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Home My WebLink About11-5108HE LOF PROTHONOTARY 1011 JUN 21 PM 1: 06 CUMBERLAND COUNTY PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank 1100 Wehrle Drive Williamsville, New York 14221 V. Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number l (. Sl UO ojh CIVIL ACTION/MORTGAGE FORECLOSURE arv4 %cl960 pa `A Ck.* 1y19-13 oL 9U07q ? NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 CIVEL ACTION/MORTGAGE FORECLOSURE Plaintiff is M&T Bank, duly organized and doing business at the above-captioned address. 2. The Defendant is Cathy A. Brookhart, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1911 Spring Road, Carlisle, Pennsylvania 17013. 3. On November 22, 2002, Cathy A. Brookhart made, executed and delivered a mortgage upon the premises hereinafter described to M&T Mortgage Corporation which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1784, Page 3371. 4. The aforesaid mortgage was thereafter assigned from M&T Mortgage Corporation to M&T Bank, by Assignment of Mortgage, to be duly recorded in the Office of the Recorder of Cumberland County. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 1911 Spring Road, Carlisle, Pennsylvania 17013. The mortgage is in default because monthly payments of principal and interest upon said mortgage due August 1, 2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $ 76,326.47 Interest through May 1, 2011 $ 4,452.40 (Plus $14.64 per diem thereafter) Attorney's Fee $ 1,300.00 Late Charges $ 31.37 Corporate Advance $ 429.59 Escrow Advance $ 619.12 GRAND TOTAL $ 83,158.95 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $83,158.95, together with interest at the rate of $14.64 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBTRC- ONWAY,P.C. BY: Kevin T. uai . Attorney for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBkRt AND- ONWAY,P.C. BY: Kevin uaif E: Attorney )6r Plaintiff M&T Bank v. Cathy A. Brookhart ?. _ J t I, t k L. ?t and be limifed I i at line Lewis ' miniltei i line of and five E by said Hundre t the Ea: ( Seventh I as and i i{ 13EING the Deed cfat'ed BARRY L. I r t Is: Ce I, 1 F r i SCHEDULE C Legal Description Number. 1160 EA48 1LL THAT CERTAIN tract of land, with improvements thereon erected, situate, lying 1g in North Middleton Township, Cumberland County` Pennsylvania, bounded and is follows, to wit: i IEGINNING at a pin on the Eastern line of Pennsylvania. State Highway Route No. 34 f land formerly of Herbert L. Meals and Mary E. Meal's,,his wife, now or formerly of dwart Swartz; thence by land now or formerly of said Swartz, North 72 degrees 21 East, Two Hundred Twenty-five and Fifty-five Hundredths (225.55) feet to a stake at ind of Eugene C. Nickel; thence by said latter land, South 19 degrees East, Eighty-one tenths (81.5) feet to a stake at line of lands now or formerly of George E. Henry; thence latter lands, South 72 degrees 54 minutes West, Two 114undred Sixty-eight and Five the (268.05) feet to a stake in the Eastern line of the afor6gaid State Highway; thence by em line of said state highway, North 9 degrees 33 m'? utes East, Eighty-eight and five Hundredths (88.75) feet to a pin, the place of BEGI?N131TG. above described premised having thereon erected a { type dwelling house known tiered 1911 Spring Road, Carlisle, Pennsylvania. me premises which BARRY L. BROOKHART AND CATHY A OROOKHART, by Special Warranty une 20, 1996, and recorded June 21, 1996, in Book 141, PAge 384, granted and conveyed unto t00KHART AND CATHY A. BROOKHART, In fee. BARRY L. BROOKHART AND CATHY A. HIS WIFE, by deed dated November 2002 granted and conveyed to CATHY A. and recorded in Record Book Page I 7( In through the office of: MCKNIGHr & HUGHES 'omfret Professional Bldg L, PA 77013 Bff 7:8#PG3381 ST ,Ajfy this to be recorded I mbcrland County PA tIl ?" Recorder of Deeds WART TITLE )ARANTY COMPANY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor FILED-OFFICE OF THE PROTNONOT3R' 20I1 JUL -7 PM ?: 43 CUMBERLAND COUN PENNSYLVANIA M & T Bank vs. Case Number . Cathy A. Brookhart 2011-5108 SHERIFF'S RETURN OF SERVICE 06/30/2011 07:09 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 30, 2011 at 1909 hours, he served a true copy of the within Complaint in Mort ga 0reclosure, upon the within named defendant, to wit: Cathy A. Brookhart, by making known unto her If ersonally, at 1911 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013 its co is rd a the same time handing to her personally the said true and correct copy of the same. f? ,DEPUTY SHERIFF COST: $34.00 July 01, 2011 SO ANSWERS, RONN'rY R ANDERSON, SHERIFF y McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorneys for Plaintiff ILLID-OrI 'ICE .3 E PFi TI- 000 TAR'i 2,1711 h"s 15 rim 11: 14 '. LI MSERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-5108 civil ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal interest from 05/02/11 to 08/10/11 $ 83,158.95 $ 1,478.64 Total $ 84,6 7.59 rw ,, TERRENCE J. McCA , ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE Q b i400 Pa a*? MARGARET GAIRO, ESQUIRE (4 , ?S ANDREW L. MARKOWITZ, ESQUIRE CSC.' HEIDI R. SPIVAK, ESQUIRE e1 V 3? 3$ MARISA J. COHEN, ESQUIRE ' KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorneys for Plaintiff AND NOW, this 1.5 day of 2011, Judgment is entered in favor of Plaintiff, M&T Bank, and against Defendant, Cathy A. Brookhart, and damages are assessed in the amount of $84,637.59, plus interest and costs. BY THE PR HON j 1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (2151790-1010 M&T Bank Plaintiff Cathy A. Brookhart Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-5108 civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Cathy A. Brookhart, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Cathy A. Brookhart, is over eighteen (18) years of age, and reside as follows: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 SWORN AND SUBSCED AY BEFORE ME THIS W 'DAY OF 'k , 2011 w NOTARY PUBLIC COMM[3NWEALTH OF PENNSYLVANIA NOTARIAL :delh AL Maleekah Wiiltbanks- Public city of Philadelphia, PhilaCounty MY CUMMJ:,, N Pl[iE6, 2015 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-5108 civil AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFORE E THIS i AY OF lc S , 2011 NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Maleekah Wiltbsnks-Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES APR. 06, 2015 EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorneys for Plaintiff / U? C ? ? I iWkl TERRENCE J. Mc A E, QUIRE MARC S. WEISBERG, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-5108 civil CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSCWED BEFORE .ME THI ' AY OF Avil S , 2011 NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA EMaleeekah iiIAL SEAL lltbanks-Notary Public elphiz, Phila ielphia County ION EXPRCS APR. 06, 2015 r TERRENCE J. MCCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRE CE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE HEIDI R. SPIVAK, ESQUIRE MARISA J. COHEN, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE BRIAN T. LaMANNA, ESQUIRE Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary July 22, 2011 To: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 M&T Bank Cumberland County Vs. Court of Common Pleas Cathy A. Brookhart Number 11-510$ civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W [TROUT 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. '171IS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFOR D TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800)990.9108 la 67&9 2-(,, NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PEIMNALMENTE O FOR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTTFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DRRECHOSIMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. ST USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDF. PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACICIN ACERCA DE LAS AGENCIES QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Ponnsylvania 17013 (800) 990-9m BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE emm -AI. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 M&T Bank V. Cathy A. Brookhart COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY Defendant No. 11-5108 civil NOTICE been tered ' e above ing Pursuant to Rule 236, you are hereby notified that a Jjr0otaiy as indicated below. /<< x Judgmen t by Default - Money Judgment - Judgment in Replevin - Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conwu, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 11-5108 civil Civil Term c7 4' M&T Bank C C= V. AMOUNT DUE: $84,637.59 rnw 33m. M X'M :U C G7 Mi= -p rn Cathy A. Brookhart INTEREST: from 08/11/11 cnr" w mp $1,641.38 at $13.91 r--z o + --{cam ATTY'S COMM.: C-n zi?, zn COSTS: b z N qM --i CS CO M TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contrac t, or acc ount based on a confession of judgment, but if it does, it is based on the appropriate original proceeding fi led purs uant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 1911 Spring Road, Carlisle, Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: August 25. 2011 Signatur O Name: Christine L. Graham, uiTe- Print 4 4a? •oo P10 ?/ Firm: MCCABE, WEISBERG AND CO 34. CO 0_6FF Address: 123 S. Broad Street, Suite 2080 44. 00 " Philadelphia, PA 19109 Attorney for: Plaintiff 1 0.00 f; Telephone: (215) 790 1010 °?'$O Supreme Court ID No. 309480 J&&,50 -PO Am/ el 14-81100 5o LL IN THE UNITED STATE BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CATHY A. BROOKHART, Debtor CHAPTER 13 CASE NO. 1:08-bk-03829 MDF M&T BANK, Movant V. CATHY A. BROOKHART, Respondent ORDER GRANTING RELIEF FROM THE AUTOMATIC STAY UPON CONSIDERATION of the Motion for Relief from the Automatic Stay filed by M&T Bank, and Debtor's Answer thereto, the Motion is GRANTED; and it is hereby: ORDERED that the automatic stay is terminated effective ninety (90) days from the date of this Order. By the Court, A do-?-M04?? 17M Date: December 21, 2010 ' Chef 8 4t'Y (ARP) Case 1:08-bk-03829-MDF Doc 80 Filed 12/21/10 Entered 12/22/1014:33:52 Desc Main Document Page 1 of 1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-5108 civil AFFIDAVIT PURSUANT TO RULE 3129 C o co m zr- w 'O rn :ci -<i' o tO D = z _X C) D? ? t- yr?n -r Q D -.; co .-J -C The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1911 Spring Road, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Members 1 st Federal Credit Union 5000 Louise Drive Mechanicsburg, Pennsylvania 17055 Name and address of every other person who has any record lien on the property: Name PA Department of Revenue Address Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Barry L. Brookhart c/o Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Address 1911 Spring Road Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. August 25, 2011 Christine L. Graham, squire DATE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff Cathy A. Brookhart V. Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-5108 civil Cl) rn chr- z= ?D r--z z C' O 2 AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. c G'7 w O -v x N co c?-y a rri- -orn GT C) -n a ii A The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 SWORN AND SUBBED BEFO ME THI DAY O , 2011 W f /V ! / `(, C/ jjj TARY DUBLIC GppANlptrWBALTH OF rI?NPI `? NOTARIAL SEAL STACEY M. OCONNELL, Notary Pubk CRY of Philadelphia, Phils, County Comm+ssian Expires My 10,'1b92 Christine L. Graham, quire Attorney for Plaintiff N McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW M&T Bank V. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Cathy A. Brookhart I Number 11-5108 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 C) C -vco e xrn ;7 CA D _ C") rv c low W 'v z O co f? "*t r*tr= -Orn ? o --s° z CD -n o? D Your house (real estate) at 1911 Spring Road, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $84,637.59 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to M&T Bank the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. if the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, with improvements thereon erected, situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows, to wit: BEGINNING at a pin on the Eastern line of Pennsylvania State Highway Route No. 34 at line of land formerly of Herbert L. Meals and Mary E. Meals, his wife, now or formerly of Lewis Edwart Swartz; thence by land now or formerly of said Swartz, North 72 degrees 21 minutes East, Two Hundred Twenty-five and Fifty-five Hundredths (225.55) feet to a stake oat line of land of Eugene C. Nickel; thence by said latter land, South 19 degrees East, Eighty-one and five tenths (81.5) feet to a stake at line of lands now or formerly of George E. Henry; thence by said latter lands, South 72 degrees 54 minutes West, Two Hundred Sixty-eight and Five Hundredths (268.05) feet to a stake in the Eastern line of the aforesaid State Highway; thence by the Eastern line of said state highway, North 9 degrees 33 minutes East, Eighty-eight and Seventy-five Hundredths (88.75) feet to a pin, the place of BEGINNING. The above described premised having thereon erected a ranch type dwelling house known as and numbered 1911 Spring Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restrictions and conditions as now appear of record. RB5678 1911 Spring Road, Carlisle, Pennsylvania 17013. BEING the same premises which BARRY L. BROOKHART AND CATHY A. BROOKHART, HIS WIFE by deed dated November 22, 2002 and recorded November 27, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 254, Page 3673, granted and conveyed to Cathy A. Brookhart in fee. TAX MAP PARCEL NUMBER: 29-17-1585-080 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-5108 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK, Plaintiff (s) From CATHY A. BROOKHART (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: $84,637.59 Interest from 8/11/11 @ $13.91 -- $1,641.38 L.L.: $.50 Atty's Comm: % Atty Paid: $1.66.50 Plaintiff Paid: Date: 8/30/11 (Seal) Due Prothy: $2.00 Other Costs: David D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name: CHRISTINE L. GRAHAM, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 309480 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 346$, MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 1 i; i 7'E R L AN D C 0 u N 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-5108 civil AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 19th day of October, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS 9C)VK DAY OF NC , 2011 NOTARY TUBLIC e I McCABE, WEISBERG WAY P.C. Attorneys for Plaintif;A `----?- By: v TERRENCE J. cCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-5108 civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 1911 Spring Road, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owner or Reputed Owner Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Members 1 st Federal Credit Union Address 5000 Louise Drive Mechanicsburg, Pennsylvania 17055 5. Name and address of every other person who has any record lien on the property: Name Commonwealth of Pennsylvania, Department of Revenue Address Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Barry L. Brookhart c/o Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Address 1911 Spring Road Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. October 19, 2011 Attorneys for Plaintiff DATE By: TERRENCE cCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN T. McQUAIL, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank Plaintiff V. Cathy A. Brookhart Defendant DATE: October 19, 2011 COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-5108 civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Cathy A. Brookhart PROPERTY: 1911 Spring Road, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on December 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thiry (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. o -m ?cnw 0~ b Z 6 I ?a ck, N 9 ! L , E a w C L7 w ?? Q31INr, ,_. x .5 ¢'? s s d o? ° E °? 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L 6a 7V2 .+ q v? G GJ i e> > C C? ?+ a+OO~ . U N d, yy'L Q? r?+ V2 r+ Z ?" ? A4 OW y w L 0 COW. w q d CAW C ++ 60 bAy V zrA a> C/2 L0, rS a ?uN= C. V omen a ka CO'?sp i" C%]?;A?? p w +?? ?? V2 y 0 C u rA y oD?? j ,Cea?EM?? ydCOy 'bq= ?cC e^ y?AW.q > Cc LF o v caFF . C? u CC= r ow as o E £0 CC cm C O ? "? i" p oe00 aS q?C/?O eC C?V2 0 ? vxvx? p 3x?w =ua;U - 3NV2 ZZel u u C.? Q O•V O w0.. a.. o •o ? u [-a d a O d 'fl u ? 7 a z ,? Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY f ` ! ? V i M & T Bank Case Number vs. Cathy A. Brookhari 2011-5108 SHERIFF'S RETURN OF SERVICE 09/29/2011 11:30 AM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Cathy A. Brook'iart at 1911 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 10/07/2011 Valarie Weary, Deputy, 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 191 Spring Road, Carlisle, Cumberland, County on 9/29/11 at 1120 hrs. 12/07/2011 Ronny F; Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been (riven according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pa. on December 7, 2011 at 1000 a.m. He sold tl e same for the sum of $1.00 to Attorney Terrance McCabe, on behalf of Federal National Mortgage Association at 1900 Market Street, #800, Philadelphia, PA 19103, oeing the buyer in this execution, paid to the Sheriff the sum of $927.24. 01/12/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. SHERIFF COST' $127.24 SO ANSWERS, January 13, 2012 RON R ANDERSON, SHERIFF d -1/:_' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRE;NCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE: - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDII R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff M&T Banl.: CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Cathv A. Brookhart Defendant NO: 11-5108 civil AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1911 Spring Road, Carlisle, Pennsylvania 1701 as of the date the Praecipe for the Writ of Executior; was filed. A copy of the description of said property being attached hereto. t. Name and address of Owner or Reputed Owner Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Cathy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 7. Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, Pennsylvania 17055 Name and address of every other person who has any record lien on the property: Name PA Department of Revenue Address Bureau of Compliance P.O. Box 281230 Harrisburg, PA' 7128-1230 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 Barry L. Brookhart c/o Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Address 1911 Spring Road Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenu. Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 31 1 Scranton. PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information ,and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. d August 25, 2011 Christine L. Graham, squire DATE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW M&T Banl: V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Cathy A. Brookhart ?JI Number 11-5108 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Cagy A. Brookhart 1911 Spring Road Carlisle, Pennsylvania 17013 Your house (real estate) at 1911 Spring Road, Carlisle., Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on December 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland. County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of 584,637.59 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to M&T Bank the back payments, late charges, costs, and reasonable attorney's fees due. To fmd out how much you must pay, you may call McCabe, Weisberg and Conway, P. C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling; McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten 10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL, SERVICE Cumberland County Bair Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, with improvements thereon erected, situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows, to wit: BEGINNING at a pin on the Eastern line of Pennsylvania State Highway Route No. 34 at line of land formerly of Herbert L. Meals and Mary E. Meals, his wife, now or formerly of Lewis Edwart Swartz; thence by land now or fora erly of said Swartz, North 72 degrees 21 minutes East, Two Hundred Twenty-five and Fifty-five Hundredths (225.55) feet to a stake oat line of land of Eugene C. Nickel; thence by said latter land, South 19 degrees East, Eighty-one and five tenths (81.5) feet to a stake at line of lands now or formerly of George E. Henry; thence by said latter lands, South 72 degrees 54 minutes West, Two Hundred Sixty-eight and Five Hundredths (268.05) feet to a stake in the Fastern line of the aforesaid State Highway; thence by the Eastern line of said state highway, North 9 degrees 33 minutes East, Eighty-eight and Seventy-five Hundredths (88.75) feet to a pin, the place of BEGINNING. The above described premised having thereon erected a ranch type dwelling house known as and numbered 1911 Spring Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restrictions and conditions as now appear of record. RB5678 19' l Spring Road, Carlisle, Pennsylvania 17013 BEING the ;anie premises which BARRY L. BROOKHART AND CATHY A. BROOKHART', HIS WIFE by deed dated November 22, 2002 and recorded November 27, 2002 in the office of the Recorder in and for Cumberland County in Deed Book 254, Page 3673, granted and conveyed to Cathy A. Brookhart in fee. TAX MAP 1'ARCEL NUMBER: 29-17-1585-080 WRIT OF EXECUTION and/or ATTACHMENT COMM(--) ;WEALTH OF PENNSYLVANIA) COUN-'Y OF CUMBERLAND) rd . Buell, Prothonotary David- TO TH': , SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK, Plaintiff (s) From CATHY A. BROOKHART (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (21 Y( a are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to ratify the garnishee(s) that: (a) an attachment has been issued; (b;) the garnishee(s) is enjoined from paying iny debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or wherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachrent is found in the possession of anyoie other than a named garnishee. you are directed to notify him/l.er that he/she has been added as a garnishee and is enjoined as above stated. Amoun Due: $84,637.59 Interest from 8/1.1/11 @ $13.91 -- $1,641.38 Attv's ( onim: % Atty Paid $166.50 Plaintif "F'aid: L.L.: S.50 Due Prothy: $2.00 Other Costs: Date: 8'30/11 (Seal) REQUfSfING PARTY: Name: CHRISTINE L. GRAHAM, ESQUIRE Addres,: NICCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorne?? tor: PLAINTIFF Teleph<,ne: 215-790-1010 Suprem ..-'..ourt ID No. 309480 NO 11-5108 Civil CIVIL ACTION -- LAW Deputy TRUE COPY FROM RECORD In Testimony whereof, l here unto set my hand and the seal of sold at Ca LW% Pa. IL of zo 1L__ On August 31, 201 1 the Sher°it'l levied upon the defendant's interest in the real property situated in North Middleton Township, k;umberland County, PA, Known and numbered as, 91 1 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 31, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-5108 Civil M & T Bank vs. Cathy A. Brookhart Atty.: Terrance McCabe ALL THAT CERTAIN tract of land, with improvements thereon erected, situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows, to wit: BEGINNING at a pin on the East- ern line of Pennsylvania State High- way Route No. 34 at line of land for- merly of Herbert L. Meals and Mary E. Meals, his wife, now or formerly of Lewis Edwart Swartz; thence by land now or formerly of said Swartz, North 72 degrees 21 minutes East, Two Hundred Twenty five and Fifty five Hundredths (225.55) feet to a stake oat line of land of Eugene C. Nickel; thence by said latter land, South 19 degrees East, Eighty one and five tenths (81.5) feet to a stake at line of lands now or formerly of George E. Henry; thence by said latter lands, South 72 degrees 54 minutes West, Two Hundred Sixty eight and Five Hundredths (268.05) feet to a stake in the Eastern line of the aforesaid State Highway; thence by the Eastern line of said state highway, North 9 de- grees 33 minutes East, Eighty eight and Seventy five Hundredths (88.75) feet to a pin, the place of BEGINNING. The above described premised having thereon erected a ranch type dwelling house known as and num- bered 1911 Spring Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restric- tions and conditions as now appear of record. RB5678 1911 Spring Road, Carl- isle, Pennsylvania 17013. BEING the same premises which BARRY L. BROOKHART AND CATHY A. BROOKHART, HIS WIFE by deed dated November 22, 2002 and re- corded November 27, 2002 in the office of the Recorder in and for Cum- berland Count} in Deed Book 254, Page 3673, granted and conveyed to Cathy A. BrooICiart in fee. TAX MAP PARCEL NUMBER: 29 17 1.585 080. 22 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire., Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: _ October 21, October 28, and November 4, 2011 Af6ant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that lie is not interested in the subject matter of 'he aforesaid notice or advertisement, and that all allegations in the foregoing statement; as to time, place and character of publication are true. //?I,i a Marie Coyne, ditor L/ SWORN TO AND SUBSCRIBED before me this -: - day of November, 2011 Notary NOTARIL" OEBCRAH A COLLINS Notary Public ECARLISLE BOROUGH, CUMBERLAND COUN i t' ommission Expires Apr 28, 2014 20115106 CIVU Term M & T Bank Vis Caft A. llrookhert AIty: 7irrance McCabe ALL THAT CERTAIN tract of land, with improvements thereon erected, situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows, to wit: BEGINNING at a pin on the Eastern line of Pennsylvania State Highway Route No. 34 at line of land formerly of Herbert L. Meals and Mary E, Meals, his wife, now or formerly of Lewis Edwart Swartz; thence by land now or formerly of said Swartz, North 72 degrees 21 minutes East, Tfvo Hundred Twenty five and Fifty five Hundredths (225.55) feet to a stake oat line of land of Eugene C. Nickel; thence by said latter land, South 19 degrees East, Eighty one and five tenths (81.5) feet to a stake at line of lands now or formerly of George E. Henry; thence by acid latter lands, South 72 degrees 54 minutes West, Tivo Hundred Sixty eight and Five Hundredths (268.05) feet to a stake in the Eastern line of the aforesaid State Highway; theme by the Eastern line of said state highway, North 9 degrees 33 minutes East, Eighty eight and Seventy fivgHundredths (88.75) feet to a pin, the place of BEGINNING. The above described premised having thereon erected a ranch type dwelling house known as and numbered 1911 Spring Road, Carlisle, Pennsylvania. TINDER AND SUBJECT to restrictions and conditions as now appear of record. RB56781911 Spring Road, Carlisle, Pennsylvania 17013. BEING the same premises which BARRY L. BROOKHARP AND CATHY A. BROOKHARL HIS WIFE by deed dated November 22, 2002 and recorded November 27, 2002 in the office of the Rec,rder in and for Cumberland County in Deed Book 254, Page 3673, granted and conveyed to Cathy A. Brookhart in fee. TAX MAP PARCEL NUMBER: 2917 1585080 r -The Patriot-News Co. ry 2020 Technology Pkwy Suite 300 Mechanicsburg,, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the'Pidtr1oi1-ltiews NOVr you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-Neivs 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, 1654, 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 ieithor she nor said Company is interested in the subject matter of said printed notice or advertising, and that all o?r 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 bendli of The Patriot-views Co. aforesaid by virtue and pursuant to a resolution unanimously passed an J1 ddt pted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office fDr they Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PC!BLICATION COPY This ad ran on the date(s) shown below: 10/21/11 10128/11 11/04111 -?- r Y c Sworn to and.SuPscribed before me thi*16 cj9,y6n ovember, 2011 A.D. z- r Notary-Public COMMONWEALTH Of' PENNSYLVANIA i Notarial !ieal Sherrie L. Owens, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIE! ehe I)atriot-Mms Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle PA 17013 ACCT.# 2260 DUPLICATE BILL JLC TOTAL DUE FOR THIS SALE: $ 300.92 McCABE, WEIISBERG AND CONWAY, P.C BY: TERRIENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE; - ID # 17616 EDANA.RD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank V. Plaintiff I COURT OF COMMON PLEAS CUMBERLAND COUNTY Cathy A. Brookhart Defendant No. 11-5108 civil ASSIGNMENT OF BID AT SHERIFF'S SALE M& I- Bank, was the successful bidder at the Sheriffs Sale conducted by the Sheriff of Cumberland County on the 7th day o''December, 2011. M& I Bank, hereby assigns its bid for $1.00 and other valuable consideration to Federal National Mortgage Association, without recourse for the property known as 1911 Spring Road, Carlisle, Pennsylvania 17013, 13y: Kevin T. cQuail, Esquire Attorney for Plaintiff COMMONWI:=ALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND f SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 7 day of December A.D., 2011, under and by virtue of a writ Execution issued on the ?0 day of August, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2111 Number 5108, at the suit of M & T Bank against Cathy A. Brookhart is duly recorded as Instrument Number 201202271. IN TESTIMONY WHEREOF, I have hereunto set my hand and,jeal of said office this __ daY of r. Q f Recorder of Deeds :4 d: ?rrLer acid County, Carlisle, PA Y°NiQ1 : pl:NS the Firs', Monday of Jan. 2014