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HomeMy WebLinkAbout11-0215~r~~-v~~i~~ OF THE PROTHONOTARY 1011,:{:` . ~` I i ~ 0 7 CllMBc~'__y°~°" ~"`TY cr McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIItE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790.1010 Chase Home Finance LLC 10790 Rancho Bernardo Road San Diego, California 92127 v. Randy J. Fultz 1112 Shannon Lane Carlisle, Pennsylvania 17013 Shelby L. Metzger 1112 Shannon Lane Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Cumberland County Court of Common Pleas ~+ 2011-ass C~v~ l T~~ Number CIVIL ACTION/MORTGAGE FORECLOSURE 'fib "CM a'~ a~ ~~ao3D~ ~~ 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) dias 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 provisiones 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 AGENCIES 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 1. Plaintiff is Chase Home Finance LLC, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Randy J. Fultz, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1112 Shannon Lane, Carlisle, Pennsylvania 17013. The Defendant is Shelby L. Metzger, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1112 Shannon Lane, Carlisle, Pennsylvania 17013. 4. On April l 1, 2008, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for AmTrust Bank which mortgage is recorded in the Office of the Recorder of Cumberland County Mortgage Instrument Number 200811743 and was re-recorded on September 9, 2008 as Mortgage Instrument Number 200830591. 5. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for AmTrust Bank to Chase Home Finance LLC, by Assignment of Mortgage, to be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 1112 Shannon Lane, Carlisle, Pennsylvania 17013. The mortgage is in default because monthly payments of principal and interest upon said mortgage due January 1, 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. The following amounts are due on the mortgage: Principal Balance $ 284,791.17 Interest through November 30, 2010 $ 18,867.36 (Plus $51.69 per diem thereafter) Attorney's Fee $ 1,325.00 Late Charges $ 278.43 Corporate Advance $ 80.50 Escrow Advance $ 7,893.39 GRAND TOTAL $ 313,235.85 9. 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 Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $313,23 5.85, together with interest at the rate of $51.69 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. .~'~ i :~~ BY: 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. /~~ Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Chase Home Finance LLC v. Randy J. Fultz and Shelby L. Metzger COMMITMENT FOR TITLE INSURANCE File No. 2010-9383 SCHEDULE A (continued) LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situated in the Borough of Cazlisle, Cumberland County, PA being The Highlands, Phase 3, Lot No. 101, as shown on a plan entitled "The Highlands Final Subdivision Plan, Phase 3, Section One" dated January 21, 1997, by PennTerra Engineering, Inc., State College, PA, recorded in Plan Book 79, Page 103, being bounded and described as follows: BEGINNING at an iron pin, lying in a southerly right of way line of Shannon Lane (60 foot right of way), and being a westerly corner of Lot No. 102; thence along said Lot, South 04 degrees 18 minutes 00 seconds East, 136.82 feet to an iron pin, being a southerly corner of said Lot and lying in a northerly line of lands owned now or formerly by Thomas Roy and Pauline V. Lebo (Deed Book N-12, Page 207); thence along said lands, South 85 degrees 44 minutes 30 seconds West, 80.00 feet to an iron pin, lying along said lands and being an easterly corner of Lot No. 100; thence along said Lot, North 04 degrees 18 minutes 00 seconds West, 136.76 feet to an iron pin, being a northerly comer of said Lot and lying in a southerly line of Shannon Lane (60 foot right of way); thence along said right of way, North 85 degrees 42 minutes 00 seconds East, 80.00 feet to an iron pin, being the place of BEGINNING. CONTAINING 0.251 acres. BEING known numbered as 1112 Shannon Lane, Cazlisle, PA 17013. Lot No. 101 is subject to a 10 foot wide utility easement along its street frontage. UNDER AND SUBJECT to the building and use restrictions set forth in Deed Book 257, Page 745. Being the same property acquired by Shelby L. Metzger and Randy J. Fultz, by Deed recorded 09/09/2008, of record in Deed in Instrument No. 200830590, in the Office of the Recorder of Cumberland County, Pennsylvania. Gxhi6itA Schedule A -Page 2 of 2 File !k: 2010-9383 - REO America Abstract Co. ALTA Commitment (6-17-06) - TIRBOP & STG modifications (4-1-07) ~S'tE?Wc'~1't tips guaranty company 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 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 2011-215 Civil Term MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 C7 C M V) ? r- c 2`_ c:) ==i na v c-a M -*t ran ? O r, Plaintiff attempted to personally serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Randy J. Fultz, at his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013. The process server was not able to serve the Defendant because the defendant was not found. Plaintiff attempted to personally serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Shelby L. Metzger, at his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013. The process server was not able to serve the Defendant because the defendant was not found. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "A". 2. Plaintiff attempted to serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendants' mortgaged property of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. The process server was not able to serve the Defendants. True and correct copy ofthe Return of Service indicating the same is attached hereto, made a part hereof, and marked as Exhibit "B". 3. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendants and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "C". 4. As a result of the investigation, a special Order of Court is required permitting service by regular and certified mail at the Defendants last known address and by posting a copy of the original process on the mortgaged premises. 5. No judge has ruled upon any other issue in this matter or in any related matter. 6. No attorney has entered an appearance in this matter on behalf of Defendants and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. If service cannot be made on the Defendants, Randy J. Fultz and Shelby L. Metzger, the Plaintiff will be prejudiced. WHEREFORE, Plaintiffprays this Honorable Court grant an Order allowing the Plaintiffto serve the Complaint in Mortgage Foreclosure, and all other subsequent pleadings that require personal service, and the Notice of Sheriff s Sale upon the Defendants,Randy J. Fultz and Shelby L. Metzger, by regular mail; certified mail, return receipt requested; and by posting at the last-known address of Defendants and the mortgaged premises known in this herein action as 1112 Shannon Lane, Carlisle, Pennsylvania 17013. AA'1-- 5'1?? T RREN E J. cCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Cumberland County Court of Common Pleas Number 2011-215 Civil Term MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. I)L2, ?I- 2L,,, TERRENC J. Mc ABE, ESQUIRE MARC S. EISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Cumberland County Court of Common Pleas Plaintiff Randy J. Fultz and Shelby L. Metzger Defendants Number 2011-215 Civil Term CERTIFICATION OF SERVICE I, MdAd?tet Esquire, attorney for the Plaintiff, hereby certify that I served a true and j correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 21 st day of February, 2011, upon the following: Randy J. Fultz 156 Virginia Avenue Carlisle, Pennsylvania 17013 Shelby L. Metzger 156 Virginia Avenue Carlisle, Pennsylvania 17013 Ito, T RREN J. cCABE, ESQUIRE MARC . WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY R s c ?1 Ronny R Anderson r .3 0 g Sheriff b Jody S Smith r fluYtt}, ct r~:trin?P?r?'t Chief Deputy Richard W Stewart Solicitor :TPjCi OF F`EE -,f.#R1FF Chase Home Finance LLC vs. Case Number Randy J. Fultz (et al.) 2011-215 SHERIFF'S RETURN OF SERVICE 01/28/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Shelby L. Metzger but was unable t l b ili , o a ocate hern his wick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Shelby L. Metzger. Request for service at 1112 Shannon Lane C li l P , ar s e, vacant. ennsylvania 17013 is 01128/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search X'--- p-----_ and inquiry for the within named defendant t it o w : Randy J. Fultz, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Rand J Fultz R e y . . equ st for service at 1112 Shannon Lane, Carlisle, Pennsylvania 17013 is vacant. 01/28/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Randy J. Fultz but was unable to lo t h b ili , ca e a im in his wick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Randy J. Fultz. Request for service at 156 Virginia Avenue C li l , ar s e, Pennsylvania 17013 the defendant was not found. The Carlisle Postmaster confirmed, Randy J. Fultz has moved and left no forwarding address. 01/28/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defenda t t i n o w t: Shelby L. Metzger, but was unable to locate her in his bailiwick, He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Shelby L Metz e R . g r. equest for service at 156 Virginia Avenue, Carlisle, Pennsylvania 17013 the defendant was not found. The Carlisle Postmaster confirmed Shelby L Metz , . ger has moved and left no forwarding address. SHERIFF COST: $106.80 January 28, 2011 SO ANSWERS, 4RONR ANDERSON, SHERIFF le; COOn`ySLAW Shentf, Tc!tvsg- lr4. Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5770 AFFIDAVIT OF GOOD FAITH INVESTIGATION SUBJECT OF INVESTIGATION: Shelby Metzger CLIENT: FILE #: 53080 MATTER #: 116-6440 AOSS FILE#: 10-9831 SUBJECT'S LAST-KNOWN ADDRESS: 1112 Shannon Lane, Carlisle, PA 17013 I, Ernest Caldwell, being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above-named subject and the extent of the investigation and the results are as follows: INQUIRY OF POSTAL AUT..HORITY: Postal authority states address is good as addressed. 2. INQUIRY OF LOCAL TELEPHONE COMPANY; Directory Assistance: Directory assistance had no listing for the subject. Page 2 Investigation of Shelby Metzger continued: (subject name) 3. INTERNET SEARCH: Search shows no address for the subject.. 4. DEATH RECORDS: Social Security has no death record for the subject. LOCAL TAX RECORD INQUIRY: Tax bill is mailed to the subject at the above stated last-known address.. INQUIRY OF COUNTY VOTER REGISTRATION: After inquiry, I was unable to confirm a listing with the County Voters Registration Office for this subject.. Page 3 Investigation of Shelby Metzger continued: (subject name) 7. INQUIRY OF NEIGHBORS: a. Neighbor, Kevin J Weddle, residing at 1108 Shannon Ln, Carlisle, 17013 with a phone number (717) 960-9922 stated that he/she does not know the subject. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information, and belief, BY: Signal urt NAME: Ernest Caldwell Pdal TITLE: Location Specialist DATE: ?12 Notary Public: Sworn to and subscr'b/1 /) before a this -??J ?/`Jday of , 2010 ? C N t7 T"? t=? r ratlr 4; fA",L Barbara J. P-!oye'r-Nclt!,? r/ City of Philadelphia, Phiiadel ltia Ce. r~3 Mr COMMISSION EXPIRES JAN, 12, 2u': r Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5770 AFFIDAVIT OF GOOD FAITH INVESTIGATION SUBJECT OF INVESTIGATION: Randy Fultz CLIENT: FILE #: 53080 MATTER #: 116-6440 AOSS FILE#: 10-9831 SUBJECT'S LAST-KNOWN ADDRESS: 1112 Shannon Lane Carlisle, PA 17013 1, Ernest Caldwell, being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above-named subject and the extent of the investigation and the results are as follows: 1. INQUIRY OF POSTAL AUTHORITY: Postal authority states address is good as addressed. 2. INQUIRY OF LOCAL TELEPHONE COMPANY; Directory Assistance: There is an unlisted number for the subject at the above stated last-known address. Page 2 Investigation of Randy Fultz continued: (subject name) INTERNET SEARCH: Search shows no address for the subject.. 4. DEATH RECORDS: Social Security has no death record for the subject. LOCAL TAX RECORD INQUIRY: Tax bill is mailed to the subject at the above stated last-known address., 6, INQUIRY OF COUNTY VOTER REGISTRATION: After inquiry, I was unable to confirm a listing with the County Voters Registration Office for this subject.. Page 3 Investigation of Randy Fultz continued: (subject name) INQUIRY OF NEIGHBORS: a. Neighbor, Kevin J Weddle, residing at 1108 Shannon Ln, Carlisle, 17013 with a phone number (717) 960-9922 stated that he/she does not know the subject. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information, and belief. BY: _ Sign$ture NAME: Ernest Caldwell Print TITLE: Location Specialist DATE: zZ/ ?///o Notary Public: Sworn to and subscribed k n before a this day of U. 2010 4LA CDMMONW L7'H OF p N p 7q R l q ANN YLbAN1 Barbara J. Mo SE A Clay o! PhiladelPhlaa philNOtA lM)' COMMISSfOIy ?? +'?1?thlt '?NH?y '1N•1? i4 Postmaster Date December 6, 2010 Carlisle, PA 17013 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address cif a boxholder) for the following: Name: Randy Fultz Address: 1112 Shannon Lane, Carlisle, PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): jQme 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Randy Fultz 4. The court in which the case has been or will be heard: CUMBERLAND, PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FAI. SF. INFORMATION TO OB'T'AIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN TI-IL SERVIC1i OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPF.("r1VE LITIGATION COULD RESULT' IN CRIMINAL PENALTIES INCLUDING A FINL OF UP TO $10,000 OR IMPRISONMENTOR (2)'1'0 AVOID PAYMENT OP THE FEL FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR. THE DEFENDANT. l certify tbat the abov information is true and that the address information is needed and will be used solely for 123 S. Broad Street, Suite 2050 Sig ature Address Q PA 19109 scrvi f legal proc in con with actual or prospective litigation. Oscar Dungan, AOSS R Printed Name City, State, ZIP Code FOR POST OFFICE USE ON.I.X Moved, left no forwarding address. No change of address order on file. Not known at address given. No such address. ?X' Good As Addressed NEW ADDRESS or BOXHOLDER'S NAME and PHYSICAL STREET ADDRESS Postmaster Date December 6, 2010 Carlisle, PA 17013 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Shelby Metzger Address: 1112 Shannon Lane, Carlisle, PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii), There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Shelby Metzger 4. The court in which the case has been or will be heard: CUMBERLAND, PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WrrH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE PEG FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SFCI'ION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. 1 certify that the above information is true and that the address information is needed and will be used solely for vice of lega ocess in connection with actual or prospective litigation. ?? 123 S. Broad Street, Suite 2050 ignatu Address Oscar Duncan, AOS Philadelphia, PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY No change of address order on tile. Not known at address given. NEW ADDRESS or BOXHOLDER'S NAME and PHYSICAL STREET ADDRESS Moved, left no forwarding address. No such address. Good As Addressed lP_a?-:? j McCABE, WEISBERG AND CONW AY, P.C. BY: TERRENCE J. McCABE, E QUIRE - ID # 16496 MARC S. WEISBERG, ESQ ARE - ID # 17616 EDWARD D. CONWAY, ES UIRE - ID # 34687 MARGARET GAIRO, ESQ IRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 2011-215 Civil Term ORDER U."I -71 .. W - AND NOW, this v?day of ! MdXcN\ , 2011, the Plaintiff is granted leave to serve process in this mortgage foreclosure action upon the D?fendant, Randy J. Fultz, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisl, Pennsylvania 17013 and by posting the mortgaged premises of 1112 Shannon Lane, Carlisle, Pennsylvania 00 13. BY THE COURT: ?*? I J. `?M aref Gaaro , Ma,11ed ?y ?9Jr11 orb OF THELPR HONOTARY 2011 MAR 29 AM 10: 14 CUMBERLAND COUNT'' PENNSYLVANIA 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 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 2011-215 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure ' hF. ove-captioned matter. ERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE t Attorneys for Plaintiff 1? I36, C/ 71,j f . FILED-QF FIDc n 11, ,F Tin-- PROTHONOTARY cU a f A?R 21 P4 12: CUMBE'R ANpD COU"T`' PI" 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 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS NUMBER 2011-215 Civil Term AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Terrence J. McCabe, Esquire, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief That he is counsel for the above-named Plaintiff; 2. That on April 1, 2011, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Randy J. Fultz by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013. True and correct copies of the letters, certificates of mailing and certified receipts are attached hereto, made a part hereof, and marked as Exhibit "A." 3. That on March 29, 2011, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendants, Randy J. Fultz and Shelby L. Metzger, by posting the same at the mortgage premises of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. True and correct copy of the Affidavit of Service indicating the same is attached hereto., m art hereof, and marked Exhibit "B." TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff SWORN AND SUBSC BEFORE ME THI? OF AP L, 2011 NO RY PUBLIC i COMM13 NWE EE3 f.; t.AL loyor- i. ;?tary Publiceiphia, Phil ceipha County ON E 0!075 JAN. 12, 2014 TERRENCE J. McCABE ••• MARC S. WEISBERG EDWARD D. CONWAY MARGARET GAIRO - LISA L. WALLACE+t DEBORAH K. CURRAN±- LAURA H.G. O'SULLIVAN±, GAYL C. SPIVAK- ANDREW L. MARKOWITZ HEIDI R. SPIVAK SCOTT T. TAGGART MARISA J. COHEN JASON BROOKSt ERIN M. BRADY - KEVIN T. McQUAIL ALEXANDRA T. GARCIA CORRIN DEMENT - ABBY K. MOYNIHAN-. CATHERINE WELKER `•' ANTOINETTE N. MOORE -- CHRISTINE GRAHAM MELISSA A. SPOSATO ^ HEATHER WEJNERT • DEBRA A. STUMP a RICHARD J. SUZOR, JR See -mm-law- for licensing key Randy J. Fultz 156 Virginia Avenue Carlisle, PA 17013 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 April 1, 2011 SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 GENERAL FAX (914) 636-8901 MEDIATION ONLY FAX (914) 819-5505 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Re: Chase Home Finance LLC v. Randy J. Fultz and Shelby L. Metzger Cumberland County; C.C.P.; Number 2011-215 Civil Term Dear Mr. Fultz: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated March 8, 2011, the original of which has been filed against you in regard to the above-captioned matter. Very truly yours, TJM/hm Enclosures TERRENCE J. McCABE SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7010 1870 0003 32718646 RETURN RECEIPT REQUESTED ExbIbIt A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. TERRENCE J. McCABE ••• MARC S. WEISBERG - EDWARD D. CONWAY - MARGARET GAIRO LISA L. WALLACE+t DEBORAH K. CURRAN t. LAURA H.G. O'SULLIVANt- GAYL C. SPIVAK ANDREW L. MARKOWITZ HEIDI R. SPIVAK SCOTT T.TAGGART- MARISA J. COHEN • JASON BROOKSt ERIN M. BRADY - KEVIN T. McQUAIL ALEXANDRA T. GARCIA CORRIN DEMENT - ABBY K. MOYNIHAN -- CATHERINE WELKER `•' ANTOINETTE N. MOORE CHRISTINE GRAHAM MELISSA A. SPOSATO - HEATHER WEJNERT• DEBRA A. STUMP z RICHARD J. SUZOR, JR See ww rn -1-wm for licensing key Shelby L. Metzger 156 Virginia Avenue Carlisle, PA 17013 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 April 1, 2011 SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 GENERAL FAX (914) 636-8901 MEDIATION ONLY FAX (914) 819-5505 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Re: Chase Home Finance LLC v. Randy J. Fultz and Shelby L. Metzger Cumberland County; C.C.P.; Number 2011-215 Civil Term Dear Mrs. Metzger: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated March 8, 2011, the original of which has been filed against you in regard to the above-captioned matter. Very t urs, TJM/hm Enclosures TERRENCE J. McCABE SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7010 1870 0003 3271 8639 RETURN RECEIPT REQUESTED This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Home Finance LLC vs. Randy J. Fultz (et al.) o?,?,,tir oc a?u,G?, fa?? YY a.?t.?. 's OPNCE OF NE 05REMPF % ? 0%0 Case Number, 2011-215 SHERIFF'S RETURN OF SERVICE 03/29/2011 09:33 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on March 29, 2011 at 2133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Randy J. Fultz, pursuant to order of court by posting the premises located at 1112 Shannon Lane, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. ARWHGVKHALL, DEPUTY 03/29/2011 09:33 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on March 29, 2011 at 2133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shelby L. Metzger, pursuant to order of court by posting the premises located at 1112 Shannon Lane, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. SHERIFF COST: $62.00 March 30, 2011 UTSHALL, DEPUTY SO ANSWERS, 6Z Kx?-r-? RbN R ANDERSON, SHERIFF 1 t "IT ,;.., {r; Cow !y5ulle Shenff, TwInsofl hr. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABr,, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas I Number 2011-215 Civil Term ,S30 ? 0 ORDER . AND NOW, this e day of MaX +b , 2011, the Plaintiff is granted leave to serve process in this mortgage foreclosure action upon the Defendant, Randy J. Fultz, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 170Q.and by posting $emortgaged premises of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. BY THE COURT: L41 a L. E6A'-,L $ 1 J. 41 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC :CUMBERLAND COUNTY :COURT OF COMMON PLEAS Plaintiff V. :NUMBER 2011-215 Civil Term Randy J. Fultz and Shelby L. Metzger Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Terrence J. McCabe, Esquire, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief: 1. That he is counsel for the above-named Plaintiff; 2. That on April 1, 2011, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Randy J. Fultz by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013. True and correct copies of the letters, certificates of mailing and certified receipts are attached hereto, made a part hereof, and marked as Exhibit "A." That on March 29, 2011, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendants, Randy J. Fultz and Shelby L. Metzger, by posting the same at the mortgage premises of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. True and correct copy of the Affidavit of Service indicating the same is attached heretomade a- pprt hereof, and marked Exhibit "B." TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff SWORN AND SUBSC BEFORE ME THIS; OF AP , 2011 ore NO RY PUBLIC COMMONWEALTH OF PEMNSYLVANI, [NE33 TARIAL SEAL r a J. Moyer- Notary Public Philadelphia, Philadelphia County MISSION EXPIRES JAN. 12, 2014 TERRENCE J. McCABE ••• MARC S. WEISBERG EDWARD D. CONWAY - MARGARET GAIRO LISA L. WALLACE+t DEBORAH K. CURRAN:. LAURA H.G. O'SULLIVAN *. GAYL C. SPIVAK ANDREW L. MARKOWITZ HEIDI R. SPIVAK SCOTT T. TAGGART MARISA J. COHEN JASON BROOKSt ERIN M. BRADY - KEVIN T. McQUAIL- ALEXANDRA T. GARCIA • CORRIN DEMENT - ABBY K. MOYNIHAN -- CATHERINE WELKER'•' ANTOINETTE N. MOORE -- CHRISTINE GRAHAM MELISSA A- SPOSATO HEATHER WEJNERT DEBRA A. STUMP x RICHARD J. SUZOR, JR See www.mwc-Inw.wm for howwng key Randy J. Fultz 156 Virginia Avenue Carlisle, PA 17013 LAW OFFICES MCCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 April 1, 2011 SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHEL F, NY 10801 (914)-636-8900 GENERAL FAX (914) 636-8901 MEDIATION ONLY FAX (914) 819-5505 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UAIIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Re: Chase Home Finance LLC v. Randy J. Fultz and Shelby L. Metzger Cumberland County; C.C.P.; Number 2011-215 Civil Term Dear Mr. Fultz: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated March 8, 2011, the original of which has been filed against you in regard to the above-captioned matter. Very truly yours, TJM/hm Enclosures TERRENCE J. McCABE SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 70101870 0003 32718646 RETURN RECEIPT REQUESTED Exhibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. TERRENCE J. McCABE ••• MARC S. WEISBERG -- EDWARD D. CONWAY MARGARET GAIRO LISA L. WALLACE +t DEBORAH K. CURRAN+• LAURA H.G. O'SULLIVAN:. GAYL C. SPIVAK ANDREW L. MARKOWITZ HEIDI R. SPIVAK SCOTT T. TAGGART MARISA J. COHEN JASON BROOKSt ERIN M. BRADY •. KEVIN T. McQUAIL ALEXANDRA T. GARCIA CORRIN DEMENT ^^ ABBY K. MOYNIHAN -- CATHERINE WELKER `•' ANTOINETTE N. MOORE -. CHRISTINE GRAHAM MELISSA A. SPOSATO ^ HEATHER WEJNERT DEBRA A. STUMP ;t RICHARD J. SUZOR, JR see waw.mwc-law.- fur licendag key Shelby L. Metzger 156 Virginia Avenue Carlisle, PA 17013 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 April 1, 2011 Re: Chase Home Finance LLC v. Randy J. Fultz and Shelby L. Metzger Cumberland County; C.C.P.; Number 2011-215 Civil Term Dear Mrs. Metzger: SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated March 8, 2011, the original of which has been filed against you in regard to the above-captioned matter. Very urs, TJM/hm Enclosures TERRENCE J. McCABE SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 70101870 0003 32718639 RETURN RECEIPT REQUESTED SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 GENERAL FAX (914) 636-8901 MEDIATION ONLY FAX (914) 819-5505 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ?o?ule OE ?n??rf? "tip;-'???•- 0"46 OF THE SHERIFF Chase Home Finance LLC vs. Randy J. Fultz (et al.) %p Case Number. 2011-215 SHERIFF'S RETURN OF SERVICE 03/29/2011 09:33 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on March 29, 2011 at 2133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Randy J. Fultz, pursuant to order of court by posting the premises located at 1112 Shannon Lane, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. ,KHAWGGUU HALL, DEPUTY 03129/2011 09:33 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on March 29, 2011 at 2133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shelby L. Metzger, pursuant to order of court by posting the premises located at 1112 Shannon Lane, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. SHERIFF COST: $62.00 March 30, 2011 UTSHALL, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF 1 ® ? ?i . .p e 9Y Exhiblt le) Com'.Y ? to Shentf, Te?amofi, Inc. '. McCABE, WEISBERG AND CONWAY, P.C. BY; TERRENCE J. McCABg;, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff I Cumberland County Court of Common Pleas Number 2011-215 Civil Term S3U8? ORDER AND NOW, this e day of MV Ch , 2011; the Plaintiff is granted leave to serve process in this mortgage foreclosure action upon the Defendant, Randy J. Fultz, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Peqnsylvapk.17013.and by posting tlie,mortgaged premises of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. BY THE COURT: tsjkl. '? J. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-215 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC Plaintiff (s) From RANDY J. FULTZ AND SHELBY L. METZGER (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: $321,609.63 L.L.: $.50 Interest from 5/12/11 - $11,102.70 at $52.87 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $311.30 Other Costs: Plaintiff Paid: Date: 7/13/11 (Seal) David D. ell, Prothonot By: 64` 6eputy REQUESTING PARTY: Name: MARC S. WEISBERG, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION Chase Home Finance LLC V. Randy J. Fultz and Shelby L. Metzger FILE NO.: 2011-215 Civil Term Civil Term c's AMOUNT DUE: $321,609.63 m -a3 rrtw ;awl - INTEREST: from 05/12/11 :X X $11,102.70 at $52.87 ATTY' S COMM.: ??- ^CG' rv (°-' C= "*1 C_ ?- C= rrT- w :Z C:>rn tJt ?"" COSTS: XQ 5s; --i 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) 1112 Shannon Lane, Carlisle. Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: y 12, 2011 10 +0.oo P4 Any lob-8o CAF W - 00 901.00 10 . oo ' oo " a.so " Signature: Print Name: M CABE, WEISBER AND CON AY -d _vv Address: 123 S. Broad Street. Suite 2080 Philadelphia. PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 31t • 30 - PO Airy 4'q-00& *6D C* lgga18 .50 !1. 04(o1 ns / k?E (.l645S? McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABx., ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff v. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 2011-215 Civil Term ORDER AND NOW, this e day of M&t01 , 2011, the Plaintiff is granted leave to serve process in this mortgage foreclosure action upon the Defendant, Randy J. Fultz, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013 and upon the Defendant, Shelby L. Metzger, by regular mail and by certified mail, return receipt requested, to his/her last known address of 156 Virginia Avenue, Carlisle, Pennsylvania 17013:andby posting th.e mortgaged premises of 1112 Shannon Lane, Carlisle, Pennsylvania 17013. BY THE COURT: L41 0. L. EhP1L'j4- 41 I J. 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 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants SS. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law, deposes and says that the Defendants, Randy J. Fultz and Shelby L. Metzger, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Randy J. Fultz and Shelby L. Metzger, are over eighteen (18) years of age, and reside as follows: Randy J. Fultz 156 Virginia Avenue Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFORE E THIS 4-?±AY OF 2011 NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA N®TosZPSAL SEAL Maleekah Wiitbanks-N,,tary Public City of Philadelph;a, Ph=!adeiphia County MY COMMIS:`._ _ ;;PR 05, 2015 Attorneys for Plaintiff f"7 ? N o ? CUMBERLAND COUNTY -a3 -- COURT OF COMMON PLEAS =rn t - tnt " Vrn :00 , -<> w C- ) r- --+o Number 2011-215 Civil Term Vic, 3 "?? xp CO Shelby L. Metzger 156 Virigina Avenue Carlisle, Pennsylvania 17013 64-? r 4 -1 TERRENCE J. MCCABE, QUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS C o r° f 3 ? - CUMBERLAND COUNTY 2 t' r r? -vM 0 tn -- w ; o Number 2011-215 Civil Term r--= zO 3?0 C! Z 3 =? C? Co Ca CO A AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendants are: Randy J. Fultz Shelby L. Metzger 156 Virginia Avenue 156 Virigina Avenue Carlisle, Pennsylvania 17013 Carlisle, Pennsylvania 17013 SWORN AND SUBSCRI ED BEFORE M THIS (XTAY OF 2011 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff NOTARY PUBLI COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Maleekah'fiJ)anks4lotary Public City Phiiadolihia County MY CCMtv'!: SI(:' EXPInES APR. 06, 2015 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 (215) 790-1010 Chase Home Finance LLC Plaintiff Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. C) NO: 2011-215 Civil Term C m _ --1 Randy J. Fultz and Shelby L. Metzger ? Ctr. om- . r0m cnr- ?p w =I= C) Defendants z = ? on rn AFFIDAVIT PURSUANT TO RULE 3129 ? ? The undersigned, attorney for Plaintiff in the above action, sets forth the following information onceerrning°- the real property located at: 1112 Shannon Lane, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owners or Reputed Owners Name Randy J. Fultz Shelby L. Metzger Address 156 Virginia Avenue Carlisle, Pennsylvania 17013 156 Virigina Avenue Carlisle, Pennsylvania 17013 2. Name and address of Defendants in the judgment: Name Randy J. Fultz Shelby L. Metzger Address 156 Virginia Avenue Carlisle, Pennsylvania 17013 156 Virigina Avenue Carlisle, Pennsylvania 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic Regsitration Systems, Inc., as nominee for AmTrust Bank Mortgage Electronic Registration Systems, Inc., as nominee for AmTrust Bank P.O. Box 2026 Flint, Michigan 48501 1801 East Ninth Street Suite 200 Cleveland, Ohio 44114 Name and address of every other person who has any record lien on the property: Name Address None 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 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 1112 Shannon Lane Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 80 Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America 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 Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address 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. ?n V? --.. zl/"? al-,,- c July 12, 2011 TERRENCE J. McCABE, ESQUIRE DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW C - Chase Home Finance LLC COURT OF COMMON PLEAS rr?03 Zr rC?- mm 'L7 ._ ;D C:1 v. CUMBERLAND COUNTY r- dZ C4 1 Randy J. Fultz and Shelby L. Metzger _xC C -TJ C-) Number 2011-215 Civil Term b.= N C:) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY co - To: Randy J. Fultz Shelby L. Metzger 156 Virginia Avenue 156 Virigina Avenue Carlisle, Pennsylvania 17013 Carlisle, Pennsylvania 17013 Your house (real estate) at 1112 Shannon Lane, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 7, 2011 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 $321,609.63 obtained by Chase Home Finance LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CI)4 TAIN tract of land situated in the Borough of Carlistc, Cmberland County, PA belrtg The Highlands, Phase 3, Lot No. 101, as shmm. on a plan entitled "T$e Highlands pinal Subdivision Plan, phase 3, Section One" daW Inawy 21, 1997, by PenaTerra. Engineering, Inc., State College, PA, iveorded in Pfau Book 79, Page 103, being bounded and described as follows: BEGDEVMG at an iron pin, lying in a sot iberly right of way lire of 5ihanlon Lxne (60 foot right of way), and being a westerly carrier of Lot No, 102; thmoo along said Lot, South 04 degrees 18 nliuutsa 00 WOOD& East, 136.82 feet to an iron pain, being a southerly corner of said Lot and lying ie, a northerly line of lands owned now or fbimerly by Thmas Roy and Pauline V- Lebo (Deed Book 1N1 12, Page 207), thence along said lands, South 85 degrees 44 minutes 30 seconds West, 80.00 feet to an j mn pin, lying along said lands and being an easterly con= of Lot No. 100; thence along said Litt, North 04 degrees 18 minutes 00 seconds West, 136.76 feet to an iron pin, being a naitthcrly corner of said Lot and lying in a souterly line of S1annon Lane (60 foot tight of way), thence along said r*ht of way, North 85 degms 42 minutes 00 seconds East, 80.00 feet to an iron pin, bang the place of BEGTN11i i11YG. CONTAINMG 0.251 acre. BEING ]mown attd .ownbered as 1112 Shannon Lane, Carlisle, PA 17013. Lot No. 101 is subject to a 10 foot wide utility easement along its street fmntage. UNDER AND SUBJECT to the btiui Xmg and use restdotiona set forth in Dced Hook 257, Page 745, 1112 Shannon Lane, Carlisle, Pennsylvania 17013. BEING the same premises which RODNEY YENTZER AND NANCY J. YENTZER, HUSBAND AND WIFE by deed dated August 25, 2008 and recorded September 9, 2008 in the office of the Recorder in and for Cumberland County in Deed Instrument# 200803590, granted and conveyed to Randy J. Fultz and Shelby L. Metzger in fee. TAX MAP PARCEL NUMBER: 05-19-1647-230 WEISBERG & CONWAY, P.C. McCABE T;, , TERRENCE J. McCABE, ESQUIRE - ID # 1649161 t nPT MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 346$7, -?'f MARGARET GAIRO, ESQUIRE - ID # 34419 D lraU T' ti?f? KEVIN T. McQUAIL, ESQUIRE - ID # 307169 r 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2011-215 Civil Term AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 19th day of October, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUB CRIBED BEFORE ME THIS DAY OF (T , 2011 NOTARY PUBLIC McCABE, WEISBERG W Y, P.C. Attorneys for Plaintiff By: TERRENCE J. cCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2011-215 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 1112 Shannon Lane, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owners or Reputed Owners Name Randy J. Fultz Address 156 Virginia Avenue Carlisle, Pennsylvania 17013 Shelby L. Metzger 156 Virigina Avenue Carlisle, Pennsylvania 17013 2. Name and address of Defendants in the judgment: Name Address Randy J. Fultz 156 Virginia Avenue Carlisle, Pennsylvania 17013 Shelby L. Metzger 156 Virigina Avenue Carlisle, Pennsylvania 17013 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 5. 6. 7. Name and address of the last recorded holder of every mortgage of record: Name Mortgage Electronic Regsitration Systems, Inc., as nominee for AmTrust Bank Mortgage Electronic Registration Systems, Inc., as nominee for AmTrust Bank Address P.O. Box 2026 Flint, Michigan 48501 1801 East Ninth Street Suite 200 Cleveland, Ohio 44114 Name and address of every other person who has any record lien on the property: Name Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 1112 Shannon Lane Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`n Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America 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 Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Name and address of Attorney of record: Name U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & NWAY, P.C. October 19, 2011 Attorneys for Plaintiff DATE By: TERRENCE . McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN T. McQUAIL, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants DATE: October 19, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 2011-215 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Randy J. Fultz and Shelby L. Metzger PROPERTY: 1112 Shannon Lane, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on December 7, 2011 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. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. O '_ rn <_, 3Mr,? O?° o Z s ? a lA ? N CL U7 lL LY::-. O "- (V J Y Q . n Q O V x ?c?r,n c., 4 a ? R V V h y y ? C a ? C C ? 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L O L y C d\ O .r N M ? ? ? +?+ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r )???r-,i t? 3EP L ? , e ?, F EWIS sf ';, EI Chase Home Finance LLC Case Number vs. 2011-215 Randy J. Fultz (et al.) SHERIFF'S RETURN OF SERVICE 09/30/2011 05:04 PM - Deputy Stephen Bender, 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 1112 Shannon Lane, Carlisle, PA 17013, Cumberland County. 11/18/2011 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/1/2012 11/21/2011 10:17 AM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Randy J. Fultz pursuant to Order of Court by "Posting" the premises located at 1112 Shannon Lane, Carlisle Borough, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 11/21/2011 10:17 AM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Shelby L. Metzger, pursuant to Order of Court by "Posting" the premises located at 1112 Shannon Lane, Carlisle Borough, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 01/30/2012 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2012 02/02/2012 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: $789.34 February 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ,2 e ? Pd Sr-V L.C_ ,?Od, ? 70 C? 5' f Shot M. 1 efeosCif. Inc. 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff V. Randy J. Fultz and Shelby L. Metzger Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2011-215 Civil Term 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: 1112 Shannon Lane, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Randy J. Fultz 156 Virginia Avenue Carlisle, Pennsylvania 17013 Shelby L. Metzger 156 Virigina Avenue Carlisle, Pennsylvania 17013 2. Name and address of Defendants in the judgment: Name Address Randy J. Fultz 156 Virginia Avenue Carlisle, Pennsylvania 17013 Shelby L. Metzger 156 Virigina Avenue Carlisle, Pennsylvania 17013 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 4. Name and address of the last recorded holder of every mortgage of record: Name Address Mortgage Electronic Regsitration Systems, Inc., as nominee for AmTrust Bank Mortgage Electronic Registration Systems, Inc., as nominee for AmTrust Bank P.O. Box 2026 Flint, Michigan 48501 1801 East Ninth Street Suite 200 Cleveland, Ohio 44114 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 1112 Shannon Lane Carlisle, Pennsylvania 17013 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 81h 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 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 Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o 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. (July 12, 2011 TERRENCE J. McCABE, ESQUIRE DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Chase Home Finance LLC COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Randy J. Fultz and Shelby L. Metzger Number 2011-215 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Randy J. Fultz Shelby L. Metzger 156 Virginia Avenue 156 Virigina Avenue Carlisle, Pennsylvania 17013 Carlisle, Pennsylvania 17013 Your house (real estate) at 1112 Shannon Lane, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 7, 2011 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 $321,609.63 obtained by Chase Home Finance LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C.,`Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE, SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CUTAYN tract of land sitnated in the Borough of Carlisle, Cumberland County, PA being The Hi0h , Phaso 3, Lot No. 101, as shown. on a plan entitled "',Me Fli*18nds PiNd Subdivision Plan, phase 3, Section One" dapsci Januay 21,1997, by PamTma. Fangtnew ng, Inc., State Coll+cgc? PA, racax(kd in Plan Book 79, Page 103, being bounded and dcscn1)ed as follows: l3E BC%NG at an iron pin, lying in a sontbwly right of way lire of Shannon Lame (64 Sant right of W&A and being a wederlyew wr of Lot N& 102; thanes along said Lot, South 04 degrees 18 MhAOS 00 seaon& But 136-82 fit to an imn pin, being a southerly corner of aid Ut and lying in a northerly line of lards owned now or fomoerly by Thomas Roy and Pauline V Lebo (Deed Booty N 12, Pale 207); tie alatag said Iands,, South 85 degrees 44 minutes 30 aeconds West, 80.QO feet to ao i mn pin, lying a1mg said lends and being an easterly corner of Lot No. 100; thetas along said Lot, Notch 04 degrees 18 minutes 00 seconds West, 13 6.76 fint to an iron giA,. being a narthrarly coma of sald Lot and lying m a souftily line of S1m wim Lane (60 foot right of way); thence along said right of way, Notch 85 degrnss 42 minutes 00 seconds Esst, 80.00 feet to an iron pin, being the place of BEGt1YPill1TG. CONTAINING 0.251 atra. BEING known mid munberred as 1112 Sl aimn Laney Carlisle, PA 17013. W NO. 101 is subject to a 10 loot wide utility easement along its street Frontage. MOM AND SUBJECT to the building and use reatriodons set forth in Deed Book 257, Page 7+45. 1112 Shannon Lane, Carlisle, Pennsylvania 17013. BEING the same premises which RODNEY YENTZER AND NANCY J. YENTZER, HUSBAND AND WIFE by deed dated August 25,'2008 and recorded September 9, 2008 in the office of the Recorder in and for Cumberland County in Deed Instrument# 200803590, granted and conveyed to Randy J. Fultz and Shelby L. Metzger in fee. TAX MAP PARCEL NUMBER: 05-19-1647-230 WRIT OF EXECUTION and/or ATTAC-MENT COMMONWEALTH OF PE;NNSY'UVANI,) COUNTY OF CUMBERLAND) N011-215 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC Plaintiff (s) From RANDY J. FULTZ AND SHELBY L. METZGER (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: $321,609.63 L.L.: $.50 Interest from 5/12/11 - $11,102.70 at $52.87 Attv's Comm: °/b Due Prothy: $2.00 Atty Paid: $311.30 Other Costs: Plaintiff Paid: Date: 7%13/11 David D. B ell, Prothonotary 1 By: ^ ac -GUS f (Seal) D uty REQUESTING PARTY: Name: MARC S. WEISBERG, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 TRUE CCP'Y FROM RECORD In Testimony whereof, I here unto set my land and the seal of said Court at Carlis?e, Pa. This 3 day of C 20 t i Prothonotary On July 14, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 1112 Shannon Lane, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference. incorporated herein. Date: July 14, 2011 By - - Real Estate Coordinator g? 41/ l 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 t"} ' HEIDI R. SPIVAK,ESQUIRE-ID#74770 _1 MARISA J.COHEN,ESQUIRE-ID#87830 �-n _ KEVIN T.MCQUAIL,ESQUIRE-ID#307169 rj -F-),-_ 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 y fir. 123 South Broad Street,Suite 1400 -"i -- Philadelphia,Pennsylvania 19109 (215)790-1010 Chase Home Finance LLC CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. No. 2011-215 Civil Term Randy J. Fultz and Shelby L. Metzger Defendants PRAECIPE TO THE PROTHONOTARY: ❑ Please mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled,Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. • DATE: l.f(Z 3 1 133 McCABE,WEISBER t AND CONWAY,P.C. BY: [ ] Terrence J.McCa'/ , 'q ne [ ] Marc S. Weisberg,Esquire [ ]Edward D. Conwa ,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [✓]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire Attorneys for Plaintiff 4 q sop) a5 CILt 1500•R- git c9 gaLiq 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 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Chase Home Finance LLC CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. No.2011-215 Civil Term Randy J. Fultz and Shelby L.Metzger Defendants CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff,hereby certifies that a true and correct copy of the within Praecipe was served on the below persons by regular first class mail,postage prepaid,on the 23- day of June,2013. Randy J.Fultz 156 Virginia Avenue Carlisle,Pennsylvania 17013 Shelby L.Metzger 156 Virigina Avenue Carlisle,Pennsylvania 17013 DATE: (51 2 S 113 McCABE,WEIS: Ci RG AND CONWAY,P.C. BY: [ ]Terrence J. Mc I a e, squire [ ]Marc S. Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [✓]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T. McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ] Joseph F. Riga,Esquire [ ] Joseph I.Foley,Esquire Attorneys for Plaintiff