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HomeMy WebLinkAbout11-6002 =rn r l <> CO ? r ? ? c.i ° N CD f, , ^'L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC Bank, National Association, Plaintiff, CIVIL DIVISION NO. Il - (o00a Civil Tern COMPLAINT IN MORTGAGE FORECLOSURE vs. Jose L. Vega, Jr. and Dana L. Miller, Defendants. TO DEFENDANT(S): YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT IN MORTGAGE FORECLOSURE WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. By: /S/ . to id V. Viii Attorney for Plaintiff MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Lois M. Vitti, Esquire PA I.D. #209865 Vitti & Vitti & Associates, P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 -*qa-DO fl0 ATTy ou sq 0 a?agS( PNC Bank, National Association, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. Jose L. Vega, Jr. and Dana L. Miller, No. Defendants. COMPLAINT IN MORTGAGE FORECLOSURE 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 THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OWECTIONS 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 SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON 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, PA 17013 1-800-990-9108 (717) 249-3166 COMPLAINT IN MORTGAGE FORECLOSURE NOW, comes the Plaintiff by its attorneys, Vitti & Vitti & Associates, P.C. and Lois M. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a national association having a principal place of business located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is the holder of the mortgage and is seeking enforcement of the mortgage through foreclosure. 2. The Defendant(s) is/are individuals with a last known mailing address of 391 Stonehedge Lane, Mechanicsburg, PA 17055. The property address is 391 Stonehedge Lane, Mechanicsburg, PA 17055 and is the subject of this action. 3. On the 27th day of July, 2004, in consideration of a loan of One Hundred Eighteen Thousand Nine Hundred Forty Seven and 00/100 ($118,947.00) Dollars made by National City Mortgage Co. to Defendant, the said Defendant executed and delivered to National City Mortgage Co. a "Note" secured by a Mortgage with the Defendant as mortgagor and National City Mortgage Co., as mortgagee, which mortgage was recorded on the 29th day of July, 2004, in the Office of the Recorder of Deeds of Cumberland County, at Book No. 1875 Page No. 1508. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. The Plaintiff is successor by merger to National City Real Estate Services LLC, which was successor by merger to National City Mortgage, Inc, which was formerly known as National City Mortgage Co. 4. The premises secured by the mortgage are: SEE EXHIBIT 'A "ATTACHED HERETO. 5. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attorney's fees." 6. Since February 1, 2011, the mortgage has been in default by reason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagee's intention to foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the mortgagor(s). 8. The amount due on said mortgage is itemized on the attached schedule. 9. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases from liability for the debt secured by the mortgage any mortgagor, personal representative, heir or devisee of the mortgagor who is not a real owner of the property at the time of the filing of this Complaint. WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff demands judgment for the amount due of One Hundred Twenty Two Thousand Ninety and 99/100 ($122,090.99) with interest and costs. Ily VrM KVgV J4 ASSOCIATES, P. C. BY: Lois fh,Vitff, Esquire Attorney for Plaintiff SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance 108,289.19 Interest @ 6.2500% from 01/01/11 through 7/31/2011 3,912.50 (Plus $18.5427 per day after 7/31/2011 ) Late charges through 7/25/2011 0 months @ 38.60 Accumulated beforehand 154.40 (Plus $38.60 on the 17th day of each month after 7/25/2011 ) Attorney's fee 5,414.46 Escrow deficit 4,320.44 (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) BALANCE DUE 122,090.99 EXHIBIT "A" LEGAL DESCRIPTION EXHIBIT "A" ALL that certain Unit, being Uait No. 391 (the "Unit'), of Stonehedge, A Townhome Condominium (the "Condominium"), located in Upper Allen Township. Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Stonehedge, A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds in Miscellaneous Book 681, Page 4605 and Right of Way Plan Book 12, Page 142 respectively, together with any and all amendments thereto. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid Declaration of Condominium, as last amended. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to any and all covenants. conditions, restrictions, rights-of-way, easements and agreements ofrocord is the aforesaid Office, the aforesaid Declaration of Condominium, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. I Certify this to be recorded In Cumberland County PA .s BKI875PG1517 VERIFICATION AND NOW Lois M. Vitti verifies that the statements made in this Complaint are true and correct to the best of her information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel based upon the information provided him by the Plaintiff. Lois M. Dated: July 25, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFF CE sF Tr E c4ERiFF FiLED-OFFICE THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor uI I AUG 30 QM 8: 30 CUMBERLAND COUNTY PENNSYLVANIA PNC Bank, NA VS. Jose L. Vega, Jr. (et al.) Case Number 2011-6002 SHERIFF'S RETURN OF SERVICE 08/25/2011 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: Jose L. Vega Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Jose L. Vega Jr. Request for service at 391 Stonehedge Lane, Mechanicsburg, Pennsylvania 17055 is vacant. Deputies were advised this address has been vacant for over one year. To date The Mechanicsburg Postmaster has been unable to provide a good forwarding address for Jose L. Vega Jr. 08/25/2011 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: Dana L. Miller, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Dana L. Miller. Request for service at 391 Stonehedge Lane, Mechanicsburg, Pennsylvania 17055 is vacant. Deputies were advised this address has been vacant for over one year. The Mechanicsburg Postmaster has confirmed, Dana L. Miller has moved and left no forwarding address. SHERIFF COST: $84.00 August 25, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) Count Suite Sheriff. Teiecsuft. Inc PNC BANK, National Association, Plaintiff V. JOSE L. VEGA, JR., and DANA L. MILLER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 11-6002 IN RE: MOTION FOR SPECIAL SERVICE PURSUANT TO RULE 430 AND THE PENNSYLVANIA RULES OF CIVIL PROCEDURE 400, ET SEQ. ORDER OF COURT G N C= ° '3 ---4 co N - z q ' -0 n r `` -- r C:3 "r4 'P, C1 o , CD , c AND NOW, this 15th day of February, 2012, upon consideration of Plaintiff's Motion for Special Service Pursuant to Rule 430 and the Pennsylvania Rules of Civil Procedure 400, et seq., it is ordered and directed that Plaintiff may serve the Complaint upon the Defendants by (1) mailing a true and correct copy of the complaint by certified mail and regular mail, to Defendants' last known address at 391 Stonehedge Lane, Mechanicsburg, PA 17055, service to be complete upon mailing, (2) publication once in the Cumberland Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 391 Stonehedge Lane, Mechanicsburg, PA 17055. SUBSEQUENT papers may be served by regular mail to Defendant at the aforesaid Stonehedge Lane address with service to be complete upon mailing. BY THE COURT, Christylee L. 'Peck, J. Louis P. Vitti, Esq. Vitti & Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 Attorney for Plaintiff :rc ec p- e"S m(t I eV -211 7//a ?U°2 FE3 29 I'M 1: L' 1 CUMBERLAND COUNT'S PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC Bank. National Association CIVIL DIVISION NO. 11-6002 PRAECIPE TO REINSTATE COMPLAINT Plaintiff, vs. Jose L. Vega, Jr., and Dana L. Miller Defendant. Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire Supreme Court #01072 Vitti & Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 S 00'4 a? o.ff a???? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) )No. 11-6002 Plaintiff ) VS. ) Jose L. Vega, Jr., and Dana L. Miller ) Defendants ) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the complaint in the above-captioned case. Respectfully submitted, VITTI & VITT SSOCIATES, P.C. v BY: Louis P. Vitti, Esquire DATE: February 2 7, 2012 C:4 rnm L rn --E ??3 r-- t ?y r n M C' CM r-? o ca 3 =C) ?C N ? ©m K` ..._ _r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA _PNC. Bank, -National;Association, ..... CIVIL-DI..VISION NO. !t - (COCA 0 Plaintiff, COMPLAINT IN MORTGAGE FORECLOSURE VS. - MORTGAGE-FORECLOSURE Jose L. Vega, Jr, and Dana L. Miller, Filed on behalf of Plaintiff Counsel of record for this party: Defendants . - Lois M. Vitti, Esquire TO DEFENDANT(S): PA I.D. #209865 YOU ARE HERESY NOTIFIED 'TO PLEAD TO THE ENCLOSED COMPLAINT IN MORTGAGE FORECLOSURE WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT.JUDGMENT MAY BE ENTERED AGAINST YOU. BY. IS/ a1-0i6 9V. da Attorney for Plaintiff Vitti & Vitti & Associates, P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 t PNC.13ank,,NationaLAssoc1abon, IN THE-COURT-OF COMMON PLEAS OF 'CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : -CIVIL ACTION - LAW Vs. No. Jose L. Vega, Jr. and Dana L. Miller, Defendants. - O*MP-LAINT-IN-MORTGA-GE-FORECLO-SU'Rf ------ NOTICE YOU'HAVE-BEEN'SUED IN-COURT. IFYOUaIVISH 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 THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND -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 9UDGMENT'MAY BE ENTERED AGAINST-YOU BY THE COURT-WIi'HOUT-FUit M 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 A7 ONCE 'IF-YOU SHOULD NOT HAVE A. LAWYER, OR CANNOT AFFORD "ONE; GO TO CDR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE 'TO PROVIDE YOU WITH INFORMATION ON AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND -COUNTY'BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 (717) 249-3166 CO:MP4LAINT IN MOUGAGE fORECLOSURE ~ NOW, comes the Plaintiff by its attorneys, Vitt! & Vitt! & Associates, P.C. and Lois M. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for Its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a national association having a principal place of business located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is the holder of the mortgage and Is seeking enforcement of the mortgage through foreclosure. 2. The Defendant(s) is/are individuals with a last known mailing address of 391 _ _ -Stonehedge-Lane, _ Mechanicsburg, PA 17055. The property address _is .391-Stonehedge - Lane, Mechanicsburg, PA 17055 and is the subject of this action. 3. On -tlie 27thday of July,--2-004, -in-consideration of a-loan of -One -Hundred - - -- Eighteen Thousand Nine-Hundred Forty Seven and 00/100 ($116,947.00) Dollars made by National City Mortgage Co. to Defendant, the said Defendant executed and delivered to National City Mortgage Co. -a "Note" secured by a Mortgage with the Defendant as mortgagor and National City Mortgage Co., as mortgagee, which mortgage was recorded on the 29th day of July, 2004, in the Office of the Recorder of Deeds of Cumberland County, at Book No. 1875 Page No. 1508. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. The Plaintiff is successor by -merger .to..National .City Real -Estate,Services LLC, -which was successor _by merger to National City Mortgage, Inc, which was formerly known as National City Mortgage Co. 4. The premises secured by the mortgage are: SEE EXHIBIT "A "ATTACHED HERETO. 5.-.Said .mortgage provides,. inter alla: "that when as soon as the principal debt secured shall become due and,payable, or in case default shall be made in the payment of any installment of principal and Interest,-Dra ny-monthly -payment,-keeping-and-performance-by, the-mortgagor-of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for - - mortgagee to bring an-Action-of-Mortgage.Foreclosure, or other proceedings-upon the mortgage, of principal debt, interest and all other recoverable sums, together with .....- 6. Since February 1, 2011, the mortgage has been in default by reason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the.terms of the mortgage, the entire principal sure is due and payable. 7. In accordance with the appropriate Pennsylvania Acts of Assembly and the ----- Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagee's intention to foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the mortgagor(s). 8. The amount due on said mortgage is itemized on the attached schedule. 9. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases from liability for the debt secured by the mortgage any mortgagor, personal representative, heir or devisee of the mortgagor who is not a real owner of the property at the time of the filing of this Complaint. WHEREFORE, pursuant to Pennsyivania Rule of'Civil Procedure-Number 1147(6), Plaintiff demands judgment for the amount due of One Hundred Twenty Two Thousand Ninety and 99/100 ($122,090.99) with interest and costs. Respe ully s bmitted, VrM ASSOCIATES, P.C. BY: Lois "t ti, Esquire Attorney for Plaintiff SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance 108,289.19 - interest @ 6.2500% ----- - --- from 01/01/11 through 7/3112011 3,912.50 -- ----- (Plus $18.5427 per day after .7/31/2011 ) -Cafe charges through 7/25/201-1 0 months @ 38.60 Accumulated beforehand 154.40 (Plus $38.60 on the 17th day of each month after 7/25/2011 ) - Attomey's fee 5,414.46 Escrow deficit 4.320.44 (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the_sheriff as charges on the writ prior to the date of the sheriffs sale) BALANCE DUE 122,090.99 EXHIBIT "A" LEGAL DESCRIPTION EXAIBIT 6W1 _ ALL that ocriain Unit, being Unit No, 391 (the "Unit"), of Staaehedge, A Townhome-Condomiaiirm(the"Coudombdtim"),located inU pcrAllen Town&*. Cumberland County, Fennsylvauia, which unit is designated in the Deolaration.of.Condasniniutt of Stonehedso, A Townhome-Condominimn (the "Declaration of Condoxuinium") and Declaration Plats and Plans reeorde d in the Office ofthe-Cuxuberiand-County Recorder ofDeeds in ASsoell9ateous Book 681, ..ht .. ...-_ Lam. _ Page 46QSand Rig of WeyPLm Book J2,1?age 142.raspeCtively,'togethrxwith?-_ . __.-.. any and all ataeadments thereto, j TOGE7M with the undivided pcam sga irdwast in the Common Moments app tmiout to the Unit as moroparticularly set forth in the aforesaid Derlatatiou of Condopainium, as last amended. TOGETMwM the-right-to use the'Limited Common Elements applicable'to-tho.Unit being convoyod herein, purnza t to the Declaration of Condominimm and. Declaration Plats and Plans, as last amended. UNDM AND SLTBP T to any and all covenants, oonditions, restrictions, rishts-ofwyay, easaments and gsm=enU oftwotd in the aforesaid Office, the aforesaid Declaration of Condominituu, andma#= which a pbysiral hupectim and-stuvey of the Unit and CommonElaneots would disclose. ] Certify this to be recorded - ;_ in Cumberland Co_unty_pA. $1{ 1875PG 1517 VERIFICATION _ AND NOW Lois M. Vitti verifies that the statements made in this Complaint are true and correct to the best of her information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification._to.-authorities._.___ _........ _ By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading, is submitted by counsel based upon the information provided him by the Plaintiff. -Lois M. Dated: July 25, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart r'! f3E! l fi ;Tat", Solicitor %r' c c d PNC Bank, NA Case Number vs. Jose L. Vega, Jr. (et al.) 2011-6002 SHERIFF'S RETURN OF SERVICE 03/07/2012 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: Jose L. Vega, Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Jose L. Vega, Jr. Request for service at 391 Stonehedge Lane, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised, no one has resided at this address in over one year. 03/07/2012 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: Dana L. Miller, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Dana L. Miller. Request for service at 391 Stonehedge Lane, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised, no one has resided at this address in over one year. SHERIFF COST: $64.45 SO ANSWERS, March 07, 2012 RON R ANDERSON, SHERIFF "FILL ? i'';1' I I10NO CA ILE 2012 M11T, _D PM 1' 5' CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC Bank, National Association CIVIL DIVISION NO. 11-6002 Plaintiff, CERTIFICATION OF MAILING vs. Code: Mortgage Foreclose Filed on behalf of Plaintiff Jose L. Vega, Jr. and Dana L. Miller Counsel of record for this party: Defendants. Louis P. Vitti, Esquire Supreme Court #01072 Vitti & Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND. COUNTY, PENNSYLVANIA ' CIVIL DIVISION U. S Bank, National Association )NO. 11-6002 Plaintiff ) vs. ) Jose L. Vega, Jr. and Dana L. Miller ) Defendant(s) CERTIFICATION OF MAILING I, Louis P. Vitti, hereby certify that on the 5th day of March, 2012, a true and correct copy of the within Complaint was served by ordinary mail on the Defendant Jose L. Vega, Jr. and Dana L. Miller at 391 Stonehedge Lane Mechanicsburg, PA 17055 as per the Order of Court dated February 15, 2012. B _ Louis P. Vitti Sworn to and subscribed before me this 6th day of March, 2012. t r ? t- otary Pu, l c UC U.S. POSTAL SERVICE CERTIFICATE OF MAILNG MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From Vitti & Vitti & Associates, P.C. 215 Fourth Avenue. Pittsburgh. PA 15222 One piece of ordinary mail addressed to: Jose L."i Jr. & Dana L. Miller 391 Stonehedge Lane Mechanicsburg, PA 17055 PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILNG MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From ' Vitti & Vitti & Associates. P.C. 215 Fourth Avenue. Pittsburgh. PA 15222 One piece of ordinary mail addressed to: PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILNG MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From Vitti & Vitti & Associates. P.C. 215 Fourth Avenue, Pittsburgh. PA 15222 One piece of ordinary mail addressed to: PS Form 3817, January 2001 Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for currert fee. $1.150 US POSTAGE FIRST-CLASS C-4 062S0007061721 0 15222 Affix fee here in'?tsmffs, or meter postage`" postmark. Inquire doff Postmaster for current fee. Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current fee. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor dj r 1'Y E }?W? pr 30 1. iiI6 I{fa<R Of 11: E712 33rN'stK? I- na 1 g Y ? t A PNC Bank, NA vs. Jose L. Vega, Jr. (et al.) Case Number 2011-6002 SHERIFF'S RETURN OF SERVICE 03/24/2012 11:25 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2012 at 1125 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jose L. Vega, Jr., pursuant to order of court by posting the premises located at 391 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylv nia 705 ith a true and correct copy according to law. MARK ON LIN, DEPUTY 03/24/2012 11:25 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2012 at 1125 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dana L. Miller, pursuant to order of court by postin% the p mises located at 391 Stonehedge Lane, Mechanicsburg, Cumberland County, PennsFT a true and correct copy according to law. MARK ONKLIN, DEPUT Y SHERIFF COST: $66.00 March 27, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF S ? c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC Bank, National association Plaintiff, VS. CIVIL DIVISION NO. 11-6002 PRAECIPE TO REINSTATE COMPLAINT Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Jose L. Vega, Jr. and Dana L. Miller Louis P. Vitti, Esquire Supreme court #01072 Vitti & Vitti & Assoc., P.C. 215 Fourth Avenue Defendant. Pittsburgh, PA 15222 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association )Civil 1 Action Law )No. 1-6002 Action Plaintiff ) VS. ) Jose L. Vega, Jr., and Dana L. Miller, j Defendants ) PRAECIPE TOTivcTATE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the complaint in the above-captioned case. Respectfully submitted, VITTI & VITTI cSSOCIATES, P.C. BY: P. Vitti, Esquire DATE: April 9, 2012 411.g6 PQ ATH ail 0'?s ?35 p,* al3 80t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION "' s c.: «, PNC Bank Natioanl Association Plaintiff ) NO. 11-6002 r VS. Jose L. Vega, Jr.and Dana L. Miller s- Defendant(s) ) CERTIFICATION OF MAILIN I, Louis P. Vitti, hereby certify that on the 17th day of April, 2012, a true and correct copy of the within Complaint was served by certified mail on the Defendant Jose L. Vega, Jr. and Dana L. Miller at 391 Stonehedge Lane, Mechanicsburg, PA 17055 as per the Order of Court dated February 15, 2012. B Louis P. Vitti Sworn to and subscribed before rday of pril, 2012. d F' ? ca .. Notary Public $ US Postal Service,W a P ostage Er- rT1 Certified Fee TM -• ru 0 Mal I Return Receipt Fee O Receipt (Endorsement Required' _ Postmark ? Restricted Delivery Fee Domestic Mail Onl Here u) y (Endorsement Required) a No Insurance r-q Coverage Total Postage & Fees .0 Serir To, O ID Q 39 Sta IF burg,, ?A ""555 380' )-tnuarv 2005 US Postal Services Certified Mall-Receipt Erru M Er- nu O t_r7 Lr) r? a o" 0 a- a r? Service R) Postage $ - 1 -d Certified Fee Return Receipt Fee (Endorsement Required) i -- -- Postmark Restricted Delivery Fee Here 11ail Only (Endorsement Required) j rance wrovided Total Postage & Fees I $ i 391 nc. 38(10 ia'it arr 2005 US Postal Service' Certified Mail-Receipt C 4 Sent To. 2: PENNSYLVdANJX IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC Bank, National Association Plaintiff, VS. Jose L. Vega, Jr. and Dana L. Miller CIVIL DIVISION NO. 11-6002 PROOF OF PUBLICATION Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this parry: Louis P. Vitti, Esquire Supreme Court #01072 Vitti & Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 Defendant. (412) 281-1725 r . ! ' PROOF OF PUBLICATION NOTICE IN CUMBERLAND L W JOURNAL (Under Act No. 587, approved May 16, 1929)9 p. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND ' and Journal, that the of the coCumberland t Law Lisa Marie Coyne, Esquire, Editor of the Cumberland Law State aforesaid, being duly sworn, according to law, deposes and says and State aforesaid, sle in the County Journal, a legal periodical published in the Borough by the local courts as the official legal was established January 2, 1952, and des g 2, 1952, been regularly periodical for the publication of all legal that the printed notic or publica ion attached hereto is issued weekly in the said County, an exactl the same as was printed in the regular editions and issues of the said Cumberland aw y Journal on the following dates, Viz ?--- A ')A17 ffianfurther deposes that he is authorized to verify this statement by the Cumberland A and that Journal the , a legal periodical of general circulation, allegations t in interested in the foregoing the subject Law matter of aforesaid noticand chadvertisement, aracter of publi athon are true. statements as to time, place 4Lisariee Coyne, Edito SWORN TO AND SUBSCRIBED before me this 4 day of May, 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas af Monroe County, Pennsylvania CASE NO. 11-6002 In Re: PNC Bank, National Association plaintiff vs. Jose L. Vega, Jr. and Dana L. Miller Defendants COMPLAINT IN MORTGAGE FORECLOSURE You have been named as De- fendants in a civil action instituted by PNC Bank, National Association against you in this Court. This action has been instituted to foreclose on a Mortgage dated July 27, 2004 and recorded Bookvolumfe 1875 Monroe County at Page No. 1508 on July 2f , 2004. You are hereby to the above-referenced Complaint within twenty (20) days from the date of publication Of judgment will be entered against you. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the Court. You are warned that proceed fail to do so the case may p without you and judgment may be entered against you without further notice for the relief requested by the or Plaintiff. You may lose immoney portant property or other rights to you SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT S OFFICE TO HIRE A LAWYER, TO MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGEN- CIES 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, PA 17013 1-800-990-9108 (717) 249-3166 LOUIS P. VITTI, ESQUIRE VITTI AND VITTI AND ASSOCIATES, P.C. 215 Fourth Ave. 15219 Pittsburgh, (412) 281-1725 May 4 PROOF OF PUBLICATION State of Pennsylvania. County of Cumberland Jackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that -'HE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular -chtions and issues of THE SENTINEL, on the I, [Mowing dav(s): April 241_201 COPY OF NOTICE OF PUBt [CATION In the Court of Common Pleas of Monroe County, Pennsylvania In Re: PNC Bank, National Association Plaintiff, vs. Jose L. Vega, Jr. and Dana L. Miller, Defendants. Attorney for Plaintiff: Louis P. Vitti, Esquire, Vitti and Vitti and Associates, P.C., 215 Fourth Ave., Pgh., PA 15219. (412) 281-1725. COMPLAINT IN MORTGAGE FORECLOSURE CASE NO. 11-6002 You have been named as Defendants in a civil action instituted by PNC Bank, National Association. against you in this Court. This action has been instituted to foreclose on a Mortgage dated July 27, 2004, and recorded in the Recorder's Office of Monroe County at Book Volume 1875 Page No. 1508 on July 29, 2004. You are hereby notified to plead to the above-referenced Complaint within twenty (20) days from the date of publication of this Notice or a judgment will be entered against you. NOTICE If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that It you fall to do so =may may proceed without you and judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NOTICE 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 FOR OR NO FEE. LAWYER REFERRAL SERVICE: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 (717) 249-3166 Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are-tru,e. 6 ?i Sworn to and subscribed before me this Z Notary Public My commission expires: I F _ J ,_.: r ........,..._ .~.,.. 2~ ~ ~ SE" - 4 Phi f ~ (14 '~U,~~Ef~~A~iD Cat!?~T~` ~'ENMSYLVANIq IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION CIVIL DIVISION NO. 11-6002 Plaintiff, PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- vs. MILITARY SERVICE JOSE L. VEGA AND DANA L. MILLER Defendants. Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this p~Y~ Louis P. Vitti, Esquire Supreme Court #01072 Vitti &Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 Gt~.k ~ II.Q • s~~ Q t ~~a~QSI ~.~ a F~l l~ I~~ Noh~ ~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO: PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of $129,396.81, in favor of the PNC Bank, National Association, Plaintiff in the above-captioned action, against the Defendants, Jose L. Vega, Jr. and Dana L. Miller and assess Plaintiff s damages as follows andlor as calculated in the Complaint: Unpaid Principal Balance $108,289.19 Interest from O1/Ol/11-08/28/12 11,218.32 (Plus @ 6% per day after 08/28/12) Late chazges (Plus $38.60 per month from 07/25/11-03/06/13 $772.00) 154.40 Attorney's fee 5,414.46 Escrow Deficit 4.320.44 (Plus any additional chazges that maybe incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriff s sale) Total Amount Due 129.396.81 The real estate, which is the subject matter of the Complaint, is situate in Upper Allen Township, Cumberland County, Cmwlth of Pennsylvania. HET a dwg k/a 391 Stonehedge Lane, Mechanicsburg, PA 17055. Pazcel No. 42-10-0646-082-U26391. !i ouis P. Vitti, Esquire Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term CERTIFICATION OF MAILING I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on June 1, 2012, giving ten (10) day notice that judgment would be entered should no action be taken. VITTI & VITTI & ASSOCIATES, P.C. BY: ouis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 28th day of August, 2012. `~ Ct~ Notary Public _~....~r , _ .. _ _..~_.~ ~A~a~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) NO: 11-6002 vs. ) JOSE L. VEGA, JR and DANA L. MILLER, Defendants. IMPORTANT NOTICE TO: Jose L. Vega, Jr Dana L. Miller 391 Stonehedge Lane Mechanicsburg, PA 17055 Date of Notice: June 1, 2012 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IlVIPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON 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, PA 17013 1.800.990.9108 717.249.3166 VITTI & ASSOCIA S, `P~C.,~ -~ BY: LoI#`is itti, Esquire Attorney for Plaintiff 215 Fourth Avenue Pittsburgh, PA 15222 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANI~.2UPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who, being duly sworn according to law, deposes and says that he is advised and believes that DEFENDANT(S) is/are not presently in the active military service of the United States of America and not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Service Members Civil Relief Act of 2004 and designated therein as military service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct, and true; and insofar as they are based on information received from others, are true and correct as he verily believes. In the alternative, should the defendant(s) be currently serving in the military the Service Members Relief Act does not apply as the mortgage in question did not originate before the period of the Service Members military service and is secured by a mortgage pursuant to 50 U.S.C. App §533 formerly cited as 50 U.S.C. App §532 (a)(1)(2). This Affidavit is made under the provisions of the S Members Civil Relief Act of 2004. V -- ------------- ----X1.47" Louis P. Vitti, Esquire SWORN to and subscribed before me this 28th day of August, 2012. ~3n~,~sflwti~ _~ 'r.v~,~at '! ~ ~ ~Iee .~ _ ~~:~ ,s,~~ . ,, , _ Notary Pu he _ ~ ~_..... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-6002 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s) From JOSE L. VEGA AND DANA L. MILLER (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: $129,396.81 L.L.: $.50 Interest FROM 8/28/2012 -3/6/2013 - $4,020.16 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $377.45 Other Costs: Plain±iff Paid: Date:- 9/4~Z01? id D. ell, Proth otary (Seal) By: Deputy REQUESTING PARTY: Name: LOUIS P. VITTI, ESQUIRE Address: VITTI &VITTI & ASSOC. 215 FOURTH AVENUE PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ID No. 01072 ~ ~ r `~ y+s ~(~ ,~r~ ~~'TffO,~~j~,°~~. ~; ~,~ ~E~~SYL ANI~NT Y A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, vs. JOSE L. VEGA AND DANA L. MILLER Defendants. l~J Q~k g `a ~. S~ ~ a~ ~. aU ~~' 11~f.~Su4 ~o_~uc, ~'a.UO urr li. ~ S ~~ ~ ~ s p ~., a sa N. ~~~. ~s CIVIL DIVISION NO. 11-6002 PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this P~'~ Louis P. Vitti, Esquire Supreme Court #01072 Vitti &Vitti & Assoc., P.C. 215 Fourth Avenue Pittsburgh, PA 15222 (412) 281-1725 ~a.as ~~. fts. Sow ~,~µ abPSl ~a8ollnl ~rtf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: in: Amount Due 129,396.81 Interest 08/28/12-03/06/13 4,020.16 Total 133133 4~~CL97CL97 The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate Upper Allen Township, Cumberland County, Cmwlth of Pennsylvania. HET a dwg k/a 391 Stonehedge Lane, Mechanicsburg, PA 17055. Parcel No. 42-10-0646-082-U26391. ouis P. Vitti, Esquire Attorney for Plaintiff IN m~ COURT OG' COM?~N PL'FAS OF CUMBERI.-riDID COCT~FI'Y r P~SYI.~VA~1IA _.. _ _ _ _ _ _ _ CIVIL DIVISION ~__ _ .__ . _ - _ PRF~ECIPE FOR WRIT OF Ei~CUTION :notion: ( ) Confessed Judgrt~nt PNC Bank, National Association, ( ) Q~11her Plaintiff, vs. Jose L. Vega, Jr. and Dana L. Miller, Defendants. TO THr P FK7IHON~ARY O F THE SAID COURT File No. 11-6002 Civil Term Arrr~unt Due $1?9,396:,81 Interest $4,020.16 Atty's Corm Costs The unde_TSigned hereby ce:-tifies that the below do~..s not arise out of a retail insta.llirent sale, cont~Tact, or account based on a confession of judgrr~nt, but ~~ it does, it is based on the appropriate or~.ginal proceeding filed pu.•-suant to Act 7 of 1966 as a ~ ed; a.*td for real prope_*-~y pursuant to Act 6 of 1974 as arr~*~ded_ Issue writ of execstior. in the above wetter to the Sheriff of Cumberland County, for debt, interest and costs upon the following des~ibed p~pe_rty of the defendant(s) Please see attached legal description. PRAECIPE FOR AZ'IA(If~r.N~ ~fl'IC-N Issue writ of attach~rent to the She_-iff of County, for debt, ;nte_rest and costs, as above, di ecting attacbrr~nt against the above-Hared ga~Tnishee(s) for the following prope_*-ty (if real estate, supply six copes of the desc_iption; supply four ~oies of len~~hy personalty list) ynd ~ ot_her prope_*-ty of the defendant(s) ' n the possession, custody or control of the said cra_rnis:7ee (s) . (Indicate) Index this writ against the garnishee(s) as ass pendens against peal estate of the defendant(s) described in the attache _ibit. SATE: August 28, 2012 Signatur - ?r1nC NalT1e: T.nnic P_ Vitti .=cdress : ~ t S Fourth A~~Pnn -- Pittsburgh, PA 15222 . tco~^ey for: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute . That the Defendants' last known address is 391 Stonehedge Lane, Mechanicsburg, PA 17055. u~ P. Vitti, SWORN to and subscribed before me this 28th day of August, 2012. ,s Notary Public .~.~.J .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term LEGAL DESCRIPTION ALL that certain Unit, being Unit No. 391 (the "Unit"), of Stonehedge, A Townhome Condominium (the "Condominium"), located in Upper Allen Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Stonehedge, A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds in Miscellaneous Book 681, Page 4605 and Right of Way Plan Book 12, Page 142 respectively, together with any and all amendments thereto. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid Declaration of Condominium, as last amended. TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of--way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration of Condominium, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. Having erected thereon a dwelling known as 391 Stonehedge Lane, Mechanicsburg, PA 17055. Parcel No. 42-10-0646-082-U26391. Being the same premises which Stonehedge Lane Associates. by deed 7/27/04 and recorded 07/29/04 in the Recorder of Deeds of Cumberland County, Pennsylvania in Instrument No.2004-030698, granted and conveyed unto Jose L. Vega, Jr. and Dana L. Miller. `f : ~ (; r it1 t r,~`~'~~C R 4 ~~.~, !!c~~,,~yy~a co~~ r yy IN THE CO~JR~~MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term AFFIDAVIT I, Louis P. Vitti, hereby certify that as representative of PNC Bank, National Association am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. SWORN to and subscribed before me this 28th day of August, 2012. ouis P. Vitti, Esquire Attorney for Plaintiff ^•x ..W ~qq ~ ~ .. _ k 1[' Notary Public a r ._ f ,~ ;~ ~, ~~ ~. ~ ~ t c,JI~ `~~~ ~'~` Qa~`~ T~ ,ti; ; -. ~'~~+rs ~'t'~. v°,~~1l~~~~'r'r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PNC Bank, National Association, ) Plaintiff, ) vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. ) No: 11-6002 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank, National Association, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 391 Stonehedge Lane, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Jose L. Vega, Jr 391 Stonehedge Lane Dana L. Miller Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) James C. Costopoulos Cumberland County Adult Probation 10 Courthouse Avenue Suite 103 Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) NONE 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest maybe affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) None 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of Upper Allen Township Upper Allen Township Office Board of Commissioners Upper Allen Township Office Pennsylvania Department of Revenue Office of Chief Counsel Commonwealth of PA -DPW Clerk of Courts Criminal/Civil Division Tax Claim Bureau of Cumberland County Cumberland County Courthouse 100 Gettysburg Pike Mechanicsburg, PA 17055. 100 Gettysburg Pike Mechanicsburg, PA 17055 Inheritance Tax Dept. PO Box 281061 Harrisburg, PA 17128 P.O. Box 8016 Harrisburg, PA 17105 One Courthouse Square Carlisle, PA 17013 One Courthouse Square Carlisle, PA 17013 Court of Common Pleas of Cumberland County Domestic Relations Division PA Dept. of Sheriff Sales Bureau of Compliance TenantlOccupant P.O. Box 320 Carlisle, PA 17013 Dept. #281230 Harrisburg, PA 17128-1230 391 Stonehedge Lane Mechanicsburg, PA 17055 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. V , August 2E, 2012 Date Louis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 28th day of August, 2012. 1.~~--~ ary Public ~,~, ~:-~ ~r~~ _~~~~t. w~ ~ul2 sip -t~ ~~~ is ~e~ "~~;M~3c~Lg4~D COJP~jY NOTICE OF SHERIFF'S SALE OF P E ~ ~d S Y LYA ~ I A REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Jose L. Vega, Jr Dana L. Miller 391 Stonehedge Lane Mechanicsburg, PA 17055 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on March 6, 2013 at 10:00 A.M., the following described real estate, of which Jose L. Vega, Jr. and Dana L. Miller are owners or reputed owners: Upper Allen Township, Cumberland County, Cmwlth of Pennsylvania. HET a dwg k/a 391 Stonehedge Lane, Mechanicsburg, PA 17055. Parcel No. 42-10-0646-082-U26391. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of PNC Bank, N.A. vs. Jose L. Vega, Jr and Dana L. Miller at 11-6002 in the amount of $129,396.81. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. The Writ of Execution has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights you must act promptly. • t YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriff s Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer maybe able to help you. You may have the right to prevent or delay the Sheriff s Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time: If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff s Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriff s Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheri . . , ~J ,~'' ouis P. Vitti, Esquire Attorney for Plaintiff 215 Fourth Avenue Pittsburgh, PA .15222 (412) 281-1725 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TffiS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r ILED-OF IC: Sheriff ` d '{t�HE b dry( 'HONJ,'-, ) THE f L. �1�V �1/ 3��.f i P1rg .. Jody S Smith ' Chief Deputy 2 13 MAY °8 AM 1 _ 4 Richard W Stewart CUMBERLAND GOW4'ry Solicitor f �` � � PENNSYLY'ANIA PNC Bank, National Association Case Number vs. Jose L.Vega, Jr. (et al.) 2011-6002 SHERIFF'S RETURN OF SERVICE 09/11/2012 Property sale removed from 12/5/2012 sale, property was mistakenly fisted for 12/5/12 should be for March 3, 2013. 01/02/2013 07:40 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant,to wit: Jose L. Vega, Jr., pursuant to Order of Court by"Posting"the premises located at 391 Stonehedge Lane, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County with a true and correct copy according to law. 01/02/2013 07:41 PM-Deputy Ryan Burgett, 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 391 Stonehedge Lane, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 01/22/2013 Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant,to wit: Dana L. Miller, pursuant to Order of Court by'Posting"the premises located at 391 Stonehedge Lane, Mechanicsburg, PA 17055, Cumberland County with a true and correct copy according to law. 03/27/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carisle, PA, Cumberland County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Louis Vitti, on behalf of PNC Bank, National Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,096.31 SO ANSWERS, May 06, 2013 RbNW R ANDERSON, SHERIFF �2 P L� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL.DIVISION PNC Bank,National Association, ) Plaintiff, ) No: 11-6002 Civil Term vs. ) Jose L. Vega, Jr. and Dana L. Miller, ) Defendants. } AFFIDAVIT PURSUANT TO RULE 3129.1 PNC Bank,National Association, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 391 Stonehedge Lane, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or Reputed Owners): Name: Address (Please indicate if this cannot be reasonably ascertained) Jose L. Vega, Jr 391 Stonehedge Lane Dana L. Miller Mechanicsburg, PA 17055 2. Name and address of Defendant(s)in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably.ascertained) James C. Costopoulos 10 Courthouse Avenue Suite 103 Carlisle, PA 17013 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(Please indicate if this cannot be reasonably ascertained) NONE 5. Name and address of every other person Who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 (Please indicate if this cannot be reasonably ascertained) Tax Collector of Upper Allen Township 100 Gettysburg Pike Upper Allen Township Office Mechanicsburg, PA 17055 Board of Commissioners 100 Gettysburg Pike Upper Allen Township Office Mechanicsburg, PA 17055 Pennsylvania Department of Revenue Inheritance Tax Dept. Office of Chief Counsel PO Box 281061 Harrisburg, PA 17128 Commonwealth of PA-DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts One Courthouse Square Criminal/Civil Division Carlisle, PA 17013 Tax Claim Bureau of Cumberland County One Courthouse Square Cumberland County Courthouse Carlisle,PA 17013 5 Court of Common Pleas of P.O. Box 320 Cumberland County Carlisle,PA 17013 Domestic Relations Division PA Dept. of Sheriff Sales Dept. #281230- Bureau of Compliance Harrisburg, PA 17128-1230 Tenant/Occupant 391 Stonehedge Lane Mechanicsburg, PA 17055 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 unworn falsification to authorities. Au ust 28. 2012 Date Louis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 28th day of August,2012. af_sl�u �p �aantg Public -.-:_w-s vrv4«.w-s.._-_,.�, ....... '...;F-•a..&uWmF-',vr.,.<W.'ast�., 'r.+,a.;maw.,€-.�- .. Cx�'e+tKw,.i&-::�..a, .. _..--. ,�..;,imrt.:'u�.r+r�:.nr^c,&*a%,w�.sas.�m .e-�a+,s.^r.±-..,.-.wT.v<.......:.. ...._. ...... -. CUMBERLAND LAW JOURNAL Writ No. 2011-6002 Civil the Recorder of Deeds of Cumberland County,Pennsylvania in Instrument PNC Bank,National Association No.2004-030698,granted and con- veyed unto Jose L. Vega, Jr. and vs. Dana L. Miller. Jose L.Vega,Jr., Dana L.Miller Atty.:Louis P.Vitti ALL that certain Unit,being Unit No.391(the"Unit"),of Stonehedge,A Townhome Condominium(the"Con- dominium"),located in'Upper Allen Township, Cumberland County, Pennsylvania, which Unit is desig- nated in the Declaration of Condo- minium of Stonehedge,A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds in Miscellaneous Book 681, Page 4605 and Right of Way Plan Book 12, Page 142 respectively, to- gether with any and all amendments thereto. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid Declaration of Condomini- um,as last amended. TOGETHER with the right to use the Limited Common Elements ap- plicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans,as last amended. UNDER AND SUBJECT to any and all covenants,conditions,restric- tions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration of Condominium, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. Having erected thereon a dwell- ingknown as 391 Stonehedge Lane, Mechanicsburg,PA 17055, Parcel No. 42-10-0646-082- U26391. Being the same premises which Stonehedge Lane Associates by deed 7/27/04 and recorded 07/29/04 in 106 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. CAVA ----� isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this C— 8 day of February,2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy e atr1*otjwXews 11 Suits 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 � , � / Under Act No. 587, Approved May 16, 1929 | Commonwealth of Pennsylvania, County ofDauphin) sm | Marianne Miller, being duly sworn according tolaw, deposes and says: That she is a Staff Accountant of The Patriot News Co., o corporation organized and existing under the laws ofthe 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 bo 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. This ad ran on the date(s)shown below: 01/2OY13 w ,Da-~~ 01129V13 vim 02/05V13 AiL that'certain Unit be Unit No.391 (the"Unft"),ofStonebeVAT9wnhome located in' Allen 16waship, ' Sworn to and 3&D. con off Condominium (the and Plans in the.,off=ot I the Cumberland Cxmnty,R=rder.9f,Deeds in Miscellaneous Book 681'P* 4605 N ublic I respectively, together with any and A TOGETHER ,with the offlvi&d Elements- apourieniatto ,tbb Unit,as Notarial Seal Notary Public more particularly,to forth'ia the aftesaid Holly Lynn Warfel, of _7or Dedaiation, as last Washington Twp.,Dauphin County amendeA. My Commission Expires Dec.12,2016 TOGETHER!with ft 1W to the MEMBER,PENNSYLVANIA ASSOCIAITON Of NU I AKLF:S limited CommonEkineats'"ficable,th and Declaration Plais and'Phq�t'ps last UNDER AND SUBJECT,to Anyand all of-way, casements and agreements of record in the aforesaid Ofte,the.aforesaid, Declaration-cif Condominium,and.marters which aphysicalinspection,andsurye Unit and Common Elementswm9disdose., as 391 Stonehedge Lane,-Mech�urgl RA 17055. Being the same premsieswhich Stonphedge Lane Associates by, deed 7/27/04 and recorded 97/29/04 in tbfRp;qrder_0f Deeds of Cumber][W Count in 4Wumv*N%4W4$k6.K granted and and Dana to lose L WV 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 PNC Bank,National Assocation 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 4th day of Se tember,A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 6002, at the suit of PNC Bank,National Association against Jose L. Vega Jr. and Dana L. Miller is duly recorded as Instrument Number 201315014. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ' A.D. / Recorder of Deeds Recorder of ,Cumberland County,Cadisle,PA My Commis the First Monday of Jan.2014