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HomeMy WebLinkAbout11-4492MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION 1 Credit Union Place Harrisburg, PA 17106 PLAINTIFF V. BRIAN E. MCPHERSON AND MARCALENE E. MCPHERSON 306 Third Street, P.O. Box 276 Summerdale, PA 17093 DEFENDANTS 28054CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ( -k4ul? C IVI? NO. CIVIL ACTION - MORTGAGE FORECLOSURE N 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 Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar 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 a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 FILED-OFFICE OF THE PROTHONOTARY 2011 MAY 20 AM 8: 49 CUMBERLAND COUNTY PENNSYLVANIA 0'.} ft93lD/od °? a/1'X #sS'S2 i2+-as96i9 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION 1 Credit Union Place Harrisburg, PA 17106 28054CFC-DD COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF V. BRIAN E. MCPHERSON AND MARCALENE E. MCPHERSON 306 Third Street, P.O. Box 276 Summerdale, PA 17093 NO. DEFENDANTS CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is The Pennsylvania State Employees Credit Union, a corporation organized and existing under state law, with offices for the conduct of business at 1 Credit Union Place, Harrisburg, PA 17106. 2. Defendants, Brian E. McPherson and Marcalene E. McPherson are the mortgagors and real owners of premises 730 North Front Street, Wormleysburg, PA 17043, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Pennsylvania State Employees Credit Union on September 17, 2002, which mortgage is recorded on October 14, 2004 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1774, Page 3767, secured on premises 730 North Front Street, Wormleysburg, PA 17043 a true and correct description of which is attached hereto as Exhibit I. 4. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 5. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from April 2008 and each month thereafter, up to and including the present time. 6. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 3/1/2008 to 5/9/2011 at $15.55 per diem Accrued Escrow deficit Attorney's Fee (5% of unpaid Principal balance) Satisfaction Fee Total $ 96,600.55 $ 18,096.11 $ 7,855.97 $ 4,830.03 $ 50.50 $ 127,433.16 8. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated prior to the Sheriffs sale, reasonable attorney's fees will be charged based on work actually performed. 9. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $127,433.16, plus per diem interest at $15.55 from May 10, 2011 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: ar a E. Von Rosenstiel, quire Jacqueline F. McNally, Esquire Attorneys for Plaintiff LEGAL DESCRIPTION ALL THOSE, CERTAIN lots of land situate in the Borough of Wormleysburg, Formerly East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey prepared by Ronald S. Raffensperger, Registered Surveyor, dated April 16, 1984, as follows, to wit: BEGINNING at an iron pipe at the Northwest corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Eastern line of a 15 feet wide alley, North 34 degrees 35 minutes 30 seconds West, a distance of 40 feet to a point on the Southern right of way line of Haldeman Street, 40 feet wide; thence along the Southern right of way line of Haldeman Street, North 55 degrees 24 minutes 30 seconds East, a distance of 175.00 feet to an iron pin on the Western right of way line of North Front Street; thence along the Western right of way line of North Front Street, South 34 degrees 35 minutes 30 seconds East, a distance of 40.00 feet to a iron pin at the Northeast corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Northern line of Lot No. 86, South 55 degrees 24 minutes 30 seconds West, a distance of 175.00 feet to an iron pipe, the place of beginning. BEING Lot Nos. 87 and 88 on the Plan of Lots laid out by Edwin M. Hershey and known as "River View" said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 103. HAVING THEREON ERECTED a two-story brick dwelling known as No. 730 North Front Street, Wormleysburg, Pennsylvania. TAX PARCEL NUMBER: 47-18-1302-183 Hw, The Pennsylvania State Employees Credit Union 1 Credit Union Place Harrisburg, PA 17106 DATE: 3/23/11 28054-MS TO: Brian E. McPherson and Marcalene E. McPherson 730 North Front Street Wormleysburg, PA 17043 and 306 Third Street, P.O. Box 276 Summerdale, PA 17093 FOR PROPERTY ADDRESS: 730 North Front Street Wormleysburg, PA 17043 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morteaee on your home is in default, and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached paces. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the proeram works EXHIBIT To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling7 A2ency. The name, address and phone number of Consumer Credit Counseling Agencies serving youur County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S) Brian E. McPherson and Marcalene E. McPherson PROPERTY ADDRESS: 730 North Front Street Wormlevsburg PA 17043 LOAN ACCOUNT NO: #: 26205 ORIGINAL LENDER/SERVICER: The Pennsylvania State Employees Credit Union CURRENT LENDER/SERVICER: The Pennsylvania State Employees Credit Union SERVICER FOR: The Pennsylvania State Employees Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. •IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, •IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND -IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days plus three (3) additional days for mailing after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counselinp, agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty three (33) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILEA HEMAP APPLICA TIONAS SOONAS POSSIBLE. IF YOUHAVEA MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 33 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE"YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALL YAPPRO VEDA T ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have tiled bankruptcy you can still apply for Emergency Mortgage Assistance.) -HOW TO CURE YOUR MORTGAGE DEFAULT (Briny it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 730 North Front Street, Wormleysburg, PA 17043 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from April 1, 2008 to October 31, 2008 L $1,368.49 per month $9,579.43 Monthly payments from November 1, 2008 to October 31, 2009 @ $1,384.39 per month $16,612.68 Monthly payments from November 1, 2009 to October 31, 2010 (&? $1,577.37 per month $18,928.44 Monthly payments from November 1, 2010 to March 31, 2011 $1,445.30 per month $7,226.50 TOTAL AMOUNT PAST DUE $52,347.05 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $52,347.05 PL US ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY THREE (33) DAYPERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: The Pennsylvania State Employees Credit Union 1 Credit Union Place Harrisburg PA 17106 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY THREE (33) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You mqy do so by paying the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately 8 months from the date set forth in this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: The Pennsylvania State Employees Credit Union Address: 1 Credit Union Place, Harrisburg, PA 17106 Phone Number: 1- 800--237-7328 Contact Person: LOAN RESOLUTION DEPARTMENT EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney" fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: *TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTEHR LENDING INSTITUTION TO PAY OFF THIS DEBT. -TO HAVE THIS MORTGAGE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF -TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). *TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. •TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. *TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.51 1.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 ov<ship; inc. '_32O North 5th Street Harrisburg, PA 17110 717;2;,,' 777 Ma:anatha 43 Philadelphia Avenue W;aynegboru;'PA1:72158 717.762.3285 PHFA 11 Nortl_ ,i,,, i ,f +st ' `? ; 0 ON AND MARCALENE E. IN THE C URT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE PENNSY,VANIA STATE EMPLOYEES CREDIT UNI N Plaintiff V. BRIAN E. MCI MCPHERSON Defendant(s) 428054CFJ-DN c? d Cn 3 mC rrn r o0 2 C:! p rn cn PRAECIPE FOR DEFAULT JUDGMENT To the Enter judgment in favor of Plaintiff and against: Brian E. McPherson and Marcalene E. McPherson for want of an answer. (X) Assess Damages as Follows Debt $ 127,433.16 Interest from 5110/11 to 6/26/11 At $15.55 per diem $ 777.50 Total $ 128,210.66 I CERTIFY' AMOUNTS CERTAIN F Praecipe was attorney of re of this Praeci S? This, ? day Defendant(s), T THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED ,EGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM A THE COMPLAINT. I certify that written notice of the intention to file this led or delivered to the party against whom judgment is to be entered and to his 1, if any, after the default occurred and at least (10) days prior to the date of the filing A copy of the Notice is attached. R.C.P. 237.1 Respectfully Submitted, NO. 11-4492-civil MARTHA E. VON ROSENSTIEL, P.C. BY: a Ma E. Von Rosenstiel, squire acqueline F. McNally, Esquire Attorneys for Plaintiff 14 f 2011 judgment is entered in favor of the Plaintiff and against an E. McPherson and Marcalene E. McPherson by default for want of an answer and damages asses, ed at the sum of $128,21 2fKry,4mberland s er the above certification. 71 W County /q CC) ?1 '? ?? X34 ? w1? MARTHA E. VOI Martha E. Von Ro Jacqueline F. Mcls 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorneys for Plaii ROSENSTIEL, P.C. -Instiel, Esquire / No. 52634 Ily, Esquire / No. 201332 Suite 7 iff STATE EMPLOYEES CREDIT THE PENNSYLV NI UNION I Credit Union Place Harrisburg, PA 1 106 BRIAN E. MCPI MCPHERSON 306 Third Street, Summerdale, PA PLAINTIFF V. N AND MARCALENE E. .0. Box 276 7093 428054CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-4492-civil DEFENDANTS Brr n E. McPherson 73 North Front Street W YOU ARE IN DEF OR BY ATTORNE CLAIMS SET FOF NOTICE, A JUDG YOUR PROPERT` YOU SHOULD TF OR TELEPHONE' ABOUT HIRING t IF YOU CANNOT INFORMATION A REDUCED FEE 0 rmleysburg, PA 17043 IMPORTANT NOTICE 6LULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY Y AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE TH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS RENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE OR OTHER IMPORTANT RIGHTS. KE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO ,HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION LAWYER. AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH BOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A Z NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: j M a E. Von Rosenstiel, Es ire r Jacqueline F. McNally, Esquire k"i Attorneys for Plaintiff Dated: June 13, 2Q 11 MARTHA E. VO ?1 ROSENSTIEL, P.C. 428054CTD - DD Martha E. Von R senstiel, Esquire / No. 52634 Jacqueline F. McN ally, Esquire / No. 201332 649 South Avenu e, Suite 7 Secane, PA 1901 (610) 328-2887 Attorneys for Plai ntiff THE PENNSYLV ANIA STATE EMPLOYEES CREDIT COURT OF COMMON PLEAS UNION CUMBERLAND COUNTY I Credit Union Pl ace Harrisburg, PA 1 106 PLAINTIFF V. Case No: 1 I-4492-civil BRIAN E. MCP ERSON AND MARCALENE E. MCPHERSON 306 Third Street, .0. Box 276 Summerdale, PA 17093 DEFENDANTS T M calene E. McPherson 73 North Front Street W rmleysburg, PA 17043 IMPORTANT NOTICE YOU ARE IN DEF AULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORN Y AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FO RTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDG MENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERT OR OTHER IMPORTANT RIGHTS. YOU SHOULD T AKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION BOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE R NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VONTROSENSTIEL. P.C. BY: it f a E. Von Rosenstiel, Es4 ire ',Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 13, 2 11 MARTHA E. VC Martha E. Von R Jacqueline F. Mc 649 South Avent Secane, PA 1901 (610) 328-2887 Attorneys for Ple 1 ROSENSTIEL, P.C. ienstiel, Esquire / No. 52634 ally, Esquire / No. 201332 Suite 7 THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION 1 Credit Union Place Harrisburg, PA 1'7106 PLAINTIFF V. BRIAN E. MCPH RSON AND MARCALENE E. MCPHERSON 306 Third Street, 11.0. Box 276 Summerdale, PA 7093 DEFENDANTS #28054CTD - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-4492-civil T Br' E. McPherson 30 Third Street, P.O. Box 276 S erdale, PA 17093 IMPORTANT NOTICE YOU ARE IN DEF AULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNE Y AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE, CLAIMS SET FOR TH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUUG ENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERT OR OTHER IMPORTANT RIGHTS. YOU SHOULD TA KE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION BOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE O NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. Marth4 E. Von Rosenstiel, Esqui .,,Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 13, 21DI I MARTHA E. VO N ROSENSTIEL, P.C. #28054CTD - DD Martha E. Von R senstiel, Esquire / No. 52634 Jacqueline F. Mc Nally, Esquire / No. 201332 649 South Avenu e, Suite 7 Secane, PA 1901 (610) 328-2887 Attorneys for Plai ntiff THE PENNSYL ANIA STATE EMPLOYEES COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY 1 Credit Union Pl ace Harrisburg, PA 1 106 PLAINTIFF V. Case No: 1 I-4492-civil BRIAN E. MCP ERSON AND MARCALENE E. MCPHERSON 306 Third Street, .0. Box 276 Summerdale, PA 17093 DEFENDANTS T M calene E. McPherson 30 Third Street, P.O. Box 276 Su merdale, PA 17093 IMPORTANT NOTICE YOU ARE IN DEF AULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNE Y AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FOR TH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDG MENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERT Y OR OTHER IMPORTANT RIGHTS. YOU SHOULD TA KE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION BOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE O NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. Oarth . Von Rosenstiel, Esqui `-.-`Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated. June 13, 2011 #28054CFJ-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von osenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION laintiff vs. BRIAN E. MCPI ERSON AND MARCALENE E MCPHERSON S COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 11-4492-civil ?r NON MILITARY AFFIDAVIT r 'WWW , Esquire hereby certifies that: 1. I am the • ttomey for the plaintiff herein. 2. The indi idual involved in this action is the owner of the premises described in the mortgage underlying this actin . 3. The proc dures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerrin g the military status of the mortgagor(s) and/or real owner(s). 4. Said progedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry rr?ade with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On infori ation and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et se o. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Q art E. Von Rosenstie , Es ?ire cqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 28, 2011 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Brian E. McPherson 306 Third Stree, P.O. Box 276 Summerdale, P A17093 THE PENNSYLV EMPLOYEES CR VS. BRIAN E. MCPH MARCALENE E. DE David D. Buell, Prothonotary IA STATE IT UNION (TIFF ?N AND HEREON )ANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 11-4492-CIVIL Notice Pursuant to Rule 36 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $128,210.66 on Ju e 28, 2011. David D. Buell Prothonotary 7X Judgment by Default F1 Money Judgment F1 Judgment in Replevin Judgment for Possession F1 Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney , Esquire at this telephone number:610-328- 2887. It p mew T "` .crr OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Marcalene E. McPherson 730 North Fron Street Wormleysburg, PA 17043 THE PENNSYLV NIA STATE EMPLOYEES CREDIT UNION VS. BRIAN E. MCPH RSON AND MARCALENE E. CPHERSON DE ENDANT(S) David D. Buell, Prothonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 11-4492-CIVIL Notice Pursuant to Rule 36 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $128,210.66 on Jug e 28, 2011. David D. Buell Prothonotary 7x Judgment by Default ? Money Judgment Judgment in Replevin 0 Judgment for Possession ? Judgment on Award of Arbitration ? Judgment on Court Findings If you have any uestions concerning this notice, please call: Attorney Esquire at this telephone number: 610-328-2887. -r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Marcalene E. M Pherson 306 Third Stree , P.O. Box 276 Summerdale, P A17093 David D. Buell, Prothonotary THE PENNSYLV? NIA STATE COURT OF COMMON PLEAS EMPLOYEES CODIT UNION CUMBERLAND COUNTY VS. BRIAN E. MCPH RSON AND NO: 11-4492-CIVIL MARCALENE E. CPHERSON DE ENDANT(S) Notice Pursuant to Rule 36 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $128,210.66 on June 28, 2011. David D. Buell Prothonotary 7X Judgment by Default 71 Money Judgment 7 Judgment in Replevin 7 Judgment for Possession ? Judgment on Award of Arbitration ? Judgment on Court Findings If you have any u stions concerning this notice, please call: Attorney , Esquire at this telephone number:610-328- 2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Brian E. McPhe son 730 North Front Street Wormleysburg, PA 17043 David D. Buell, Prothonotary THE PENNSYLVANIA STATE COURT OF COMMON PLEAS EMPLOYEES C DIT UNION CUMBERLAND COUNTY PLAINTIFF VS. BRIAN E. MCPH RSON AND NO: 11-4492-CIVIL MARCALENE E. CPHERSON : DEI ENDANT(S) Notice Pursuant to Rule has been entered $128,210.66 on Ju. :36 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment against you in the above proceeding as indicated below in the amount of -28,2011. David D. Buell Prothonotary 7x Judgment by Default 0 Money Judgment Judgment in Replevin F1 Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any?estions concerning this notice, please call: Attorney 1???F_ AC- Esquire at this telephone number: 610-328-2887. Jf THE PENNSYL BRIAN E Commonwealth of Pennsylvania COUNTY OF CUMBERLAND 28054C WE-DN STATE EMPLOYEES CREDIT UNION COURT OF COMMON PLEAS V. DOCKET NO. 11-4492-civil N AND MARCALENE E. MCPHERSON ATTORNEY I.D. # Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Exec tion in the above matter: AMOUNT DUE $ 128,210.66 INTEREST from /29/2011 to 12/7/11 At 6 % $ 3,414.96 TOTAL* $ 131,625.62 *Plus costs to beendorsed PREM: 730 North Front Street, Wormleysburg, PA 17043 / 4- Op , Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: a E. Von Rosenstie , Es Lire cqueline F. McNally, Esquire Attorneys for Plaintiff C-) , z r- "Om ?n -- °? o Z --t ? -n ° o P SCb W ? a o? Q z U ? wW O? O O U N d' 0 W W O a W W H H z ¢ ?z O aQ W W W U Q Q W ?z WW Q U C O r.i i? U w ? 4-w O O ? *Eli w a? bD i. ? 4° o w ?U ?p ?O N O ?' N M ^- 06 'd a ? ?oN O O o ? O N ??N?IO a M N ? M N M Lr) bo!? E09) Ioq O O z ? O ?z d" tO. W ? U cd ? .-, G-? N O r` RS ? N Q N M :z C/D .? ¢ 0 C/S ' CWE28054-DN Commonwealth Of Pennsylvania COUNTY OF CUMBERLAND THE PENNSYLVA IA STATE EMPLOYEES COURT OF COMMON PLEAS CREDIT UNION DOCKET NO. 11-44civil 1 Credit Union Place ATTORNEY I.D. # 13 3.- Harrisburg, PA 1710 v BRIAN E. MCPHE SON AND MARCALENE E. MCPHERSON 306 Third Street, P. O. Box 276 Summerdale, PA 17093 Writ Of Execution (Mortgage Foreclosure) TO THE SHERIFF F CUMBERLAND COUNTY To satisfy the judgm following described interest and costs in the above matter you are directed to levy upon and sell the erty: 730 North Front Street, Wormleysburg, PA 17043 (see attached Exhibit I) AMOUNT DUE $ 128,210.66 INTEREST FROM 6/29/2011 to 12/7/ 11 at 6 % $ 3,414.96 TOTAL* $ 131,625.62 *Plus costs to be endorsed David D. Buell, Prothonotary By: Deputy w w a w O U Z w Q z °U Q ° > ?x z Z S U N > v 0 pp Z a~ Q wx Z? ¢ w ? ~? z H ?w V U r-+ M W o ? ? w V) 00 >1 "r4l Q (5 °Ud .???¢¢C?a v)v)w M N ? M N M O ? N ?z w ? ° Z ' Cd C) ooc 00 > ¢ ¢ N ua Q ;, as O0 RS j ? Q ? f'1 428054-DN MARTHA E. VO] Martha E. Von Ro Jacqueline F. Mcl` 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorneys for Plaii THE PENNSYLV EMPLOYEES CR VS. ROSENSTIEL, P.C. enstiel, Esquire / No. 52634 illy, Esquire / No. 201332 Suite 7 IA STATE IT UNION COURT OF COMMON PLEAS CUMBERLAND COUNTY BRIAN E. MCPHtRSON AND MARCALENE E. IMCPHERSON : NO: 11-4492-CIVIL LEGAL DESCRIPTION ALL THOSE CE AIN lots of land situate in the Borough of Wormleysburg, Formerly East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey prepared b Ronald S. Raffensperger, Registered Surveyor, dated April 16, 1984, as follows, to wit: BEGINNING at iron pipe at the Northwest corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Eastern line of a 15 feet wide alley, North 34 degrees 35 minutes 30 seconds West, a distance of 40 feet to a poin on the Southern right of way line of Haldeman Street, 40 feet wide; thence along the Southern right of ay line of Haldeman Street, North 55 degrees 24 minutes 30 seconds East, a distance of 175.00 feet to an it n pin on the Western right of way line of North Front Street; thence along the Western right of way line of Nort Front Street, South 34 degrees 35 minutes 30 seconds East, a distance of 40.00 feet to a iron pin at the Nort east corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Northern line of L t No. 86, South 55 degrees 24 minutes 30 seconds West, a distance of 175.00 feet to an iron pipe, the place of b ginning. BEING Lot Nos. 8 and 88 on the Plan of Lots laid out by Edwin M. Hershey and known as "River View" said Plan being recorde in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 03. HAVING THEREN ERECTED a two-story brick dwelling known as No. 730 North Front Street, Wormleysburg, Pe sylvania. TAX PARCEL NUMBER: 47-18-1302-183 IMPROVEMENTS: Residential dwelling TITLE TO SAID P EMISES IS VESTED IN Brian E. McPherson and Marcalene E. McPherson, husband and wife their heirs and assigns, by Deed from Suanne R. Rohrbaugh, a single woman, dated 9/24/1996 and recorded 10/7/1996 in the County of Cumberland in Record Book 147, Page 163. i a? MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Ro,enstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plai tiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Plaintiff VS. BRIAN E. MCPH RSON AND MARCALENE E. CPHERSON De .ndantk) #28054CAM - DN COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4492-CIVIL AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 fie , ESQUIRE, attorney for the Plaintiff in the above .1 y action, sets forth a of the date the Praecipe for the Writ of Execution was filed the following information concerning the rea property located at 730 North Front Street, Wormleysburg, PA 17043: 1. Name anal address of owners(s) or reputed owner(s) Brian E. M cPherson c o 306 Third , treet, P.O. Box 276 -.4 Summerdal , PA 17093 =rr" r- - =r? urn Marcalene . McPherson ?Z 306 Third S treet, P.O. Box 276 ?'° a o? Summerdal , PA 17093 3;*c-) 2? = © s.._ o 2. Name an address of defendant(s) in the judgment: ?? cn v Brian E. M Pherson 306 Third S treet, P.O. Box 276 Summerdal, PA 17093 Marcalene McPherson 306 Third Street, P.O. Box 276 Summerdal , PA 17093 3. Name anal address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiBank (S uth Dakota) N.A. 701 East 60 n Street Sioux Falls SD 57117 Yomi13 w, r 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name an address of every other person who has any record interest in the property and whose interest ma be affected by the sale: NONE 7. Name an address of every other person of whom plaintiff has knowledge who has any interest in the property w ich may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, P A17013 Cumberlan Register of Wills County Courthouse Carlisle, P 17013 Attorney G neral of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 2 7 Washineto . DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11 th Floor Harrisburg, PA 17128 Family Cou. /Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Depart ent of Revenue Bureau of Compliance Attn: Sheri Sale Section P.O. Box 218230 Harrisburg. PA. 17128-1230 Dept of Pub is Welfare P.O. Box 2q75 Harrisburg, A 17105 '3ennsylvai Bureau of PO Box 2E Harrisburg Occupant 730 North Wormleys I verify understand that unsworn falsifii a Department of Revenue idividual Taxes 1603 PA 17128-0603 ront Street ,ire, PA 17043 the statements made in this affidavit are true and correct upon information and belief. I e statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to >n to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: (' a D&K&L?? - arty E. Von Rosenstie , E uire J cqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 27, 2011 MARTHA E. VON R )SENSTIEL, P.C. Martha E. Von Rosen, tiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff The Pennsylvania S to Employees Credit Union 1 Credit Union Place Harrisburg PA 1710 Plaintiff vs. Brian E. McPherson and Marcalene E. McPherson 306 Third Street, P. O. Box 276 Summerdale, PA 17093 Defendants COURT OF COMMON PLEAS CUMBERLANDCOUNTY No: 11-4492-civil AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF PEI AWARE ue?inu F. Mditly e-? G tip - 9' y Cr's pC ) attorney for the plaintiff in the above action, sets forth as of the date the p aecipe for the Writ of Execution was filed the following information concerning the last known addresses o the defendants are: 1. Name an? address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Brian E. Mc herson 306 Third St eet, P.O. Box 276 Summerdale PA 17093 Marcalene E McPherson 306 Third St feet, P.O. Box 276 Summerdale PA 17093 I verify that the statements made in this affidavit are true and correct upon 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: G is E. Von Rosenstiel, quire Jacqueline F. McNally, Esquire Attorneys for Plaintiff , , -low, .4 grillsoc3fit, .i;e? #28054-CWE-DN MARTHA E. V01 4 ROSENSTIEL, P.C. Martha E. Von Ro •enstiel, Esquire / No. 52634 Jacqueline F. McN ally, Esquire / No. 201332 649 South Avenue Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plain tiff r-? c - THE PENNSYLV ANIA STATE COURT OF COMMON PLEA S EMPLOYEES CR EDIT UNION CUMBERLAND COUNTY Plai ntiff u r i o , CD -ao ??r vs. x? c'3 a 3 t Z-- BRIAN E. MCPH RSON AND No: 11-4492-civil vC_- MARCALENE E. CPHERSON Def endant(s) c-n CERTIFICATE TO THE SHERIFF I hereby ce ify that I am the attorney of record for the plaintiff in this action again real property and further certify that his property is: FHA - Te nant Occupied or Vacant Commerc 'al As a result of a Complaint in Assumpsit XX That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Con umer Credit Counseling Agency (d) Deft dants' Failure to file application with the Homeowners Eme gency Assistance Program I further agree to herein. and hold harmless the Sheriff for any false statement given Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: ar E. Von Rosenstiel, quire Jacqueline F. McNally, Esquire Attorneys for Plaintiff 28054CAM-DN MARTHA E. V( Martha E. Von R Jacqueline F. Mc 649 South Avern Secane, PA 1901 (610) 328-2887 Attorneys for Ph THE PENNSYL EMPLOYEES C Plai VS. N ROSENSTIEL, P.C. )senstiel, Esquire /No. 52634 dally, Esquire / No. 201332 Suite 7 0 3 c -n x --4 -n ntiff 7ANIA STATE COURT OF COMMON PLEAS -<z - °© ZEDIT UNION CUMBERLAND COUNTY = .tiff zQ C) o fir,, : No: 11-4492-civil BRIAN E. MCI MARCALENE De ?RSON AND MCPHERSON dant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTItS IN INTEREST AND CLAIMANTS: The real estate a d improvements, if any, located at and known as 730 North Front Street Wormleysburg, A 17043 will be sold by the Sheriff of Cumberland County on Date of Sale: D cember 7, 2011 Time of Sale: 10 00 a.m. Place of Sale: C mberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 11-4492- civil in the Court of Common Pleas of Cumberland County by The Pennsylvania State Employees Credit Union, Plaintiff against Brian E. McPherson and Marcalene E. McPherson, Defendant(s). Judgment was entered on June 28, 2011 in the amount of $128,210.66. The property was seiz d and taken in execution as the property of Brian E. McPherson and Marcalene E. McPherson. The property to bo sold at Sheriff's Sale is described as follows: ALL THOSE CE TAIN lots of land situate in the Borough of Wormleysburg, Formerly East Pennsboro Town hip, Cumberland County, Pennsylvania, more particularly bounded and described in acco dance with a survey prepared by Ronald S. Raffensperger, Registered Surveyor, dated April 16, 1984, as follows, to wit: I ? BEGINNING at mentioned Plan c 35 minutes 30 se Haldeman Street North 55 degree,, Western right of North Front Strei iron pin at the Nc along the Northe of 175.00 feet to in iron pipe at the Northwest corner of Lot No. 86 on the hereinafter f Lots; thence along the Eastern line of a 15 feet wide alley, North 34 degrees ;onds West, a distance of 40 feet to a point on the Southern right of way line of 40 feet wide; thence along the Southern right of way line of Haldeman Street, 24 minutes 30 seconds East, a distance of 175.00 feet to an iron pin on the Nay line of North Front Street; thence along the Western right of way line of t, South 34 degrees 35 minutes 30 seconds East, a distance of 40.00 feet to a rtheast corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence n line of Lot No. 86, South 55 degrees 24 minutes 30 seconds West, a distance in iron pipe, the place of beginning. BEING Lot Nos. 87 and 88 on the Plan of Lots laid out by Edwin M. Hershey and known as "River View" said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland Cou ty, Pennsylvania, in Plan Book 1, Page 103. HAVING THER Street, Wormley TAX PARCEL IMPRO A schedule of di than 30 days aft( unless exception schedule. Judgm Action No. 11-4. 6390 to determir the Schedule of I N ERECTED a two-story brick dwelling known as No. 730 North Front rg, Pennsylvania. 47-18-1302-183 : Residential Dwelling tribution will be filed by the Sheriff on a date specified by the Sheriff no later said sale, and distribution will be made in accordance with the schedule are filed thereto within ten (10) days after the date of the filing of said nt was recovered in the Court of Common Pleas of Cumberland County Civil 92-civil. You should check with the Sheriff's Office by calling (717) 240- the actual date of the filing of the schedule. No further notice of the filing of ,istribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOl Z PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-4492 Civil COUNT OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due The Pennsylvania State Employees Credit Union Plaintiff (s) From Brian E. McPherson and Marcalene E. McPherson (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description . (2) YOL are also directed to attach the property of the defendant(s) not levied upon in the possession of S) as follows: and to no ify 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 pr perry of the defendant(s) not levied upon an subject to attachment is found in the possession of anyon 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 I ue$128,210.66 Interest from 6/29/2011 to 12/7/11 at 6% Atty's Comm % Atty Paid $250.50 Othe CostsPlus costs to be endorsed Plaintiff Date: 7F (Seal) REQUES Name Ja( Address: Attorney I Telephone Supreme ( L.L. $.50 $3414.96 Due Prothy $2.00 1 David D. Buell, Pro Vonotary By: Deputy ING PARTY: ueline F. McNally, Esq. artha E. Von Rosenstiel, P. C. 9 South Ave., Suite 7 cane, PA 19018 r: PLAINTIFF 610-328-2887 )urt ID No. 201332 ,MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Plaintiff VS. BRIAN E. MCPHERSON AND MARCALENE E. MCPHERSON Defendant(s) #28054CAM - DN f9, o ? m M = tn COURT OF COMMON PLEASr'?- -- ? c3 ?c+ CUMBERLAND >55CD c? ---s C-3 X- NO:11-4492-CIVIL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 ,acqueline F. MCNIN7 ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on ( I true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BYffh!eline a Von Rosenstiel, Esq •e F. McNally, Esquire Attorneys for Plaintiff r? c 3 CL N o CO V For Accountable Mail 0) ? A W ---7-t,) r N S t ?. Q ? ?m r?,z (nv(?2?W? V ? ?c?pp3??Doo?°?poo??cDdnmd..?(`DC?(?( 0-0 m y x 3. • 3.. o, O p x x :v 0 C to c o rn' :u v c c? 0 3 T O O Q C tD O i W y W to N v in C q' W v _S O O ? C 3? 0 3 o ??c o m'm c Stn W vD3 to w Q?Z'xO,mtnx??xo? Inc ??0ocg<'.mcntp`?cgco c o cn a cn ? O. y + D CNO - 17 N N -.. O tU ,. x p to N• n OR O .' C p 2 0 N 0 to tla -0 CL OUj D cn c o m ??o " w 0 3 D? ?(n-?? o N? d ce D °c a Dc° o ?? ?a?. ?? Dcn?DWS?3 i(n Dc ,mo. vv ?o -` ?0 a 0 V 0 V c o ??o c -?CII) _o? CO > 14 H N D W N N V O W O 0 :3 O O y0 tQ O C v ?` \ m V OD N -i tD V fD n< N :U fA :U '* W tD q. W pCj r \_\b X g?? ? c N O < O? 0 gC M t?D cc O CD O O CA W W = C tp -n m G) C x CD Of Z CD O CD J N _ 9 0 m to 3' z m z w 3 tD M 0 p a CL n fD N y fD ay y tD 01 7 CL 0 o? N 0 c CL 3 e • ? Ja m 3? m wv °. 3 c • J ? N CL 'C 1 O 6/ A' 7 J otw CL z$ m J a .0 61 a w ' 3w's a c .- m _ N -0'd.3 47 ?Eb6-8! JOO 6Jj \ 7 C '> f 1 3? 1 J y w J 0gm Z CL .!M S Sc; a m o°- -- x ? it) i y M N t(D 0 2 ? N J CD tG M m v D m 6 C A 0 F, vim 3 ? . 'n . o ti m?.? )?,C: y D a O CL ! W -y ? y N9)D to 4 O c_ DAD D» to ? d 0 C qD SD (_ V ?0T [ 00 t[ a p 0@ a @ C a 00 c x o C m ?;p0 a y A t(D C O??i OOH N C J a ' m to m v 300M3 N 3 ?RH•? R c o p dl N 631 ID J C J 61 R CA. CIL o' cb 0 ° v. 63i N j 0(0 O o PLAINTIFF: The Pennsylvania State Employees Credit Union DEFENDANT Brian E. McPherson and Marcalene E. McPherson SERVE UPON: Brian E. McPherson 306 Third Street, P.O. Box 276 Summerdale, PA 17093 FILED-OFFICE ' THE 'RQtiIC jr71 ' AFFIDAVIT OF SERVICE 2011 SEP 25 Alf 11: 09 COURT OF COMMON PLE ill Cumberland COUNTY f"9BELANM. COUNTY p r COURTNO. 11-4492-civil PENNCJYLVAMA SPECIAL INSTRUCTIONS: please serve defendant personally or adult in charge of premises Served and TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriffs Sale Sheriffs Sale Date: 12-./ h/ SERVED L i Defendant, on the _74kdav of A-U6-_1.-r 2 28054-DN Defendant personally served. Adult family member with whom Defendant resides. Manager/Clerk of place of lodging in which Defendant resides. Relationship is I _ Adult in charge of Defendant's residence who Agent or person in charge of Defendant's office or usual place of business. refused to give name/relationship. Other i Description: Age 40 5 Height I, 1 4, Weight 30 Race W Sex F Other i, 1 f"4-" a competent adult, being duly sworn according to law, depose and state that I personally handed I is QSe a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriff's Sale to issued in the captioned case on the date and at the address indicated above. Sworn to and subscribedt- before me this 7l? _ day of r' 2 Notary: By. NOT SERV ' On the daWo . , 20_, at o'clock - M., Defendant NOT FOUND because Moved Unknown No Answer Vacant Time of Attempt: Result: Date of Attempt: I ? f I Sworn to and subscribed before me this day of 200_. Notary: By ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 TAIC ESTAVE IERLRTY EY Zpt3 OFM ON MARCH 7`+ it FILED-OFFICE f . HE °ROTH0N0,TAP,- PLAINTIFF: The Pennsylvania State Employees Credit Union DE I7 ENDANT Brian E. McPherson and Marcalene E. McPherson SERVE UPON: Marcalene E. McPherson 730 North Front Street Wormleysburg, PA 17043 2011 SEP 26 AM I I : 09 AFFIDAVIT OF SERVICE CUMBERLAND COUNT PENNSYLVANIA COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 11-4492-civil TYPE OF ACTION XX WRIT OF EXECUTION and Notice of Sheriff's Sale SPECIAL INSTRUCTIONS: lease serve defendant personally Sheriffs Sale Date: or adult in charge of premises made known to M described below: sonally served. mvmhar with whom Defendant Adult in charge of Defendant's residence who refused to give name/relationship. on the 146 day o Manager/Clerk of place of lodging in which Defendant resides. Agent or person in charge of Defendant's office or usual place of business. Other in 28054-DN Description: Aged Height-SW' Weight (3U Race W Sex_F Other I, Romb::D MO C.L a competent adult, being duly sworn according to law, depose and state that I personally handed to M&ACALF-Pre C c}?RS a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address indicated above. A S.A. i S V4C4.M . ( N V F-tS n 4*Tro N Sworn to and subscribge r_ 1)t6 CC-d by TIWT 'p??,D?u7 !%g m(?SSr- Of +t before me thi - da -3c)(. -ml fLD . 2 k?X4 _PA Notary : By: Sit of," EA0*t-Er NOT SF..RV On the 20_. at Moved Unknown No Answer o'clock - M., Defendant NOT FOUND because: Vacant ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 7 owv,n N a ...._..,,...,_ before me this day of 200 Notary: By: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t, 3 . ?t' , L Sheriff 7 'HE P OTI?'«p, a Jody S Smith 12 APR 2 6 ,? Chief Deputy t 8= Richard W Stewart CUMBERLAyp COUNTY Solicitor PENNSYLVANIA The Pennsylvania State Employees Credit Union Case Number vs. 2011-4492 Brian E. McPherson (et al.) SHERIFF'S RETURN OF SERVICE 09/28/2011 01:24 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 730 North Front Street, Wormleysburg, PA 17043, Cumberland County. 12/06/2011 As directed by Martha E. Von Rosenstiel, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/7/2012 03/22/2012 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 March 07, 2012 at 10:00 AM. He sold the same for the sum of $xxxxx to Attorney Martha E. Von Rosenstiel, on behalf of The Pennsylvania State Employees Credit Union. The Sheriffs Bid was assigned to Federal National Bank at 14221 Dallas Parkway, Dallas, Texas 72554. The Pennsylvania State Employees Credit Union, being the buyer in this execution, paid to the Sheriff the sum of $1, 035.16. 03/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED. SHERIFF COST: $1,035.16 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF 46- 0"A a.teV 7yar(Ci <;GUnlySu'.e SYretiN, (eIEY?iCfl. ?:lt;. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire /No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff THE PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Plaintiff VS. BRIAN E. MCPHERSON AND MARCALENE E. MCPHERSON Defendant(s) #28054CAM - DN f COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4492-CIVIL AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 j F. k4CN* , ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 730 North Front Street, Wormleysburg, PA 17043: 1. Name and address of owners(s) or reputed owner(s) Brian E. McPherson 306 Third Street, P.O. Box 276 Summerdale, PA 17093 Marcalene E. McPherson 306 Third Street, P.O. Box 276 Summerdale, PA 17093 2. Name and address of defendant(s) in the judgment: Brian E. McPherson 306 Third Street, P.O. Box 276 Summerdale, PA 17093 Marcalene E. McPherson 306 Third Street, P.O. Box 276 Summerdale, PA 17093 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiBank (South Dakota) N.A. 701 East 60`x' Street Sioux Falls, SD 57117 1 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, I lth Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg. PA 17105 Penns}clvania'Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Occupant 730 North Front Street Wormleysburg, PA 17043 I verify that the statements made in this affidavit are true and correct upon 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. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: C art l E. Von Rosenstie , E uire J cqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 27, 2011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-4492 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due The Pennsylvania State Employees Credit. Union Plaintiff (s) From Brian E. McPherson and Marcalene E. McPherson (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$128,210.66 L.L. $.50 Interest from 6/29/2011 to 12/7/11 at 6% $3414.96 Atty's Comm % Due Prothy $2.00 Atty Paid $250.50 Other CostsPlus costs to be endorsed Plaintiff Paid Date: 7/1/2011 uell, Prothonota (Seal) By: Deputy REQUESTING PARTY: Name Jacqueline F. McNally, Esq. Address: Martha E. Von Rosenstiel, P. C. TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand 649 South Ave., Suite 7 and the seal of said Court at Carlisle, Pa. Secane, PA 19018 This day of2012 41 Prothorw Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 201332 On July 14, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberl'and County, PA, Known and numbered as, 730 North Front Street, Wormleysburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: July 14, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-4492 Civil The Pennsylvania State Employees Credit Union vs. Brian E. McPherson Marcalene E. McPherson Atty.: Martha E. Von Rosenstiel ALL THOSE CERTAIN lots of land situate in the Borough of Worm- leysburg, Formerly East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described in accor- dance with a survey prepared by Ronald S. Raffensperger, Registered Surveyor, dated April 16, 1984, as follows, to wit: BEGINNING at an iron pipe at the Northwest corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Eastern line of a 15 feet wide alley, North 34 degrees 35 minutes 30 seconds West, a distance of 40 feet to a point on the Southern right of way line of Haldeman Street, 40 feet wide; thence along the South- ern right of way line of Haldeman Street, North 55 degrees 24 minutes 30 seconds East, a distance of 175.00 feet to an iron pin on the Western right of way line of North Front Street; thence along the Western right of way line of North Front Street, South 34 degrees 35 minutes 30 seconds East, a distance of 40.00 feet to a iron pin at the Northeast corner of Lot No. 86 on the hereinafter mentioned Plan of Lots; thence along the Northern line of Lot No. 86, South 55 degrees 24 minutes 30 seconds West, a distance of 175.00 feet to an iron pipe, the place of beginning. BEING Lot Nos. 87 and 88 on the Plan of Lots laid out by Edwin M. Hershey and known as "River View" said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 103. HAVING THEREON ERECTED a two-story brick dwelling known as No. 730 North Front Street, Worln- leysburg, Pennsylvania. TAX PARCEL NUMBER: 47-18- 1302-183. IMPROVEMENTS: Residential dwelling. TITLE TO SAID PREMISES IS VESTED IN Brian E. McPherson and Marcalene E. McPherson, husband and wife their heirs and assigns, by Deed from Suanne R. Rohrbaugh, a single woman, dated 9/24/1996 and recorded 10/7/1996 in the County of Cumberland in Record Book 147, Page 163. 61 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: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. V Li a Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this da of November, 2011 Notary NOTARIAL SE DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 14 t Pa?triot News Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on beilaif of The-Patriot-News Co. aforesaid- by virtue-and pursuant to a, resolution unanimously passed -and adopted severalty 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. OUBLICATION COPY I This ad ran on the date(s) shown below: 10/21/11 to an?Ksubidibed before`mte this y6 06106f November, 2011 A.D. Notary Pidblic COMMON TH OF PENNSYLVAW NOUWW sew Sherrie L. Owens, Notary "Ic Low PsAm Twp., Deuphln County My Comrisom Nov. 26, 2015 MEMBER, PENNMVANIA ASSOaATWN OF NOTARIES 10/28/11 11/04/11 2011-4492 Chril Term The Pennsylvania state Employees Credit Union Brian E, Vs Marcalene McPherson Atty. Martha E ' McPherson ALL THOSE CERTAIN lot Roof and stlel Fo Mate the Borough of Worntleysburg, y East Pennsboro Township Cumberland County, Pennsylvania more Particularly bounded and described in accordance with a survey prepared by Ronald S. RaffenspergerRegistered to Surveyor, wit: yor, dated April 16,'] 984, as follows, BEGINNING at an iron pipe at the hereNorthwescorner of Lot No. 86 on the inafte; mentioned Plan of Lot. thence along the Eastern line of a 15 feet wide alley, North 34 degrees 35 minutes 30 seconds West, a distance of 40 f ' a Point on the Southe ee[ t rn tight of way line of Haldeman Street, 40 feet wide; thence along the Southern tight fee way Haldeman Street, N line e North 55 degrees 24 minutes 30 seconEa st,a di stance of 175.00 feet to an iron right of way line of North Front Street; of North pin on the Western thence along the Western right of way line Front Street, South 34 degrees 35 minutes 30 seconds East a distance of 40.00 feet to a iron pin at the Northeast corner of Of No. 86 on t the he hereinafter mentioned Pfan of Lots; thence along Northern line of Lot No. 86, South 55 degrees 24 minutes 30 seconds distance of 175.00ng feet West, a Place of beginn i to an iron pipe, the . BEING Lot Nos. 87 and 88 on the Plan of Lots laid out by Edwin M. Hershey and known as "River View" said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland county , Pennsylvania in Plan Book 1, Page 103. HAVING THEREON ERECTED a two-s ,ory brick dwelling (mown as No. 730 North Front Street, Wormleysburg, Pennsylvania. ?ROL NUMBER: 47-18-1302-183 TITLE TO SAID ENTS: Residential dwelling IN Brian E. REMISES IS VESTED McPherson and Marc E. McPherson, husband and alene Wife their heirs and assigns, by Deed from Suanne R. R,,hrbaugh, a single woman, dated 924/1996 and recorded 10/7/1996 in the County C 147, PaE umberland in Record Book . le 163. e11e patriot-Nuns Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL 10/21/11 10/28/11 11/04/11 Of Ad Sheriff Sale 4492 9.22 $12.00 $ 110.64 Sheriff Sale 4492 9.22 $12.00 $ 110.64 Sheriff Sale 4492 9.22 $12.00 $ 110.64 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 336.92 JLC 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 Federal National Mortgage Assoc is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 1 day of Jam, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 4492, at the suit of The Pennsyvlania State Employees Credit Union against Brian E. McPherson and Marcalene E. McPherson is duly recorded as Instrument Number 201212004. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this '; ,S A.D. P, c day of id4- tk - ( u Recorder of Deeds ardor ^t [feeds, Cumhedand County, Carlisle, PA y Commission Expires the First Monday of Jan. 2014