Loading...
HomeMy WebLinkAbout11-3804Phelan Hallinan & Schmieg, LLP Laurence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza `-fi?I" l? { _ 6 ,C 'll0N0TA=? A % ?:"F Et2! AND COUNT ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 215-563-7000 259736 CITICORP TRUST BANK, FSB 1000 TECHNOLOGY DRIVE MAIL STATION O'FALLON, MO 63368-2240 Plaintiff V. SHAD D. MCCONNELL 53 SAMPLE BRIDGE ROAD MECHANICSBURG, PA 17050-2386 Defendant COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 1 CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 259736 6) a? VID. Ob ?c1? Qm"A ?,ILAt b-19 RAU NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 259736 1. Plaintiff is CITICORP TRUST BANK, FSB 1000 TECHNOLOGY DRIVE MAIL STATION OTALLON, MO 63368-2240 2. The name(s) and last known address(es) of the Defendant(s) are: SHAD D. MCCONNELL 53 SAMPLE BRIDGE ROAD MECHANICSBURG, PA 17050-2386 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/10/2004 SHAD D. MCCONNELL and CHARLOTTE MCCONNELL made, executed and delivered a mortgage upon the premises hereinafter described to PNC BANK NATIONAL ASSOCIATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1870, Page 1267. By Assignment of Mortgage recorded 06/18/2004 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 709, Page 863. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/16/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 259736 6 The following amounts are due on the mortgage: Principal Balance $105,267.55 Interest $7,450.72 04/28/2010 through 12/13/2010 Late Charges through 12/13/2010 $0.00 TOTAL $112,718.27 7 8 9 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. Plaintiff hereby releases CHARLOTTE MCCONNELL from liability for the debt secured by the mortgage. File #: 259736 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $112,718.27, together with interest from 12/13/2010 at the rate of $26.187 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage, including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: U LJ enL.Hallin . Phelan Esq., Id. No. 32227 ? Fis , Esq., IdNo. 62695 Daniel chm' g, Esq., Id. No. 62205 Micheladford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorneys for Plaintiff File #: 259736 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D. P. Raffensperger, Registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg-Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or formerly of R. E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a corner of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. 38-18-1328-003 DBV 36-R PAGE 417 PROPERTY ADDRESS: 53 SAMPLE BRIDGE ROAD, MECHANICSBURG, PA 17050-2386 PARCEL # 38-18-1328-003 File #: 259736 r VERIFICATION C"W k Ld%Oft hereby states that he/she is of CITIMORTGAGE, INC., servicing agent for Plaintiff in this matter, CITICORP TRUST BANK, FSB, that he/she is authorized to make this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: PHS#: 259736 Name: MCCONNELL Name: Crystal X Lahore Title: DommeM Comd C fter Servicer: CITIMORTGAGE, INC. 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 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citicorp Trust Bank, FSB, V. Shad D. McConnell, TO THE PROTHONOTARY: Attorneys for Plaintiff Court of Common Pleas Plaintiff, of Cumberland County No. 11-3804 Defendant. I Civil Action ENTRY OF APPEARANCE . J 4ti? =M C - ?._' Cn N) ?Q D C:) O >= -«- c:-r Kindly enter the appearance of McCabe, Weisberg & Conway, P.C. as counsel in the above referenced action on behalf of Plaintiff, Citicorp Trust Bank.. Date: July 18, 2011 Heidi .Spivak, Esquire Attorney for Plaintiff, Citicorp Trust Bank, FSB 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 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citicorp Trust Bank, FSB, V. Shad D. McConnell, Plaintiff, Defendant Attorneys for Plaintiff Court of Common Pleas of Cumberland County No. 11-3804 Civil Action CERTIFICATE OF SERVICE I, Heidi R. Spivak, Esquire, hereby certify that a true and correct copy of the within Entry of Appearance and Praecipe to Withdraw was served on the below person by the United States mail, first class, postage prepaid, on July 18, 2011 Shad D. McConnell 53 Sample Bridge Road Mechanicsburg, PA 17050 r DATE: Julv 18, 2011 Heidi R. Spiv , Esquire Attorney for Plaintiff, M&T Bank By: Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff -o - '' mrn -CT-n -G 5-- 7 Cr p CZ::: CITICORP TRUST BANK, FSB Plaintiff VS. SHAD D. MCCONNELL COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 11-3804 Defendant WITHDRAWAL OF APPEARANCE To the Prothonotary: Kindly withdraw my appearance on behalf of Plaintiff, CITICORP TRUST BANK, FSB. Phelan Hallinan & Schmieg, LLP PHS # 259736 Date: j r LJ Lawre 1 Phelan Es C. 4o.32227 TJ-Francis S. Hallina q., Id. No. 95 ? Daniel G. Schmieg, Esq., Id. No. 622 5 ? Michele M. Bradford, Esq., Id. No. 9849 ? Judith T. Romano, Esq., Id. No 745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? A 'Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Scheiner, Esq., Id. No. 308912 Attorney for Plaintiff PHS # 259736 r 1 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 Citicorp Trust Bank, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys ,fo 1 ' Cc E E F ROTHONOTARY ^1011 UG 15 AM 11: 10 ;0 1aERl AND COUNTY PEN14SYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-3804 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 12/14/10 - 8/11/2011 S 112,718.27 $ 6,311.79 Total $ 119,0,0.06 ", _]?? 6c TE ENCE J. MCCABE, ESQUIRE 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 Attorney for Plaintiff G?4114'00 a 1 CkM ? yb999 Q.?a b 3?,? AND NOW, this is day of , 2011, Judgment is entered in favor of Plaintiff, Citicorp Trust Bank, FSB, and against Defendant, Shad Mc onnell, and damages are assessed in the amount of $119,030.06, plus interest and costs. BY THE PRO ON RI .? G 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 Citicorp Trust Bank, FSB Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-3804 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Shad Mcconnell, is 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 Defendant, Shad Mcconnell, is over eighteen (18) years of age, and reside as follows: Shad Mcconnell 53 Sample Bridge Rd Mechanicsburg, Pennsylvania 17050 SWORN AND SUBSCRI ED BEFORE E THIS ?AY OF S , 2011 NOTARY PUBLIC Eee? WEALTH OF PENNSYLVANIA 1 6AL SEAL iltbanks ?latary Public elphia, Philadelphia County ?N i x IRES APR. 05, 2015 Terrence J. McCabe, Esquire 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 Attorney 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 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 Citicorp Trust Bank, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-3804 AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. 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 address of the Defendant is: Shad Mcconnell 53 Sample Bridge Rd Mechanicsburg, Pennsylvania 17050 SWORN AND SUBSC ED BEFORE YE THIS DAY OF 2011 i- NOTARY PUBLIr COMMONWEALTH{ O.F?ENNSY?ygNIA N©T.CAQIAb Maleekah 1jIt3anks No A L City m E'Nadel p`+ia ary public , MY COMMISSION hilade,Qnla County EXPIRES APR. Cr" x,^,15 TERRENCE J. MCCABE, ESQUIRE 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 Attorney 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 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 Citicorp Trust Bank, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-3804 CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSC&WED BEFORE E THIS it DAY OF 2011 L11--? NOTARY PUBLIC EMY OMMONWEALTH OF PENNSYLVANIA n'rARIAL SEAL leekah Wiltbank?-Notary Public y of r'hiladelphia, Philadelphia County G04iml : ION UPIi ES AF 'R, O5, 2015 J Terrence J. McCabe, Esquire 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 Attorney for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he is the Attorney for the Plaintiff in the within action, and that he 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 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. Terrence J. McCabe, Esquire 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 Attorney for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary it July 25, 2011 To: Shad Mcconnell 53 Sample Bridge Rd Mechanicsburg, Pennsylvania 17050 Citicorp Cumberland County vs. Court of Common Pleas Shad McConnell Number 11-3804 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Citicorp Trust Bank, FSB 1000 Technology Drive Mail Station O'Fallon, Missouri 63368 (800) 990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR S ENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. 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 INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACON ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEOIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Citicorp Trust Bank, FSB 1000 Technology Drive Mail Station O'Fallon, Missouri 63368 (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 tp 1' 4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Shad Mcconnell 53 Sample Bridge Rd Mechanicsburg, Pennsylvania 17050 Citicorp Trust Bank, FSB COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Shad Mcconnell Defendant No. 11-3804 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT h been a Xmabove pro as indicated below. Proth ry x Judgment by Default - Money Judgment - Judgment in Replevin .- Judgment for Possession If you have any questidns concerning this Judgment, please call McCabe, Weisberg and Conwav P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION CITICORP TRUST BANK, FSB V. Shad Mcconnell FILE NO.: 11-3804 Civil Civil Term, AMOUNT DUE: $119,030.06 MC r-n ri ti-) INTEREST: from 08/12/11 r _-A - - " $4,090.13 at $19.57 G ATTY'S COMM.: e so . _ '? -'. c-7 . COSTS: - TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 5? Sam le Brid a Road Mechanicsbur Penns ]vania 17050 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. o DATE: October 13, 2011 v 3$-.00 e.B? 99.00 M" 7? . ('SD a u a ?N p , Sb °i ,V'1 Signature/* Print Name: Terrence J. McCabe, Esquire Firm: MCCABE, WEISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 "Z6 LL- Cyr-1sau8 wc?i a P(4? -JEt-?s" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg-Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or formerly of R.E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a corner of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one story frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road; Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L. BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6, 1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 38-18-1328-003 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 -=o or CITICORP TRUST BANK, FSB CUMBERLAND COUNTY - COURT OF COMMON PLEAS - Plaintiff V. NO: 11-3804 Civil Shad Mcconnell Defendant 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: 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050, 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 Owner or Reputed Owner Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 Name and address of Defendant in the judgment: Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 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 5 Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address 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 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 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 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th 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: 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 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 auth October 13. 2011 errence J. McCabe, Esquire DATE Attorney 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 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 CITICORP TRUST BANK, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys for Plaintiff C*J C_'D 7F {. , > t 3 C 3{i c-a g COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-3804 Civil AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. 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 address of the Defendant is: Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 SWORN AND SUBSCRI BEFO ME TTI,S? OF IV ( 20a L Y PUBLIC q ui : hia AUft'/ f CCM AN.12, 2014 Terrence J. McCabe, Esquire Attorney 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 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 CIVIL ACTION LAW CITICORP TRUST BANK, FSB V. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Shad Mcconnell Number 11-3804 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 r'? 7 d Your house (real estate) at 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050 is scheduled to be sold at Sheriffs Sale on March 7, 2012 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 $119,03 0.06 obtained by CITICORP TRUST BANK, FSB 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 CITICORP TRUST BANK, FSB 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. 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 Mail Station Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Mail Station Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg-Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or formerly of R.E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a corner of lands now or formerly of Harry A. Timmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one story frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L. BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6, 1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 38-18-1328-003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3804 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITICORP TRUST BANK, FSB Plaintiff (s) From SHAD MCCONNELL (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: $119,030.06 L.L.: $.50 Interest from 8/12/11 - $4,090.13 at $19.57 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $170.50 Other Costs: Plaintiff Paid: Date: October 19, 2011 Buell rothonotary (Sea,) By: Deputy REQUESTING PARTY: Name: TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITICORP TRUST BANK, FSB U, tiui t` prn ,, , r r a Attorney for Plaintiff COUNT' CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. Number 11-3804 Civil Shad Mcconnell Defendant 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 2nd day of April, 2012, 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 SUBSCRIBED BEFORE ME THIS _,g3fol- DAY OF 2012 NOtA4K PUBLI OF tEs SEAL NpTARIA`L LM 9h tihja P? adeelph iUCoun1Y CITES NOV. 22 201 ? ??S10N McCABE, WEJKBEP,,G "ONNYAV, P.C. By - TER ENCE J. c ABE, ESQUI - ID # 16496 MARC S. WEISBERG, ESQUIR - ID # 7616 EDWARD D. CONWAY, ESQU E; 34687 MARGARET GAIRO, ESQUIR - 114 34419 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITICORP TRUST BANK, FSB Plaintiff V. Shad Mcconnell Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-3804 Civil 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 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 2. Name and address of Defendant in the judgment: Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 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 Plaintiff herein 5. 6. 7. 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 Address Tenants/ Occupants 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 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 8`h 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: 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 United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States c/o United States Attorney for the 11-3804 Civil 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 U.S. Dept. of Justice, Rm. 5111 950 Pennsylvania Avenue Washington, DC 20530-0001 U.S. Dept. of Justice, Rm. 4400 950 Pennsylvania Avenue Washington, DC 20530-0001 Name and address of Attorney of record: Name 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, W RG & C AY, P.C. April 2, 2012 Attorney r P inti DATE X/ - TERYNCE J. Mc4!ABE, ESQUIRI MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, 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 CITICORP TRUST BANK, FSB Plaintiff V. Shad Mcconnell Defendant DATE: April 19, 2012 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-3804 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Shad Mcconnell PROPERTY: 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050 IMPROVEMENTS: The above-captioned property is scheduled to be sold at the Sheriffs Sale on May 2, 2012 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 ofthe schedule. i ? N N 1 t ' ? ... tws. a. o < ? v ? 11N€', E c1 o. U a Ego. H? a E 1 I C R °' o O O C E o ? ? '" O u OMr U ? c 5 ? N 'CS € - C. ? C? L R L W R R ? L R= R d 6? a oL v? CC >-y > a v d a y t ol O i s? °= e3o ??+ r e[°•°i . 3y 00 > r l o v R i u L•=C'v oN N yaL oL N pppp r.+ Rya CJ u d y _u O C7 . ?' 00 = h C d y O o0 y C y w> 40 ~ , 41 EV, 1 O Q.b bC w.C= -? o =V1 Z 00? O:oAoo.. 5 ;6 =•C R ... ? O? d t-N o d O"" a 04. r,.Q Q L 4 C?Or C o '3 .L = "?o a u ?wfl Q•? or?4oG L k? Q = CQS °" L k ;ap Lua =- Q.] L.? o DM?AQ.a ? 0 Y ENa C y r o ow? w = C 6? h ? ° ? +L+ ? i W € 0 6? h 0? u y+"U\O pp C ; ywN { R G?00 ; u=? Cr dr 7?VJ?'' ;w v w La T aoi oQ aaoo EUoo ?'WN i? C?••Vj L 3 a°i d LO= V '? '?C/?Z ?a ?? O. N d m ?+p c o k =A OL1 .. o?= a o og OwNy O e o o L = O==o?L o O x= R? 3 R o x? a u =?n v u C CQ "C d •k. p i 0 CdS CO RW E? R y Lz O ak ? LZ L?# O _ V'I-;` R L E LU W,= R O o L a u v A d? L R i E R L Lz L O F fl y V'c= ?? r W 5 C u u V?ppp? M E-tn? Y 7 0 M F UAcs?4xd C7 S U-r?v?4 O= C +_•+ UW., oAx d C .? d AFx34x 7 0 a, cca,x a C UAUxd O O t C C O?F3a?a F a 0 42- d L w L 3 ? Q' a a A o ,°o =Uc z 4 z 4r O a?+ G ? L ? C ??Q ? p o v + ?3 ova ?' ? r F L a.. ??mdz jQ v? E L) vi F u ^, N M eY v r o0 R 4 r y E O Z E O Y U d w ?+O O L WQ °o? Lo ?.ov> $ o •L L O •E 00 •` O .L C a C= •` C W > O Q ? h 0 wa0a ?W?? E"''y e7 .?.. CCU EOy G9 V]fV u.'7. ?>? E L VQN N aC?J ? G V V•? Cc = O O Q 41 C d a O E C V > arCO~ A y r ?a+??, VSO > O wry ?/l O AW >A Go C C C O dAar ?O C V A M Qw a y k p? p? A -0 y E C E ?+ B r' y, > ?+ C r3 O a0+ C y i y, e3 C. OA y C r d O? ow.: R? OQ? x''00..3 W oo L L O L p V G7 d d C 0, G> m O 6 6 L. • ? C?? Cr"V]? RS O E AUaU C O.y AN A ??..xNx C 0 U?ra ?d:7o+3 ?Q ??3 Vl u u u V a0 O rn L ? „a fia E 'O z; •d u N ? v u .? L ad o? E0r E 'fl zy o, o .. ? ? o a r 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 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITICORP TRUST BANK, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-3804 Civil PRAECIPE TO MARK JUDGMENT/ WRIT OF EXECUTION TO PLAINTIFF'S USE TO THE PROTHONOTARY: N " 7 C-) - c , o , Kindly mark the Judgment and Writ of Execution entered in the above-captioned matter to the use of Plaintiff, U.S. Bank Trust, N.A., as Trustee for VOLT Asset Holdings NPL3, whose address is 13801 Wireless Way, Oklahoma City, Oklahoma 73108 C??' xs?? - TERRENCE J. McCABE, k S IRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff 9. Sopd ate, iUsa') Lt 0 • r MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ED # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITICORP TRUST BANK, FSB Plaintiff V. Shad Mcconnell Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-3804 Civil CERTIFICATION OF SERVICE I, the undersigned, hereby certify that a true and correct copy of the within Substitution of Successor Plaintiff pertaining to the above-captioned matter was served on April }92012, by first-class mail, postage prepaid, upon the following: Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 Date: TERRENCE J. MCCABE, S IRE MARC S. WEISBERG, ESQUME EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??,,rtit}? ut u?anitrf?l???b ED rH 2 121121 '! 21 F, 2; 59 CUM3ERLAND RENNSYL vANIA Citicorp Trust Bank, FSB vs. Shad D. McConnell Case Number 2011-3804 SHERIFF'S RETURN OF SERVICE 01/06/2012 03:52 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 53 Sample Bridge Road, Mechanicsburg, Cumberland County, PA 17050. 01/10/2012 05:33 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Shad D. McConnell at 53 Sample Bridge Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 03/05/2012 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/2/2012 05/02/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on May 2, 2012 at 1000 am. He sold the same for the sum of $1.00 to Attorney Terrance McCabe, on behalf of Citicorp Trust Bank, FSB. Citicorp Trust Bank, FSB being the buyer in this execution, paid to the Sheriff the sum of $1,222.76. SHERIFF COST: $891.22 SO ANSWERS, May 21, 2012 RON R ANDERSON, SHERIFF y?.,19v t-ir4. (". o a- 1?'d - a- .0 ,`&97? ?''t°`` ? 7 s 5"Sr) ;cj Cour ? t=She r Te .^..a?. [nr. 1 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 Attorneys for Plaintiff CITICORP TRUST BANK, FSB CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 11-3804 Civil Shad Mcconnell Defendant 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: 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050, 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 Owner or Reputed Owner Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 2. Name and address of Defendant in the judgment: Name Address Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 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 r ? r 4. 5 Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address 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 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 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h 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 r A United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None P.O. Box 320 Carlisle, PA 17013 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 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 auth '9? October 13, 2011 errence I McCabe, Esquire DATE Attorney for Plaintiff ak, LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg-Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or formerly of R.E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a comer of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one story frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L. BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6, 1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 38-18-1328-003 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 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW CITICORP TRUST BANK, FSB COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Shad Mcconnell Number 11-3804 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Shad Mcconnell 53 Sample Bridge Road Mechanicsburg, Pennsylvania 17050 Your house (real estate) at 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050 is scheduled to be sold at Sheriffs Sale on March 7, 2012 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 $119,030.06 obtained by CITICORP TRUST BANK, FSB 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 CITICORP TRUST BANK, FSB 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 Mail Station Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Mail Station Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg-Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or formerly of R.E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a comer of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one story frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L. BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6, 1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 38-18-1328-003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-3804 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITICORP TRUST BANK, FSB Plaintiff (s) From SHAD MCCONNELL (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: $119,030.06 Interest from 8/12/11 - $4,090.13 at $19.57 Atty's Comm: % Arty Paid: $170.50 Plaintiff Paid: Date: October 19, 2011 L.L.: $.50 Due Prothy: $2.00 Other Costs: (Seal) REQUESTING PARTY: Name: TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 - y hand °a.. ass ' ?' y On October 27, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as, 53 Sample Bridge Road, Mechanicsburg, more fully described on Exhibit "A filed with this writ and by this reference incorporated herein. Date October 27, 2011 By: eal Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-3804 Civil Term Citicorp Trust Bank FSB vs. Shad McConnell Atty.: Terrence McCabe ALL THAT CERTAIN piece or parcel of land situate in the Town- ship of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a sur- vey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point be- ing 300 feet Northeast of Creek Road; thence along lands now or formerly of R.E. Lashley North 46 degrees West 213 feet to a point in Conodoguinet Creek; thence in and along the same North 32 degrees 48 minutes East 100 feet to a corner of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213 feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one story frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L. BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6, 1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 38 18 1328 003. 57 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: January 27, February 3, and February 10, 2012 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 10 da of Februaa 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suito 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Notary Public CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: t4tPahiot News Now you know of Itebruary, 2012 A.D. COMMONWEALTH OF PENNSYLVANIA j Notarial Seal Sherrie L. Owens, Notary Public i Lower Paxton Twp., Dauphin county MY Commission EXpirps Nov. 26, 2015 MEMBER PENNSYLVAnIA ASSOCIATION OF NOTARIES 01/27/12 02/03/12 02/10/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which U.S. Bank Trust N.A. as Trustee for VOLT Asset Holdinas NPL3 is the grantee the same having been sold to said grantee on the 2 day of May A.D., 2012, under and by virtue of a writ Execution issued on the 19 day of October, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 3804, at the suit of CITICORP Trust Bank, FSB against Shae McConnell is duly recorded as Instrument Number 201215086. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. Recorder of Deeds Recorder d ?eeda, *Mt9 nd 0aety, Oahe. PA My ComnWm ft Fist M=* of Jan. 2014 2011.3804 Civil Term Citicorp Trust Bank FSB VS Shad McConnell Atty. Terrence McCabe ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and Plan thereof made by D.P. Raffensperger, registered Surveyor, dated May 15, 1964, as follows: BEGINNING at an iron pin in the Northwestern side of a public road leading from the Harrisburg Carlisle Highway to Sample's Bridge known as Sample Bridge Road said point being 300 feet Northeast of Creek Road; thence along lands now or furrt erly of R.E. Lashley North 46 degrees We, ' 213 feet to a point in Conodoguinet Cre -?; thence in and along the same North 32 c -'-gees 48 minutes East 100 feet to a corner of lands now or formerly of Harry A. Zimmerman; thence along said lands South 46 degrees East 213,feet to an iron pin in the aforesaid Sample Bridge Road; thence in and along the same South 32 degrees 48 minutes West 100 feet to the point and place of BEGINNING. HAVING THEREON ERECTED a one stir , frame dwelling known as No. 53 Sample Bridge Road (formerly 407 Sample Bridge Road). RB5678 53 Sample Bridge Road, Mechanicsburg, Pennsylvania 17050. BEING the same premises which BRADLEY L BEECHER, A SINGLE PERSON by deed dated November 30, 1993 and recorded December 6,1993 in the office of the Recorder in and for Cumberland County in Deed Book R36, Page 417, granted and conveyed to Shad D. Mcconnell, a single person, in fee. TAX MAP PARCEL NUMBER: 3818 1328 003