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Home My WebLink About11-4568Phelan 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. 5280 CORPORATE DRIVE MS1011 FREDERICK, MD 21703 Plaintiff V. 266109 CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS 1600 CHATMAN ROAD CAMP HILL, PA 17011 VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS 1702 ELAND DOWNE PHOENIXVILLE, PA 19460 Defendants FILED-4FFICE THE PROTHONOTARY AU I 1 11 HAY 25 AM i0: 24 £u pE IRIrNLAND COUNTY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO.'1.uS(O? b CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 266109 o 01\k A- ",Q-60 Pd a 44y C k- #* 111M MS 11 a4-asl704? 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 #: 266109 Plaintiff is CITIMORTGAGE, INC. 5280 CORPORATE DRIVE MS1011 FREDERICK, MD 21703 2. The name(s) and last known address(es) of the Defendant(s) are: CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS 1600 CHATMAN ROAD CAMP HILL, PA 17011 VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS 1702 ELAND DOWNE PHOENIXVILLE, PA 19460 who is/are the real owner(s) of the property hereinafter described. 3. On 01/26/2009 CHARLOTTE A. VACONDIOS made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR RESIDENTIAL FINANCE CORPORATION, AN OHIO CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200903327. The PLAINTIFF is now the mortgagee and is in the process of formalizing an assignment of same. 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. File #: 266109 The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/0 1 /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. 6 The following amounts are due on the mortgage as of 03/01/2011: Principal Balance $151,279.26 Interest $3,624.40 10/01/2010 through 03/01/2011 Late Charges $180.50 Mortgage Insurance Premium / $122.48 Private Mortgage Insurance Escrow Deficit $155.40 TOTAL $155,362.04 7. 8 9. 10 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 pursuant to Act 6 of 1974 is not required because the defendants are not a "Residential Mortgage Debtor" as defined by the Act, having failed to provide Plaintiff notice of its acquisition of title. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. Mortgagor CHARLOTTE A. VACONDIOS died on 1/16/2011, leaving a Will dated 5/1/2007. Letters Testamentary were granted to CLARENCE NICHOLSON on 2/10/2011 File #: 266109 in CUMBERLAND County, No. 21-11-0183. Decedent's surviving heirs at law and next- of-kin are CLARENCE NICHOLSON and VALERIE NICHOLSON. 11. By executed waivers, CLARENCE NICHOLSON waived his right to be named as a defendant in his capacity as devisee in the foreclosure action. Said waiver(s) is attached as Exhibit" A ". 12. Plaintiff does not hold the named Defendants, CLARENCE NICHOLSON and VALERIE NICHOLSON, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendant(s) in the aforesaid real estate only, and the Defendant(s) has/have been named in accordance with the requirements of Pa. R.C.P. I I44(a)(2) and 20 Pa. C.S.A. § 301(b). File #: 266109 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $155,362.04, together with interest, 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: 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 1. Goldman, Esq., Id. No. 205047 ourtenay 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 #: 266109 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION 1, Clarence Nicholson, Devisee of the Estate of Charlotte A. Vacondios, in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. Section 301(b)], hereby waive my right to be named as a defendant in my capacity as Devisee of the Estate of Charlotte A. Vacondios in a foreclosure action which may be instituted by CITIMORTGAGE, INC. involving a mortgage secured on premises 212 South Locust Street, Camp Hill, PA 17011-6765 a/k/a 212 Locust Street, Camp Hill, PA 17011-6765, which property was owned by the decedent at the time of her death. I hereby consent to any such foreclosure action, without any further notice of proceedings of Sheriffs sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I understand that it is Plaintiff's intention to name me as a Defendant in any such foreclosure action in my capacity as Executor of the Estate of Charlotte A. Vacondios, only. Date: 0*0/e7"70- -4 Clarence Nicholson, Devisee' Of the Estate of Charlotte A. Vacondios, Deceased LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly set forth on Plan of 'Cumberland Park' recorded in Plan Book 4, Page 86), Cumberland County Records, and being Lot No. 64 on said plan, bounded and described as follows, to wit: BEGINNING at the intersection of the Southwesterly side of Locust Street (60 feet wide) with the northwesterly side of Allen Road (formerly Avenue 'R') (40 feet wide); thence along the northwesterly side of Allen Road (formerly Avenue 'R') South fifty-eight (58) degrees thirty (30) minutes West one hundred thirty-four and eighty-five one-hundredths (134.85) feet to a point; thence along part of Lot No. 63 North thirty-one (31) degrees thirty (30) minutes West ninety-one and twenty-seven one-hundredths (91.27) feet to a point; thence along Lot No. 65 North sixty- seven (67) degrees ten (10) minutes East one hundred forty-seven and six one-hundredths (147.06) feet to a point on the southwesterly side of Locust Street; thence along the said side of Locust Street South twenty-two (22) degrees fifty (50) minutes East sixty-nine and sixty-one one- hundredths (69.61) feet to the first mentioned point and place of BEGINNING. PROPERTY ADDRESS: 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 PARCEL # 1.3-24-0797-188 File #<: 266109 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: ttorney for Plaintiff File #: 266109 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -:K „-f Sheriff v CD Fn = ? --C Jody S Smith = . Chief Deputy ^- r? Richard W Stewart Solicitor Citimortgage, Inc Case Number vs. Clarence Nicholson (et al.) 2011-4568 SHERIFF'S RETURN OF SERVICE 05/26/2011 04:38 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Clarence Nicholson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Clarence Nicholson. Request for service at 212 S. Locust Street, Camp Hill, Pennsylvania 17011 is vacant. Clarence Nicholson currently resides at 1600 Chathan Road, Camp Hill, Pennsylvania 17011. 05/26/2011 04:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on May 26, 2011 at 1655 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Clarence Nicholson, by making known unto himself personally, at 1600 Chathan Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. R ERT BITNE , EPUTY 05/26/2011 04:38 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Valerie Nicholson, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Valerie Nicholson. Request for service at 212 S. Locust Street, Camp Hill, Pennsylvania 17011 is vacant. Clarence Nicholson advised Deputies, Valerie Nicholson never resided at this address and is thought to be residing in Downington, Pennsylvania. 05/26/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Valerie Nicholson, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Chester County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 06/09/2011 05:05 PM - Chester County Return: And now June 9, 2011 at 1705 hours I, Carolyn B. Welsh, Sheriff of Chester County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Valerie Nicholson by making known unto herself personally, at 1702 Eland Downe, Phoenixville, Pennsylvania 19460 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $125.00 June 23, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ;oi Cc,uiiy5nlte Sham. TeievSOft. Irc. :)HERI?=FS COSTS SHERIFF'S OFFICE OF CUMBERLAND COUNT)Yto, .5--31-It Ronny R Anderson at CINN61"f> r r S6 Pall sneriff Receipt No. 41-,1-?36 Jody S Smith Rl???t? 111E S'tewart Chief Deputy OF «=E =F ``"=RIFF Solicitor I N N W 0 a X W 0 ao 0 Q a ui J J_ > K z W O a LLi Z O D 0 Z g N O 0 to 0 IT 0 N W_ W W J a Z O J O 2 U z Citimortgage, Inc vs. Clarence Nicholson (et al.) Case Number 2011-4568 SERVICE COVER SHEET U C 1-" N-141-0 0 M Category: Civil Action - Complaint in Mortgage Foreclosure Zone: Manner: Deputize Expires: 06/24/2011 Warrant: Notes: .:.. Name: Valerie Nicholson Served: Personall - dult In Charge • Pc6d -?3%er Primary 1702 Eland Downe Adult In Address: iPhoenixville, PA 19460 Charge: V Relation: Phone: C'73 I Alternate Date: Time: c" n Address: ?'?. .?? Phone: Deputy: _ O Mileage: Name: 'Francis Hallinan Phone: 215-563-7000 Now, May 26, 2011 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Chester County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff V (0 rNA > TAE PROTHONOTARY 20! I JUL. 1 I PM t: 25 CUMBERLAND COUNTY PENNSYLVANIA 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 CITIMORTGAGE, INC. Plaintiff VS. CLARENCE NICHOLSON VALERIE NICHOLSON Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 11-4568 CIVIL : CUMBERLAND COUNTY PHS #: 266109 PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Attorney for Plaint By- n e T. Phelan, Esq., Id. N . 32227 Francis S. Hallinan, Esq., Id. o. 62695 ? Daniel G. Schmieg, Esq., Id. N .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 1. Goldman, Esq., Id. No. 205047 ? Court . Dunn, Esq., Id. No. 206779 ? rew 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 Date: 7-8-11 PHS #: 266109 VERIFICATION Crystal A, LaRoss , hereby states that he/she is Ofturrrent.Contr+oi Olfiomf, CITIMORTGAGE, INC., Plaintiff in this matter, that he/she is authorized to make this Verification, and verify 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: File #: 266109 Name: NICHOLSON 0J ? 41ad - fa-'J?a Name: Crystal A, LaRose Title: oocuffwlt Control 0grx r Servicer: CITIMORTGAGE, INC. File #: 266109 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 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 Melissa J. Scheiner, Esq., Id. No. 308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Plaintiff VS. CLARENCE NICHOLSON VALERIE NICHOLSON Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 11-4568 CIVIL : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: CLARENCE NICHOLSON 1600 CHATMAN ROAD CAMP HILL, PA 17011 PHS #: 266109 VALERIE NICHOLSON 1702 ELAND DOWNE PHOENIXVILLE, PA 19460 JILL M. WINEKA PURCELL, KRUG & HALLER, 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 Phelan Attorni Date: 7-8-11 U Lawrence T. Phelan, Esq., Id. 2227 ? Francis S. Hallinan, Esq., I,1 695 No. 2 ? Daniel G. Schmieg, Esq., Id. .62205 ? Michele M. Bradford, Esq.; wId. 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 unn, Esq., Id. No. 206779 w C. 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 PHS #: 266109 PHELAN HALLINAN & SCHMIEG, LLP BY: SHEETAL R. SHAH-JANI, ESQUIRE Identification No. 81760 1617 JFK Boulevard, Suite 1,400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CitiMortgage, Inc. 5280 Corporate Drive MS1011 Frederick, MD 21703 Plaintiff V. Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondios 1600 Chatman Road Camp Hill, PA 17011 Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A. Vacondios 1702 Eland Downe Phoenixville, PA 19460 Defendants Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County No. 11-4568 Civil c r-; m pl M c- s '? = ??v r r r -nrn -< n ccnn o ' r- :Z: -? CD C) T'' a CD c :r _,. c, PRAECIPE FOR IN REM JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against, Defendant Clarence Nicholson, pursuant to the attached Consent Judgment, and foreclosure and sale of the mortgaged premises, kindly assess Plaintiff's damages against Clarence Nicholson, as follows: As set forth in Complaint & order of court $155,362.04 Interest - 03/01/2011 to 07/19/2011 $3,360.27 TOTAL $158.722.31 DATE: _ Z??4 1 Sheetal R. Shah- ni, E q., Id. No. 81760 Attorney for Plainti 14.00 Fd,aL 266109 `2?a?1. ru JLIL-12-2011 14:54 PLIRCELL,KRUG,&HALLER PHELAN HALLINAN & SCMVIIEG, LLP BY: SHEETAL R. SHAM ANT, ESQUIRF, Identification No. 81760 One Penn Center at Suburban Station 1617 Jobe F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CitiMortgage, Inc. 5280 Corporate Drive MS1011 Frederick, MD 21703 Plaintiff V. Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacozidios 1600 Chatman Road Camp Hill, PA 17011 Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A_ Vacondios 1702 Eland Down,-- Phoenixville, PA 19460 Defendants 717 720 4939 Attorney for Plaintiff : Court of Common Pleas : Civil Division Cumberland County : No. 11-4568 Civil P.02 Tk CONSENT JUDGMENT AND NOW, This ? day of , 2011 it is hereby agreed by and between, CitiMortgage, Inc. (hereinafter "Plaintiff' ay and through its counsel, Sheetal R. Shah- Jani, Esquire and Defendant, Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondios (hereinafter "Defendant"), by and through his counsel Jill M. Wineka, Esquire as follows: JLIL-12-2011 14:54 PURCELL,KRUG,&HALLER 717 760 4939 P.03 WHEREAS, Plaintiff is the holder of the Mortgage on the property located at 212 South Locust Street a/k/a 212 Locust Street, Camp Hill, PA 17911-6765 (hereinafter the "Property"); -At 0 ClhurI d A. Ueceohd iof? -Dec -,w CI WHEREAS, is the owner of the Property? ah ? JGych[-Ir <<<1 doh W kf a i d EX-C( ??f-hc Es4¢T, d 1Pd 1, h?J c 0,.b,C .a Oa P1"° WHERE.A.S the Mortgage on the property is in default b6cause monthly pay?ients on thedd[Ord Mortgage due November 1, 2010 and each month thereafter are due and unpaid; i1 Am " 20-00W WHEREAS, by the terms of the Mortgage, upon default in such payments for a period of f.• one month, the entire principal balance and all interest due thereon are due forthwith; WHEREAS, the parties to this Consent Judgment are desirous of resolving the issues raised in the Complaint and therefore, Plaintiff and Defendant Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondios agree as follows: ] . An in rem judgment is entered in favor of Plaintiff" and against Defend t Safely DectCJ2? Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondiosin the sum of $155,362.04 plus interest from March 1, 2011 at the rate of $23.8317 per diem and other costs and charges collectible under the Mortgage, for foreclosuze and sale of the Property, 2- Plaintiff may immediately tale the instant Consent Judgment with the Court. 3. In the event. that, prior to a Sheriffs Sale, it is determined that Plaintiff has expended sums with regard to the Mortgaged Property, including but not limited to real estate taxes and insurance, then Defendant will stipulate with Plaintiff to the reassessment of damages in order to increase or decrease the judgment to reflect the expenditure made by Plaintiff, ? 4 0P r1y o WC( tuhf a11d heu 'Scecwrd by fAt- U I h' ? t"t- , Ci N 5- Defendant hereby releases and forever discharges Plaintiff, its successors and assigns, predecessors, servicers, agents, employees, officers, directors, representatives, and attorneys from any and all claims, demands, damages, or liabilities whether now known or JUL-12-2511 14:54 PURCELL,KRUG,&HALLER 717 780 4939 P.04 rho unknown arising out of or in any way connected to Plainti6s servicing of De€ex =loan and the within foreclosure action. o jhorld -e A v?eCcln?iUl? rC??y? C, hash 6. The attomeyl executing this Covseut Judgment havt done so only after having ??.1 her (N 4-c?Jain f 4j'- C N discussed the terms with respecti/vae client and having obtained4hrecr-consent to be bound by the terms of this Consent 7ud ent, l_ ?H Ch l -C N i Ut o h ei s ?h e EyeC & kk, ' v" h .I-&PC 4 01404'p d?, VO (oftchdS )S -C rUe'j ?hc_ CGhJ (h ? JUCl ynr ?tiv ?+t 7. This Consent Judgment may b4xecuted in counterpart- G N b cr-C WUAhTA facsimile version of a signature on this document shall be treated for all purposes as the equivalent of the original signatures. DATE- Sheetal R. Sl ah-Jani, quire Attorney for Plaintiff DATE- vxCa Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacoridios Defendant PHELAN HALLINAN & SCHMIEG, LLP BY: SHEETAL R. SHAH-JANI, ESQUIRE Identification No. 81760 1617 JFK Boulevard, Suite 1,400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CitiMortgage, Inc. 5280 Corporate Drive MS1011 Frederick, MD 21703 Plaintiff V. Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondios 1600 Chatman Road Camp Hill, PA 17011 Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A. Vacondios 1702 Eland Downe Phoenixville, PA 19460 Defendants Attorney for Plaintiff : Court of Common Pleas : Civil Division Cumberland County No. 11-4568 Civil AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: a) Plaintiff was not able to complete a Soldiers' and Sailors' Civil Relief Act search upon Clarence Nicholson as Plaintiff did not have the prerequisite information to search the database (b) that defendant Clarence Nicholson is over 18 years of age and resides at 1600 Chatham Road, Camp Hill, PA 17011-6007. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to uns rn falsification to authorities. DATE: a??Z ? Shee R. Shah-Jar( !ELsq., I . No. 81760 Attorney for Plaintiff 266109 (Rule of Civil Procedure No. 236) - Revised CitiMortgage, Inc. 5280 Corporate Drive MS1011 Frederick, MD 21703 Plaintiff V. Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Court of Common Pleas Civil Division Cumberland County No. 11-4568 Civil V acondios 1600 Chatman Road Camp Hill, PA 17011 Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A. Vacondios 1702 Eland Downe Phoenixville, PA 19460 Defendants Notice is given that a Judgment in the above captioned matter has been entered against you on 7? By: If you have any questions concernin atter lea ntact: heetal R. Shah-Jam, ., Id. No. 81760 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 266109 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOI1-4568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC. Plaintiff (s) From CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS, VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS (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: $158,722.31 L. L.: $.50 Interest from 7/20/11 to Date of Sale ($26.09 per diem) -- $6,052.88 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $271.50 Other Costs: Plaintiff Paid: Date: 11/30/11 ?ae'cb David D. B ell, Prothonota (Seal) Deputy REQUESTING PARTY: Name: WILLIAM E. MILLER, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308951 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CITIMORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 11-4568 CIVIL CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE CUMBERLAND COUNTY ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due $158,722.31 Interest from 07/20/2011 to Date of Sale $6,052.88 ($26.09 per diem) % c-a TOTAL $164,775.19 helan Hallina Sehmieg, LLP William E. Miller, Esq., Id. No.308951 Attorney for Plaintiff Note: Please attach description of property. PHS # 266109 ? 015.Oo ? q,g. 06 14.00 4 • t4 . CZ 250 4N "11- S? ?C? Q J C sd C?L_ ? ?? l 13??-aq Fz' Wf;4 '?'c ? d `n d d d ?O VO H W d ? °" d ? H UU ?U O ? ?,O Ww "t? H p -I rn O U R A W ? rQl, W W d ?a ?? QW Qp? EW-? O 0x eg? W 'x ,? d d .o ? Q 7 O H ? ?W?,?v ?, o d 0 U W A d r, H d d O ?' U U U v a O W 'z ? O H ? ?,, O W ? ? ? O on O d? ?, rr, ?, O? W o O? Via, O?O 4U a? 0 d? 51?w a3W'' ?-a d=? "3d LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly set forth on Plan of 'Cumberland Park' recorded in Plan Book 4, Page 86, Cumberland County Records, and being Lot No. 64 on said plan, bounded and described as follows, to wit: BEGINNING at the intersection of the Southwesterly side of Locust Street (60 feet wide) with the northwesterly side of Allen Road (formerly Avenue 'R') (40 feet wide); thence along the northwesterly side of Allen Road (formerly Avenue'R') South fifty-eight (58) degrees thirty (30) minutes West one hundred thirty-four and eighty-five one-hundredths (134.85) feet to a point; thence along part of Lot No. 63 North thirty-one (31) degrees thirty (30) minutes West ninety- one and twenty-seven one-hundredths (91.27) feet to a point; thence along Lot No. 65 North sixty-seven (67) degrees ten (10) minutes East one hundred forty-seven and six one-hundredths (147.06) feet to a point on the southwesterly side of Locust Street; thence along the said side of Locust Street South twenty-two (22) degrees fifty (50) minutes East sixty-nine and sixty-one one-hundredths (69.61) feet to the first mentioned point and place of BEGINNING. TITLE TO SAID PREMISES IS VESTED IN Charlotte A. Vacondios, single woman, by Deed from Charlotte A. Vacondios, Executrix for the Estate of Shirley L. Freedman, deceased, dated 12/22/2005, recorded 12/28/2005 in Book 272, Page 2563. Mortgagor CHARLOTTE A. VACONDIOS died on 1/16/2011, leaving a Will dated 5/1/2007. Letters Testamentary were granted to CLARENCE NICHOLSON on 2/10/2011 in CUMBERLAND County, No. 21-11-0183. Decedent's surviving heirs at law and next-of-kin are CLARENCE NICHOLSON and VALERIE NICHOLSON. PREMISES BEING: 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 PARCEL NO. 13-24-0797-188 PHELAN HALLINAN & SCHMIEG, LLP William E. Miller, Esq., Id. No.308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 y t l} ``'a ' it 215-563-7000 CITIMORTGAGE, INC. Plaintiff v. Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 11-4568 CIVIL CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF CUMBERLAND COUNTY THE ESTATE OF CHARLOTTE A. VACONDIOS . Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: (X) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: helan Hallinan & Schmieg, LLP William E. Miller, Esq., Id. No.308951 Attorney for Plaintiff CITIMORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff - ' CIVIL DIVISION NO.: 114568 CIVIL CLARENCE NICHOLSON, IN HIS C rT?,''Oll, ti °` EXECUTOR OF THE ESTATE OF CIAr+Q'1f ?S ? VACONDIOS CUMBERLAND COUNTY VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. PHS # 266109 VACONDIOS Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) CLARENCE NICHOLSON, IN HIS CAPACITY 1600 CHATHAM RD AS EXECUTOR OF THE ESTATE OF CAMP HILL, PA 17011-6007 CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY 1702 ELAND DOWNE AS DEVISEE OF THE ESTATE OF PHOENIXVILLE, PA 19460 CHARLOTTE A. VACONDIOS 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 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 (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND PARK INC . CUMBERLAND PARK INC CUMBERLAND PARK, INC. PO BOX 211 CAMP HILL, PA 17001-0211 5700 SIXTH AVE ALTOONA, PA 16602 5700 6TH AVE ALTOONA, PA 16602-1111 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 212 SOUTH LOCUST STREET A/K/A 212 LOCUST STREET CAMP HILL, PA 17011-6765 COMMONWEALTH OF PENNSYLVANIA, BUREAU OF INDIVIDUAL TAX, INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING, PA 17105 PROGRAM JILL M. WINEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OF PA HARRISBURG, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. Date: By: helan Hallinan & Schmieg, LLP William E. Miller, Esq., Id. No.308951 Attorney for Plaintiff CITIMORTGAGE, INC. t(N 3 4#7 1:6 b Plaintiff vs CLARENCE NICHOLSON, IN HIS CAIN V AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 11-4568 CIVIL : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CLARENCE NICHOLSON, IN HIS VALERIE NICHOLSON, IN HER CAPACITY CAPACITY AS EXECUTOR OF THE AS DEVISEE OF THE ESTATE OF ESTATE OF CHARLOTTE A. VACONDIOS CHARLOTTE A. VACONDIOS 1600 CHATHAM ROAD 1702 ELAND DOWNE CAMP HILL, PA 17011 PHOENIXVILLE, PA 19460 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $158,722.31 obtained by CITIMORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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. t. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 in the sale. To find out if this has happened, you may call 215-563-7000. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly set forth on Plan of 'Cumberland Park' recorded in Plan Book 4, Page 86, Cumberland County Records, and being Lot No. 64 on said plan, bounded and described as follows, to wit: BEGINNING at the intersection of the Southwesterly side of Locust Street (60 feet wide) with the northwesterly side of Allen Road (formerly Avenue 'R') (40 feet wide); thence along the northwesterly side of Allen Road (formerly Avenue 'R') South fifty-eight (58) degrees thirty (30) minutes West one hundred thirty-four and eighty-five one-hundredths (134.85) feet to a point; thence along part of Lot No. 63 North thirty-one (31) degrees thirty (30) minutes West ninety- one and twenty-seven one-hundredths (91.27) feet to a point; thence along Lot No. 65 North sixty-seven (67) degrees ten (10) minutes East one hundred forty-seven and six one-hundredths (147.06) feet to a point on the southwesterly side of Locust Street; thence along the said side of Locust Street South twenty-two (22) degrees fifty (50) minutes East sixty-nine and sixty-one one-hundredths (69.61) feet to the first mentioned point and place of BEGINNING. TITLE TO SAID PREMISES IS VESTED IN Charlotte A. Vacondios, single woman, by Deed from Charlotte A. Vacondios, Executrix for the Estate of Shirley L. Freedman, deceased, dated 12/22/2005, recorded 12/28/2005 in Book 272, Page 2563. Mortgagor CHARLOTTE A. VACONDIOS died on 1/16/2011, leaving a Will dated 5/1/2007. Letters Testamentary were granted to CLARENCE NICHOLSON on 2/10/2011 in CUMBERLAND County, No. 21-11-0183. Decedent's surviving heirs at law and next-of-kin are CLARENCE NICHOLSON and VALERIE NICHOLSON. PREMISES BEING: 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 PARCEL NO. 13-24-0797-188 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-4568 CIVIL CITIMORTGAGE, INC. VS. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 Parcel No. 13-24-0797-188 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $158,722.31 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY CWMORTGAGE, INC. PHS # 266109 DEFENDANT SERVICE TEAM/ Ixh CLARENCE NICHOLSON, in his capacity as Executor of the Estate COURT NO.: 11-4568 CIVIL of CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, in her capacity as Devisee of the Estate of CHARLOTTE A. VACONDIOS SERVE CLARENCE NICHOLSON, in his capacity as Executor of the TYPE OF ACTION Estate of CHARLOTTE A. VACONDIOS AT: XX Notice of Sheriff's Sale 1600 CHATHAM RD SALE DATE: March 7, 2012 CAMP HILL, PA 17011-6007 SERVED Served and made known to CLARENCE NICHOLSUN to his capacity as Executor of the tsta VACONDIOS, Defendant on the I day of bb:? 20,1 , at 30, o'clock 'P. M., at I6a0 CA-Ai W& R4 EAW ?T in the manner described below: [Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. p. ? "S4 ' ? Q ?'r f ? S L L"3 N d Z? a rr: p ? c+a _ Other: Description: Age- 60 S Height Weight (&S Race w Sex AA Other 1, ?44,0 /?4j t1- , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsififcati to authorities. DATE: t ? ?? I NAME: PRINTED NAME: M o l o U- TITLE: Sa--V? NOT SERVED On the day of , 20_, at - o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF 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 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 30 s C U1 4 l.. RC_ M1IY i Y F,, ,t E?i4J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CITIMORTGAGE, INC. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF No.: 11-4568 CIVIL CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACOND lOS Defendants RULE AND I\ OW, this X73 /?? day of ( ! 2012, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendants shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT J. 266109 Robert W. Cusick, Esq., Id. No.80193 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, P.A 19103 TEL: (215) 56.3-7000 FAX: (215) 563-3459 V JILL M. WfNEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 VALERIE NICHOLSON 1702 ELAND DOWNE PHOENIXVILLE, PA 19460 male-d IlDqll.-? Aa- 266109 THE PROTHONOTAR), 2912 JAN 31 AM 10: 18 Phelan Hallinan & Schmieg, LLP CUMBERLAND Allison F. Wells, Esq., Id. No.309519 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CITIMORTGAGE, INC. Plaintiff VS. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendants Court of Common Pleas Civil Division CUMBERLAND County No.: 11-4568 CIVIL CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's January 24, 2012 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. JILL M. WINEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 DATE: VALERIE NICHOLSON 1702 ELAND DOWNE PHOENIXVILLE, PA 19460 Phelan Ha' chmieg, LLP B: lison . Wells, Esquire Attorney for Plaintiff 266109 Ft! L 7-9-0F FICE G TAIL T'R0TH0N0TA;R T' PHELAN HALLINAN & SCHMIEG, LLFO 12 FEB 21 AM 10:) mey for Plaintiff Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNT`;` One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIMORTGAGE, INC. Plaintiff, V. CLARENCE NICHOLSON VALERIE NICHOLSON Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.: 11-4568 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached here Exhibit "A" Melissa J. Cantwell, Esquire Attorney for Plaintiff Date: ?17 ?IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS 4 266109 EXHIBIT "A" s ao .) Y M U x? ? y 70 a ?O a O b zao o d ro w ?~ 0u 0 u v ? o 0 y N O A n a 0 S ? a r ? s? o> o $ u a d i ? o ? o o ? ? CC i ry o ? nG roCV? ? ? •+ y W ? q r u S Fwn?? ? m a x _ W ? K W ? w Q b d W u ? y Q 0?. u w , Ow? duo 0 h U V $ Q °?' w L b y a ' ?Ur x Y f .u ? 4?W? z "p,, WW as ? z ci ? M ?? A h ??a o Wvz U v? C o V 7' d 0 tl ?? ? O O? y 4 U 3 u f.o y a j# ? ''N !'K is i{ i? # # i? it •k .? o A g en ? ?n ?o r o0 ON I W a N c r?- 0 m 0 .a g U ?=tea 5 ° ?a it ? Q b C z¢? ?._ . _ .... - _.. - - - ------- ------- -- - ----- O O O C H ? w v o w w oa ?U W F fs1 C W ? F" ? ? aw U0 d a. C"W tn 4 ¢ w o F ul .r q F c, 3 p4Fe? w ? ? ? e. x > ?d4 r,? v •`• v, `4 ?-' - F` •." G N ? ? 4 ? o ? ? ? ? ?'y ? {„? G ? Cxvl,r r O?0.r W M pW ? 3 4` w?N ? Gr,F ?... ? ? ? w ?' 0 O Vi s d F rG W o d W? a ? , . . '„? Fed .?P?p d w d d $ w , W ,?f , ? , „ H O>o w d W W><. ? , ?Zw•c ? . "? w c. s?° ' w z d a zw? tL d wa w? ?Qj. 0, wz?,c? t` qG ` w OC F 5?? F H ?; t? xz U d ..Fp.. +t'?pp ?^?"" wri'' OGE";? d.? ? ? ` ao ? ?3 H.3 3aoG?+ p,, {? Fa?x.? ?tr+Nr ? aa aL?iyr dw J dO..??pa Wr': aw? w o d H::vx r 0. c?a OF w ,x? wxx O ? w ?a gH wx Ha oa?oo gF F xco d?a t?. .a ao w VZ ao wHv? TA a?. WC?.i1O ?IGZ oFv, ao? .e?ppf? a AC 6 ?? wacn [.r g w ? wd- aew G < w ?W Cam a: „ W??d C1H and r-a ?a w0-• 3 ?1 ? ? ??,,•r Ow «C y HNNV VG UaU V?nd Uind Aaa sa..- CZ ffi .o ? GJ i v An e h a6 a p .. :. ....._._..........__ - 1- ............._.__ ... ro ?? w +n c m N 5?. c L G ti ?s sr G Y. W w w L ? c a ? e; n??4 32 e. T .? d if a w ?E .a o°. x 0 x z CITIMORTGAGE, INC. Plaintiff v. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4568 CIVIL CUMBERLAND COUNTY PHS # 266109 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) CLARENCE NICHOLSON, IN HIS CAPACITY 1600 CHATHAM RD AS EXECUTOR OF THE ESTATE OF CAMP HILL, PA 17011-6007 CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY 1702 ELAND DOWNE AS DEVISEE OF THE ESTATE OF PHOENIXVILLE, PA 19460 CHARLOTTE A. VACONDIOS 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 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 (if address cannot be reasonably ascertained, please indicate) Citibank South Dakota, N.A. 1835 Market Street, Suite 501 C/o Blatt Hasenmiller Leibskse Philadelphia, PA 19103 C/o Daniel Joseph Santucci, Esquire 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND PARK INC PO BOX 211 CAMP HILL, PA 17001-0211 CUMBERLAND PARK INC CUMBERLAND PARK, INC. 5700 SIXTH AVE ALTOONA, PA 16602 5700 6TH AVE ALTOONA, PA 16602-1111 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 212 SOUTH LOCUST STREET AWA 212 LOCUST STREET CAMP HILL, PA 17011-6765 COMMONWEALTH OF PENNSYLVANIA, BUREAU OF INDIVIDUAL TAX, INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING, PA 17105 PROGRAM JILL M. WINEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OF PA HARRISBURG, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. Date: 9,10k, By: \ Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff PHELAN 14ALLINAN & SCHMIEG, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 (uiZFIS ?1? tt,?rt ? • for Plaintiff " L""I B 13 PE iNSY'1, 3UPdT,, CIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIMORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS V. CLARENCE NICHOLSON VALERIE NICHOLSON Defendant(s) CIVIL DIVISION No.: 11-4568 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129„1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817 and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is atta ed here Exhibit "A".S ' r 1S Melissa J. Cantwell, Esquire -- Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS 4 266109 E 'B'T «A„ I nw 0 N M O U w N d ? b d o? a ? v? ? V] O CJ1 p y cd ? ?''. C a ice.. N y p ?? ? " n°'. ? a? ? Ca A ,n ?w Cs ?':. o o?:a ?,.,_pa. z;UUU.*G• y s..' s a? i? ?z x V ? V 'D u7 b v ?f -< d o ?' 8 a N C??+ 4 ? N 0 a a 0 S E°A E ' a?K e Hd ?ssw d o? ?O O? W't ? ?w a 'x d ?_ ?? Krn u u u o Qw Fwc?,.i?x 4 VO w w w? c yd. w u F+ A Ua G. u a? ?o UU? °:w zw ?? ?Wa€ as _....... _.... zx oz? tz .U. O wpa ?? zU, w? 0 0 ww -Ile UaJ z'?; v N;M ?r in?or0007, " 0. ? by ? y?J r% M cnd ?? ?vd ? a G a g o a? ? ^WU O R o i v a € Q ? I CITIMORTGAGE, INC. Plaintiff V. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4568 CIVIL CUMBERLAND COUNTY PHS # 266109 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) CLARENCE NICHOLSON, IN HIS CAPACITY 1600 CHATHAM RD AS EXECUTOR OF THE ESTATE OF CAMP HILL, PA 17011-6007 CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY 1702 ELAND DOWNE AS DEVISEE OF THE ESTATE OF PHOENIXVILLE, PA 19460 CHARLOTTE A. VACONDIOS Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Citibank South Dakota, N.A. 1835 Market Street, Suite 501 C/o Blatt Hasenmiller Leibskse Philadelphia, PA 19103 C/o Daniel Joseph Santucci, Esquire 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND PARK INC PO BOX 211 CAMP HILL, PA 17001-0211 CUMBERLAND PARK INC CUMBERLAND PARK, INC. 5700 SIXTH AVE ALTOONA, PA 16602 5700 6TH AVE ALTOONA, PA 16602-1111 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 212 SOUTH LOCUST STREET A/K/A 212 LOCUST STREET CAMP HILL, PA 17011-6765 COMMONWEALTH OF PENNSYLVANIA, BUREAU OF INDIVIDUAL TAX, INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING, PA 17105 PROGRAM JILL M. WINEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OFPA HARRISBURG, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. Date: By. Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff r CITIMORTGAGE, INC., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE ; OF CHARLOTTE A. ' VACONDIOS; VALERIE NICHOLSON, IN HER r r CAPACITY AS DEVISEE OF ' THE ESTATE OF F= `Ml CHARLOTTE A. VACONDIOS, : Defendants NO. 11-4568 CIVIL TERM IN RE: MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this 14'h day of March, 2012, upon consideration of Plaintiff's Motion To Reassess Damages and Motion To Make Rule Absolute, and Defendants having failed to respond to the rule to show cause why Plaintiff's motion to reassess damages should not be granted, Plaintiffs motion to make the rule absolute is hereby granted and the Prothonotary is ordered to amend the in rem judgment and the Sheriff is ordered to amend the writ nunc pro tunc in this case as follows: Principal Balance $151,279.26 Interest Through March 7, 2012 $12,465.95 Per Diem $23.83 Legal Fees $1,450.00 Cost of Suit and Title $1,424.00 Property Inspections $292.50 Property Preservation $905.00 Mortgage Insurance Premium/ Private Mortgage $736„66 Insurance Escrow Deficit 1937.41 TOTAL $170,490.78 BY THE COURT, ?/" ? a -I' r? Christylee . Peck, J. V Melissa J. Cantwell, Esq. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff V Jill M. Wineka, Esq. 1719 North Front Street Harrisburg, Pa 17102-2392 v Valerie Nicholson 1702 Eland Downe Phoenixville, PA 19460 :rc 6Ae",. Copies oo,W 311sjja )ey,- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Clarence Nicholson (et al.) ngktltk?, of 4ri?rt?a???r t .? !I LJ ?Ir t' v ! rHE F'MrtT'9 C u T.r, 2'312 APR 26- Alk4 3: 5 PENN5YD/ANIA Case Number 2011-4568 SHERIFF'S RETURN OF SERVICE 12/29/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Valerie Nicholson, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Chester County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 01/05/2012 03:06 PM - Deputy Michael Barrick, 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 212 South Locust Street A/K/A 212 Locust Street, Camp Hill, Cumberland County, PA 17011. 01/05/2012 07:12 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: Clarence Nicholson at 1600 Chathan Road, Lower Allen Township, Camp Hill, Cumberland County, PA 17011. 01/26/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Chester County upon Valerie Nicholson, personally, at 1702 Eland Downe, Phoenixville, PA 19460. So Answers: Carolyn B. Welsh, Sheriff. 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 $1.00 to Attorney Daniel Schmieg, on behalf of Citimortgage, Inc. at 1000 Technology Drive, O'Fallon, MO 63368. Citimortgage, Inc., being the buyer in this execution, paid to the Sheriff the sum of $995.77. 03/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED. SHERIFFCOST $995.77 SO ANSWERS, March 22, 2012 RON J R ANDERSON, SHERIFF CITIMORTGAGE, INC. Plaintiff V. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS :DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4568 CIVIL CUMBERLAND COUNTY PHS # 266109 AFFIDAVIT PURSUANT TO RULE 3129.1 CITIMORTGAGE, INC., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) CLARENCE NICHOLSON, IN HIS CAPACITY 1600 CHATHAM RD AS EXECUTOR OF THE ESTATE OF CAMP HILL, PA 17011-6007 CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY 1702 ELAND DOWNS AS DEVISEE OF THE ESTATE OF PHOENIXVILLE, PA 19460 CHARLOTTE A. VACONDIOS 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND PARK INC CUMBERLAND PARK INC CUMBERLAND PARK, INC. PO BOX 211 CAMP HILL, PA 17001-0211 5700 SIXTH AVE ALTOONA, PA 16602 5700 6TH AVE ALTOONA, PA 16602-1111 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 (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 212 SOUTH LOCUST STREET A/K/A 212 LOCUST STREET CAMP HILL, PA 17011-6765 COMMONWEALTH OF PENNSYLVANIA, 6TH FLOOR, STRAWBERRY SQ., DEPT 280601 BUREAU OF INDIVIDUAL TAX, HARRISBURG, PA 17128 INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING, PA 17105 PROGRAM JILL M. WINEKA, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OF PA HARRISBURG, PA 17108 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.A. § 4904 relating to unsworn falsification to authorities. Date: BY: helan Hallinan & Schmieg, LLP William E. Miller, Esq., Id. No.308951 Attorney for Plaintiff CITIMORTGAGE, INC. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS Defendant(s) : NO.: 11-4568 CIVIL : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CLARENCE NICHOLSON, IN HIS VALERIE NICHOLSON, IN HER CAPACITY CAPACITY AS EXECUTOR OF THE AS DEVISEE OF THE ESTATE OF ESTATE OF CHARLOTTE A. VACONDIOS CHARLOTTE A. VACONDIOS 1600 CHATHAM ROAD 1702 ELAND DOWNE CAMP HILL, PA 17011 PHOENIXVILLE, PA 19460 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 is scheduled to be sold at the Sheriffs Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $158,722.31 obtained by CITIMORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney„) VE VE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 in the sale. To find out if this has happened, you may call 215-563-7000. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Township of Lower Allen, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly set forth on Plan of 'Cumberland Park' recorded in Plan Book 4, Page 86, Cumberland County Records, and being Lot No. 64 on said plan, bounded and described as follows, to wit: BEGINNING at the intersection of the Southwesterly side of Locust Street (60 feet wide) with the northwesterly side of Allen Road (formerly Avenue 'R') (40 feet wide); thence along the northwesterly side of Allen Road (formerly Avenue'R') South fifty-eight (58) degrees thirty (30) minutes West one hundred thirty-four and eighty-five one-hundredths (134.85) feet to a point; thence along part of Lot No. 63 North thirty-one (31) degrees thirty (30) minutes West ninety- one and twenty-seven one-hundredths (91.27) feet to a point; thence along Lot No. 65 North sixty-seven (67) degrees ten (10) minutes East one hundred forty-seven and six one-hundredths (147.06) feet to a point on the southwesterly side of Locust Street; thence along the said side of Locust Street South twenty-two (22) degrees fifty (50) minutes East sixty-nine and sixty-one one-hundredths (69.61) feet to the first mentioned point and place of BEGINNING. TITLE TO SAID PREMISES IS VESTED IN Charlotte A. Vacondios, single woman, by Deed from Charlotte A. Vacondios, Executrix for the Estate of Shirley L. Freedman, deceased, dated 12/22/2005, recorded 12/28/2005 in Book 272, Page 2563. Mortgagor CHARLOTTE A. VACONDIOS died on 1/16/2011, leaving a Will dated 5/1/2007. Letters Testamentary were granted to CLARENCE NICHOLSON on 2/10/2011 in CUMBERLAND County, No. 21-11-0183. Decedent's surviving heirs at law and next-of-kin are CLARENCE NICHOLSON and VALERIE NICHOLSON. PREMISES BEING: 212 SOUTH LOCUST STREET A/K/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 PARCEL NO. 13-24-0797-188 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-4568 CIVIL CITIMORTGAGE, INC. VS. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 212 SOUTH LOCUST STREET A/K_/A, 212 LOCUST STREET, CAMP HILL, PA 17011-6765 Parcel No. 13-24-0797-188 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $158,722.31 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOII-4568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC. Plaintiff (s) From CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VACONDIOS, VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACONDIOS (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: $158,722.31 L.L.: $.50 Interest from 7/20/11 to Date of Sale ($26.09 per diem) -- $6,052.88 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $271.50 Other Costs: Plaintiff Paid: Date: 11/30/11 David D. Buell, Prothonotary. (Seal) Deputy REQUESTING PARTY: Name: WILLIAM E. MILLER, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308951 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said at Carlisle, Pa. This ? day of _. 20 Prothonotary On December 15, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 212 South Locust Street, A/K/A 212 Locust Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date December 15, 2011 By: CJ -; -- Real Estate Coordinator 10 :Z cj 1- 310 i 1Ol CUMBERLAND LAW JOURNAL Writ No. 2011-4568 Civil Term Citimortgage, Inc. vs. Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondios and Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A. Vacondios Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 11-4568 CIVIL, CITIMORTGAGE, INC. vs. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF THE ESTATE OF CHARLOTTE A. VA- CONDIOS, VALERIE NICHOLSON, IN HER CAPACITY AS DEVISEE OF THE ESTATE OF CHARLOTTE A. VACON- DIOS owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being 212 SOUTH LOCUST STREET a/k/a, 212 LOCUST STREET, CAMP HILL, PA 17011-6765. Parcel No. 13-24-0797-188. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $158,- 722.31. 60 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 Afflant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 10 da of February, 220/012 Notary NOTARIAL. SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Patriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/27/12 02/03/12 02110/12 ,,.......... Sworr?,ta a subscribed?efor'eme tais 2 ay Of February, 2012 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2015 MEMBER, PENNSYLVANfA ASSOCIATION OF NOTARIES 4568 Civil Term .:Imortgage, Inc. VS Clarence Nicholson, in his capacity as Executor of the Estate of Charlotte A. Vacondlos and Valerie Nicholson, in her capacity as Devisee of the Estate of Charlotte A. Vacondlos Atty. Daniel Schmieg By virtue of a Writ of Execution N0.11- 4568 CIVIL CITIMORTGAGE, INC. VS. CLARENCE NICHOLSON, IN HIS CAPACITY AS EXECUTOR OF D P ESTATE OF CHARLOTTE A. v, tONDIOS VALERIE NICHOLSON, IN HER C A.PACITY AS DEVISEE OF THE E:,TATE OF CHARLOTTE A. VACONDIOS owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 212 SOUTH LOCUST STREET A/K/A, 213 LOCUST STREET, CAMP HILL, PA 17011-6765 Parcel No. 13-24-0797-188 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $158,722.31 %up 13atriot-Xims Now you know 2020 Technology Parkway Mechanicsburg, PA (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL 01/27/12 02/03/12 02/10/12 Of Ad Sheriff Sale 4568 5.59 $12.00 $ 67.08 Sheriff Sale 4568 5.59 $12.00 $ 67.08 Sheriff Sale 4568 5.59 $12.00 $ 67.08 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 206.24 JLC COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citimortg_a eg Inc. 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 30 day of November, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 4568, at the suit of Citimortga a Inc. against Estate of Charlotte A. Vacondios (Exor Devisee) is duly recorded as Instrument Number 201212005. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _ ;? S day of A.D. d,_ ?ecorder of Deeds, Cumberland County, Carlisle, PA Recorder of Deeds Ay Commission Expires the Fust Monday of Jan. 2014