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Home My WebLink About11-0006 BF T~jE pRa y~ 1B~ NOTARY 101f J~~t _3 A~ 8. 34 C(I~BFRL A NO PENNSYLVAH1q T Y McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 / EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (21~ 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 961 Weigel Drive Elmhurst, Illinois 60126 v. Patrick Aaron Taylor 1270 Newburg Road Shippenburg, Pennsylvania 17257 and Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania17257 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number ~ ~~ t _ lp Cc ~ ~ ~ ~~~ CIVIL ACTION/MORTGAGE FORECLOSURE - ~D a~ ~_,~~~qa~° ~3 aC~ ~'`~ ~o to °1 ~.~.a 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800)990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800)990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE - Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Patrick Aaron Taylor, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1270 Newburg Road, Shippenburg, Pennsylvania 17257. 3. The Defendant is Kimberly Sue Taylor, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1270 Newburg Road, Shippensburg, Pennsylvania 17257. 4. On April 24, 2007, Patrick Aaron Taylor and Kimberly Sue Taylor made, executed and delivered a mortgage upon the premises hereinafter described to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1990, Page 854. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 1270 Newburg Road, Shippensburg, Pennsylvania 17257. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due April 28, 2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts aze due on the mortgage: Principal Balance $ 303,909.23 Interest through November 10, 2010 $ 10,018.32 (Plus $43.94 per diem therea8er) Attorney's Fee $ 1 250.00 Late Charges $ 874.42 Corporate Advance $ 2,973.94 Escrow Advance $ 5,897.59 GRAND TOTAL $ 324,923.50 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands an in rem Judgment against the Defendants in the sum of $324,923.50, together with interest at the rate of $43.94 per diem and other costs and chazges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P. . EY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY,P.C. BY: v" Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania v. Patrick Aazon Taylor and Kimberly Sue Taylor Exhibit A EXHIBIT A ALL THE FOLLOWING DESCRIBED REAL ESTATE, LYING AND BEING SITUTATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND LIMITED AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN S.R. 0696 (NEWBURG ROAD) AT CORNER OF LANDS NOW OR FORMERLY OF MARK D. KEENER; THENCE WITH SAID LANDS OF KEENER, NORTH 72 DEGREES 25 MINUTES 26 SECONDS WEST, 424.64 FEET TO AN IRON PIN AT CORNER OF OTHER LANDS OF THE GRANTORS HEREIN; THENCE WITH SAID LANDS ON A CURVE TO THE RIGHT HAVING A RADIUS OF 350.00 FEET, A CHORD BEARING OF NORTH 04 DEGREES 29 MINUTES 58 SECONDS WEST, A CHORD LENGTH OF 462.48 FEET, AND AN ARC LENGTH OF 505.21 FEET TO AN IRON PIN IN LINE OF LANDS NOW OR FORMERLY OF KENNETH M. HALE,JR., AND JUDITH E. HALE; THENCE WITH SAID LAND'S OF HALE, SOUTH 89 DEGREES 40 MINUTES 00 SECONDS EAST, 150.00 FEET TO A RAILROAD SPIKE IN S.R. 0696; THENCE IN S.R. 0696 ON CURVE TO THE LEFT HAVING A RADIUS OF 1910.08 FEET, A CHORD BEARING OF SOUTH 25 DEGREES 23 MINUTES 22 SECONDS EAST, A CHORD LENGTH OF 93.48 FEET, AND AN ARC LENGTH OF 93.49 FEET TO A PARKER KALON NAIL; THENCE CONTINUING IN S.R. 0696 THE FOLLIWNG TWO COURSES; SOUTH 26 DEGREES 52 MINUTES 16 SECONDS EAST, 330.11 FEET TO A PARKER KALON NAIL; SOUTH 25 DEGREES 55 MINUTES 11 SECONDS EAST, 232.92 FEET TO A PARKER KALON NAIL AT CORNER OF LANDS OF KEEFER, THE PLACE OF BEGINNING. TAX MAP OR PARCEL ID NO.: 39-11-6312-021 ADDRESS: 1270 NEWBURG ROAD; SHIPPENSBURG, PA 17257-8607 SHERIFF'S OFFICE OF CUMBERLAND COUNTY P Ronny R Anderson r fi Sheriff T _! Jody S Smith' Chief Deputy F 11 JAN 13 A 10' Richard W Stewart ':'U MBtRLrr Solicitor 'N F5'4IA". Beneficial Consumer Discount Company Case Number vs. 2011-6 Patrick Aaron Taylor (et al.) SHERIFF'S RETURN OF SERVICE 01/05/2011 01:58 PM - Sheldon Marshall, Deputy Sheriff, who being duly sworn according to law, states that on January 6, 2011 at 1358 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Patrick Aaron Taylor, by making known unto himself personally, at 1270 Newburg 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 sa ' A SHELDON MARSHALL, DEPUTY 01/05/2011 01:58 PM - Sheldon Marshall, Deputy Sheriff, who being duly sworn according to law, states that on January 6, 2011 at 1358 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kimberly Sue Taylor, by making known unto Patrick Taylor, adult in charge at 1270 Newburg Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy o the same. f . ?1 v SHELDON MARSHALL, DEPUTY SHERIFF COST: $62.00 January 07, 2011 SO ANSWERS, RONW R ANDERSON, SHERIFF McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 r " =`- JOSEPH F.RIGA,ESQUIRE-ID#57716 ' ? F JOSEPH L FOLEY,ESQUIRE-ID#314675 T � CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 -< LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 �'a Philadelphia,Pennsylvania 19109 '" G 215 790-1010 _ .. Beneficial Consumer Discount Company d/b/a CUMBERLAND COUNTY Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS Plaintiff V. Number 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor ofPlaintiff and against Defendants,Patrick Aaron Taylor and Kimberly Sue Taylor, in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure,and assess damages as follows: Principal $ 324,923.50 Interest from 11/11/10 to 01/16/14 $ 51,102.22 @ 43.94 per diem thereafter Total $ 376,025.72 McCABE,WEISBER AND CONWAY,P.C. BY: [ ]Terrence J. cCabe,Esq. [ ]Marc S.Weisberg,Esq. [ ]Edward D. onway,Esq. [.i]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff AND NOW,this of �Mn ,2014, Judgment is entered in favor of Plaintiff,Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company ofPennsylvania,and against Defendants,Patrick Aaron Taylor and Kimberly Sue Taylor,in rem only aqd not in personam,and damages are assessed in the amount of$376,025.72, OL plus interest and costs. , T f BY T PRO O D*O 0 P 2DO9 01 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Beneficial Consumer Discount Company d/b/a CUMBERLAND COUNTY Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS Plaintiff V. Number 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants AFFIDAVIT AS TO MILITARY SERVICE Diane Nguyen,being of lawful age and being first duly sworn on oath, states and deposes as follows: 1. I am a Legal Assistant at McCabe,Weisberg&Conway,P.C. 2. On the Sixteenth day of January, 2014, I personally conducted an online search through the Department ofDefense Manpower Data Center at httys://www.dmde.osd.mil/scra/owa/home,which indicated that the Defendants,Patrick Aaron Taylor and Kimberly Sue Taylor,were not in the military service of the United States as of the date I conducted the search. A true and accurate copy of the printout of the online search results from the Department of Defense Manpower Data Center is attached hereto. 3. To my knowledge,defendants,Patrick Aaron Taylor and Kimberly Sue Taylor,are not infants or incompetent. I affirm,under the penalties for perjury,that the foregoing representations are true. SWORN AND SUBSCRIBED :�'BEFORE ME THI DAY Name: Diane Ng OF 2014 NOTARY PUBLIC . 'rt, �+� Public.._. "� C y of r ii G 1?rlfc3,i`ila.County MyCcn,rniss€cn EXPires January 12,'4018 Department of Defense Manpower Data Center Results as of:Jan-17-2014 06:06:25 AM SCRA 3.0 40 Status Report Pursuant to Scry cemembers Civil Relief Act. Last Name: TAYLOR First Name: PATRICK Middle Name: AARON Active Duty Status As Of: Jan-17-2014 tM Ave Du DM Active Dutv Stalls Dad# Active D Start Date "a Du Ern!Date status Sendce Can k ::."� �,' �" NA NA NA This response reflects thedividuaa'active.du status based on the A YO D status Date Left Active Duty':within 367 Days of Active Du statue Data Active D Start Date Active End Date Status Service ent NA ��NA !.No NA This response reflects where tits'individual left active d `status wltfdn'36�'da ecedi the Active Ru Status Date The Member or His/Her Unit Was NoWed of a Future CaWp to Active Di on Alive D!q Status Deta Order Notification Start Date Order No6flcatlon End Data ° status service Componerit NA r'ac'_NGl NA This response reflects whether. Ya1 or his/hecuFit hasrecelved aarj #6n to report for active duty Upon searching the data banks of the Department of Defense ManpowerData Ca(►tr,�baed on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Sery ices(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. %4k Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers Civil Relief Act(50 USC App.§501 at 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 only 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 was on active duty for the active duty status date,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/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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(NOAH Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: A6MFX3DESOBC200 Department of Defense Manpower Data Center Results as of:Jan-1 7-2014 06:30:46 AM SCRA 3.0 Status Report Pursuant to Servicentembers Civil Relief Act. Last Name: TAYLOR First Name: KIMBERLY Middle Name: SUE Active Duty Status As Of: Jan-17-2014 OnActiveDutYbrtActive OW status Date= ActiveOu StartDate Active OWEnd Data - S#attfla� $arvkaCam t,` , .� << �Q6�"uIR 'ti NA NA 11:1 NA `. w. This response reflecs theSxUvidual.'active du status based on the X; DuZ Status Date Lett Acdve Duty within 367Daysi of Active Dn Status Date' Active Duty Start Date Active ; End Date status service Cont powt NA -A NA No - 0 T NA .a This res onse reflects Where tut indMdual left active d afffi4a Wn4md i6THa preceding the Active D`u Status Date W fi .o p The Member or�i1&44er Unit was Notttied of a Future Ce R va on Alive Duty 4stebg Deco Order Notification Start Date Order Notiflca*m End Date Status service Com none NA NA This response reflects whether 6reindNTdua1 a his/her unithae feaelved earl eGGa1 to report for active duty Upon searching the data banks of the Department of Defense Manpowet Dahlentei,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. k dr aim+ a/ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers Civil Relief Act(50 USC App.§501 at 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 only 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 was on active duty for the active duty status date,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:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: X6G4W3DE10FB780 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Beneficial Consumer Discount Company d/b/a COURT OF COMMON PLEAS Beneficial Mortgage Company of Pennsylvania CUMBERLAND COUNTY Plaintiff Number 11-6 Civil Term V. Patrick Aaron Taylor and Kimberly Sue Taylor Defendants AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last-known mailing addresses of the Defendants are: Patrick Aaron Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBE BY: BEFORE ME THI DAY [ ]T ence .McCabe,Esq. [ ]Marc S.Weisberg,Esq. [ ]Edward .Conway,Esq. f�jrZrgaret Gairo,Esq. OF 2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ] Christine L.Graham,Esq. a [ J Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. N ARY PUBa.` °' [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. Jennifer L.Wunder,Esquire Celine P.DerKrikorian,Esq. [ ] Lena Kravets,Esquire BRa J. pia,Phita.C;bu�iY phtiiadalp aes Jarua � � Attorneys for Plaintiff F-./ My Cam�`i�s�an xp McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Beneficial Consumer Discount Company d/b/a CUMBERLAND COUNTY Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS Plaintiff V. Number 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff,being duly sworn according to law. deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against him/her/them within ten(10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS DAY ( ]Te ence J cCa e,Esq. [ ]Marc S.Weisberg,Esq. [ ]Edward .Conway,Esq. ;,-]-Margaret Gairo,Esq. OF 014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NO ARY PUBL [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire PF C# `;i%'_@.RV'e3� e L tiR [ ]Lena Kravets,Esquire BARD Yt=J. $C�' R,Nom, P blICAtt rneys for Plaintiff City of Ptsila;leiphia,Phila.County 1M�y Commission Expires January 12,209 8 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE WEISBERG AND CONWAY,P.C. BY: [ ]Terrence J. cCabe,Esq. [ ]Marc S. Weisberg,Esq. [ ]Edward D. onway,Esq. [.-Nargaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania v.Patrick Aaron Taylor and Kimberly Sue Taylor Cumberland County;Number: 11-6 Civil Term OFFICE OF THE PROTHONOTARY /7 COURT OF COMMON PLEAS �Q Cumberland County Courthouse,Carlisle, Pennsylvania 17013 Curt Long Prothonotary January 28,2011 To: Patrick Aaron Taylor 1270 Newburg Road Shippenburg,Pennsylvania 17257 Beneficial Consumer Discount Company Cumberland County d/b/a Beneficial Mortgage Company of Court of Common Pleas Pennsylvania VS. Patrick Aaron Taylor Number 11-6 Civil Term Kimberly Sue Taylor NOTICE,RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER OR BY PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITTEN APPEARANCE PERSONALLY DEFENSES ATTORNEY AND FILE I OR OBJECTIONS TO THE PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR WRITING WITH THE COURT YOUR DEFE ESCRTO CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS CLAIMS SET FORTH AOAINST YOU. UNLESS YOU ACT WITHIN TEN(10) RscRITo S N ESTE TRIBUNAL A CONTRA NSAS OB NO TOMAR LA DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED DE LA FECHA AGAINST YOU WTTFIOUTAHEAR(NGAND YOU MAYLOSE YOUR PROPERTY NOTIFICACI N,+ EL TRIBUNAL (PODRA,SSIN NECES DAD�DE OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SEA A E SU CONTRNA Y USTED PODRIA PERDER BIIDMS U OTROS DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH DERECHOS IMPORTANTES. BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO HIRING A LAWYER. INMEDIATAMENTE. S1 USTED NO TIENE A UN ABOGADO,VA A 0 IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TELEFONEA LA OFICINA EXPUsO ABAJO.ESTA OFICINA LO PUEDE TO PROVIDE YOU WITH INFORMATION ABOUTAGENCIES THAT MAY OFFER PROPORCIONAR CON INFORMAci& ACERCA DE EMPLEAR A UN LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEET OR NO FEE. AROGADO Cumberland County Bar Association SI USTED NOPUEDEPROPORCIONARPARAEMPLEARUNABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON 2 Liberty Avenue 1NFORMAcl&ACERCA DE LAS AOENCIAS QUE PUEDEN OFRECER LOS Carlisle,Pennsylvania 17013 SERVICIOS LEGALES A PERSONAS EL901BLES EN IN HONORARIO (800)990-9108 RE13UCIDO NI NINON HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle,Pennsylvania 17013 �— (800)990.9108 BY: Attorneys for Plaintiff TERRENCE J.McCABE,ESQUIRE MARC S.WEISBERG,ESQUIRE EDWARD D.CONWAY,ESQUIRE MARGARET GAIRO,ESQUIRE ANDREW L.MARKOWITZ,ESQUIRE CHRISTINE L.GRAHAM,ESQUIRE bm P;l. 0(09 k� T'ILI b 1/17 OFFICE OF THE PROTHONOTARY /Q COURT OF COMMON PLEAS Cumberland County Courthouse,Carlisle,Pennsylvania 17013 Curt Long Prothonotary January 28, 2011 To: Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Beneficial Consumer Discount Company d/b/a Cumberland County Beneficial Mortgage Company of Pennsylvania Court of Common Pleas Vs. Patrick Aaron Taylor Kimberly Sue Taylor Number 11-6 Civil Term NOTICE,RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A LISTED SE ENCUENTRA EN ESTADO DE REBELDIA FOR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PERSONALMENTE 0 OR A$OGADO Y FOR NO HABER RA, ADO SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LAS CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN R RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED ED ACCION DEBIDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE ESTA AGAINST YOU WI THOUTAHEARINGANDYOUMAYLOSEYOURPROPERTY NOTIFICACION, EL TRIBUNAL PODRA, SIN NF.CESIDAD DE OR OTHER IMPORTANT RIGHTS. COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA,DICTAR YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SENTENCIA FN SU CONTRA YUSTED PODRIA PPRDERBIENES U OTROS DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH DERECHOS IMPORTANTES. BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO HIRING A LAWYER. INMHDIATAMENTE. Sl USTED NO TIENE A UN ABOGADO,VA A 0 IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TELEFONEA LA TE. SI A TED N A IENE ESTA N ABOGA , PUEDE TO PROVIDE YOU WITH INFORMATIONABOUTAGENCIESTHATMAYOFFER PROPORCIONAR CON INFXPUS AB ACERCA O EMPLEAR A DE UN LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ABOGADO Cumberland County Bar Association SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON 2 Liberty Avenue INFORMACION ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS Carlisle,Pennsylvania 17013 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO (800)990-9108 REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle,Pennsylvania 17013 (800)990-91114 BY: Attorneys for Plaintiff TERRENCE J.McCABE,ESQUIRE MARC S.WEISBERG,ESQUIRE EDWARD D.CONWAY,ESQUIRE MARGARET GAIRO,ESQUIRE ANDREW L.MARKOWITZ,ESQUIRE CHRISTINE L.GRAHAM,ESQUIRE hm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Patrick Aaron Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. No. 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe Weisbers and Conway. P.C.at(215)790-1010. F OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. No. 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe Weisberg and Conway. P.C.at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 11-6 Civil Term Civil Term 'c3 T Beneficial Consumer Discount Company d/b/a ; d, Beneficial Mortgage Company of Pennsylvania AMOUNT DUE: $376,025.72 u) V. -L . � INTEREST: from 01/17/14 r -o '? Patrick Aaron Taylor and Kimberly Sue Taylor $8,591.59 at$61.81 p N ATTY'S COMM.: • COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt,interest and costs upon the following described property of the defendant(s) 1270 Newburg Road,Shippensburg,Pennsylvania 17257 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE:11—CL241- BY: [ ]Terrence J cCabe,Esq. [ ]Marc S.Weisberg,Esq. glO [ ]Edward Conway,Esq. [..- Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. - [ ]Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. �1 - a? 5bP CI a [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. ,1 �O a rg ' [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. qa, oo t i * Attorneys for Plaintiff Print Name:Margaret Gairo,Esquire S b 4 I' Firm:MCCABE,WEISBERG AND CONWAY Address:123 S.Broad Street, Suite 1400 4 t9'61 0r) Philadelphia,PA 19109 Attorney for: Plaintiff Telephone:(215)790 1010 �.a S 7>ve 4upreme Court ID No. 34419 �t, 50LC• Ot A66P2o e# 3001(4 601/. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-6 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA Plaintiff(s) From PATRICK AARON TAYLOR AND KIMBERLY SUE TAYLOR (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: $376,025.72 L.L.: $.50 Interest FROM 1/17/14-$8,591.59 AT$61.81 Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.00 Other Costs: Plaintiff Paid: Date: 1/27/14 / David D. Buell,Prothonota (Seal) �/ ',. Ay-.4., _ Deputy REQUESTING PARTY: Name: MARGARET CAIRO, ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone:215-790-1010 Supreme Court ID No.34419 LEGAL DESCRIPTION ALL the following described real estate,lying and being situate in Southampton Township,Cumberland County, Pennsylvania,bounded and limited as follows: BEGINNING at a Parker Kalong nail in S.R.0696(Newburg Road)at corner of lands now or formerly of Mark D.Keener; thence with said lands of Keener,North 72 degrees 25 minutes 26 seconds West,424.64 feet to an iron pin at corner of other lands of the granters herein;thence with said lands on a curve with said lands on a curve to the right having a radius of 350.00 feet,a chord bearing of North 04 degrees 29 minutes 58 seconds West,a chord length of 462.48 feet,and an arc length of 505.21 feet to an iron pin in line of lands now or formerly of Kenneth M.Hale,Jr.,and Judith E.Hale;thence with said lands of Hale, South 89 degrees 40 minutes 00 seconds East, 150.00 feet to a railroad spike in S.R.0696;thence in S.R.0696 on a curve to the left having a radius of 1910.08 feet,a chord bearing of South 25 degrees 23 minutes 22 seconds East,a chord length of 93.48 feet,and an arc length of 93.49 feet to a Parker Kalon nail;thence continuing in S.R. 0696 the following two courses; South 26 degrees 52 minutes 16 seconds East,330.11 feet to a Parker Kalon nail; South 25 degrees 55 minutes 11 seconds East,232.92 feet to a Parker Kalon nail at corner of lands of Keefer,the place of BEGINNING. CONTAINING 3.7464 acres,and BEING Lot No.2 shown on a subdivision plan prepared for the grantors herein by Eric Diffenbaugh,dated May 28,2004, bearing the approvals of the Southampton Township Supervisor,and recorded in Cumberland County Plan Book Volume 89,page 99. SUBJECT TO all restrictions,easements,and rights-of-way of record,or as may appear on the ground by an inspection of the premises,and SUBJECT TO a 10-foot sewer easement shown on the subdivision plan hereinbefore referred to and to all notes appearing on the said plan. 1270 Newburg Road, Shippensburg,Pennsylvania 17257. BEING the same premises which ROBERT DALE TAYLOR AND MARY JANE TAYLOR,HUSBAND AND WIFE by deed dated January 4,2005 and recorded January 13,2005 in the office of the Recorder in and for Cumberland County in Deed Book 267,Page 637,granted and conveyed to Patrick Aaron Taylor and Kimberly Sue Taylor,husband and wife,in fee. TAX MAP PARCEL NUMBER:39-11-0312-021 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 eAr ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 Cpoir HEIDI R.SPIVAK,ESQUIRE-ID#74770 $ ,` MARISA J.COHEN,ESQUIRE-ID#87830 p 7 KEVIN T.McQUAIL,ESQUIRE-ID#307169 I .' q CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 ,� 3 P BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 ✓J�` JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Beneficial Consumer Discount Company d/b/a CUMBERLAND COUNTY Beneficial Mortgage Company of Pennsylvania COURT OF COMMON PLEAS Plaintiff v. NO: 11-6 Civil Term Patrick Aaron Taylor and Kimberly Sue Taylor Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 1270 Newburg Road,Shippensburg,Pennsylvania 17257,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Patrick Aaron Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 2. Name and address of Defendants in the judgment: Name Address Patrick Aaron Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 Kimberly Sue Taylor 1270 Newburg Road Shippensburg,Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Pennswood Apartment c/o Jager 2000 Maplewood Drive Management Maple Shade,New Jersey 08052 Pennswood Apartment c/o Jager c/o Craig B. Sobel,Esquire Management The Bellevue,Ste 400 200 South Broad Street Philadelphia,Pennsylvania 19102 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1270 Newburg Road Shippensburg,Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Western District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 and U.S.Post Office and Courthouse 700 Grant Street, Suite 400 Pittsburgh,PA 15219 United States of America c% U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: ZC / [ ]Terrence .Mc abe,Esq. [ ] Marc S.Weisberg,Esq. DA E [ ]Edward .Conway,Esq. [ j1cIargaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 a v CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 c +' Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW ..<c) , t_s _ , Beneficial Consumer Discount Company d/b/a COURT OF COMMON PLEAS ;` Beneficial Mortgage Company of Pennsylvania —, 4' CUMBERLAND COUNTY C l v. Patrick Aaron Taylor and Kimberly Sue Taylor Number 11-6 Civil Term NOTICE OF SHERIFFS SALE OF REAL PROPERTY To: Patrick Aaron Taylor Kimberly Sue Taylor 1270 Newburg Road 1270 Newburg Road Shippensburg,Pennsylvania 17257 Shippensburg,Pennsylvania 17257 Your house(real estate)at 1270 Newburg Road,Shippensburg,Pennsylvania 17257 is scheduled to be sold at Sheriffs Sale on June 4,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$376,025.72 obtained by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania the back payments,late charges,costs,and reasonable attorney's fees due. To fmd out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may fmd out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To fmd out if this has happened,you may call McCabe,Weisberg and Conway,P.C.at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL the following described real estate,lying and being situate in Southampton Township,Cumberland County, Pennsylvania,bounded and limited as follows: BEGINNING at a Parker Kalong nail in S.R.0696(Newburg Road)at corner of lands now or formerly of Mark D.Keener; thence with said lands of Keener,North 72 degrees 25 minutes 26 seconds West,424.64 feet to an iron pin at corner of other lands of the granters herein;thence with said lands on a curve with said lands on a curve to the right having a radius of 350.00 feet,a chord bearing of North 04 degrees 29 minutes 58 seconds West,a chord length of 462.48 feet,and an arc length of 505.21 feet to an iron pin in line of lands now or formerly of Kenneth M.Hale,Jr.,and Judith E.Hale;thence with said lands of Hale, South 89 degrees 40 minutes 00 seconds East, 150.00 feet to a railroad spike in S.R.0696;thence in S.R.0696 on a curve to the left having a radius of 1910.08 feet,a chord bearing of South 25 degrees 23 minutes 22 seconds East,a chord length of 93.48 feet,and an arc length of 93.49 feet to a Parker Kalon nail;thence continuing in S.R. 0696 the following two courses; South 26 degrees 52 minutes 16 seconds East,330.11 feet to a Parker Kalon nail; South 25 degrees 55 minutes 11 seconds East,232.92 feet to a Parker Kalon nail at corner of lands of Keefer,the place of BEGINNING. CONTAINING 3.7464 acres, and BEING Lot No.2 shown on a subdivision plan prepared for the grantors herein by Eric Diffenbaugh,dated May 28,2004, bearing the approvals of the Southampton Township Supervisor,and recorded in Cumberland County Plan Book Volume 89,page 99. SUBJECT TO all restrictions,easements,and rights-of-way of record,or as may appear on the ground by an inspection of the premises,and SUBJECT TO a 10-foot sewer easement shown on the subdivision plan hereinbefore referred to and to all notes appearing on the said plan. 1270 Newburg Road, Shippensburg,Pennsylvania 17257. BEING the same premises which ROBERT DALE TAYLOR AND MARY JANE TAYLOR,HUSBAND AND WIFE by deed dated January 4,2005 and recorded January 13,2005 in the office of the Recorder in and for Cumberland County in Deed Book 267,Page 637,granted and conveyed to Patrick Aaron Taylor and Kimberly Sue Taylor,husband and wife,in fee. TAX MAP PARCEL NUMBER:39-11-0312-021 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson-+ 73.tQ, F Sheriff �pRo i(Uh` 0 iii N Jody S Smith Chief Deputy Richard W Stewart Solicitor T4c. SHERI 7T,114 PIM 19 ! 11' 01 co PENNSYLVANIA I✓�,�M AND TY Beneficial Consumer Discount Company vs. Case Number Patrick Aaron Taylor (et al.) 2011-6 SHERIFF'S RETURN OF SERVICE 03/26/2014 02:30 PM - Deputy Tim Black, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1270 Newburg Road, Southampton - Township, Shippensburg, PA 17257, Cumberland County. 04/02/2014 02:20 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patrick Aaron Taylor at 1270 Newburg Road, Southampton Township, Shippensburg, PA 17257, Cumberland County. 04/02/2014 02:20 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Patrick Taylor, Husband, who accepted as "Adult Person in Charge" for Kimberly Sue Taylor at 1270 Newburg Road, Southampton Township, Shippensburg, PA 17257, Cumberland County. 05/15/2014 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: $1,196.49 SO ANSWERS, May 15, 2014 (c) CountySute iff. 'ieleosott, 1 eta RONR ANDERSON, SHERIFF R-f On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, 00c Known and numbered as 1270 Newburg Road, 0-- "' Shippensburg, as Exhibit "A" filed with this . Writ and by this Reference incorporated herein. Date: March 3, 2014 By: eal Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2011-6 Civil Term Beneficial Consumer Discount Company vs. Patrick Aaron Taylor Kimberly Sue Taylor Atty.: Terrence McCabe ALL the following described real estate, lying and being situate in Southampton Township, Cumber- land County, Pennsylvania, bounded and limited as follows: BEGINNING at a Parker Kalong nail in S.R. 0696 (Newburg Road) at corner of lands now or formerly of Mark D. Keener; thence with said lands of Keener, North 72 degrees 25 minutes 26 seconds West, 424.64 feet to an iron pin at corner of other lands of the granters herein; thence with said lands on a curve with said lands on a curve to the right having a radius of 350.00 feet, a chord bear- ing of North 04 degrees 29 minutes 58 seconds West, a chord length of 462.48 feet, and an arc length of 505.21 feet to an iron pin in line of lands now or formerly of Kenneth M. Hale, Jr., and Judith E. Hale; thence with said lands of Hale, South 89 degrees 40 minutes 00 seconds East, 150.00 feet to a railroad spike in S.R. 0696; thence in S.R. 0696 on a curve to the left having a radius of 1910.08 feet, a chord bearing of South 25 de- grees 23 minutes 22 seconds East, a chord length of 93.48 feet, and an arc length of 93.49 feet to a Parker Kalon nail; thence continuing in S.R. 0696 the following two courses; South 26 degrees 52 minutes 16 seconds East, 330.11 feet to a Parker Kalon nail; South 25 degrees 55 minutes 11 seconds East, 232.92 feet to a Parker Kalon nail at corner of lands of Keefer, the place of BEGINNING. CONTAINING 3.7464 acres, and BEING Lot No. 2 shown on a subdivi- sion plan prepared for the grantors herein by Eric Diffenbaugh, dated May 28, 2004, bearing the approv- als of the Southampton Township Supervisor, and recorded in Cum- berland County Plan Book Volume 89, page 99. SUBJECT TO all restrictions, easements, and rights-of-way of rec- ord, or as may appear on the ground by an inspection of the premises, and SUBJECT TO a 10 -foot sewer easement shown on the subdivision plan hereinbefore referred to and to all notes appearing on the said plan. 1270 Newburg Road, Shippens- burg, Pennsylvania 17257. BEING the same premises which ROBERT DALE TAYLOR AND MARY JANE TAYLOR, HUSBAND AND WIFE by deed dated January 4, 2005 and recorded January 13, 2005 in the office of the Recorder in and for Cum- berland County in Deed Book 267, Page 637, granted and conveyed to Patrick Aaron Taylor and Kimberly Sue Taylor, husband and wife, in fee. TAX MAP PARCEL NUMBER: 39- 11-0312-021. 110 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 18, April 25 and May 2, 2014 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 Coyne, E SWORN TO AND SUBSCRIBED before me this da of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE KORO., CUMBERLAND CNTY My Commission Expires Apr 28. 2018 The Patriot -News Co. S 2020 Technology Pkwy Suite 300 `Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 iie atriotXcws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller 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. Aleyas gdesor :Ault sutepl!MMANI sA lands now or formerly of Kenneth M. Hale, Jr., and Judith E. Hale; thence with said lands of Hale, South 89 degrees 40 minutes 00 seconds East, 150.00 feet to a railroad spike in S.R 0696; thence. in c 2011-6 Civil Term Beneficial Consumer Discount Company Vs Patrick Aaron Taylor LIl Kimberly Sue Taylor Atty. Terrance McCabe \IL the following described real Is tate, ling and being situate in Southampton Township, Cumberland u belded and County, Pennsylvania, bouR limited as follows: aa Parker Kalong L BEGINNING -..,«4, (NPW�uru.Road) at This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 is 02 day of May, 2014 A.D. COMMC^VE ALft•i Ot- PENNSYLVANIA "otartai Seat r:coy Lynn 1.,.4.:°.', :ry pt;ac R- Ywphtn County ' sDec.12,2016_ MEMBER. PENNSYLVANIA As "'rTATION OF NOTARIES