 23, 2011. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on June 15, 2011 and requested the Defendants' Concurrence. On June 20, 2011, Plaintiff received a facsimile from Defendant Tonya S. Millhouse's counsel, Jerry A Weigle, Esquire. Counsel indicated that he intended to "respond before the end of the week". True and correct copies of Plaintiff's letter pursuant to Local Rule 208.3(9), certification of mailing, and facsimile received from Defendant's counsel are attached hereto, made part hereof, and marked as Exhibit "A". A Rule was issued by the Honorable M.L. Ebert, Jr. on or about June 24, 2011 directing the Defendants to show cause why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 4. Defendants failed to respond or otherwise plead by the Rule Returnable date of July 14, 2011. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. DATE: Phelan H ieg, LLP 1 1..1 =?elanEEsq.,,W. No. 32227 ? Francis an, s Td. No. 62695 ? Daniel G. Schmieg sq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 245254 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 245254 Exhibit "A" 245254 PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan & Schmieg, LLP Representing Lenders in Pennsylvania and New Jersey June 15, 2011 WENDELL E. MILLHOUSE, JR UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 JERRY WEIGLE, ESQUIRE 126 EAST KINGS STREET SHIPPENSBURG, PA 17257 RE: GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION v. TONYA S. MILLHOUSE, WENDELL E. MILLHOUSE, JR and UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED Premises Address: 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 CUMBERLAND County CCP, No. 10-7560 Dear Defendants & Counsel, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by June 20, 2011. Should you have further questions or concerns, please do not hesitate to contact me, Otherwise, please be guided accordingly. ')A ;)4A 4 ry ?CL1Jy (> a tc h , Esquire Francis S, HalIjin n, [squire I aaiel G, ScIimiep,, Espire ichele M. I3railfiord, l%-sgiuire Judith T. Romano, Esquire Sheetal R. Shah-Janis Esquire Jenine K Davey, Esquire -Law-ea) 1 .'I abas, L tluirc Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire William E. Miller, Esquire Melissa J. Scheiner, Esquire Enclosure ')ac')r,d .. X4 O O tt a a a _W •o U G? U d v b C m L y': zao c P L ? y c ° o E k C ?soo u? F ? C 3 ?+ n C x ? t? m .7. tip W . ro 3 n `c' ? , v u J '5 uzQ ? ?ro? ? Ir ? OV a F- ? v w C' d 5v,aao ?; m zoo ' s ?+"+ O?"f=tvri ?" a WC4 ? w y? c v w a°w sue. r n ? -Z rs? w Owe a x? x a a w z?v' 'b ? W WfL? V 3 c d .,aaF' W o c aav,? ? 3 ? " 0? a °• a> A d O4 + ? z 3d?m ? °a z in N ?r N kf) N ?ue•2C%'" 'LAU 'iieIg1e & ASSOCIateS JERRY A. WEIGLE. Associates JOSEPIIP RIJANE RJCHARD L. WEBBER, JR. OfCounsd THOMAS 1.. R]UGtrr VIA FACSIM LE TO (215) 563-3459 WEIGLE & ASSOCIATES, P.C. Attorneys-at-Law 126 EAST KING s7RE>rr SHIPPENSBURG, PENNSYLVANIA 17257-1397 TELEPHONE (717) 5324388 FAX (717) 532-5289 June 20, 2011 Michele M. Bradford, Esquire PHELAN HALUNAN & SCHNHEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 bear Attorney Bradford: In Re- Estatc of Wendell E. Millhouse, Sr,. Your correspondence and Motion in the above referenced hatter just reached my desk this morning. I will respond before the end of the week- Sincerely, WEIGLE & ASSOCIATES, PC., Jerry A. Weigle JAW/paf Exhibit "B" 245254 GMAC MORTGAGE LLC, S/I/I to GMAC MORTGAGE CORPORATION PLAINTIFF V. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR. DECEASED, WENDELL E. MILLHOUSE, JR. IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, SR., DECEASED, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-7560 CIVIL ORDER OF COURT AND NOW, this 24'" day of June, 2011, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendants will file an answer on or before July 14, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendants file an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, M. L. Ebert, Jr., J. ?u5 William Miller, Esquire Attomey for Plaintiff Jerry Weigle, Esquire bas Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE LLC, S/I/I TO GMAC MORTGAGE CORPORATION Plaintiff Court of Common Pleas Civil Division vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASEED WENDELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Defendants CUMBERLAND County No.: 10-7560 CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute \were served upon the following individuals on the date indicated below. JERRY WEIGLE, ESQUIRE WENDELL E. MILLHOUSE, JR 126 E KING STREET UNKNOWN HEIRS, SUCCESSORS, SHIPPENSBURG, PA 17257-1326 ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, DECEASED 626 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257-9648 245254 Phelan DATE: lan, Esq., Id o. 32227 ? Francis S. Hallinan, Esq.,-Td. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? C y R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 245254 Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE LLC, S/I/I TO GMAC Court of Common Pleas MORTGAGE CORPORATION Plaintiff Civil Division vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASEED WENDELL, E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED Defendants CUMBERLAND County No.: 10-7560 .-:, r1h ORDER AND NOW, this a day of A03 , 2011, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $47,720.90 Interest Through September 7, 2011 $5,789.28 Per Diem $10.46 Late Charges $489.09 Legal fees $1,325.00 I',- 245254 Cost of Suit and Title $2,574.91 Property Inspections/ Property Preservation $213.75 Appraisal/Brokers Price Opinion $95.00 Suspense/Misc. Credits ($420.16) Escrow to be paid prior to September 7, 2011 $909.65 Escrow Deficit $219.20 TOTAL $58,916.62 Plus interest from September 7, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. Allison F Wells, &t Jerry wetgl6 I ts% "/ Wended E. MiNkome, Jx BY THE COURT- 4J. ( I je M?°'Qa5 245254 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE LLC, S/I/I TO GMAC CUMBERLAND COUNTY MORTGAGE CORPORATION Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION TONYA S. MILLHOUSE No.: 10-7560 WENDELL E. MILLHOUSE JR , UNKNOWN HEIRS, SUCCESSORS ASSIGNS - , , AND ALL PERSONS, FIRMS, OR ASSOCIATIONS ,:- ` ` C=) ° _: CLAIMING RIGHT, TITLE OR INTEREST FROM rn CO s Z-. OR UNDER WENDELL E. MILLHOUSE r :70 ?. c , ? , DECEASED . Cr- -<> 7 -V O rlri Defendant(s) ? o - ; AFFIDAVIT OF SERVICE PURSUANT TO RULE 31 D? n r 29.1 COMMONWEALTH OF PENNSYLVANIA K PHILADELPHIA COUNTY SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if III applicable. A copy of the Certificate of Mailing (Form 3817) and/or a etrn Receipt stamped by the U.S. Postal Service is attached here . ihit «A 9? Allison F. Wells, s , Id. No.309519 Attorney or Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a re resentative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 245254 EXHIBIT A H j ? _d Y DO ON L"` O + I N G a w w s L ?,e• ran fs,A Zd °.€E ? ?"ems ww OQ' ?a v,aa oA F " ?Od FD, O? xw U A dW I?Irl 00 QwrA oUGW o 00 rv u ?i c b ?a = °er in o F° y q v p y .? g R p a ui Q (. P d-° rn?"fs. y ?? p,? ?uN ti0 c vE °v'N 3 oc? rHGQ `r3 CL °' O o E. WE' .a oZj ?'?U C 7 y r. 03 .... y y,r, °''" ..r. 7•- ?n.a « 1. 5? ?xaH0. ?a o >o.a o >^?... L mou d... 0 ;vA ? ° a? ?.,?Q?? a?•v ? w.? > F, a y'?r/2p+ ?'flE.r ?C?, o u?o v? f?U• v?p4 q?°pi4 ea `O a... ??Q., a,w .+?'>aoCCCL ;z rr1w dF ?:9 p. 3 ?+N i-0.,' u ar a ° 3,,, urn o w o`* ^ZC7 ZO? Q a ?0° ca ,,3 WzrA a w ,? u p.. ?.n ? m..• vim. ?a o w 6 kO o °? o. '3 A., o . 8 W a ?-1 ? ee ?, o ... o .a eet 04 0 0 3 ? W W ? a u d `° S Z ,o .., 8 E Z E d i o .C7 Cad ,3 .` E a? i 0 '3 a.U.l o •C ?.. eC cL sf ?o C R N0 D ,,y ai o u O m .? a vi ? v oo '- E? ?+ w t w w- oo.z ?ou,rat>..vUAa;x,S.,a.?ak:N WxaHwa3x Ij ?'z > eq 'Tr 31, z Q o .-? ._ _..,._._._._____..._. _... _...?.. _..__ .fir .SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor GMAC Mortgage, LLC I Case Number vs. 2010-7560 Wendell E. Millhouse, Jr. (et al.) SHERIFF'S RETURN OF SERVICE 06/23/2011 06:41 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by postinc a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 626 Walnut Bottom Road, Shippensburg, PA 17257, Cumberland County. 07/01/2011 11:09 AM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Unknown Heirs of Wendell E. Millhouse, Sr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 626 Walnut Bottom Road, Shippensburg, PA 17257, Wendell Millhouse states that he is the only resident at above address. 07/05/2011 08:51 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Wendell E. Millhouse, Jr. at 626 Walnut Bottom Road, Southampton Township, Shippensburg, PA 17257, Cumberland County. 07/05/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Tonya S. Millhouse, but was unable to locate the Defendani in his bailiwick. He therefore deputized the Sheriff of Franklin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/05/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Franklin County upon Donald Deshong, (Caretaker) who accepted for Tonya S. Millhouse, at 7867 Kuhn Road, Greencastle, PA 17225. So Answers: Robert Marshall, Deputy Sheriff. 09/08/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of, Federal Home Loan Mortgage Corporation, of, 8200 Jones Branch Drive, Mailstop 202, McLean, VA 22102, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $903.25 SO ANSWERS, 11721 October 21, 2011 RON R ANDERSON, SHERIFF Ll e. 0t1,4- ae'le d -00 fjet - rel. ell-0 ?- 391,, ' l.cj Cow tyS,Awl Sheriff. TeKeosoft_ Irtl. ??? On May 26, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Known and numbered as, 626 Walnut Bottom Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 26, 2011 By: aaj",?,-4 Real Estate Coordinator X113 3URT 111, 7 WWt Yn to.- r:unf 1MMi? ? ' n r !fE t i,'ci t s ! ,e'? .at?t?e? ? tN?tld4 bars ?a Iwri +? t WIF CUMBERLAND LAW JOURNAL Writ No. 2010-7560 civil GMAC Mortgage, LLC VS. Wendell E. Millhouse, Jr. Tonya S. Millhouse Unknown Heirs of Wendell E. Millhouse, Sr., Deceased Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 10-7560, GMAC MORT- GAGE LLC, S/I/I TO GMAC MORT- GAGE CORPORATION vs. TONYA S. MILLHOUSE, IN HER CAPACITY AS HEIR OF WENDELL E. MILL- HOUSE, A/K/A WENDELL E. MILL- HOUSE, SR., DECEASED, WEN- DELL E. MILLHOUSE, JR, IN HIS CAPACITY AS HEIR OF WENDELL E. MILLHOUSE, A/K/A WENDELL E. MILLHOUSE, SR., DECEASED, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIM- ING RIGHT, TITLE OR INTEREST FROM OR UNDER WENDELL E. MILLHOUSE A/K/A WENDELL E. MILLHOUSE, SR., DECEASED, owner(s) of property situate in the TOWNSHIP OF SOUTHAMPTON, Cumberland County, Pennsylvania, being 626 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-9648. Parcel No. 39-33-1883-042. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $51,626- .47. 48 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 15, July 22 and July 29, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Co , Editor SWORN TO AND SUBSCRIBED before me this 9 da of Jul 2011 Notary a F OTARIAL SEAL ORAH A COLLINS Notary Public UGH, CUMBERLAND COUNTY ion Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the atrIAot'W`d(WS Now YOU know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and ex st ng under the laws )f the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technolog}, 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 t'he City, County and is tate aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854 and September 1 3th, 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 it and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown bellow: 07/15111 07122/11 4 *Witt *wA0016*N0. 10- 'P7W OMAC ,1I11b . '6?#TlON V& 07129/11 Sworn to and scribed befo this da` of August, 2011 A.D. .el ) Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Klsner, Notary Public Lower Paxton Twp., Dauphin county i my Commission Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 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 Federal Home Loan Mortgage Corp. is the grantee the same having been sold to said grantee on the 7 day of September A.D., 2011, under and by virtue of a writ Execution issued on the 23 day of May, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7560, at the suit of GMAC Mortgage LLC S/I/I to GMAC Mortgage Corp. against Tonga S. Millhouse & Wendell E. Millhouse Jr. Heirs of Wendell E. Millhouse A/K/A Wendell E. Millhouse Sr. Deceased is duly recorded as Instrument Number 201129279. IN TESTIMONY WHEREOF, I have heWunto set my hand and seal of said office this cc j day of - 6E A.D. c>?Ol n of Deeds Recorder of Cumberland County, Carlisle, PA My Commission ires the Frst Monday of Jan. 2014