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HomeMy WebLinkAbout10-76451000 ze4ooe EXHIBIT B SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r"-ILED-OFF #?F ?C, 10 DEC 21 PM 3'- 03 `FLMSERLA D COUNT'_' PENNSYLVA'1 1A American General Consumer Discount Co. vs. Cheryl L. Riddle Case Number 2010-7645 SHERIFF'S RETURN OF SERVICE 12/16/2010 05:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on December 16, 2010 at 1745 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Cheryl L. Riddle, by making known unto herself personally, at 18 E. Green Street, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 December 17, 2010 . Mt Gout- Suite Sherft, ie'.eosott. inc. TEP EN BENDER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF PARKER McCAY P.A. By: Stuart I. Seiden, Esquire Attorney ID# 200162 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Plaintiff, V. Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Defendant. r -ED ? 1 {LL tiy$ 71';7 !?)ooTHONOTAR?s 2011 IAN' 24 P111 11: !-1 CU'ME.+ERLANID COUNT°t PE-NNSYLVA4IA COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM, 2010 DOCKET NO. 10-7645 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment by Default in favor of Plaintiff, American General Consumer Discount Company and against the Defendant, Cheryl L. Riddle, for failure to file an Answer on Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $74,914.13 Interest @ $88.66 per diem (11/19/10 to 01/18/11) $5,319.60 Late Charges $140.32 Co orate Advance $1,812.50 TOTAL $82,186.55 Together with interest at the contract rate after the date of judgment, and costs. I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT IN MORTGAGE FORECLOSURE AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT IN MORTGAGE FORECLOSURE. A.rn? ?1?. ?? alh? ?.? d Ss51 I hereby certify that the attached Notices of Intention to "rake Default were forwarded to Defendants more than ten (10) days ago. By: Date: January 18, 2010 PARKER McCAY P.A. Esq 00 ?7ve West P.O. Box 974 Marlton, NJ 08053-0974 2 A T T O R N E Y S AT L A W January 6, 2011 Parker McCay P.A. Three Greeirtree Centre 7066 Lincoln Drive We t PO Box 974 Marlton, NJ 08053-0974 P: 856-596-8900 F: 856-596-9631 www.parkermccay.com Foreclosure/Bankruptcy Dept. P 856-810-5815 F 856-596-3427 File No. 14885-0004 l Via Certified Mail, R. R.R. & Regular Mail 7160 3 9 8 4 9 2209 8042 Cheryl L. Riddle SENDEWS RECORD 18 East Green Street Shiremanstown, PA 17011 Re: American General Consumer Discount Co. v. Chervil L. Riddle November Term 2010, No. 10-7645 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. Il-vou should ha%,,e any questions, please do not hesitate to contact our 0111CC. PLEASE NOTE THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. M W/aj p Enclosure Very truly yours, i MAR U L PA<?rlt??n N ,: Jersey L :r nceville. Nev, Jersev Atlantic City. New Jersey PARKER McCAY P.A. By: Mary Wu, Esquire Attorney ID #209171 Three Greentree Centre, Suite 401 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorneys for Plaintiff File No. 14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM 2010 NO. 10-7645 Plaintiff. V. Chervl L. Riddle 18 East Green Street Shiremanstown. PA 17011 CIVIL ACTION MORTGAGE FORECLOSURE Defendants. NOTICE OF INTENTION TO FILE PRAECIPF FOR ENTRY OF DEFAULT JUDGMENT TO: Cheryl L. Riddle 18 East Green Street Shiremanstown. PA 17011 DATE OF NOTICE: January 6,2011 IMPORTANT NOTICE YOU ARE. IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Respectfully Submitted, PARKER McCAY P.A. BY: M RY 4 Attorne or Plaintiff DATE: Januar 6,20 11 VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL U O T O W ?7' 00 Co mCD V oN ? ? CL N z Y Cn W 0 J I N ?. O p 1 Ln I ? I ? O 3 3 II 3 'd ?7 rd W O CD W ?a K o K N? N Cz1 o rt 0 0 X C fD a? K n° Fl- 3 n J n 0 0 l1 ?n C-I N ¢1 ?nm p 3a co o K R" °3 1i7 d d. Ul F 3 O ? Z m ?] fD A (J1 ? (7 a c U, P ?r ti Jd# X121 ? t 1 1 171 y u 16-1 a n tD fy f(D 1.15 7160 3901 9849 2209 8042 TO: Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 SENDER: Anthony REFERENCE: 14885-0004 10 Day Notice RETURN Postage RECEIPT Cert ified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage $ Fees US Postal Servioe Receipt for Certified Mail No ftumnm C Wrage Prawa.a Do Not use br k*mww r ma I 0.00 ?Oti1 PARKER McCAY P.A. By: Stuart I. Seiden, Esquire Attorney ID# 200162 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 V. Plaintiff, Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM, 2010 DOCKET NO. 10-7645 CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION OF NON-MILITARY SERVICE I, Stuart 1. Seiden, Esquire, hereby certify that I represent Plaintiff in the above entitled case; that I am authorized to make this Verification on behalf of Plaintiff; that the above-named Defendant is over 18 years of age; that the address of the Defendant, Cheryl L. Riddle is 18 East Green Street, Shiremanstown, PA 17011; that the occupations of the Defendant are unknown; and that the Defendant is not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I also certify that the address of the Plaintiff is 125 Gateway Drive, Suite 109, Mechanicsburg, PA 17055. I understand that the statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. PARKER MCCAY, P.A. By: Sei Date: January 18. 2011 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jan-17-2011 08:55:51 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency RIDDLE CHERYL L Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). )ut t4. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fag/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmde.osd.mil/appj/scra/popreport.do 1/17/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:AGLROJ200U https://www.dmdc.osd.mil/appj/scra/popreport.do 1/17/2011 PARKER McCAY P.A. By: Stuart I. Seiden, Esquire Attorney ID# 200162 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Plaintiff, V. Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM, 2010 DOCKET NO. 10-7645 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATION 1, Stuart I. Seiden, Esquire, do hereby certify that the Defendant, Cheryl L. Riddle was served with the Complaint in Mortgage Foreclosure in this action, by the Cumberland County Sheriff on December 16, 2010. A true and correct copy of the Cumberland County Sheriffs Return of Service is attached hereto as Exhibit "A". PARKER MCCAY, P.A. By: I 7UUTLincoTn Drive West P.O. Box 974 Marlton, NJ 08053-0974 Date: January 18, 2011 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor American General Consumer Discount Co. vs. Cheryl L. Riddle SHERIFF'S RETURN OF SERVICE ?JV29`' -,/4 - Case Number 2010-7645 r? 12/16/2010 05:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on December 16, 2010 at 1745 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Cheryl L. Riddle, by making known unto herself personally, at 18 E. Green Street, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. TEP EN BENDER, DEPUTY SHERIFF COST: $41.50 December 17, 2010 SO ANSWERS, 4RON ANDERSON, SHERIFF f0) COL014SUite Sheriff, Teieosoff, fit-. PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West P.O. Box 974 Marlton, NJ 08053-0974 (856) 596-8900 Attorney for Plaintiff File #:14885-0004 _ rv (L E. 0 f JUN 13 pH 3a , PUMBERLANL) P E N N s LMt4 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Plaintiff, V. Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NOVEMBER TERM, 2010 : DOCKET NO. 10-7645 : CIVIL ACTION : MORTGAGE FORECLOSURE PRAECIPE TO MARK JUDGMENT TO THE USE Kindly mark the judgment entered in the above captioned matter to the use of Springleaf Financial Services of Pennsylvania, Inc. formerly known as American General Consumer Discount Company, upon payment of your costs only. DATED: May 26.2011 PARKER CAY P.A. Attorney f Plaintiff BY: C ISTINE A. PINTO, ESQUIRE 1Q?.'*f e 04-0 X1 -7 plw aUo t161 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson +. r ? r Sheriff Jody S Smith re r{ { Chief Deputy ?` !! Richard W Stewart { ! Solicitor 3t Ff L H „ 0 JN -f Y. - 11A American General Consumer Discount Co. vs. Case Number Cheryl L. Riddle 2010-7645 SHERIFF'S RETURN OF SERVICE 03/10/2011 04:25 PM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 18 East Green Street, Shiremanstown, PA 17011, Cumberland County. 03/10/2011 04:25 PM - Deputy Ronald Hoover, 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: Cheryl L. Riddle at 18 E. Green Street, Shiremanstown Borough, Shiremanstown, PA 17011, Cumberland County. 06/01/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County, Courthouse, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 85,001.00 to Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $2,845.34 July 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF Amended SCHEDULE OF DISTRIBUTION Date Filed: June 23, 2011 Writ No. 2010-7645 Civil Term American General Consumer Discount Company -vs- Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Sale Date: Buyer: Bid Price: Real Debt: Interest: Attorney P June 1, 2011 Members 1St FCU $ 85,001.00 $ 82,186.55 11,791.78 /rit Costs: 174.00 Total Due: $ 94,152.33 DISTRIBUTION: Receipts: Cash on Account (02/14/2011): $ 1,500.00 Cash on Account (06/01/2011): 10,500.00 Cash on Account (06/16/2011): 79,907.02 Total Receipts: $ 91,907.02 Disbursements: Sheriffs Costs $ 2,545.34 Legal Search 300.00 Transfer Tax (Local) 1,703.00 Transfer Tax (State) 1,703.00 Cumberland County Tax Claim Bureau 2,593.92 Judy C. Prowell, Shiremanstown Borough Tax Collector 739.02 Judy C. Prowell, Shiremanstown Borough Tax Collector (2011 School Taxes) 2,07121 Lower Allen Township Authority 18.33 Attorney Christine Pinto 1,500.00 American General Consumer Discount Company 78,732.20 Total Disbursements: Balance for distribution: So Answers: Ronny R. Anderson - Sheriff ($91,907.02) 00.00 SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-7645 Held June 1, 2011 EFFECTIVE DATE: June 1, 2011 PREMISES: 18 East Green Street, Borough of Shiremanstown, Cumberland County, Pennsylvania, Tax Parcel No. 37-23-0555-105 (the "Premises") RECITAL: Being the same Premises which Charles D. Riddle and Cheryl L. Riddle, husband and wife, by their deed dated July 25, 1995 and recorded August 2, 1995 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 126, Page 58, granted and conveyed unto Cheryl L. Riddle. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3 . The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court:. 1 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2011. 20. Subject to the rights in and to the Premises of any spouse of Cheryl L. Riddle. 21. Mortgage in the amount of $70,500.00 from Cheryl L. Riddle to American General Consumer Discount Co. dated June 18, 2007 and recorded June 25, 2007 in Mortgage Book 1991, Page 1. -2- 22. Mortgage in the amount of $100,400.00 from Cheryl L. Riddle to Members l"F. C.U. dated October 16, 2008 and recorded October 27, 2008 to Instrument No. 200835058. 23. Mortgage in the amount of $17,000.00 from Cheryl L. Riddle to Members 1" F.C.U. dated October 16, 2008 and recorded October 27, 2008 to Instrument No. 200835059. 24. Judgment against Cheryl L. Riddle in the amount of $82,186.55 entered January 24, 2011 in favor of American General Consumer Discount Company to No. 2010-7645. 25. Subject to unpaid taxes due the Tax Claim Bureau in the amount of $2,577.08. together with any interest and penalties accrued thereon. 26. Subject to the coal rights and right of support contained in the Notice in Deed Book 126, Page 58. 27. Subject to the rights of others in and to any portion of the Premises lying within or adjoining Green Street and an alley. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: Keith O. Brenneman -3- Writ No. 2010-7645 Civil American General Consumer Discount Co. vs. Cheryl L. Riddle Atty.: Christine A. Pinto ALL THAT CERTAIN house and lot of ground situated on the South side of East Green Street, Shiremans- town, Cumberland County, Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb line of said Green Street and the line of land now or formerly of H. C. Hendricks; thence Southward along said line, 200 feet to an alley; thence along the line of said alley, Westward 30 feet to the line of land formerly of John Maxwell, now or late of Frank E. Weber; thence along the line of said land formerly of John Maxwell, now or late of Frank E. Weber, Northward, 200 feet to the curb line of said Green Street; thence along the line of said Street, Eastward, 30 feet to the place of BEGINNING. HAVING thereon erected a two story frame dwelling known and numbered as 18 East Green Street. FOR title see Cumberland County Deed Book X, Volume 29, page 119. PARCEL IDENTIFICATION NO: 37-23-0555-105, CONTROL 37000113. BEING the same premises Kim A. Eiffes and Ursula V. Eiffes, his wife, by their deed dated December 11, 1989, in Book H-34, page 1153, on December 14, 1989, granted and conveyed unto Charles D. Riddle and Cheryl L. Riddle, his wife, Grantors herein. EXHIBIT A PARKER McCAY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Plaintiff, Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM, 2010 DOCKET NO. 10-7645 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 American General Consumer Discount Company, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 18 East Green Street, Shiremanstown, PA 17011: I . Name and address of Owner(s) or Reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Sheryl 1.. Kiddle Name Cheryl L. Riddle 18 East Green Street Shiremanstown. PA 17011 Name and address of Defendants in the judgment: Address (if address cannot be reasonably ascertained, please so indicate) 18 East Green Street Shiremanstown, PA 1701 1 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Address (if address cannot be reasonably ascertained, please so indicate) 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Members 1" Federal Credit Union _ 5000 Louise Drive Mechanicsburg, PA 17055 Name ONLY THOSE LISTED ABOVE. Address (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property ,,N;hich may be affected by the sale: Name Shippensburg School District Shiremanstown Borough Tax Collector Address (if address cannot be reasonably ascertained, please so indicate) c/o Judith Prowell 21 1 Chestnut Street Shiremanstown, PA 1701 1 c/o Judith Prowell 21 1 Chestnut Street Shiremanstown, PA 17011 I '-V l11I K I Ik-41I VV 2tLC[ Lower Allen Township Sewer Authority Cumberland Counri "I 3x Claim Bureau Cumberland County Domestic Relations Conu11olmcalth of Pennsvk-ania Department of ?'?'elfarc ?. Name and address of every other person who has any record lien on the property: 800 West Hersheypark Drive Hershey. PA 17033 P.O. Box 128 Newburg, PA 17240 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 33 Health and Welfare Buildin -1 I iarrisburrO, PA 17 105 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name ONLY THOSE LISTED ABOVE. Address (if address cannot be reasonably ascertained, please so indicate) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand thajalse statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn faliftation to authorities. CHRISTINE A. PINTO, ESQUIRI? Attorney for Plaintiff Date: Januarv 28, 2011 PARKER NIX AY P.A. By: Christine A. Pinto, Esquire Attorney ID# 205622 Three Greentree Centre 7001 Lincoln Drive West, P.O. Box 974 Marlton, NJ 08053-0974 (856) 810-5815 Attorney for Plaintiff File #:14885-0004 American General Consumer Discount Company 125 Gateway Drive, Suite 109 Mechanicsburg, PA 17055 Plaintiff, V. Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NOVEMBER TERM, 2010 DOCKET NO. 10-7645 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Cheryl L. Riddle 18 East Green Street Shiremanstown, PA 17011 The real estate located at 18 East Green Street, Shiremanstown, PA 17011 is scheduled to be sold at Sheriffs Sale on June 1, 2011 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $82,186.55 plus fees, costs and other charges obtained by American General Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Christine A. Pinto, Esquire, Three Greentree Centre, 7001 Lincoln Drive, P.O. Box 974, Marlton, NJ 08053. To find out how much you must pay, you may call (856) 810-5815. 2. You may be able to stop the sale by filing a petition asking the court to strike or open the judgment, if the judgment was improperly entered. You may also ask the court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriffs Office at (717) 240-6390 or Christine A. Pinto, Esquire at (856) 810-5815. 2. You may be able to petition the court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffs Office at (717) 240-6390 or Christine A. Pinto,, Esquire at (856) 810-5815. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. Al 1, fl 1A I CFR'lAIN house and lot of ground situated on the South side of Last Green Strc?,a. Shircmansto\an. Cumberland County, Pennsylvania, bounded and described as follo?Ns, to wit.: BEGINNING at a point in the curb line of said Green Street and the line of land now or formerly of 11. C. Hendricks; thence Southward along said line, 200 feet to an alley; thence along the line of said alley, Westward 30 feet to the line of land formerly of John Maxwell, now or late of Frank E. 'Weber; thence along the line of said land formerly of John Maxwell, now or late of f=rank F Weber, Northv? ard, 200 feet to the curb line of said Green Street: thence along the line of said Street. Fastward. 30 feet to the place of BEGINNING. HAVING thereon erected a two story frame dwelling known and numbered as 18 East Green Street. FOR title see Cumberland County Deed Book X. Volume 29, page 119. I'ARCEI, IDENTIFICATION NO: 37-23-0555-105, CONTROL #: 3700011' BEING the same premises Kim A. Eiffes and Ursula V. Eiffes, his wife, by their deed dated December 1 1, 1989, in Book H-34, page 1153, on December 14, 1989, granted and conveyed unto Charles D. Riddle and Cheryl L. Riddle, his wife, Grantors herein. TITLE TO SAID PREMISES IS VESTED IN Cheryl L. Riddle, by Deed from Charles D. Riddle and Cheryl L. Riddle, his wife, dated 07/25/1995, recorded 08/02/1995 in Book 126, Page 58. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-7645 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL CONSUMER DISCOUNT COMPANY. Plaintiff (s) From CHERYL L. RIDDLE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (?.) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $82,186.55 L.L.S.50 Interest from 1/19/11 to 6/1/11 (at a per diem rate of $88.66) - - 511,791.78 Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Other Costs Plaintiff Paid Date: 2/10/11 David D. B ell, Protho to (Seal) - Deputy REQUESTING PARTY: Name: CHRISTINE A. PINTO, ESQUIRE Address: PARKER MCCAY P.A. THREE GREENTREE CENTRE 7001 LINCOLN DRIVE WEST, P.O. BOX 974 MARLTON, NJ 08053-0974 Attorney for: PLAINTIFF TRUE COPY FROM R%CORD In Testimony ;vherecf, I here unto r et my nand and the seal of said Coup at Carlisle, Pa. This -LU day of e- 2(: f 1 T''rothonctary Telephone: 856-810-5815 Supreme Court ID No. 205622 On March .". _210 tfle Sheriff levied upon the defendant's interest. in to rear property situated in Shiremanstown Borough, Cumberland County, PA. Known and numbered as, 18 Last Green Street, Shiremanstown, more fully described on Exhibit "A" filed with this writ and by this reference incorporated heren, Dates March .. 2( )1 I By: a `l Zeal Estate Coordinator N., PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 22, April 29, and May 6, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 6 day of May, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public. CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-7645 Civil American General Consumer Discount Co. VS. Cheryl L. Riddle Atty.: Christine A. Pinto ALL THAT CERTAIN house and lot of ground situated on the South side of East Green Street, Shiremans- town, Cumberland County, Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb line of said Green Street and the line of land now or formerly of H. C. Hendricks; thence Southward along said line, 200 feet to an alley; thence along the line of said alley, Westward 30 feet to the line of land formerly of John Maxwell, now or late of Frank E. Weber; thence along the line of said land formerly of John Maxwell, now or late of Frank E. Weber, Northward, 200 feet to the curb line of said Green Street; thence along the line of said Street, Eastward, 30 feet to the place of BEGINNING. HAVING thereon erected a two story frame dwelling known and numbered as 18 East Green Street. FOR title see Cumberland County Deed Book X, Volume 29, page 119. PARCEL IDENTIFICATION NO: 37-23-0555-105, CONTROL #: 37000113. BEING the same premises Kim A. Eiffes and Ursula V. Eiffes, his wife, by their deed dated December 11, 1989, in Book H-34, page 1153, on December 14, 1989, granted and conveyed unto Charles D. Riddle and Cheryl L. Riddle, his wife, Grantors herein. 68 The Patriot-Nevis Co. 2020 Technology Pkwy Suite 300 Mechanicsburg; PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE the Patti* ot-News Now you know CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 05/06/11 (. ' r _ .... ......... 't Sworn to anc(subscribed bef?re me this 23.d4y of May, 2011 A.D. Notary Public _ COMMONWEALTH OF PENNSYLVANIA Notarial seal Sherrie L KIV-1 NOMY Publlc Lower Paxton Twp., Dauphin county _ My Commission EVkps NOV. a 2011 Member. Penns vanla Assoclatl?h tl Notaries i 20110-7645 CWV Term Amman General Consumer DWounll Co. Vs Cheryl L. Riddle Atty: Christine A Pinto ALL THAT CERTAIN house and lot of ground situated on the South side of East Green Street, Shiremanstown, Cumberland County, Pennsylvania, bounded And described as follows, to wit: BEGINNING at a point in the curb line of said Grr -- Street and the line of land now or f„uterly of H. C. Hendricks; thence Southward along said be, 200 feet to an alley; thence along the line of said alley, Westward 30 feet to the line of land formerly of John Maxwell, now or late of Frank E. Weber; thence along the line of said land formerly of John Maxwell, now or late of Frank E Weber, Northward, 200 feet to the curb line of said Green Street; thence along the he of said Street, Eastward, 30 feet to the place of BEGINNING. HAVING thereon erected a two story frame dwelling known and numbered as 18 East Green Street. FOR title see Cumberland County Deed Book X, Volume 29, page 119. PARCEL IDENTIFICATION NO: 37- 23-0555-105, CONTROL #: 37000113 BEING the same premises Kim A. Eiffes and Ursula V. Eiffes, his wife, by their deed dated December 11, 1989, in Book H-34, page 1153, on December 14, 1989, granted and conveyed unto Charles D. Riddle and Cheryl L. Riddle; his wife, Grantors herein. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Members 1 st Federal Credit Union is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 10 day of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7645, at the suit of American General Consumer Discount CompanX against Cher l L. Riddle is duly recorded as Instrument Number 201118975. IN TESTIMONY WHEREOF, I have hereunto set my hand and,seal of said office this ` ---day of A.D. -2? of Deeds Recorder of Cumberland Comer, Cadisie, PA My Cormissioh Expires the First M"4ay of Jan. 2014