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Home My WebLink About11-4717Phelan 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 Jaime McGuinness, Esq., Id. No. 90134 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 Plaintiff V. ESTHER R. LEBO 16 VALLEY STREET CARLISLE, PA 17013-3143 Defendant r-I .l NE PRO HONO-T AR`t 20,11 jum - i Am 9: 28 "UMBERLANO COUNTY PENNSYLVANIA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM n NO. II-LI-71-] Clh? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 257044 257044 am?*9a^ Pd O-Wi Iz4 9!S99 U9 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 #: 257044 I- I . Plaintiff is AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 2. The name(s) and last known address(es) of the Defendant(s) are: ESTHER R. LEBO 16 VALLEY STREET CARLISLE, PA 17013-3143 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/01/2006 ESTHER R. LEBO made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR BALTIMORE AMERICAN MORTGAGE COMPANY, INC., A MARYLAND CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1976, Page 2198. By Assignment of Mortgage Recorded 03/23/2009 the mortgage was Assigned To PLAINTIFF which Assignment is recorded in Assignment Of Mortgage in Instrument # 200908602. 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 #: 257044 5 6 The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2010 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. The following amounts are due as of 04/14/2011: Principal Balance $137,416.67 Interest $2,968.78 07/01/2010 through 04/14/2011 Late Charges $92.52 Escrow Deficit $701.49 TOTAL $141,179.46 7 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 257044 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $141,179.46, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN. BSI EG, LLP By, La h an, Esq., Id. No 32227 ? Francis S. Hallinan, Esq., Id. N e( 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 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courte}ay R. Dunn, Esq., Id. No. 206779 ? rew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff File #: 257044 LEGAL DESCRIPTION ALL THAT CERTAIN messuage and tract of land with the buildings and improvements thereon erected, SITUATE in North Coventry Township, Chester County, Pennsylvania, bounded and described in accordance with a survye as made by George F, Shaner, R.E., as follows, to wit: BEGINNING at a corner of lands of Edna Sponagle Grepps, said point being in the middle of the Pottstown West Chester State Highway, Traffic Route #100; thence along the middle of said Road North 10 degrees 27 minutes East 75.00 feet to a corner of other lands of Robert Gresh; thence along the same South 84 degrees 07 minutes East 342.50 feet to a corner of line of lands of Kasver A. Krepps; thence along the same South 37 degrees West 87.33 feet to a corner aforesaid of lands of Edna S. Grepps; thence along the same North 84 degrees 07 minutes West 303.16 feet to the place of beginning. CONTAINING 0 acres and 88.62 perches of land. Being the same premises which Darin S. Domin, a/k/a Darrin S. Domin and Kelly C. Domin, Husband and Wife by Deed dated 3-26-2004 and recorded 3-29-2004 in Chester County in Record Book 6103 Page 1134 conveyed unto Darrin W. Harris and Tina M. Harris, Husband and Wife, in fee. PROPERTY ADDRESS: 16 VALLEY STREET, CARLISLE, PA 17013-3143 PARCEL # 40-22-0489-077 File #: 257044 VERIFICATION , hereby states that he/she is of Aurora Loan Services, LLC, Plaintiff in this matter, that he/she is authorized to take 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. !go DATE: it Inh-OR-6 'rila( Servicer: Aurora Loan Services, LLC. File #: 257044 Name: LEBO 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 AURORA LOAN SERVICES, LLC. Plaintiff vs. ESTHER R. LEBO Defendants = - PROTHONOTAR' zt I 1 Jt."N 22 AM 9: "5 CUMBERLAND NNVANA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY : No. 11-4717-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE Gb &V w'4 %10.00 pal O-tt'( ?IC.c?- 1?4W(?od TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: ?--. !awreenceT. Phelan, Esq., Id. N . 2227 ? 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 ? Je ne R. Davey, Esq., Id. No. 87077 auren 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 Attorneys for Plaintiff Date: June 21, 2011 !jnc, Svc Dept. File# 257044 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor t: 2 RLED-OFFICE L 'T 7HC* PROTHONO lAFl% 2011 JUL I I AM 11: 23 CUMBERLAND COUNTY PENNSYLVANIA Aurora Loan Services, LLC i vs. Esther R. Lebo Case Number 2011-4717 SHERIFF'S RETURN OF SERVICE 06/23/2011 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: Esther R. Lebo, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lycoming County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 06/30/2011 10:06 AM - Lycoming County Return: And now June 30, 2011 at 1006 hours I, Mark T. Lusk, Sheriff of Lycoming 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: Esther R. Lebo by making known unto herself personally, at SCI Muncy, BOX 180 Route 405, Muncy, Pennsylvania 17756 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, July 06, 2011 ,n COUITyS.;ite She;,°t. 72?e?os:;'t. Ir„ RbNt,N R ANDERSON, SHERIFF It PHELAN HALLINAN & SCHMIEG, LLP Jenine R. Davey, Esq., Id. No.87077 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. VS. ESTHER R. LEBO Attorney for Plaintiff C r? r ryl m Ln CUMBERLAND COUNTY r'x Q x=» C; COURT OF COMMON PLEA S E5 c:)n CIVIL DIVISION C:-' - : No. 11-4717-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ESTHER R. LEBO, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: y.00P'? all set forth in Complaint $141,179.46 Oak +? eta 1163 {1$ a TOTAL $141,179.46 * a(P (\A6 AT Mcu lp'A I hereby certify that (1) the Defendant's last known addresses are BOX 180 ROUTE 405, SCI MUNCY, INMATE #OQ4109, MUNCY, PA 17756-0180 and 16 VALLEY STREET, CARLISLE, PA 17013-3143, and (2) that notice has been 5Atto accordance with Pa.R.C.P 23 .1. 74 Date . Davey, Es q., Id. No .87 77 for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS # 257044 PROTHONOTARY 257044 PHELAN HALLINAN & SCHMIEG, LLP Jenine R. Davey, Esq., Id. No.87077 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. VS. ESTHER R. LEBO Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 11-4717-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) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ESTHER R. LEBO is over 18 years of age and resides at BOX 180 ROUTE 405, SCI MUNCY, INMATE #OQ4109, MUNCY, PA 17756-0180 and 16 VALLEY STREET, CARLISLE, PA 17013-3143. This statement is made subject to the relating to unsworn falsification to authorities. Date Jenine Attorn of 18 Pa. C.S. Section 4904 v6y, Esq., Id. No.87 Plaintiff 257044 (Rule of Civil Procedure No. 236) - Revised AURORA LOAN SERVICES, LLC. VS. ESTHER R. LEBO : CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : No 11-4717-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on By: % If you have any questions concerning this matter please contact: Jenine R. Davey, Esq., Id. No.87077 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 ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. ** AURORA LOAN SERVICES, LLC. v. Plaintiff ESTHER R. LEBO Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-4717-CIVIL CUMBERLAND COUNTY TO: ESTHER R. LEBO BOX 180 ROUTE 405, SCI MUNCY INMATE #OQ4109 MUNCY, PA 17756-0180 DATE OF NOTICE: July 22, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRTITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 257044 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: *vwnre khe Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 aniel 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 Jenne 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257044 AURORA LOAN SERVICES, LLC. v. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-4717-CIVIL ESTHER R. LEBO Defendant(s) TO: ESTHER R. LEBO 16 VALLEY STREET CARLISLE, PA 17013-3143 DATE OF NOTICE: July 22, 2011. CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT -BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 257044 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 VAcme By: Mqq,, . Fr ancis S. Hallinan, Esq., Id. No. 62695 aniel 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 Jenne 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 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257044 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOII-4717 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC., Plaintiff (s) From ESTHER R. LEBO (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: $141,179.46 L,L,: $.50 Interest FROM 8/6/2011 TO DATE OF SALE ($23.21 PER DIEM) - $4,990.15 Atty's Comm: % Atty Paid: $235.50 Plaintiff Paid: Date: DECEMBER 1, 2011 (Seal) Due Prothy: $2.00 Other Costs: vid D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, 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. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 AURORA LOAN SERVICES, LLC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 11-4717-CIVIL ESTHER R. LEBO Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 08/06/2011 to Date of Sale ($23.21 per diem) TOTAL CUMBERLAND COUNTY t i"", Y? (n- $141 179 46 , . $4,990.15 -- - -------- ------- Note: Please attach description of property. PHS # 257044 l? no. ov CgF 37.oo «!? 4^ 3S SbP? a ?a P"k dz Allison F. Wells, Esq., Id. No.309519 Attorney for Plaintiff U ti a? sa r``? o d W o°?o ? U Q ? ? a ? ? d a p x w ?; p6A o o z O a ? w v w? W `? N u y Q 0 O? ?? W ? ? a d O , d ?U > PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza t. JJ Philadelphia, PA 19103 215-563-7000 -: R_AURORA LOAN SERVICES, LLC. Plaintiff V. ESTHER R. LEBO Defendant(s) .,r I4 kc..:Etp 91`vD C0U!fl CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4717-CIVIL CUMBERLAND COUNTY 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: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 authorities. to i Ha inan & Schmieg, L Allison F. Wells, Esq., Id. No.309 19 Attorney for Plaintiff AURORA LOAN SERVICES, LLC. COURT OF COMMON PLEAS Plaintiff #, r CIVIL DIVISION V. NO.: 11-4717-CIVIL ESTHER'R. LEBO , Defendant(s) `E A IN D C H IA' CUMBERLAND COUNTY PHS # 257044 AFFIDAVIT PURSUANT TO RULE 3129.1 AURORA LOAN SERVICES, LLC., 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 16 VALLEY STREET, CARLISLE, PA 17013-3143. Name and address of Owner(s) or reputed Owner(s): Name 2. ESTHER R. LEBO SAME AS ABOVE Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) BOX 180 ROUTE 405, SCI MUNCY, INMATE #OQ4109 MUNCY, PA 17756-0180 Address (if address cannot be reasonably ascertained, please so indicate) 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) James L. Lebo Aurora Loan Services, LLC Mary L. Lebo James L. Lebo C/o: Michael A. Scherer, Esquire Mary L. Lebo C/o: Michael A. Scherer, Esquire 104 Channel Drive Carlisle, PA 17013 601 5th Avenue Scottsbluff, NE 69361 104 CHANNEL DRIVE CARLISLE, PA 17013 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) Baltimore American Mortgage Corporation, Inc. 4 Candlewood Road, Suites B-J a Maryland Corporation Hanover, MD 21076 Baltimore American Mortgage Corporation, Inc. 7484 CANDLEWOOD ROAD; SUITES B-J a Maryland Corporation HANOVER, MD 21076 Baltimore American Mortgage Corporation, Inc. 341 SCIENCE PARK ROAD; SUITE 2051 a Maryland Corporation STATE COLLEGE, PA 16803 C/O: VICTORY SETTLEMENT SERVICES, LLC. Anna Mae Smith 1203 YORK ROAD MECHANICSBURG, PA 17055 Anna Mae Smith 203 York Road Mechanicsburg, PA 17055 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) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name 41 TENANT/OCCUPANT Commonwealth of Pennsylvania; Bureau of Individual Tax; Inheritance Tax Division Department of Public Welfare; TPL Casualty Unit; Estate Recovery Program Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Address (if address cannot be reasonably ascertained, please indicate) 16 VALLEY STREET CARLISLE, PA 17013-3143 6th Floor, Strawberry Sq.; Dept 280601 Harrisburg, PA 17128 P.O. Box 8486; Willow Oak Building Harrisburg, PA 17105 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street 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_tQtbc of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. ,?- Date- 1? 1 L I j Phelan Hallinan & chmieg, LLP-' Ils, Esq., Id. No.309519 Attorney for Plaint-iff- AURORA LOAN SERVICES, LLC, ESTHER R. LEBO ' `' L'iA?II : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO.: 11-4717-CIVIL Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ESTHER R. LEBO ESTHER R. LEBO BOX 180 ROUTE 405, SCI MUNCY, 16 VALLEY STREET INMATE #OQ4109 CARLISLE, PA 17013-3143 MUNCY, PA 17756-0180 "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 16 VALLEY STREET, CARLISLE, PA 17013-3143 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 $141,179.46 obtained by AURORA LOAN SERVICES, LLC. (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. 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 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-4717-CIVIL AURORA LOAN SERVICES, LLC. vs. ESTHER R. LEBO owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 16 VALLEY STREET, CARLISLE, PA 17013-3143 Parcel No. 40-22-0489-077 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $141,179.46 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THOSE CERTAIN two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots Nos. 17 and 18, Block 'L', of that certain Plan of Lots known as Carlisle Manor Extention, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99, said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North, a depth of 150 feet along the southern line of Lot No. 18, Block'L' of said Plan on the South, and a width of 5.4 feet in the rear. TITLE TO SAID PREMISES IS VESTED IN Esther R. Lebo, widow, by Deed from Carl E. Souders and Ardella F. Souders, h/w, dated 12/20/1990, recorded 12/20/1990 in Book 34-X, Page 542. PREMISES BEING: 16 VALLEY STREET, CARLISLE, PA 17013-3143 PARCEL NO. 40-22-0489-077 0 Tk E PR,0THONNOTA't; I' PHELAN HALLINAN & SCHMIEG, LLP n Attorney for Plaintiff Allison F. Wells, Esq., Id. No.309519,13 12 t B 214 Aid 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza CUMBERLAND COUNT` Philadelphia, PA 19103 PENNSYLVANIA 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AURORA LOAN SERVICES, LLC. Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION ESTHER R. LEBO Defendant(s) No.: 11-4717-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 am f applicable. A copy of the Certificate of Mailing (Form 3817) and/or Cc • ' ai Return Receipt stamped by the U.S. Postal Service is attached heret I . A". 2?K ZAZ ??9uire Attorney or 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 # 257044 EXHIBIT "A" ? O r, CJ' bD 4 o d a1 U t b z¢o ° o ..1 XU xx ? v G o'°.`OO b ? Nb ZQO N ? •L •? ? 3 V 9 !j fi N i R. w ° c .Ali EN u ? w n v. N {Y O YJ z".o M ? N w ? U?b R N N « ? ? C N N x j ? 0 d d d '" a° a c. ? z o 0 y u a 0 0 a s = W V c? as •? a °a cq d :es ?. ?:+ a ;;ti ?b8 a99 U _ 99 off? p ?r"?Fa ?W?Ei? N w a o o, o o h 99 z a ? b a V „'C w c t 3 z esa V go C (? CND W o Z V+••? V CnU f/]Vitm OG x ?I ? -K •K i? ? it % i? # IT kn I'D t- v ...... ...,.I. .. °^ o Jo Lf% tC M a ImU x AL c n v r .^ a °0cL H z¢o j S ?O ,u 2 _ c 8 ? 8 p q E ° `H ° 1..- __ E C UN 0. ? ? W C 0 c E g:5 Q a ro N ? ' a o ? C I u ? ? 0. X F ? i V ? aWi o c ? A a w ywSn? G r. fi T ? p V n N ?' ys a? r i ? 7 •? o _ ? ? vPi c- '? Gl a ? u a . - u 0 ?..., a r w e a F o 6 . c a o o a u c $ a ,? o. g C v a GY U O V Q V t c O ? ry y a a a F ? , d G u ` i I E F ?' _'c GL E O C ti C w W y L , , o `o L o p `o Gp ao 04 u n x a o V m U? on A V? °' c a.. a °' F.? A d d w Ai !' M wo c < a ? qq . a ? •^ ? o '3 'a.ara o CG w oQ ? o a d c?y a fn w G? 3 p =-° c•- v W? rn tno e n w o aGn u pw '? rAo n u °%'v? h ? O ? q p,, Wn CG^ Fd s m 0. adU ?Om n ?t a a an Coo uaev ?vN aw ? C16W ua' w n o?'., « 3d n a3.. d uM > Co fix., ?d p^ ad oa1-? C?E"d e ?M c o u = o o ° w u ? 03 d « .? u i?0 a, y v)Or a 6 0 a ya j ? , , w oaG e9o q d a a d e Vw d L°a -« _ ? w o O. ?A..+ u- a °° O a WO'+ SO i n V C... dva w - Ora, ?, cc W' 'o d w o wa ..l r /,7 .. o v .E 0 .. av o > .a d o o? c- u o p .,z o U ? 3 O toy a ., ' r o .ad C3A j a u ? Zn .a Fem. Vj J a" ?h 7 ?cr ? a F v2 l? a d s a50. u t c 3 „? e x - o .. v a b u e dd.x >a a ?, ? ? U AM W NZ ri , o e o z ?, E Q a r., e ? z e EW. 4 e aCi a E Q a a d V j x a W ?3 a a o. a ex. E E n Q W LJ ? a 7_ W o d F..U o o r '+ drr... . ° N , d..r. o 0 dveYs a V a Av oa s Gf?n « a v F OGeyv? o$ a v? U ° u A a g `° ti U m ti o +F; ? u V o? M a AU V a o u UAG v OG o E x # # k k # # k i i # k k k k k # # t # k i i # i # i # # k i t k Y ? ? } t # # % # k k # k i K k , t ? t p N w y I t g p a? ? z k9 Z AURORA LOAN SERVICES, LLC. Plaintiff V. ESTHER R. LEBO Defendant(s) Name and address of Defendant(s) in the judgment: Name AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AURORA LOAN SERVICES, LLC., 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 16 VALLEY STREET, CARLISLE, PA 17013-3143. Name and address of Owner(s) or reputed Owner(s): Name ESTHER R. LEBO 2 3 SAME AS ABOVE COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4717-CIVIL CUMBERLAND COUNTY PHS # 257044 Address (if address cannot be reasonably ascertained, please so indicate) BOX 180 ROUTE 405, SCI MUNCY, INMATE #OQ4109 MUNCY, PA 17756-0180 Address (if address cannot be reasonably ascertained, please so indicate) 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) James L. Lebo Aurora Loan Services, LLC Mary L. Lebo James L. Lebo C/o: Michael A. Scherer, Esquire Mary L. Lebo C/o: Michael A. Scherer, Esquire Cumberland County Adult Probation 104 Channel Drive Carlisle, PA 17013 601 5th Avenue Scottsbluff, NE 69361 104 CHANNEL DRIVE CARLISLE, PA 17013 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 1 Courthouse Square Carlisle, PA 17013-3387 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) Baltimore American Mortgage Corporation, Inc. 4 Candlewood Road, Suites B-J a Maryland Corporation Hanover, MD 21076 Baltimore American Mortgage Corporation, Inc. 7484 CANDLEWOOD ROAD; SUITES B-J a Maryland Corporation HANOVER, MD 21076 Baltimore American Mortgage Corporation, Inc. 341 SCIENCE PARK ROAD; SUITE 2051 a Maryland Corporation STATE COLLEGE, PA 16803 C/O: VICTORY SETTLEMENT SERVICES, LLC. Anna Mae Smith 1203 YORK ROAD MECHANICSBURG, PA 17055 Anna Mae Smith 203 York Road Mechanicsburg, PA 17055 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) South Middleton Township Municipal Authority C/O Keith Orr Brenneman ESQ. 44 W MAIN STREET MECHANICSBURG, PA 17055 South Middleton Township Municipal Authority CRISWELL DRIVE RD #2 BOILING SPRINGS PA 17007 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) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Commonwealth of Pennsylvania; Bureau of Individual Tax; Inheritance Tax Division Department of Public Welfare; TPL Casualty Unit; Estate Recovery Program Domestic Relations of Cumberland County 16 VALLEY STREET CARLISLE, PA 17013-3143 6th Floor, Strawberry Sq.; Dept 280601 Harrisburg, PA 17128 P.O. Box 8486; Willow Oak Building Harrisburg, PA 17105 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street 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: elan Hall' an & Sclu Allison ells, Esq., Id Attorney for Plaintiff No.309519 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson. ` Sheriff , r - Jody S Smith Chief Deputy Richard W Stewart L ; C SolicitorM1r YLY ?,, Aurora Loan Services, LLC vs. Esther R. Lebo Case Number 2011-4717 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: Esther R. Lebo, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Lycoming County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 01/05/2012 03:42 PM - Deputy Elizabeth Muller, 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 16 Valley Street, Carlisle, Cumberland County, PA 17013. 01/19/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Timothy Nelson, Deputy Sheriff Lycoming County upon Esther R. Lebo, personally, at SCI Muncy, Box 180, Route 405, Muncy, PA 17756. So Answers: R. Mark Lusk, Sheriff. 01/30/2012 Affidavit of Service on Esther R. Lebo filed in the Sheriffs Office 03/07/2012 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/2/2012 04/17/2012 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/6/2012 06/04/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $698.89 SO ANSWERS, June 04, 2012 RON R ANDERSON, SHERIFF SZ) Z- &/W, ?'("cu S'Aitc She f ( AURORA LOAN SERVICES, LLC. Plaintiff V. ESTHER R. LEBO Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-4717-CIVIL CUMBERLAND COUNTY PHS # 257044 AURORA LOAN SERVICES, LLC., 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 16 VALLEY STREET, CARLISLE, PA 17013-3143. 1 Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) 2. 3 ESTHER R. LEBO Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE BOX 180 ROUTE 405, SCI MUNCY, INMATE #OQ4109 MUNCY, PA 17756-0180 Address (if address cannot be reasonably ascertained, please so indicate) 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) James L. Lebo Aurora Loan Services, LLC Mary L. Lebo Jnmrc L- Lp.hn C/o: Michael A. Scherer, Esquire Mary L. Lebo C/o: Michael A. Scherer, Esquire 104 Channel Drive Carlisle, PA 17013 601 5th Avenue Scottsbluff, NE 69361 104 CHANNEL DRIVE CARLISLE, PA 17013 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 19 WEST SOUTH STREET CARLISLE, PA 17013-3444 Name and address of last recorded holder of every mortgage of record: Name' Address (if address cannot be reasonably ascertained, please indicate) Baltimore American Mortgage Corporation, Inc. 4 Candlewood Road, Suites B-J a Maryland Corporation Hanover, MD 21076 Baltimore American Mortgage Corporation, Inc. 7484 CANDLEWOOD ROAD; SUITES B-J a Maryland Corporation HANOVER, MD 21076 Baltimore American Mortgage Corporation, Inc. 341 SCIENCE PARK ROAD; SUITE 2051 a Maryland Corporation STATE COLLEGE, PA 16803 C/O: VICTORY SETTLEMENT SERVICES, LLC. Anna Mae Smith 1203 YORK ROAD MECHANICSBURG, PA 17055 Anna Mae Smith 203 York Road Mechanicsburg, PA 17055 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. 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) None. 7. Name?and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Commonwealth of Pennsylvania; Bureau of Individual Tax; Inheritance Tax Division Department of Public Welfare; TPL Casualty Unit; Estate Recovery Program Domestic Relations of Cumberland County 16 VALLEY STREET CARLISLE, PA 17013-3143 6th Floor, Strawberry Sq.; Dept 280601 Harrisburg, PA 17128 P.O. Box 8486; Willow Oak Building Harrisburg, PA 17105 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street 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 t of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: MD) t ( By: Phelan Hallinan & chmieg, LLP ells. Esa.. Id. No.309519 Attorney for y AURORA LOAN SERVICES, LLC. VS. Plaintiff : CIVIL DIVISION ESTHER R. LEBO : COURT OF COMMON PLEAS : NO.:11-4717-CIVIL Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ESTHER R. LEBO ESTHER R. LEBO BOX 180 ROUTE 405, SCI MUNCY, 16 VALLEY STREET INMATE #OQ4109 CARLISLE, PA 17013-3143 MUNCY, PA 17756-0180 "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 16 VALLEY STREET, CARLISLE, PA 17013-3143 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 courtjudgment of $141,179.46 obtained by AURORA LOAN SERVICES, LLC. (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. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. P 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 F SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-4717-CIVIL AURORA LOAN SERVICES, LLC. VS. ESTHER R. LEBO owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 16 VALLEY STREET, CARLISLE, PA 17013-3143 Parcel No. 40-22-0489-077 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $141,179.46 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THOSE CERTAIN two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEING Lots Nos. 17 and 18, Block'L', of that certain Plan of Lots known as Carlisle Manor Extention, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99, said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North, a depth of 150 feet along the southern line of Lot No. 18, Block 'L' of said Plan on the South, and a width of 5.4 feet in the rear. TITLE TO SAID PREMISES IS VESTED IN Esther R. Lebo, widow, by Deed from Carl E. Souders and Ardella F. Souders, h/w, dated 12/20/1990, recorded 12/20/1990 in Book 34-X, Page 542. PREMISES BEING: 16 VALLEY STREET, CARLISLE, PA 17013-3143 PARCEL NO. 40-22-0489-077 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOI1-4717 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC., Plaintiff (s) From ESTHER R. LEBO (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: $141,179.46 L.L.: $.50 Interest FROM 8/6/2011 TO DATE OF SALE ($23.21 PER DIEM) - $4,990.15 Atty's Comm: % Atty Paid: $235.50 Plaintiff Paid: Date: DECEMBER 1, 2011 Due Prothy: $2.00 Other Costs: , honotary 4n. 2. Buelllrot (Seal) By: Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, 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. 309519 TRITE COPY FROM RECOR rny L'and set In Testimony whereof, 1 hreat Canis e, lea. and the sett of said ' 209- This SA-- =T day of Qrothonotary ?. j On December 15, 2011 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 16 Valley Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date December 15, 2011 By: 0 Real Estate coordinator S 1 :? c C- J10 i it L/ , CUMBERLAND LAW JOURNAL Writ No. 2011-4717 Civil Term Aurora Loan Services, LLC VS. Esther R. Lebo Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 11-4717-CML, AURORA LOAN SERVICES, LLC. vs. ESTHER R. LEBO owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, Pennsylvania, being 16 VALLEY STREET, CAR- LISLE, PA 17013-3143. Parcel No. 40-22-0489-077. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $141,- 179.46. 55 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, January 27, February 3, and February 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, Edit r SWORN TO AND SUBSCRIBED before me this da of Februar 2012 Notary NO (ARIAL 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. SHERIFF-S OFFICE CUMBERLAND COUNTY COURT DOUSE CARLISLE PA 17013 the patriot Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn accorcmg to law, deposes and says: That she is a Staff Accountant of The Patrot 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 statemen, 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 behalt of The Patriot-News Co. aforesaid by ? rtue 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: 01127/12 r 2011.4717 Civil Term Arrora Loan Services, LLC vs Esther R. Lebo Atty. Daniel Schmieg By virtue of a Writ of Execution NO. 114717-CIVIL AURORA LOAN SERVICES, LLC. VS. ESTHER R. LEBO owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 16 V EY STREET, CARLISLE, PA 17013 143 Parce No. 40-22-W9-077 (Acre, a or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $141,179.46 1 Sworn to and subscribed before me this 24 day of February. 2012 A D. Notary Public _ COMMONWEALTH OF PENNSYLVgNgA Notarial Seal theme 1 Owens, Notarv public Loftr My Commxton Twp' Dauphin County NOV. Ianir Q?ES . `` SSS?tLAT 02/03/12 02/10/12 PHELAN HALLINAN & SCHM John M. Kolesnik, Esq.,Id.No.308?1 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff VS. ESTHER R. LEBO Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 11-4717-CIVIL WITHDRAWAL OF APPEARANCE To the Prothonotary: Kindly withdraw my appearance on behalf of Plaintiff, AURORA LOAN SERVICES, LLC.. Date: Phelan Hallinan & Schmieg, LLP By: J OM. Kolesnik, Esq.,Id.No.308877 ttomey for Plaintiff PHS # 257044 By: FEDERMAN & ASSOCIATES, LLC Thomas M. Federman, Esq., ID No. 64068 Danielle Boyle-Ebersole, Esq., ID No. 81747 305 York Road, Suite 300 Jenkintown, PA 19046 (215) 572-5095 AURORA LOAN SERVICES, LLC ? 4 ANA COON e ATTORNEY FO> ' ANt m COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. NO. 11-4717 CIVIL ESTHER R. LEBO Defendant(s) CUMBERLAND COUNTY ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Federman & Associates, LLC on behalf of Aurora Loan Services, LLC as Plaintiff in the above-captioned matter. Date: ?-? Respectfully submitted, FEDERMAN & ASSOCIATES, LLC By. Thomas M. Federman, Esq. Danielle Boyle-Ebersole, Esq. Attorney for Plaintiff By: FEDERMAN & ASSOCIATES, LLC Thomas 1VI. Federman, Esquire, ID No. 64068 305 Yorl: Road, Suite 300 Jenkintown, PA I'a046 ATTORNEY FOR PLAINTIFF 21( 5) 572-5095 AURORA LOAN SER'JICES, LLC Plaintiff V ESTHER R. LEBO Defendant(s) COURT OF CGMMON PLEr~S CUMBERLAND~COUNTY No. 2011-1717 Civil ~ ,::;; .~ `.~ { _, PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF TO THE PROTHONOTARY: Kindly mark the judgment to the use of Wells Fargo Bank, National Association, not in its individual capacity, but solely as trustee for SRMOF 11 2011-1 Trust. Respectfully submitted, ,- Date: ~ ~ ' ---G ; -;~--,_~ FEDERMAN & ASSOCIATF;S, LLC ,- ~ - ~~ _ ___. . ~;W.--_ ... r~ B• 'Thomas M. Federman, Esq. .Attorney for plaintiff ~Q. 5 ca P A ~ rn/ ~~ ~.53a ~,~ a?$o2f 50 PRAECIPE FOR WRFC OF E7CtiCUTION MORTGAGE~;FORECLOSllRE COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND WELLS FARGO BANK, NATIONAL COURT OF COMMON PLEAS ASSOCIAT[ON. NOT IN ITS INDIVIDUAL CUMBERLANC- COUNTY OR BANKING CAPACITY, BUT SOLELY AS TRUSTEE FOR SRMOF 11 2011-1 TRUST Plaintiff V. Number 2011-4717-C[VIL ESTHER R. LEBO Defendant(s) PRAECIPE FOR WRIT C)F EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest -from 04/15/2011 to 3/6/2013 $10.35 ~~er diem $ 141,179..46 $ 7,162.20 (Costs to be added) a$ . 5o P ~ Am/ 5(o.Ob ~F~ 37. DO `~ 1D48.8g `~ 9a.oo `~ 10. Do '~ I~• 00 a~f.oo ~' ~• 50 " 9(p9.S9 - Po A~ _- ... >>; .R _. ~:^ .___ '~3' I~ L l THOMAS M. FEDERMAN, ESQUIRE: ID # 64068 DANIELLE BOYLE-EBERSOLE, ESQUIRE ID # 81747 305 York Road, Suite 300 Jenkintown, PA 19046 ~?IS~s~2-so9s Attorney for Plaintiff a . a 5 ~IV~ C~aSo~~.S-so 2~ a 8d 150 ~2E Gc~r~ f ~=~ All those certain two lots of ground situate in South Middleton Township, Cumberland County. Pennsylvania, -7x~re pa--ticularly described as follows: Beim. Lots No>. 17 and 18, Block "L'', of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page S~9_ said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North, a depth of 150 feet along the southern line of Lot No. 18. 1Block "L'" of saHd Plan on the South. and a width of 5.4 feet in the rear. Parcel No. 22-0489-0077-0000000-40 Being known as~ 16 Valley Street, Carlisle, PA ] 7013 BEING the carne premises that Carl E. Souders and Ardella F. Souders, husband] and wife, by Leed dated 2/20/1990 and recorded 12/20/1990 in the County of Cumberland (Book X34 /Page 542) granted and conveyed unto Esther R. l ebo, wido~a~. his/her heirs and assigns, in fee. FEDERPv1AN & ASSOCIATES, LLC. BY: TH~~MAS M. FEDERMAN, F,SQUIRE ID # 6406$ BY: DANIELLE BC-YLE-EBERSOLE, ESQUIRE ID # 81747 305 Yor[c Road, Suite 300 Jenkintown, PA 19046 ~2 15) 57"?_095 _ WELL5 FARGO BANK, N.gTIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL OR BANK[NG CAPACITY, BUT SOLELY AS TRUSTEE FOR SRMOF [ 1 20[ I-I TRUST Plaintiff V. ESTHER R. LEBO Defendant(s) Attorneys for Plaintiff COURT OF' COMMON PLEAS CUMBERLAND COUNTY Nurnber 201 ]-4717-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 The undersigned hereby certifies that he is the attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution vvas filed the following inforn~-ation concerning the real property located at: 16 Valley Street, Carlisle, PA 1 i'013, a copy of the description of said property is attached hereto and marked Exhibit "A". l . Name and address of Owners or Reputed Owners: Name Address Esther F.. Lebo, Inmate No~. OQ4 ] 09 SCI Muncy, Box 180, Route 405 Muncy, PA 17756 ?. Name and address of Defendants in the judgment: Name Address Esther R. Lebo, Inmate I'~Io. OQ4109 SCI Muncy, PO Box 180, Route 405 Muncy, PA 17756 ~. Name and last known address of every judgment creditor whose judgmer~it is a record lien on the real property to be sold: Name Address James L. Lebo 104 Channel Drive Carlisle, PA 1701 s Mary L. Lebo 104 Channel Urive Carlisle, PA ] 701 Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address Anna Mae Smith 1203 York Road Mechanicsburg, PA 17055 Mortgage Electronic Registrations P.O. Box 2026 Systems, Inc as nominee for Flint, MI 48501-21)26 Baltimore American Mortgage Corp. Inc. Mortgage Electronic Registrations 7484 Candlewood Road, Suites B~-.1 Systems, Inc as nominee for Hanover, Maryland 21076 Baltimore American Mortgage Corp. Inc. 5. Name and address of every other person who has any record lien on the property: Name Address South Middleton Township P.O. Bo~c 8 Municipal Authority Boilings Springs, PA 17007 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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 Tenant/Occupants Address 16 Valley Street Carlisle, PA ] 7013 Domestic Relations Section Cumberland County Courthouse P.O. Box 320 13 North Hanover Street Carlisle., PA 17013 Cormonwealth of PA Department of Publie Welfare P.O. Bo:x 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania 6th Floor, Strawberry Sq. Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Well-are P.O. Box: 8486 TPL Casualty Unit Estate Willow Oak Building Recovery Program Harrisburg, PA 17]05-8486 lJnited States of America c/o United States Attorney for the Western District of United S1.ates Post Office & Courthouse PA 700 Grant Street, Suite 4000 Pittsburgh, PA 15219 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Comronwealth of Harrisburg, PA 17128-]230 Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 280946 Harrisburg, PA 1 71 28-1 230 ATTN: Sheriffs Sales 8. Name and address of Attorney of record: NOT'J E [ verity that the statements made in this Affidavit are true and correct to the: best of my personal knowledge or information and belief. I unde-rstand that false statements herein are made subject to the penalties of 18 1?a.C.S. Section 4904 relating:. to unsworn falsification to authorities. ~, ~ Date: >,: ~<~ ~,~ ;~..._ Thomas M. Federman, Esquire C-anielle Boyle-Ebersole, Esquire All those certain two lots of ground situate in South Middleton Township, Cumberland Count.. Pennsylvania, more particularly described as fiollows: Being Luts Nos. 17 and 18. Block "L", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99. said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 fleet along Bolton Avenue on the North, a depth of 150 feet along the southern line of Lot No. 18, Block ``L'~ of said flan on the South. and a ~ti idth of 5.4 feet in the rear. Parcel No. 22~-0489-0077-0000000-40 Being known as_ 16 Valley Street, Carlisle, PA 170li BN ING the same premises that Carl E. Souders and Ardella F. Souders, husband and wife, by L)eed dated 12!'0/ 1990 and recorded l:Z/20/1990 in the ~ ounty of Cumberland (Book X34 %Page 542) granted and conveyed unto Fsthcr R, I ebo, widow, his/her heirs and assigns. in fee. FEDERMAN & ASSOCIATES, LLC BY: THOMAS M. FEDERMAN, ESQUIRE I LU #64068 BY: DANIELLE BOYLE-EBERSOL,E, ESQUIRE [D # 81747 305 York Road. Suite 300 Jenkintown, PA 19046 (215)72-5095 WELLS F'ARGO BANK, NATIONAL ASSOCIATION, NOT IN [TS INDIVIDUAL OR BANKING CAPACITY, BUT SOLELY AS TRUST}~E FOR SRMOF 11 2011-1 TRUST Plaintiff V. ES~THER R LEBO Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 20ll-4717-CIVIL CERTIFICATION TO SHERIFF Premises: l6 Vallee Street, Carlisle, PA 17013 `~ ~~ Book & Writ No. This certifies that the 3129 Affidavit for the above-mentioned property is correct, complete, and current to the date of filing the Praecipe for Writ of Execution, and accurate. This certifies that the Attorney on the Writ, upon demand, will substantiate information in the Affidavit and its inforrr~ation, and further This certifies that the Attorney on the Writ will indennnify the Sheriff of the City and County of Cumberland for any costs andior claims arising out of any and all inaccuracies in and/or failure to cure defects in said 3129 Affidavit. Fraudulent practice(s) on the part of the Plaintiff shall invalidate the sale. I further certify that my client, the plaintiff, has not engaged in any fraudulent practices with regards to this particular mortgage. Criminal prosecution may result from any fraudulent practices with regards to this particular mortga,~c. `~°' r / llated: _ { __ __ ""~ TEIOMAS M. FEDERMAN. F.SQUIKE DANIELLE BOYLE-EBERSOLE, ESQIRRE 305 York Road, Suite 300 Jenkintown, PA 19046 Certificate ~o the Sheriff COURT OF COMMON PLF,AS CUMBERLAND COUNTY WELLS FARGO SANK, NATIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL OR BANKING CAPACITY, SUT SOLELY AS TRUSTEE POR SR.MOF 1 i 2011-1 TRUST Number 2011-4717-C'IV[L Plaintiff V. ESTHER. K. LEBO Defendant(s) I HEREBY CER'i fFY THAT: L ll~e judgment entered in above matter is based on an action: ~ ) ~1. In Assumpsit (Cnntract) ( ) li. In Trespass (Accident) (X) C'_ In Mortgage Foreclosure ( ) I ). C)n a note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property 11. "~~he defi:ndants own the property being exposed to sale as. (X ; ~~. An individual ( ) B Tenants by Entireties ( ) C. Joint tenants with right of survivorship ~ ) IJ. A partnership f ) t:, l~cnants in Common 1 ) i~. ,h corporati~_>n IIf. "The defendants arc: (X) A Resident in the Commonwealth of Pennsylvania 13. Not resident in the Commonwealth of Pennsylvania t ) C_ If more than one defendant and either A or B above arc not applicable, state which defendants are residents in the Commonwealth of Pennsylvania. Re~idems This certiii~_arion must 6e signed by the attorney of record if an appearance has been entered: othcr~.cise certif7cati~~n must he signed b~° plaintiff. Name:_Federm~n,dk Associates. LLC Phone TJumber ~ i i) 572-~09~ Signature __ 1.;~~i __`~.=_,.: __ Address: Suite 300 305 York Road Jenkintown. PA 19046 FF,DER.MAN & ASSOCIATES. LLC BY: TI-IOMAS M. FEDERMAN, ESQUIRE ID #64068 BY: DANiELI_E BOYLE-EBERSOLE, ESQUIRE ID # 81747 30ti York Road. Suite 300 Jenkintown, PA 19046 ~_' 1 ?~5%2-095 -- -- WELLS F.ARGO BANK, NATIONAL ASSOCIATION, NOT IN [TS IND[VIDUAL OR BAIy~KING CAPACITY, BUT SOLELY AS TRUSTEE FOR S:RMOF 11 2011-1 TRUS"T" COURT OF COMMON PLEAS Plaintiff CUMBERLATJD COC1N~i'Y ~, ESTHER R. LEBO Number 201 l-4'717-CIVIL ~ °. . Defendant(s) .--r- ~~ AFFIDAVIT OF LAST KNOWN MAILING ADDRESS OF DEFENDANT(S~ .=- -~ The undersigned, attorney for Plaintiff in the within matter, being; duly sworn ~~" , - according to law. Hereby depose anal say that the last known mailing; address of the defendant(s) are: Esther R. Lebo, [nmate No. OQ4109 SCI Muncy, PO Box 1.80 '.Muncy. F'A 17756 DA7"E: FEDERMAI`J & ASSOCIATES, LLC ~ , :' } ~ _. Attorneys far Plaintiff THOMAS M. FEDERMAN, ESQUIRE DANIELLE BOYLE-EBERSOLF;, ESQU(RE~: SWORN "fU AND SUE3~CRIBED E3EFO~E MF; THIS _~ ~ i DAY OE .~~. , _ ~_• 2012 ~. ~-f ,~ .; NO"MARY PUd3LI,C ~ 7 ex~*woMwc~-.TM oF-s~a~.v NOTARIAL 3EAi. TIFFANY AI+IN+i Mc~tNTY, PubNc Jenkinbwn 8oro., Mongon~y Condon ExpKes 2, Z01 FEDERMAN & ASSOCIATES, LLC BY: THOMAS M. FEDERMAN, ESQUIRE ID X64068 BY: DANIELLE BO~YLE-EBERSOLE, ESQUIRE [D # 81741 30~ Yorl: Road_ Suite 300 Jenkintown, PA 19046 ~? 1 ~~57-•-~09~ - WEL,LS 1=ARG0 BAN''K, NATIONAL ASSOCIATION. NOT IN ITS INDIVIDUAL OR BANKING CAPACITY, BUT SOLELY AS TRUS~FEE FOR SRMOF I 1 201 1-1 ['RUST COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff \'. ES~TFIERR. LEBO Number 2011-41'17-CIVIL Defendant(s) CERTIFICATE The undersigned, 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 provision of act 9u because it is: O An FHA insured mortgage ONon-owners occupied ( )Vacant (X) Act 91/6 procedures have been fulfilled This. certification is made subject to the penalties of 18 PA. C.S. section 4904 relating to unswon~~ falsification to authorities. FEDERMAN & ASSOCIATES, LLC -„ ,. !~ ~ .___ . Attorneys fir Plaintiff "THOMAS M. FEDERMAN, ESQUIRE; f/ DANIELLE BOYLE-EBERSOLE, ESQUIRE ,, Dated: ~~ ~ ) ,: f ~~"_ /, f, FEDERMAN & ASSOCIATES, LLC BY: "THOMAS M. FEDERMAN, ESQUIRE ID #64068 BY: DANIELLE BOYLE-EBERSOLE, ESQUIRE 1D # 81747 305 York Road, Suite 300 Jenkintown. PA 19046 (? 15) 572-5095 WELLS FARGO BANk:, NATIONAL ASSOCIATION, NOT IN ITS INDIVIDUAL OR BANKING CAPACITY, BUT SOLELY AS TRUS~d'EE FOR SRIVIOF 11 2011-1 TRUST COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff ~.: ~ b'. _ a ESTHER R:. LEBO Number201]-4717-CIVIL t.~ Defendant(s) _...,,_ WAIVER OF WATCHMAN/WAIVER OF INSURANCE ANY DEPUTY SEIERIFF LEVYING UPON OR ATTACHING ANY PROPF,IE2TY UNDE?K WHICH WRI"f MAY LEAVE SAME WI"TROUT A WATCHEMAN, IN CUS"TODY OF WI{OWNER IS FOUND IN POSSESSION. AFTER NOTIFYING SUCH PERSONS OF SUCH LEVY OR A7~TACHMF.N"T, WITHOUT LEABAII,1'fY ON "I'HE PART OF SUCI-I DEPUTY OR "THE SHERIFF TO ANY PLAIN"TIFF HEREIN FOR ANY LOSS, DES"I'RUCTION OR REMOVI1_ OF .1NY SUCH PROEPRTY BEFORE SHERIFF'S SALE THEREOF; AND "fHE SHERIFF IS F[1',RFBY R}~:LF,ASED FROM ALL LIABILITY TO PROTECT THE PROPERTY DESCRIBED 1N "THE ABOVI~: EXECUTION BY INSURANCE, WHICH INSURANCE IS HEREBY WAIVED. FEDERMAN~i AS~;sOCIA3'ES, LLC ~ 4~ _ Attorneys for Plaintiff THOMAS M. FEDERMAN, I~SQU[RE f ~ DANIELLE BOYLE-EBERS~OLE, ESQUIRE Dated: ~: `~ r~..-.. FEDERMAN & A5SGCIATES, LLC BY: THOMAS M. 1FEDERMAN, ESQUIRE ID Y64068 BY: DANIELLE BOYLE-EBERSOLE, ESQUIRE 1D ~ 81 ?4i 305 York Road, Suite 300 Jenkintov~n, PA 19046 ~? 1 _>~_ ~7:?-5095 _. WELLS FARGO BANK, NATIONAL ASSOCIAT[ON. NOT IN ITS IND[~IIDUAL OR BANKING CAPACITY, BUT SOLELY AS TRUS~TE'E FOR SF:MOF 11 2011-I TRUST Plaintiff ES'1"HER R. LEBO COUK"I' OF' COMMON PLEAS CUMBERLAND coUN~rY Number 201 1-4717-CIVIL .., ---i f.:I ~"^ ~~ -_~ '_.,~r Defendant(s) NOTICE, OF SHF,RIFF'S SALE OF REAL PROPER"fY TO: I?S"I~fiGK K. LEBO Box 180 Route 405. SCf Muncv Inmate ~#OQ4109 Muncv, PA 17756 Your house (real estate) at 16 Valley Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on ~16J2013 at l 0:00 a.m. at the Cumberland County Courthouse, l Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $ 141,179.46 obtained by Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. 'The sale will be canceled if you pay to Plaintiff the back payrnents, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may cal I Federman & Associates, LLC, at (215) 572-5095. ~. You maybe able to stop the sale by filing a petition asking the Court to strike or open the .judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. ~. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) °• ~ YU~U MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND_YOU HAVE OTHER RIGHTS 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Federman & Associates, LLC, at (215) ~ 72-5095. ? You may be able to petition the Court to set aside the sale if the bid price was grossly inadequaxe compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Federran & Associates.. LLC, at (21 ~) 57:?-5095. ~. if the amount due from the buyer is not paid Ito the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. b. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for ;your real estate will be filed by the Sheriff within thirty (30) days of the sale. Thus schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting ~ofthe schedule of distribution. 7. You may also have other rights and defenses, ~or ways of getting your real estate back, if you act immediately after the sale. Y~)U 51 iOULD "I'AK:E TH1S PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A (,AWYER, GO "TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICt; CAN YROVIt~E YOU WITH tNFORMAT'ION ABOUT HIR[NG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVCI~f; YOU WITl1 INFORMATION ABOUT AGF,NCIF,S THA"F MAY OFFER LEGAL SFRVICF,S TO C~L[~~aIBLE PERSONS AT A REDUCED FEE FOR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717} 249-3166 (800 990-9108 .All those certain two lots of ground situate in South Middleton Township, Cumberland Count.-~, Pennsylvania, more pa--ticularl~ described as follows: Bein~~ lots Nos. 17 and 18. Block ``L'", of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3. Page 9~. said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North. a depth of 150 feet along the southern line of Lot No. 18, Block "L" of said Plan on the South. and a ~~idth of 5.4 feet in the rear. Parcel ?~o. ~'?-0=X89-00?7-0000000-40 Being known as: 16 Valle_Y Street, Carlisle, PA 17013 BE[NG the same premises that Carl E. Souders and Ardella F. Souders, husband and wife, by Geed dated 12/20! 1990 and recorded 12/20/ 1990 in the County of Cumberland (Book X34 /Page 542) granted and conveyed unto Esther R. Lebo, widow, his/her heirs and assigns, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMiV10NWEALT'H OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. I1-4717 Civil CIVIL ACTIC)N -LAW l 0 TI ifi SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, NATIONAL ASSOCIATION, Plaintiff (s) From ESTHER R. LEBO (l) You are directed to levy upon the property of the defendant (s)and ~[o sell SEE LEGAL. DESCRIPTION . (_'1 You are also directed to attach they property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnaishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is en~~,>ined from paving any debt to or for the account of the defendant (s) and fi-om delivering ,any property of the defendant (s) or otherwise disposing thereof; (=) ]f 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: $141,179.46 L.L.: Interest from 4/l5/] l to 3/6/13 @ $10.35 per diem -- $7,162.20 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $969.89 Other Costs: Plaintiff Paid: Date: 10/19/12 (Seal) RI~QUESTING PARTY: Name: THOMAS M. FEDERMAN, ESQUIRE Address: FEDERMAN & ASSOCIATES, LLC 305 YORK ROAD, SUITE 3(10 JENKINSTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-572-5095 Supreme Court ID No. 64068 David D. Buell, Prothonotar ~~-- Deputy SHERI��K��o�� Uo�� CUMBERLAND COUNTY FF'S" =, �~" " "~~~~ �=" ~~~~.~.�~~~. ~�~ ..~~- .~~'.~'- ' ' Ronny ��nderoon F|��0 FF{�� Sheriff � �F T�� p OT","��-` Jody SSmith ~ - Chief Deputy 2513 MAY -7 "M °; uco) Richard VVStewart CUMBERLAND Ty Solicitor mrp/csopr�s*~smpp PENNSYLVANIA Aurora Loan Semiceo LLC ' Case Number vs. | 2011-4717 Esther R. Lebo | SHERIFF'S RETURN OF SERVICE 11/01/2012 Entry of Appearance Of Thomas Federman, As Plaintiffs Atty, filed in Prothonotary's Office on 6/14/12. cab 11/01/2012 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: Esther R. Lebo, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Lycoming County to serve the within Real Estate Writ, Notice and Daocription, in the above titled action. according to law. 12/28/2012 02:58 PM -Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 16 Valley Street, Carlisle, PA 17013, Cumberland County. 01/18/2013 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: Esther R. Lebo, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, ou"Not Found"sd SCI [Nuncy. Box 180, Route 405, Muncy, PA 17756, defendant was paroled in May 2012, Left forwarding with SCI K8unoy of, 513BS. West Street, Carlisle, PA 17013. 01/25/2013 08:28 PM ' Deputy Shawn Harrison, being duly sworn according holaw, served the requested Real Estate VVht. Notice and Deocription, in the above titled action, by making known its contents and at the same time personally handing o true copy toa person representing themselves toba the Defendant, towit: Esther R. Lebo at5138S. West Street, Carlisle, PA17O13. Cumberland County. 03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to|aw, he exposed the within described pnami000 at public venue or outcry at the Cumberland County Courthouoa, 1 Courthouse Square, Cor|io|e, Cumbedad County, on March 6, 2013 at 10:00 o.m. He sold the same for the sum of$ 1.00 to Attorney Thomas Federman, on behalf of Wells Fargo Bank, National Aeouciation, not in its individual or banking capacity but solely an Trustee for GRN1OF ||. 2011'1 Trust, being the buyer in this execution, paid to the Sheriff the sum ofs SHERIFF COST: $924.44 SO ANSWERS, April 3O. 2O13 N[)NNYR ANDERSON, SHERIFF ' wr""m,o".ma.`w�f m- - r FEDERMAN & ASSOCIATES, LLC. BY: THOMAS M. FEDERMAN, ESQUIRE Attorneys for Plaintiff ID # 64068 BY: DANIELLE BOYLE-EBERSOLE, ESQUIRE ID# 81747 305 York Road, Suite 300 Jenkintown, PA 19046 (215)572-5095 WELLS FARGO BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,NOT IN ITS INDIVIDUAL CUMBERLAND COUNTY OR BANKING CAPACITY,BUT SOLELY AS TRUSTEE FOR SRMOF 11 2011-1 TRUST Plaintiff K Number 2011-4717-CIVIL ESTHER R.LEBO Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 The undersigned hereby certifies that he is the attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 16 Valley Street, Carlisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit"A". I. Name and address of Owners or Reputed Owners: Name Address Esther R.Lebo, Inmate No.OQ4109 SCI Muncy,Box 180,Route 405 Muncy,PA 17756 K 2. Name and address of Defendants in the judgment: Name Address Esther R. Lebo, Inmate No. OQ4109 SCI Muncy,PO Box 180,Route 405 Muncy, PA 17756 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 James L. Lebo 104 Channel Drive Carlisle, PA 17013 Mary L. Lebo 104 Channel Drive Carlisle, PA 17013 Cumberland County Adult Probation I Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address Anna Mae Smith 1203 York Road Mechanicsburg, PA 17055 Mortgage Electronic Registrations P.O. Box 2026 Systems, Inc as nominee for Flint, MI 48501-2026 Baltimore American Mortgage Corp. Inc. Mortgage Electronic Registrations 7484 Candlewood Road, Suites B-J Systems, Inc as nominee for Hanover, Maryland 21076 Baltimore American Mortgage Corp. Inc. 5. Name and address of every other person who has any record lien on the property: Name Address South Middleton Township P.O. Box 8 Municipal Authority Boilings Springs, PA 17007 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 7. Name and address of every other person of whom the plaintiff has r knowledge who has any interest in the property which may be affected by the sale: Name Address Tenant/Occupants 16 Valley Street Carlisle,PA 17013 Domestic Relations Section Cumberland County Courthouse P.O. Box 320 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania 6th Floor, Strawberry Sq. Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare P.O.Box 8486 TPL Casualty Unit Estate Willow Oak Building Recovery Program Harrisburg,PA 17105-8486 United States of America c/o United States Attorney United States Post Office &Courthouse for the Western District of 700 Grant Street, Suite 4000 PA Pittsburgh,PA 15219 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Commonwealth of Harrisburg, PA 17128-1230 Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 280946 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 8. Name and address of Attorney of record: NONE 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: ' / A� ,� �.... Thomas M. Federman, Esquire Danielle Boyle-Ebersole,Esquire All those certain two lots of ground situate in South Middleton Township,Cumberland County, Pennsylvania, more particularly described as follows: Being Lots Nos. 17 and 18, Block"L",of that certain Plan of Lots known as Carlisle Manor Extension,which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 3, Page 99, said lots having a frontage of 100 feet on Valley Street,a depth of 176.82 feet along Bolton Avenue on the North, a depth.of 150 feet along the southern line of Lot No. 18, Block"L"of said Plan on the South,and a width of 5.4 feet in the rear. Parcel No. 22-0489-0077-0000000-40 Being known as: 16 Valley Street, Carlisle, PA 17013 BEING the same premises that Carl E. Souders and Ardella F. Souders, husband and wife,by Deed dated 12/20/1990 and recorded 12/20/1990 in the County of Cumberland(Book X34/Page 542)granted and conveyed unto Esther R. Lebo, widow, his/her heirs and assigns, in fee. TO THE SHERIFF OF CUMBERLAND COUNTY: As the attorney for the Plaintiff,in the matter of Wells Fargo Bank,National Association,not in its individual or banking capacity but solely as trustee for the SRMOF 112011-1 Trust Loan Services,LLC,VS.Esther R.Lebo,Defendant(s),I submit the following information with the request that it be used,verbatim,FOR ADVERTISEMENT PURPOSES IN THE CUMBERLAND COUNTY NEWSPAPER AND SUCH OTHER NEWSPAPER OR NEWSPAPERS AS REQUIRED BY LAW, Date: THOMAS M.FEDERMAN,ESQUIRE DANIELLE BOYLE-EBERSOLE,ESQUIRE Attorney for Plaintiff BIOIIIIIIIII� i o xecution NQjWjjCIVIL issued out of the Court of Common Pleas of Cumberland County,PA,to me directed will be sold at z >.zg , i,prevailing time,in the Cumberland County Courthouse, I Courthouse Square,Carlisle,PA 17013 the following described Real Estate: All those certain two lots of ground situate in South Middleton Township,Cumberland County, Pennsylvania,more particularly described as follows: Being Lots Nos. 17 and 18,Block"L",of that certain Plan of Lots known as Carlisle Manor Extension, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania, in Plan Book 3,Page 99,said lots having a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North, a depth of 150 feet along the southern line of Lot No. 18,Block"L"of said Plan on the South,and a width of 5.4 feet in the rear. Parcel No. 22-0489-0077-0000000-40 BEING the same premises that Carl E. Souders and Ardella F. Souders,husband and wife,by Deed dated 12/20/1990 and recorded 12/20/1990 in the County of Cumberland(Book X34/Page 542)granted and conveyed unto Esther R.Lebo,widow,his/her heirs and assigns,in fee. LOCATION OF PROPERTY: 16 Valley Street,Carlisle PA 17013 Tax Map No.22-0489-0077-0000000-40 THE IMPROVEMENTS THEREON ARE:Residential dwelling SEIZED AND TAKEN IN execution as the property of Esther R.Lebo REAL DEBT:$ 141,179.46 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-4717 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,NATIONAL ASSOCIATION, Plaintiff(s) From ESTHER R.LEBO (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: $141,179.46 L.L.: Interest from 4/15/11 to 316113 @$10.35 per diem -- $7,162.20 Atty's Comm: % Due Prothy:$2.25 Atty Paid: $969.89 Other Costs: Plaintiff Paid: Date: 10/19/12 14ZL 0 David D. Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: THOMAS M.FEDERMAN,ESQUIRE Address: FEDERMAN&ASSOCIATES,LLC TRUE COPY FROM RECORD In Testimony whereot l here unto set my hand 305 YORK ROAD,SUITE 300 and the seal of said Coyrt at Cadiisie,Pa. JENKINSTOWN,PA 19046 This Dada of 20L2— Attorney for: PLAINTIFF P Prathonotary Telephone: 215-572-5095 Supreme Court ID No. 64068 z On October 31, 2012 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 16 Valley Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 31, 2012 By: Real Estate Coordinator I b' E(I 1�0 ZIOl i The Patriot-News Co. 2020 Technology Pkwy the atr1*ot*tXtws Suite 300 Mechanicsburg, PA 17050 NOW you know Inquiries - 717-255-8213 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 Marianne Miller, 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. 2011.47F1 This ad ran on the date(s)shown below: Aurora Loan' LLC va 01/22/13 Eether R.Lebo Atty: Thomas M.Federman 01/29/13 All those certain two lots of ground situate 02/05113 in South Middleton Tmnstop,Cumberland County, PumsyMnia, more particularly descnbed as follows. . . . . . . . . . . . . . . . . . . Being Lots Nos.17 and 18,Block'T,of that certain Plan of Lots]mown as Carlisle Manor Extension,which Plan is recorded Sworn to and s bscribed before me this 14 day of February, 2013 A.D. in the Office of the Recorder of Deeds in and for Cumberland County,Pennsybnnia, in Plan Book 3,Page 99,said lots having a frontage of 100 feet on Valley Street,a depth of 176.82 feet along Bolton Avenue bIIC on the North,a depth of 150 feet along the southern line of Lot No.18,Block"L"of said Plan on the South,and a width 9f.5.4 feet in the rear. Parcel No 22-0489.00774000000.40" COMMONWEALTH OF PENNSYLVANIA BEING the same premises that Carl E Souders and Ardena F.Souders,husband Notarial Seal and wife,by Deed dated =/1590 and Holly Lynn Warfel,Notary Public /20/1 recorded 12990 in the County of Washington Twp.,Dauphin County Cumberland(Book X34/Page 542)granted My Commission Expires Dec.12,2016 1 and conveyed unto Esther R.Lebo,widow, MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES t his/her heirs and assigns;in fee.. "f atri —Xtws Now you Know 2020 Technology Parkway STE 300 Mechanicsburg,PA 17050-9498 (717)255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT.# 2260 DUPLICATE BILL Date Description Sale# Size Rate Net Cost Of Ad 01/22/13 Sheriff Sale 4717 5.11 $20.00 $ 102.20 01/29/13 Sheriff Sale 4717 5.11 $20.00 $ 102.20 02/05/13 Sheriff Sale 4717 5.11 $20.00 $ 102.20 Notary Fee $5.00 TOTAL DUE FOR THIS SALE: $ 311.60 JLC k CUMBERLAND LAW JOURNAL Writ No. 2011-4717 Civil Aurora Loan Services,LLC VS. Esther R.Lebo Atty.:Thomas M. Federman All those certain two lots of ground situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly described as fol- lows: Being Lots Nos. 17 and 18,Block "L",of that certain Plan of Lots known as Carlisle Manor Extension,which Plan is recorded in the Office of the Recorder of Deeds in and for Cum- berland County, Pennsylvania, in Plan Book 3,Page 99,said lots hav- ing a frontage of 100 feet on Valley Street, a depth of 176.82 feet along Bolton Avenue on the North,a depth of 150 feet along the southern line of Lot No. 18,Block"L"of said Plan on the South,and a width of 5.4 feet in the rear. Parcel No. 22-0489-0077- 0000000-40. BEING the same premises that Carl E. Souders and Ardeila F. Souders, husband and wife, by Deed dated 12/20/1990 and re- corded 12/20/1990 in the County of Cumberland (Book X34 /Page 542) granted and conveyed unto Esther R. Lebo, widow, his/her heirs and assigns,in fee. 77 Y r 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 25, February 1, and February 8, 2013 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. isa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this da of Februga, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 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 Wells Fargo Bank as Trustee for SRMOF 112011-1 Trust is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the 19th day of October,A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 4717, at the suit of Wells Fargo Bank as Trustee for SRMOF II 2011-1 Trust against Esther R. Lebo is duly recorded as Instrument Number 201314819. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this �-� day of A.D. c 1) 7 Recorder of Deeds Recorder of Dieds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan,2014