HomeMy WebLinkAbout10-7813SHERIFF'S OFFICE OF CUMBERLAND CQ
?1 UNTY
Ronny R Anderson L.ECl_()FFj(;t '?'Y
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor t,SYLd?N
BAC Home Loans Servicing, L.P.
vs. Case Number
Christopher M. Umberger 2010-7813
SHERIFF'S RETURN OF SERVICE
12/22/2010 06:53 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
December 22, 2010 at 1853 hours, he served a true copy of the within Compla in Mortgage
Foreclosure, upon the within named defendant, to wit: Christopher M. U ber r, by making known unto
himself personally, at 12 W. Main Street, New Kingstown, Cumberlan ount , ennsylvania 17072 its
contents and at the same time handing to him personally the said tru n c re t copy of the same.
WN HARRISON, DEPUTY
SHERIFF COST: $34.30
December 27, 2010
SO ANSWERS,
ARONW ANDERSON, SHERIFF
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400 Attorney for Plaintiff
BAC Home Loans Servicing, LP FKA COURT OF COMMON PLEAS
Countrywide Home Loans Servicing LP CUMBERLAND COUNTY -?
475 Crosspoint Parkway == -
Getzville, NY 14068,
Plaintiff,
No.: 10-7813
Vs.
Christopher M. Umberger
12 West Main Street
New Kingstown, PA 17072,
Defendant.
PRAECIPE FOR JUDGMENT, INREM, FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter Judgment, in rem, in favor of Plaintiff and against Christopher M. Umberger,
Defendant, 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
Interest 12/21/10 through 02/01/11
TOTAL
$154,309.75
152.02
$154,461.77
I hereby certify that (1) the addresses of the Plaintiff and Defendant is as shown above
and (2) that notice has been given in accordance with Rule 237.1. co attached.
her, Esquire
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: -? -/I
PROTHONOTARY ?T
Q 214.'6° ?d a
asN 553
a? led
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP,
Plaintiff,
Vs.
Christopher M. Umberger,
Defendant.
Our file number: 45.14066
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-7813
TO: Christopher M. Umberger
12 West Main Street,
New Kingstown, PA 17072
DATE OF NOTICE: January 20, 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.
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 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.
{00540698}
Page I of 2
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
MILSTEAD & ASSOCIATES, LLC
J. esner, squire
ID No. 203
Attorney for Plaintiff
{00540698}
Page 2 of 2
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
Vs.
No.: 10-7813
Christopher M. Umberger,
Defendant.
VERIFICATION OF NON-MILITARY SERVICE
Patrick J. Wesner, Esquire, hereby verifies that she is attorney for the Plaintiff in the
above-captioned matter, and that on information and belief, she has knowledge of the following
facts, to wit:
1. that the defendant is not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldier' and Sailors' Civil Relief Act of
Congress of 1940, as amended,
2. defendant, Christopher M. Umberger, is over 18 years of age and resides at 12 West
Main Street, New Kingstown, PA 17072.
Patrick J. W r, Esquire
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO10-7813 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP FKA
COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff (s)
From CHRISTOPHER M. UMBERGER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $154,461.77 L.L..50
Interest From 2/2/11 to 6/1/11 at $25.39 per diem (6%)
Atty's Comm % Due Prothy $2.00
Atty Paid $166.80 Other Costs
Plaintiff Paid
Date: 2/25/11
David D. Buell, rothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: PATRICK J. WESNER, ESQUIRE
Address: 220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-482-1400
Supreme Court ID No. 203145
*4 !,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BAC Home Loans Servicing, LP FKA ; CIVIL ACTION
Countrywide Home Loans Servicing LP,
Plaintiff, NO.: 10-7813
Vs. PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Christopher M. Umberger
Defendant.
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: rn? „ri ?.-
i
Co -'arn
1. Directed to the Sheriff of CUMBERLAND County; (.*F_
__4p
= Gn _4(7)
:r--
2. Against the Defendant(s) in the above-captioned matter; w
Z c
3. and index this writ against the Defendant(s) as follows:
CZ-
'4
Christopher M. Umberger
Real Property involved: 12 West Main Street
New Kingstown, PA 17072
Amount Due
Interest from 2/2/11 to 6/1/11
at $25.39 per diem (6%)
TOTAL
(Costs to be added)
DATE: February 23, 2011
3.4, go &&P
q,r,L 00 kit"
?r oC) u i
? ?t?l?. go ?a any
{00553304}
$154,461.77
Respectively submitted,
Milstead & Associate
Patrick J. We r, Esquire
Attorney for aintiff
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
1; 2.bobca Goo.
,4j Sa I-L
C4*_86-7Sb
to 2;55-7414
I,A)r;+ bP Q.9.15sue,i
x
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being in the
Village of New Kingstown in the Township of Silver Spring in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows:
BEGINNING at a point on the northern side of Main Street, also known as US Route 11
("Carlisle Pike") in the Village of New Kingstown at corner of lot of ground now or
formerly of Robert Bear; thence along said latter lot in a northerly direction a distance of
182 feet to a public alley; thence along said public alley in an easterly direction a distance
of 41 feet to a lot now or formerly of George Lesher; thence by the latter lot in a
southerly direction a distance of 182 feet to said Main Street; thence by the northern side
of Main Street in a westerly direction a distance of 41 feet to the place of BEGINNING.
BEING improved with a three story brick dwelling house with a two story frame building
on the rear of the lot, said premises being known and numbered as 12 West Main Street,
New Kingstown, Pa. 17072.
Being known as 12 West Main Street, New Kingstown, PA 17072
Tax Parcel Number: 38-19-1621-024
{00553304}
s
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
"OTHONOTARf
20 11 FEB 25 PM 2: ;35
CUMBERLAND COUNTY
PENNSYLVANIA
BAC Home Loans Servicing, LP FKA COURT OF COMMON PLEAS
Countrywide Home Loans Servicing LP, CUMBERLAND COUNTY
Plaintiff, No.: 10-7813
Vs.
AFFIDAVIT OF SERVICE
Christopher M. Umberger, PURSUANT TO RULE 3129.1
Defendant.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing LP,
Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of
execution was filed the following information concerning the real property located at 12 West
Main Street, New Kingstown, PA 17072:
1. Name and address of Owners(s) or Reputed Owner(s):
Christopher M. Umberger
12 West Main Street
New Kingstown, PA 17072
Christopher M. Umberger
291 Walnut Lane
Carlisle, PA 17015-7816
2. Name and address of Defendant(s) in the Judgment:
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Penn Waste
P.O. Box 3066
York, PA 17402
4. Name and Address of the last recorded holder of every mortgage of record:
1005533041
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP
(Plaintiff herein)
475 Crosspoint Parkway
Getzville, NY 14068
5. Name and address of every other person who has any record lien on the property:
None Known
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Yolanda R. Umberger
164 Cedar Lane
Carlisle, PA 17013
Michelle A. Hawk
1049 Powell's Valley Road
Halifax, PA 17032
Christopher M. Umberger
c/o Carol J. Lindsay, Esq.
26 West High Street
Carlisle, PA 17013-2956
Michelle A. Hawk
c/o Diane G. Radcliff, Esq.
3448 Trindle Road
Camp Hill, PA 17011-4436
7. Name and address of every person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant/Occupant
12 West Main Street
New Kingstown, PA 17072
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Patrick J. esner, Esquire
Attorney or Plaintiff
Date: February 23, 2011
{00553304)
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
FIED-OFFICE
1 HE PP,O T HONOTAR"T
2011 FEB 25 PM 2'. 35
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for Plaintiff
BAC Home Loans Servicing, LP FKA COURT OF COMMON PLEAS
Countrywide Home Loans Servicing LP, CUMBERLAND COUNTY
Plaintiff,
No.: 10-7813
Vs.
NOTICE OF SHERIFF'S SALE OF
Christopher M. Umberger, REAL PROPERTY PURSUANT
Defendant. TO PA.R.C.P.3129
TAKE NOTICE:
Your house (real estate) at 12 West Main Street, New Kingstown, PA 17072, is
scheduled to be sold at sheriff's sale on June 1, 2011 at 10:00 am in the Commissioner's Hearing
Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of
$154,461.77 obtained by BAC Home Loans Servicing, LP FKA Countrywide Home Loans
Servicing LP.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To Prevent this Sheriff's Sale you must take immediate action:
1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for
Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call 856-482-1400.
2. You may be able to stop the Sale by filing a petition asking the court to strike or open
the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone
the Sale for good cause.
3. You may also be able to stop the Sale through other legal proceedings. You may need
an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the Sale. (See notice on following page on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the bid price by calling Milstead & Associates at 856-482-1400.
{00553304}
2. You may be able to petition the Court to set aside the Sale if the bid price was grossly
inadequate compared to the market value of your property.
3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the
Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner
of the property as if the Sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date
specified by the Sheriff not later than thirty days 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 after.
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 YOU LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
45.14066
{00553304}
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being in the
Village of New Kingstown in the Township of Silver Spring in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly described as
follows:
BEGINNING at a point on the northern side of Main Street, also known as US Route 11
("Carlisle Pike") in the Village of New Kingstown at corner of lot of ground now or
formerly of Robert Bear; thence along said latter lot in a northerly direction a distance of
182 feet to a public alley; thence along said public alley in an easterly direction a distance
of 41 feet to a lot now or formerly of George Lesher; thence by the latter lot in a
southerly direction a distance of 182 feet to said Main Street; thence by the northern side
of Main Street in a westerly direction a distance of 41 feet to the place of BEGINNING.
BEING improved with a three story brick dwelling house with a two story frame building
on the rear of the lot, said premises being known and numbered as 12 West Main Street,
New Kingstown, Pa. 17072.
Being known as 12 West Main Street, New Kingstown, PA 17072
Tax Parcel Number: 38-19-1621-024
100553304}
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
4?Yrits' ?i l' :nru'rrr/a,
w t?
BAC Home Loans Servicing, L.P. Case Number
vs.
Christopher M. Umberger 2010-7813
SHERIFF'S RETURN OF SERVICE
03/15/2011 06:17 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 12 West Main Street, New Kingstown, PA 17072, Cumberland County.
03/30/2011 Robert Bitner, Deputy Sheriff, being duly sworn according to law, served the requested Real Estate Writ,
Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Christopher M. Umberger at 12 W. Main Street, New Kingstown, PA, Cumberland County.
06/01/2011 As directed by Patrick J. Wesner, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/3/2011
07/29/2011 As directed by Patrick J. Wesner, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/5/2011
10/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $719.23 SO ANSWERS.
f
6,?,,October 04, 2011 RONW R ANDE=RSON, SHERIFF
pcl.
C/ 4 ? 3 ???
On March 3, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA,
Known and numbered as, 12 West Main Street,
New Kingstown, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: March 3, 2011
By:
r ?
Real Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2010-7813 Civil
BAC Home Loans Servicing, L.P.
VS.
Christopher M. Umberger
Atty.: Patrick J. Wesner
ALL THAT CERTAIN tract or
parcel of land and premises situate,
lying and being in the Village of New
Kingstown in the Township of Silver
Spring in the County of Cumberland
and Commonwealth of Pennsylva-
nia, more particularly described as
follows:
BEGINNING at a point on the
northern side of Main Street, also
known as US Route 11 ("Carlisle
Pike") in the Village of New Kingstown
at corner of lot of ground now or for-
merly of Robert Bear; thence along
said latter lot in a northerly direction
a distance of 182 feet to a public al-
ley; thence along said public alley in
an easterly direction a distance of 41
feet to a lot now or formerly of George
Lesher; thence by the latter lot in a
southerly direction a distance of 182
feet to said Main Street; thence by
the northern side of Main Street in
a westerly direction a distance of 41
feet to the place of BEGINNING.
BEING improved with a three
story brick dwelling house with a two
story frame building on the rear of the
lot, said premises being known and
numbered as 12 West Main Street,
New Kingstown, Pa. 17072.
Being known as 12 West Main
Street, New Kingstown, PA 17072.
Tax Parcel Number: 38-19-1621-
024.
84
J
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, 19:52, 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.
- - - *' - L, J---
isa Marie Coyne, 1? itor
SWORN TO AND SUBSCRIBED before me this
C da of May, 2011
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission 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 Patr1*otwXews
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 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:
04122111
04/29/11
05/06/11
T1 ..........
Sworn to and- sPscribed be?re me this Pdaty of May, 2011 A.D.
rNotary Public
COMMONWEALTH OF PENNSYLVANIA
Notarw Seal
Sherrie L Kl9w, Notary Public
Lower Paxton Tarp., Dauphin County
My Commission 150m Nov. 26, 2011
^1emtwr, pennsylvanla Association of Notaries
MO-7843 00 lje
B= MM LltWW SWVMft L.P.
=7IJ. t
ALLZTt;KTFt$vtract orparceiofland
and premises situate, lying and being m the
Millage of New K*ptowvn in the Township of
Silver Spring in die County of Cumberland
and Commonwealth of Pennsylvania,
more particjilarly described as follows:
BEG1NNM at a point on the northern
side of Main Street, also known as US
Route Jl ("Cad* Pike") in the Village
of New Kingnv n at corner of lot of
ground ndw or brtnerly of Robert Bear,
thence along said latter lot in a northerly
direction a- dope of 182 feet to a public
alley; thence si * said public alley- in an
easterly direa4p : a distance of 41 feet to
a lot now or # of George Leshar;
thence by 'the' fitter lot in a southerly
dire? a dWaace, of 182 feet to said Main
Street; th¢tce by t4p.poi{hcm shte of Main
Street in a wegrly direction a distance
of 41 feet to the place of BEGINNING.
BEING improved with a three story brick
dwelling house with a two story frame
building on the rear of the lot, said premises
being known and numbered as 12 West
Main Street, New Pa 17072.
Being 0001 -'1, VAO I %fain
Street, New PA 170r.
'Pax Parcel Number 16214)24
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-7813 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP Uk/a
COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff (s)
From CHRISTOPHER M. UMBERGER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $154,461.77 L.L.:
Interest from 2/2/11 to 6/6/12 @ $25.39 per diem (6%)
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $912.03 Other Costs:
Plaintiff Paid:
Date: 2/24/12
ICU ?-David D. Buell, Prothonota
(Seal) y:
Deputy
'
REQUESTING PARTY:
Name: PATRICK J. WESNER, ESQUIRE
Address: MILSTEAD & ASSOCIATES, LLC
220 LAKE DRIVE EAST, SUITE 301
CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 310530
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
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PENNSYLVANIA a; W -0
BAC Home Loans Servicing, LP FKA CIVIL ACTION I
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Plaintiff, NO.: 10-7813 N i
Vs. PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Christopher M. Umberger
Defendant.
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
1. Directed to the Sheriff of CUMBERLAND County;
2. Against the Defendant(s) in the above-captioned matter;
3. and index this writ against the Defendant(s) as follows:
Christopher M. Umberger
Real Property involved: 12 West Main Street
New Kingstown, PA 17072
Amount Due
Interest from 2/2/11 to 06/06/12
at $25.39 per diem (6%)
$154,461.77
TOTAL
(Costs to be added)
DATE: tD 4C, 3? \2
Respectively submitted
Milstead fcsso ' e , LLC
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Patrick J. Z
Esquire
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Attorney Ia'
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220 Lake Drive ast, Suite 301
Cherry Hill, NJ 08002
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MILSTEAD & ASSOCIATES, LLC zm rn MF
BY: Patrick J. Wesner, Esquire ? ;10=
ID No. 203145 ,
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220 Lake Drive East, Suite 301 , _
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP,
Plaintiff,
Vs.
Christopher M. Umberger,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-7813
AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing LP,
Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of
execution was filed the following information concerning the real property located at 12 West
Main Street, New Kingstown, PA 17072:
1. Name and address of Owners(s) or Reputed Owner(s):
Christopher M. Umberger
12 West Main Street
New Kingstown, PA 17072
Christopher M. Umberger
291 Walnut Lane
Carlisle, PA 17015-7816
2. Name and address of Defendant(s) in the Judgment:
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Penn Waste
P.O. Box 3066
York, PA 17402
4. Name and Address of the last recorded holder of every mortgage of record:
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP
(Plaintiff herein)
475 Crosspoint Parkway
Getzville, NY 14068
5. Name and address of every other person who has any record lien on the property:
None Known
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Yolanda R. Umberger
164 Cedar Lane
Carlisle, PA 17013
Michelle A. Hawk
1049 Powell's Valley Road
Halifax, PA 17032
Christopher M. Umberger
c/o Carol J. Lindsay, Esq.
26 West High Street
Carlisle, PA 17013-2956
Michelle A. Hawk
c/o Diane G. Radcliff, Esq.
3448 Trindle Road
Camp Hill, PA 17011-4436
7. Name and address of every person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant/Occupant
12 West Main Street
New Kingstown, PA 17072
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
-1}arric J. We I Esquire
Attorney for P intiff
Date: p 2_ 3 12-
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP,
Plaintiff,
Vs.
Christopher M. Umberger,
Defendant.
TAKE NOTICE:
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Attorney for Plaintiff
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-7813
NOTICE OF SHERIFF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
Your house (real estate) at 12 West Main Street, New Kingstown, PA 17072, is
scheduled to be sold at sheriff's sale on June 6, 2012 at 10:00 am. in the Commissioner's Hearing
Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of
$154,461.77 obtained by BAC Home Loans Servicing, LP FKA Countrywide Home Loans
Servicing LP.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To Prevent this Sheriff's Sale you must take immediate action:
1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for
Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call 856-482-1400.
2. You may be able to stop the Sale by filing a petition asking the court to strike or open
the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone
the Sale for good cause.
3. You may also be able to stop the Sale through other legal proceedings. You may need
an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the Sale. (See notice on following page on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the bid price by calling Milstead & Associates at 856-482-1400.
2. You may be able to petition the Court to set aside the Sale if the bid price was grossly
inadequate compared to the market value of your property.
3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the
Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner
of the properly as if the Sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a Deed to the Buyer. At that time, the Buyer may bring legal
proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date
specified by the Sheriff not later than thirty days 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 after.
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 YOU LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
45.14066
ALL THAT CERTAIN tract or parcel of land and premises situate, lying and being in the
Village of New Kingstown in the Township of Silver Spring in the County of Cumberland and
Commonwealth of Pennsylvania, more particularly described as follows:
BEGINNING at a point on the northern side of Main Street, also known as US Route 11
("Carlisle Pike") in the Village of New Kingstown at corner of lot of ground now or fonnerly of
Robert Bear; thence along said latter lot in a northerly direction a distance of 182 feet to a public
alley; thence along said public alley in an easterly direction a distance of 41 feet to a lot now or
formerly of George Lesher; thence by the latter lot in a southerly direction a distance of 182 feet
to said Main Street; thence by the northern side of Main Street in a westerly direction a distance
of 41 feet to the place of BEGINNING.
BEING improved with a three story brick dwelling house with a two story frame building on the
rear of the lot, said premises being known and numbered as 12 West Main Street, New
Kingstown, Pa. 17072.
Being known as 12 West Main Street, New Kingstown, PA 17072
Tax Parcel Number: 38-19-1621-024
MILSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
File No. 45.14066
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BAC Home Loans Servicing, LP FKA COURT OF COMMON PLEAS
Countrywide Home Loans Servicing LP, CUMBERLAND COUNTY
Plaintiff,
NO.: 10-7813
Vs.
AFFIDAVIT PURSUANT TO
Christopher M. Umberger, ; Pa.R.C.P. 3129.2
Defendant.
I, Patrick J. Wesner, Esquire, say:
1. On April 4, 2012, a copy of the Notice of Sheriff s Sale of Real Property was served
upon the defendant, Christopher M. Umberger, by the Sheriffs Office of Cumberland County.
A copy of the Sheriff s return and signed certified card is attached hereto and made a part hereof
as Exhibit "A".
2. On February 27, 2012, a notice of Sheriff s Sale was served upon lien holders of
record and interested parties by ordinary mail. A copy of the certificate of mailing is attached
hereto and made a part hereof as Exhibit "B".
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
Patrick J. e er, squire
Attorney ID N . 20 145
Milstead and Associates, LLC
Dated: May 9, 2012
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriffn4trtt3' t?,?ur?i,rrtr
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
BAC Home Loans Servicing, L.P.
vs.
Christopher M. Umberger
Case Number
2010-7813
SHERIFF'S RETURN OF SERVICE
03/20/2012 05:04 PM - Deputy Shawn Gutshall, 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 12 W. Main Street, Silver Spring Township, New Kingstown, PA 17072,
Cumberland County.
03/20/2012 05:04 PM - Deputy Shawn Gutshall, being duly sworn according to law, attempted service to the
Defendant, to wit: Christopher M. Umberger at 12 W. Main Street, Silver Spring Township, New
Kingstown, PA 17072. The address was found to be vacant.
04/04/2012 05:40 PM - 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: Christopher M. Umberger at the Cumberland County Sheriffs
Office, 1 Courthouse Square, Carlisle, Cumberland County, by Sheriff Ron Anderson on 4/4/12 at 0805
h rs.
SHERIFF COST: $906.20 SO ANSWERS,
April 04, 2012 RON R ANDERSON, SHERIFF
EXHIBIT "B"
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N41LSTEAD & ASSOCIATES, LLC
BY: Patrick J. Wesner, Esquire
ID No. 203145
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
File No. 45.14066
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;- ,..NL ' ROTHONOTAR Y
231'2 JUL -9 PM I: 02
CUMBERLAND COUNTY
PENNSYLVANIA
BAC Home Loans Servicing, LP FKA
Countrywide Home Loans Servicing LP,
Plaintiff,
Vs.
Christopher M. Umberger,
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 10-7813
AMENDED AFFIDAVIT PURSUANT
TO Pa.R.C.P. 3129.2
I, Patrick J. Wesner, Esquire, say:
1. On April 4, 2012, a copy of the Notice of Sheriffs Sale of Real Property was
upon the defendant, Christopher M. Umberger, by the Sheriffs Office of Cumberland (
A copy of the Sheriff s return and signed certified card is attached hereto and made a part
as Exhibit "A".
2. On February 27, 2012, a notice of Sheriffs Sale was served upon lien holders
record and interested parties by ordinary mail. A copy of the certificate of mailing is
hereto and made a part hereof as Exhibit "B".
3. On June 15, 2012, a notice of Sheriff s Sale was served upon additional lien holders
record and interested parties by ordinary mail. A copy of the certificate of mailing is
hereto and made a part hereof as Exhibit "C".
I verify that the statements made in this affidavit are true and correct to the best of
personal knowledge or information and belief. I understand that false statements herein
made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authoriti
Patrick sner, Esquire
Attorney D o. 203145
Milstead Associates, LLC
Dated: June 15, 2012
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff citlab"r,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor OMC E OF TKE'?ERIFF,
BAC Home Loans Servicing, L.P. Case Number
vs. 2010-7813
Christopher M. Umberger
SHERIFF'S RETURN OF SERVICE
03/20/2012 05:04 PM - Deputy Shawn Gutshall, 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 12 W. Main Street, Silver Spring Township, New Kingstown, PA 17072,
Cumberland County.
03/20/2012 05:04 PM - Deputy Shawn Gutshall, being duly sworn according to law, attempted service to the
Defendant, to wit: Christopher M. Umberger at 12 W. Main Street, Silver Spring Township, New
Kingstown, PA 17072. The address was found to be vacant.
04/04/2012 05:40 PM - 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 representin
themselves to be the Defendant, to wit: Christopher M. Umberger at the Cumberland County Sheriffs
Office, 1 Courthouse Square, Carlisle, Cumberland County, by Sheriff Ron Anderson on 4/4/12 at 0805
hrs.
SHERIFF COST: $906.20
April 04, 2012
SO ANSWERS,
R ANDERSON, SHERIFF
Ic GountySuite Shent TeieOSO$, Irv..
EXHIBIT "B"
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MILS'CEAI'~ & ASSOCIATES, LLC ~ ~ ~~ ~~
BY: Patrick J. Werner, Esquire
ID No. 203145 ~ -~ ~ ~'
220 Lake Drive Fast, Suite 301 ~ - ~ ~ ~~
~~ .
Chem Hill. N.l 08002 , ~~~~~
(856) 482-1400
Attorney for ]Plaintiff
File Nc. 45.14066
BAC Home Loans Servicing, LP FKA COi1RT OF COMMON PLF,AS
Countrywide Home Loans Servicing LP, CUMBERLAND COUNTY
Plaintiff,
I
Vs. No.: 10-7813
Christopher M. Umberger, Praecipe to Vacate Judgment and
Discontinue and End Action
:Defendant(s). ~~ _ _ ______
TO THE PROTHONOTARY:
Kindiy vacate the Default Judgment filed on February 2, 2011 in the amount of
$154.461.77 and discontinue and end the above captioned Mortgage Foreclosure action without
Prejudice.
MILSTEAD & ASSO `IATEnS,
Patrick---~!-~;-~s~u~re
Attorney ID No. 20314i~5 '~
ate} ~~.~~~ a~
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