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HomeMy WebLinkAbout11-7039MAR)iA E. VON ROSENSTIEL, P.C. 28557CFC-DD MartIV E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION COURT OF COMMON PLEAS OF 616 Shelden Ave., Suite 300 CUMBERLAND COUNTY Houghton, MI 49931 PLAINTIFF Q (? NO. THE ESTATE OF CAROL M. HENCH, DECEASED 930 Gobin Drive Carlisle, PA 17013 CD AND C= ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS MUD -"n. AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND __;xl -n -L, ALL PERSONS, FIRMS, OR ASSOCIATIONS, `,r ??? CLAIMING RIGHT, TITLE OR INTEREST FROM OR Iv UNDER THE ESTATE OF CAROL M. HENCH T cam: - :)-n 930 Gobin Drive - - wn Carlisle, PA 17013 y a DEFENDANTS y CIVIL ACTION - MORTGAGE FORECLOSURE 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 Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. 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 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 (is p,0 ArW 00.00 I ?1+ y7960 e# 41 og59y THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA F, VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 28557CFC-DD Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION 616 Shelden Ave., Suite 300 Houghton, MI 49931 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF V. THE ESTATE OF CAROL M. HENCH, DECEASED 930 Gobin Drive Carlisle, PA 17013 NO. AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, .AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH 930 Gobin Drive Carlisle, PA 17013 DEFENDANTS CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Americhoice Federal Credit Union, a corporation organized and existing tinder state law, with offices for the conduct of business at 616 Shelden Ave., Suite 300, Houghton, MI 49931. 2. Defendants are The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench, Deceased who are or may be the heirs at law and equitable owners of premises 930 Gobin Drive, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, real owners and equitable owner and/or heirs at law, to foreclose a certain indenture of mortgage made, executed and delivered by Carol M. Hench to Americhoice Federal Credit Union on August 2, 2010, which mortgage is recorded on August 9, 2010 in the Office of the Recorder of Deeds of Cumberland County as Document ID# 201021906, secured on premises 930 Gobin Drive, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 5. On or about February 3, 2011, Carol M. Hench departed this life intestate. 6. Plaintiff avers that no Estate has been raised nor have Administration proceedings been commenced. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from February 2011 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 30,262.25 Interest from 1/1/2011 to 8/30/2011 at $9.11 per diem $ 2,204.29 Accrued late charges to 8/30/2011 $ 149.38 Corporate Advances $ 756.27 Attorney's Fee (5% of unpaid Principal balance) $ 1,513.11 Total $ 34,885.30 10. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated prior to the Sheriffs sale, reasonable attorney's fees will be charged based on work actually performed. 11. As there are no successor record owners, notice under Act 6 of 1974 is not required. 12. As the premises is not owner occupied, Notice under Act 91 of 1983 is not required. 13. Plaintiff has named All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench, Deceased, in accordance with Pa. R.C.P 1144(a)(2),and in order to divest any equitable interest they may have in the above described real estate. The named defendants have no individual and personal liability for the mortgage debt. 14. Plaintiff releases, Carol M. Hench, Deceased, The Estate of Carol M. Hench, Deceased, and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench, Deceased from personal liability for the debt secured by this mortgage. This action is being brought to foreclose any potential interest they may have in the above-described real estate only. WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $34,885.30 , plus per diem interest at $9.11 from August 30, 2011 to the date of judgment plus costs thereon. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: 4?kddc,: 6_7)v Tar<thal E. Von Rosenstiel, Eire acqueline F. McNally, Esquire Attorneys for Plaintiff VERIFICATION hereby states that he/she is the ?CLOSur- ??-W i, cC/r of Midwest Loan Services, Inc., Servicing Agent for Americhoice Federal Credit Union, plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Americhoice Federal Credit Union and verifies that the statements made in the foregoing Complaint in Americhoice Federal Credit Union v. Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench relating to the property located at 930 Gobin Drive, Carlisle, PA 17013 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: Title: r-ec-&s4rr ?11aY Midwest Loan Services, Inc. as servicer for Americhoice Federal Credit Union Dated: CA ( /J LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Northern side of Gobin Street which point is a corner of Lot No. 64 on the hereinafter mentioned Plan of Lots; thence Northwardly along Lot No. 64 a distance of 152.6 feet to a point in line of Lot No. 80; thence Eastwardly along Lot No. 80 a distance of 75.1 feet to a point in line of Lot No. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet to a point in the Northern side of said Gobin Street; thence Westwardly along the Northern side of said Gobin Street a distance of 75 feet to a point, the place of beginning. TAX PARCEL NUMBER: 29-19-1639-032 oar SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?yyzrs?tg of tui,ubep????b Mc,,'E ^F --F SrERIFF ED-t1 Its t PR0TH 0l? 2011 SEP 26 PM 2: 22 IFUMBERLAta[O COUNT'i' PENNSYLVA I t Americhoice Federal Credit Union Case Number vs. 2011-7039 Estate of Carol M. Hench, Deceased (et al.) SHERIFF'S RETURN OF SERVICE 09/15/2011 04:42 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2011 at 1642 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Estate of Carol M. Hench, Deceased, by making known unto Savanna Sanders, current Occupant at 930 Gobin Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY 09/21/2011 03:28 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2011 at 1528 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and ALL Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench, by making known unto Melissa Matrese, Executrix of The Estate of Carol M. Hench at 930 Gobin Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. i NOAH CL( E, DEPUTY SHERIFF COST: $50.00 September 22, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c; GouniySutte She",. Te;ecSUft ,^v;. #28557 DDCPG MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff n I , tW n"tf 0 07 10 N1 2: 1 1;`3 RL_/; [i COUP i'. CLlila LJ(A AMERICHOICE FEDERAL CREDIT UNION COURT OF COMMON PLEAS CUMBERLAND COUNTY PLAINTIFF VS. THE ESTATE, OF CAROL M. HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE, OF CAROL M. HENCH : Case No: 11-7039 DEFENDANTS PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECLOSURE To the Prothonotary: Kindly reinstate the Complaint in Mortgage Foreclosure in the above matter. Respectfully Submitted, MARTHA E. VON ROSENSTI L, P.C. i BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff DATED: November 7, 2011 AD Q'?"i I ID OD H a ,i = us Martha E. Von Rosenstiel, P.Ci,?Ic.,LRo Attorney for Plaintiff AIHO t? ? ,: Martha E. Von Rosenstiel, Esquire '?Cl +P,,? fi YLVA?dIA Jacqueline F. McNally, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 AMERICHOICE FEDERAL CREDIT UNION Plaintiff VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-7039 CERTIFICATION OF SERVICE 28557-SS CSV Martha E. Von Rosenstiel, Esquire, hereby certifies that she is the attorney for the plaintiff herein and that service of the Civil Action in Mortgage Foreclosure in the above matter was made upon on the defendants THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH by certified mail and by regular mail, pursuant to Court Order on November 15, 2011 . This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. S L' . 3 4&-? hAaxiha E. Von Rosenstiel, squire acqueline F. McNally, Esquire Attorneys for Plaintiff DATED: November 15, 2011 AMERICHOICE FEDERAL IN THE COURT' OF COMMON PLEAS OF CREDI'T' t'NION, CUMBERLAND COUNTY, PENTNSYL.VAN14 Plaintiff V. : CIVIL ACTION -- LAW THE ESTATE, OF CAROL. M. UI NCH, DECEASED and ALL KNOWN ANT) UNKNOWN HEIRS. SUCCESSORS AND ASSIGNS, REPRESENTATIVES,: DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT. TITLE; OR INTEREST : FROM OR UNDER THE ESTATE: OF CAROL, M. HENCH, Defendants NO. 11-7039 CIVIL. TERM IN RE: MOTION FOR SPECIAL: SERVICE PURSUANT TO SPECIAL ORDER OF COURT ORDER OF COURT AND NOW, this 29`x' day of September, 2011, upon consideration of the Motion for Special Service Pursuant to Special. Order of Court, it is ordered and directed that service of the complaint in this case upon the Estate of Carol M. I-Tench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, "Title or Interest from or Under the Estate of Carol M. 1-lench, Deceased, may be made (1) by regular and certified mail at the last known address, 930 Gobin Drive, Carlisle, PA 17013, service to be deemed complete upon mailing, (2) by posting the Complaint on the most public portion of the property located at 930 Gobin Drive; Carlisle, PA 17013, and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania. SUBSEQUENT papers may be served by regular mail to Defendant at the aforesaid Gobin Drive address with service to be deemed complete, j Ma a F. Von Rosenstiel, Esq. 9 South Avenue, Unit 7 Secane, PA 19018 Attornev for Plaintiff BY THE COURT, r O z, e - s'.... o- - ir,r,{ r ri N QS t fC ul ? t M . 0 Rea ,Fr?iFt F t C3 t cvser ni Req it O __ i t ' -r?r3? ! G r ? = r c\ PI n 3i: 1 G C3 o 1.9 c n1 - 4 rv THE ESTAT HENCH .DECEASED C3 1S?30 Gobin Drive - ----- -- ----- - - ---------- -- --- - --- C3 sQ; h ?r vided) -p SC^SSC - a ;'?? .„ wit, ?:4w ?r;. i u ?"??? Er 'n ? ,M05 s rTl _____. _ F7ta?k 7 1 }Rv \i? M ? ALLKN ?W IU NOVVNO EN SEELk PERSONS fTRINS 1pR - ?- -__-_ _ CD yrA SOCIATIONS, CLAIMING RIGHT, C3 e ? ?1 1N1ERE51 FROM NDEi r 4F ESTATE OF CARGO,.HENCH ---------------------- --7-,9W te Drive __ Carlisle, PA 17013 5 - U.S POSIAt SEPVICE CERTIFICATE OF MAILING 4?sc MAY BE 115ED FOR DOW571C AND TNTERNAI I N?Q9 PROVIDE FOR INSURANCE-POS-l MASIER ? cv' Received From: MARTHA VON ROSEN 649 SOUTH AVE 1 UNIT 7 SECANE, PA 19018 One Piece of ordiw-y mail WJdre5sed lo: THE ESTATE OF 1 930 Gobin Drive Carlisle, PA 17013 U"S POSI AL SER VICE CERTIFICATE OF MAILING MAY BE I1SED FOP. DON:ESTIC AND rNTERNAI l NQf IOU PROVIDE FOR M5IJRANCE-I10SIMASIER Received From: r?- .. i qJ MARTHA VON ROSEN ; 649 SOUTH AVENUE UNIT 7 i) fee her[ in scamps _mclcr P051agc and 4 0. 15 C, 6? ED 4f )l fee here. in !ramps IC,Pcla Pollage and 1 r k -p TNF.8th=r,q _ Ic c?{ SECANE, PA 19018 I Onc piece rrf ord,rAa it addre-scd ic- Su U ?(?VOWN, UNKNOWN HEIRS, I CCESSORS ASSIGNS, REPRESENTATIVES, ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER 930 Gobin Drive Caffi I- PA 1=I PS r-orm 3N 17, Mar.! 9E? } SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Lglllll- Q1 Cmob'" t t4 t,II NOY 28 AM 8: 41 `'' `:IIMBERLAQ C0U"4TY P EP#I'SYt..''ANI Americhoice Federal Credit Union Case Number vs. Estate of Carol M. Hench, Deceased (et al.) 2011-7039 SHERIFF'S RETURN OF SERVICE 11/17/2011 11:20 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2011 at 1120 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: The Estate of Carol M. Hench, Deceased, pursuant to order of court by posting the premises located at 930 Gobin Drive, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. MICHELLE GUTSHALL, DEPUTY 11/17/2011 11:20 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2011 at 1120 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under The Estate of Carol M. Hench, pursuant to order of court by posting the premises located at 930 Gobin Drive, Carlisle, Cumberland County, Pennsylvania 17013 with a true and correct copy according to law. MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $62.00 November 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-7039 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICHOICE FEDERAL CREDIT UNION, Plaintiff (s) From THE ESTATE OF CAROL M. HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH (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: $36,005.83 L.L.: $.50 Interest FROM 12/31/11 to 6/6/12 AT 6% - 't 9`ll,x-? Atty's Comm: % Due Prothy: $2.25 Arty Paid: $261.50 Other Costs: efRu-s coTf" 40 be- eworsea Plaintiff Paid: Date: 119/12 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: JACQUELINE F & ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19108 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 201332 Commonwealth of Pennsylvania COUNTY OF CUMBERLAND AMERICHOICE FEDERAL CREDIT UNION V. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH 28557CWE-DN COURT OF COMMON PLEAS DOCKET NO. 11-7039 ATTORNEY I.D. # ^ C), S ? C, c Q -X 3Z N m --f rn- z z? -um U rr , Q 7 o z < = z ° o N A Praecipe for Writ of Execution = a' TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $ 36,005.83 INTEREST from 12/31/2011 to 6/6/12 At 6 % $ 941.28 TOTAL* $ 36,947.11 *Plus costs to be endorsed Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: Aartl E. Von Rosenstie , Esquire cqueline F. McNally, Esquire Attorneys for Plaintiff PREM: 930 Gobin Drive, Carlisle, PA 17013 V a ? ? ,S? a • ',?o • oo c?F 90. 00 t 10.ObuC, 1 lQ• so u a.so??d a? %Pul- y SCLL C" gjmcl WO o 9Z# a09 5y; w? r, Qo Q oa U W ?v Ua a Q o U 2 ` c:7 x dooz ca U p c/? dam,, W r, o U '? ?, cta p ?.' . v a H?4 a? ct?E Fd- *? r+ b"" d U ? ? "r rw M 00. Ln O lz?l 110 M p -Zr M N M a N 0 0 N o d cn Q r- c? 0 o?tod d N, 7 G? cd i H ? ? o #28557-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION Plaintiff VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 11-7039 THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Northern side of Gobin Street which point is a corner of Lot No. 64 on the hereinafter mentioned Plan of Lots; thence Northwardly along Lot No. 64 a distance of 152.6 feet to a point in line of Lot No. 80; thence Eastwardly along Lot No. 80 a distance of 75.1 feet to a point in line of Lot No. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet to a point in the Northern side of said Gobin Street; thence Westwardly along the Northern side of said Gobin Street a distance of 75 feet to a point, the place of beginning. TAX PARCEL NUMBER: 29-19-1639-032 IMPROVEMENT'S: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Carol Hench, single person, her heirs and assigns, by Deed from R. Scott Martin and Pamela S. Martin, husband and wife dated 5/21/2008 and recorded 5/23/2008 in the County of Cumberland in Instrument #200817243. A MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION Plaintiff VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) #28557CAM - DN COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-7039 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 N a rn cnr i o0 „{D tD --i G7 n N C) ell 1 , ESQUIRE, attorney for the Plaintiff in the above action; sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 930 Gobin Drive, Carlisle, PA 17013: 1. Name and address of owners(s) or reputed owner(s) The Estate of Carol M.Hench, Deceased 930 Gobin Drive Carlisle, PA 17013 All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: The Estate of Carol M.Hench, Deceased 930 Gobin Drive Carlisle, PA 17013 All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 i 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Wanda Fry 1772 W. Trindle Road Carlisle, PA 17015 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Carl K. Hench 930 Gobin Drive Carlisle, PA 17013 Charles A. Hench 930 Gobin Driv Carlisle, PA 17013 Melissa Matrese 930 Gobin Drive Carlisle, PA. 17013 Melissa Matrese 172 West Trindle Road Carlisle, PA 17013 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 9 T PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, 11th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, 13A 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, 13A 17128-0603 Occupant 930 Gobin Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. C BYJE a . Von Rosenstie , .,sq e que line F. McNally, Esquire torneys for Plaintiff Dated: December 29, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff Americhoice Federal Credit Union 616 Shelden Ave., Suite 300 Houghton MI 49931 Plaintiff vs. The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 Defendants COURT OF COMMON PLEAS CUMBERLANDCOUNTY No: 11-7039 AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE ca M Z +t=s &- ME One F, , attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: The Estate of Carol M.Hench, Deceased 930 Gobin Drive Carlisle, PA 17013 All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. a E. Von Rosenstiel, Esquire queline F. McNally, Esquire BYIt,torneys _ for Plaintiff #28557-C W E-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION Plaintiff vs. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE, OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY to S a No: 11-7039 Z -- p G Z p I'D CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit XX That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement given herein. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: art E. Von Rosenstie , Esqui cqueline F. McNally, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FILED-OFFICE CIF THE PROTHONOTARY 2012 JAN -9 PM 2.- 19 Cl} PENNSYLVANIA OUNTY AMERICHOICE FEDERAL CREDIT COURT OF COMMON PLEAS UNION CUMBERLAND COUNTY Plaintiff VS. : No: 11-7039 THE ESTATE OF CAROL M.HENCH, : DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: 28557CAM-DN The real estate and improvements, if any, located at and known as 930 Gobin Drive Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on Date of Sale: 06/06/2012 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 11-7039 in the Court of Common Pleas of Cumberland County by Americhoice Federal Credit Union, Plaintiff against The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench, Defendant(s). Judgment was entered on December 30, 2011 in the amount of $36,005.83. The property was r • j seized and taken in execution as the property of The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Northern side of Gobin Street which point is a corner of Lot No. 64 on the hereinafter mentioned Plan of Lots; thence Northwardly along Lot No. 64 a distance of 152.6 feet to a point in line of Lot No. 80; thence Eastwardly along Lot No. 80 a distance of 75.1 feet to a point in line of Lot No. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet to a point in the Northern side of said Gobin Street; thence Westwardly along the Northern side of said Gobin Street a distance of 75 feet to a point, the place of beginning. TAX PARCEL NUMBER: 29-19-1639-032 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 11-7039. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 w #28557CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICHOICE FEDERAL CREDIT UNION Plaintiff V. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) NO. 11-7039 PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: c -_ N ? =M =M r- : := m -0 - ' V) -<v , .- J Q CD nom . yC N c5n (XX) Enter judgment in favor of Plaintiff and against: The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench for want of an answer. (X) Assess Damages as Follows Debt Interest from 12/31/2011 to December 30, 2011 At $9.11 per diem Total $ 34,885.30 $ 1,120.53 $ 36,005.83 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: C?Iar E. Von Rosenstiel, Esq e acqueline F. McNally, Esquire Attorneys for Plaintiff QMN ` 16.Q fA a?j Lo s ?r3 Inc fvo? C-Av This C\ day of ?O-Y\ , 201 -A judgment is entered in favor of the Plaintiff and against Defendant(s), The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate Carol M. Hen by default f ant of an answer and damages assessed at the sum of $36,005.83 a r the ve ificatio Proth u era ounty MARTHA,E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (61.0) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION 616 Shelden Ave., Suite 300 Houghton, MI 49931 PLAINTIFF V. THE ESTATE OF CAROL M. HENCH, DECEASED 930 Gobin Drive Carlisle, PA 17013 AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS. REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH 930 Gobin Drive Carlisle. PA 17013 DEFENDANTS TO: All Known and Unknown Heirs, et al. 930 Gobin Drive Carlisle, PA 17013 #28557C'I'D - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-7039 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AT] ORNEY AND f'11.E IN WRITING WITH THE COURT YOUR DEFENSES OR 0$JEC"PEONS'TO THE CLAIMS SET FORTH AGAINST YOU. tJNL.ESS YOU, ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OT14ER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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 FF,E. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted., MARTHA E. VON ROSENStTEL, P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: December 16, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue. Suite 7 Secane. PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION 616 Shelden Ave., Suite 300 Houghton, MI 49931 PLAINTIFF V. THE ESTATE OF CAROL M. HENCH, DECEASED 930 Gobin Drive Carlisle. PA 17013 AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH 930 Gobin Drive Carlisle, PA 17013 DEFENDANTS TO: The Estate of Carol M.Hench, Deceased 930 Gobin Drive Carlisle, PA 17013 #28557CI'D - DD COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 11-7039 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. IINLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOti SHOULD TAKE. THIS NOTICE TO A 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 CAN-NOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES I HAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTkhA E. VON ROSENST* P.C. BY: ? Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: December 1.6, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. THE ESTATE OF CAROL M.HENCH, DECEASED : AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(S) No: 11-7039 NON MILITARY AFFIDAVIT In I F, McN* Esquire hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: a a E. Von Rosenstiel, ,sq G le acqueline F. McNally, Esquire Attorneys for Plaintiff Dated: December 30, 2011 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary The Estate of Carol M.Hench, Deceased 930 Gobin Drive Carlisle, PA17013 AMERICHOICE FEDERAL CREDIT UNION PLAINTIFF VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-7039 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $36,005.83 on December 30, 2011. D David D. Bue Prothonotary Judgment by Default %14,j I ?' Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney , Esquire at this telephone number:610-328-whowbranewputwell .1 ne F. 2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, I Courthouse Square, Carlisle, PA 17013 All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 AMERICHOICE FEDERAL CREDIT UNION PLAINTIFF VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL, M. HENCH DEFENDANT(S) David D. Buell, Prothonotary COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-7039 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $36,005.83 on December 30, 2011. David D. Buell Prothonotary 7X Judgment by Default ?/q is .. ? Money Judgment F1 Judgment in Replevin Judgment for Possession ? Judgment on Award of Arbitration ? Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney { F. N*?_, Esquire at this telephone number: 610-328-2887. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT UNION Plaintiff #28557CAM - DN 3' 1L E10-0F iUE OPOTHONOTAR'Y 23{2 JAN 25 PM 2= 20 CUMBERLAND COUNTY COURT OF COMMON CUMBERLAND COUNTY vs. THE ESTATE OF CAROL M.HENCH. DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIA `IONS, CLAIMING RIGHT, TITLE OR INTEkl ST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) NO: 11-7039 AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 !no F. M ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on / O-L) •- ? '?- , true and correct copies of the Notice of Sheriff s Sale were served upon Defendants pursuant to COURT ORDER dated 9/29/11 and upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. I verify that the statements made in this affidavit are true and correct upon information and belief. I u iderstand that false statements herein are made subject to the penalties of' 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted. MART'-IA E. VON ROSENSTIEL, P.C. . Von Rosenstiel, Esqui Jac Gue F. McNally, Esquire Attfor Plaintifl' - e?'l AMI?RICHOICI FEDERAL IN THE COURT OF COMMON PLEAS OF . k CREIAT UNION, CUMBERLAND COUNTY, PENNSYLVANI!? Plaintiff CIVIL ACTION -- LAW THE; FS"FA"IT: OF CAROL M. HI NCH, DECEASED and ALL KNOWN AND UNKNOWN HEIRS, SLJCC ESSORS AND ASSIGN S, REPRESENTATIVES,: DEVISI ES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATI.: (--)F CAROL M. IIENCI1, Del?ndants NO. 11-7039 CIVIL TERM IN RE: MO'T'ION FOR SPECIAL, SERVICE PURSUANT TO SPECIAL ORDER OF COURT" ORDER OF COURT AM) NOW, this 29`x' day of September, 2011, upon consideration of the Motion for Special Service Pursuant to Special. Order of Court, it is ordered and directed that service of the complaint in this case upon the Estate of Carol M. Hench, Deceased and All Knot,°n and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Pers(?ns, Firms, or Associations, Claiming Right, "Title or Interest from or Under the F 'state of Carol M. Hench, Deceased, may be made (1) by regular and certified mail at the last kno,,N n address, 930 Gobin Drive, Carlisle, PA 17013, scrvice to be deemed complete upon mailing. (') by posting the Complaint on the most public portion of the property located at 930 Gobin Drive; Carlisle, PA 17013, and (3) by publication. once in the Curnberland County' L3W Journal and once in a newspaper of general circt.ilation in Cumberland County, Pennsylvania. St_JISEQUENT papers may be served by regular mail to Defendant at the aforesaid Gobin Drive address with service to be deemed complete. B Y T HE CURT, eslev Oter,/ - J. Ma a' ?.. Won Rosenstiel, Esq. 9 Sou(h Avenue, Unit 7 Secane, PA 19018 Attornev for Plaintiff -r 0 r- m r n r n ma'r' -. •.'; The state--of Caret .I`A 14I filch ____ _ 930 Gobin Drive Deceasee G*ui le, PA 17013 U.J. YJJTAL SERVICE CERTIFICATE OF MA Y BE USED FOR DOMUSTIC AND TNTERNATIO ,4 PROVIDE FOR iNSIJRAI?CE-POSTMASTER clc Rcccivcd From- MARTHA VON ROSENJ 649 SOUTH AVENt UNIT 7 SECANE, PA 19018 Onc Piccc of ordirarY mail addresscd lo: rq 4 . _7 l - .. .. , . _ a,. o- Lr) M 0 ED - -- - - to All Known ,Unkr1own-Flelri r- tinuct pAsg4ns, Representatives , Devisees All Pe sons- _. Finns or o 'PAssociations, Claiming Right, Title - a ?- otlnterestf orn orunder- theEstate - ``o r Hench - ar?tsl'e,4A 17013 pjTix fee hcrc in stamps a`tlIer Postage and t ? -*?1F?-rte' Xltlttaae?[, ?6 - - ?'Ctk PITNEY EOWF- 6 6 < _ Successors, Assigns, Representatives - Devisees, All Persons Fi rms ra tuns, aiming Right Title . , or Interest from or Under the Estate 930 Gobin Drive r ;. Carlisle PA 17nia 3 Form 3817, Mar. 198'r CERTIFICATE OF MAILING - ?- U.S. POSTAL SERVICE - Affix tec pert in ._ MAY BE USED FOR DOMESTIC AND FNTERNAJ.I?I III ROES Elr meter postart and _ PROVIDE FOR INSIJRANC:E-POSTMASTER . 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G N CD N cGeo. ° 03CD W n 0 G C N N CD (P a LT F ?'D m rJ Oam D W jMCD 77 AF_7DjV1I7 OF SERVICE PLAINTIFF: Americhoice Federal Credit Union DEFENDANT The Estate of Carol M.Hench, Deceased and All Known and Untown Heirs, Successors and Assigns, Representatives, Dev ees, and All Persons, Firms, or Associations, Claiming Right. Title or interest from or Under the Estate of Carol M. Hench SERVE UPON: The Estate of Carol M.Hench, Deceased 930 Goldin Drive Carlisle, PA 17013 SPEC AL ?UC ON& serve pursuant to COURT ORDER made known to described below: (`Oi R TOI:CON! M(IN I'LFAS CD Cumbcda,';i CC:UN i'I' COURT NO. 11-7039 MCD TYPE OF ACT ION XX WRIT OF EXECUTION and Notice of Sheriff's Sate Sheriffs Sale Date: 616112 SERVED ^??_V Defendant, on the li/ day of (? r l ,'sd e , P-4- 1701 25557-DN ty "I C Z.,> 7-1 Z i> 12- , at ia, in the manner Defendant personally served. ManagerlGierk of place of lodging to which Adult family member with whom Defendant resides. Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual place of business, refused x Other I / f to dive name/relationship. Pce Description: Age _ Height Weight Race _ Sex J Other _ ,,is We '11, r, n • ( )s r a competent adult, being duly sworn according to iaw, depose and state that I persona lly-aane{ecl. -to- pb ,? d a true and correct copy of the WRIT OF EXECUTION and Notice of Sherif's Sale issued in the captioned case on the date and at the address indicated above. COMMONWEALTH OF PENNSYLVANIA Sworn to and subscjiC?d? Notarial semi before me this day Donna S. Datleiter, Notary Public of p I , ! Emmaus Sm, LeFdgh County 35 / My Commission Expires Aug. 4, 2015 Notary: F It ,..?- l BY NOI S6:RVI.t) "I'M?a< ^rr,tai ••.ir.e1TA AS.S"170NOFNOTARIES On the day cf 20_, at _ o'clock - M . Defendant NOT FOUND because Moved Unknown No Answer Vacant Time of Attempt: Date of Attempt Sworn to and subscribed before me this day of 200 Notary: - By ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 AFFZL`n i? _ L,P SE__1TCE PLAINTIFF: Americhoice Federal Credit Union DEFEND N-1 The Estate of Caro( M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or interest from or Under the Estate of Carol M. Hench SERVE UPON: All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Henc 930 Gobin Drive Carlisle, PA 17013 SPECIAL INSTRUCTIONS: pLURS41 UANT TO COURT ORDER Served and made ;o o'clo k ?a COt!R i Oi: COMIMON ILL ;AS Ccinhcr)md COU'NTY `p COURT NO, 11-7039 Fn ? A •[ Ct C; TYPE OF ACTION _ (Z) XX WRIT OF EXECUTION and Notice of Sheriff's Sal ?*?. ? l' z Sheriffs Sale Date: 616112 SERVED _ pt) 'endant, on the 1 V day of Tn:.. a 28557-DN F-a t CD Jt2- , at Z c , } `11 w kebr.o Ur,V?- uommonweattn of Pennsylvania, in the manner described below; C ?? i-?o13 ur'i' S)c Defendant personally served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides, Defendant resides. Relationship is _ Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual plaa;of business. refused X Other r to ive tio namelrelanship. I Description: Age Height Weight _ Race Sex Other 1, (0.? ,}c lY Linn C (}y?,r! a competent adult, being duly sworn according to law, depose and state that I personally4+ancfed I) sfea _ a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned case on the date and at the address ndicated above. coMMONwEat.Tr+ of PEIVNSnvavra Sworn to and subscribed Nt#iv1al Seal before me this 'C hf` day Donna S. Danker, Notary Public of a4 20 / &mmm gory, Lehigh County Notary: !) l tc1 -- Sy My Cwwdsslon Expires Aug. 4, 2015 NOT SFRVED MEMBER, PENNSYLVANTA ASSOCIATION OF NOTARIES On the _` day 20?.. at _ o'clock M., Defendan+ NOT FOUND because Moved Unknown No Answer Vacant Date otAttempt: Result: I Swom, to and subscribed 1 before me this day of Notary: By ATTORNEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 I IW, Martha'E. Von Rosenstiel, P.C. M-Aha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 AMERICHOICE FEDERAL, CREDIT' UNION Plaintiff ,C, U0 2 12 }!AY -4 PH I Iwo RENNISYL':ANIA VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-7039 (e SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on May 1, 2012, true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. Orrstown Bank 77 East King Street PO Box 250 Shippensburg, PA 17257 I verify that the statements made in this affidavit are true and correct upon informatiop(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. Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff #28557CAM - SS Attorney for Plaintiff Dated: May 1, 2012, 2012 U.S POSTAL SERVICE CERTIFI ATE OF MAILINGe PAY BE USED FOR DOW511C AND fNTERNATIONAL MAIL. DOES PROVIDE FOR INSURANCE-POSTMASTER M-14' Z Rcccived From: 0 P MARTHA VON ROSIE 0001 669 649 SOUTH AVEMAi! '.' F.. UNIT 7 SECANE, PA 119018 Onc piccc t,f onitnary mail addtcsscd 1c: Affix fcc hca in stamps Qr, mclct postagc and PITMEN ®vw? .150 79 thP,' LC1t ?S F c ? A". rrstown an j 77 East King StrOet ? ox Shippensburg, PA 17257 - i 1 ' 1'S Form 381 1, Mar.19F? S l0 ?. Sq. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~ ~~~, ~1 wa~tttt~~rp~~;,, Jody S Smith ~ , , ,, ~, , Chief Deputy ~ . ~._ ; ~ ,.~ ., '_ ;' Richard W Stewart '-,;~E_r 'w - ,;_; ~- __. Americhoice Federal Credit Union Case Number vs. Carol MHench -Deceased, Estate Of (et al.) 2011-7039 -- ---~ - SHERIFF'S RETURN OF SERVICE 03/19!2012 06:56 PM -Deputy Valerie Weary, 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 930 Gobin Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County. ', 03/19/2012 06:56 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estat Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Estat of Carol M. Hench, Deceased, pursuant to Order of Court by "Posting" the premises located at 930 Gobin Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy) according to law. 03/19/2012 06:56 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estat~ Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Unknown Heirs, pursuant to Order of Court by "Posting" the premises located at 930 Gobin Drive, Nortdi Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 06/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice h d been given according to law, he exposed the within described premises at public venue or outcry at th Cumberland County Courthouse, Carlisle PA on June 6, 2012 at 10:00 a.m.. He sold the same for the sum of $20,000.00 to Attorney Nathan Wolf, on behalf of Americhoice Federal Credit Union, being the ~!, buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,575.92 SO ANSWERS, /.~- July 05, 2012 RON R ANDERSON, SHERIFF ry +/ ,~ , .,,~ SCHEDULE OF DISTRIBUTION Date Filed: 6/11/12 Writ Noo 2011-7039 Civil Term Americhoice Federal Credit Union -vs- The Estate of Carol M. Hench, Deceased and All Known and Unknown Heirs., Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or Associations, Claiming Right, Title or Interest from or Under the Estate of Carol M. Hench 930 Gobin Drive Carlisle, PA 17013 Sale Date: .Tune 6, 2012 Buyer: .?~merichoice Federal Credit Union Bid Price:, $ 20,000.00 Real Debt: $ 36,005.83 Interest: 941.28 Attorney Writ (hosts: 261.50 Total Due: $ 37,208.61 DISTRIBUTION: Receipts: Cash on Account (01/30/2012): $ 1,500.00 Cash on Account (06/06/2012): 2,000.00 <:redit Writ 2011-7039 Civil Term 16,500.00 Total Receipts: $ 20,000.00 .~ Disbursements: Sheriffs Costs North Middleton Twp Refund. of Advance Costs to .Attorney Martha Von Rosenstiel Paid to Atty Martha Von Rosensteil Credit Writ 2011-7039 Civil Term Total Disbursements: Balance for distribution: $ 1,575.92 64.60 1,500.00 359.48 16,500.00 ($20,000.00) 00.00 #28557CAM - DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 5263 Jacqueline F. McNa115~, Esquire / No. 201332 649 South Avenue. Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEL)ERAL CREDIT UNION Plaintiff SHERIFF'S COQY COURT OF COMMON PLEAS CUMBERLAND COUNTY V~S. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS. REPRF_,SF,NTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT. TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) NO: 1 I -7039 AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 J~1~~I1'18 F, MC~IY ,ESQUIRE, attorney for the Plaintiff in the abo~ e 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 930 Gobin Drive. Carlisle, PA 17013: !i I .Name and address of owners(s) or reputed owner(s) ~~, The Estate of Carol M.Hench, Deceased I 930 Gobin Drive j, Carlisle. PA 17013 !, All Known and Unknown Heirs,. Successors and Assigns. Representatives, Devisees, and All Persons, Firms, or Associations. Claiming Right, Title or Interest from or Under the Estate of Carol M. I~fench 930 Gobin Drive ~~, Carlisle, PA 1.7013 ~, 2. Name and address of defendant(s) in the judgment: The Istatc of Carol M.Hench, Deceased ', 930 Gobin Drive '~~, Carlisle. PA 17013 ', All Known and Unknown Heirs. Successors and Assigns. Representatives. Devisees. and All P .rso~:ls, ~~ ~ in Right Title or Interest from or Under the Estate <~l~ Carol M. I~ench Finns. or .AS.ociatrons, Clarm g 930 Uobin Drive '~ Carlisle. PA 17013 ~i 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: Wanda Frv 1772 W. Trindle Road Carlisle. PA 17015 5. Name and address of every other person who has any record lien on the property: ~~, NONE ~'~, 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: ', Carl K. Hench 9 30 Gobin Drive Carlisle. PA 1.7013 Charles A. Hench 930 Gobin Driv Carlisle, PA 17013 Melissa M atrese 930 Gobin Drive Carlisle, PA 170] 3 Melissa Matr~ese 172 West ~Trindle Road Carlisle, P.A 17013 7. Name and address of every other person of whom plaintiff has knowledge who has any inter~st in. the property which may be affected by the sale: ', Cumberland County Tax Claim 1 Courthouse Square Carlisle. P!1 17013 Cumberland Register of Wills County Courthouse Carlisle. PA 17013 Attorney General of the ti.S. C/O Assistanr, Attorney General 7lax Division L1.S. Department of Justice P.O. Box 227 Washin~toi~. DC 20044 PA Dept of Revenue Inheritance Tax Bureau Strawberry Square, I 1 th Floor Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square Carlisle. PA 1 ",'0 13 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 2182.30 Harrisburg. PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, P,A ] 7l 05 Pemisylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg. PA 1.7128-0603 Occupant 930 Gobin Drive Carlisle. PA 17013 I verify that the statements made in this affidavit are true and correct upon information and beli~f. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 rel Ming to unsworn falsification to authorities. ~~ Respectfully- Submi MARTHA E. VON ROSENSTIEL, P.C. ~Md a E. Von Kosenstie , ,sq ~re Jacqueline F. McNally, Esq~~ire ~__~ttorneys'orPlaintilf ~~, Dated: December 29. 201 28~57CAM-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue., Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff AMERICHOICE FEDERAL CREDIT COURT OF COMMON PLEAS UNION CUMBERLAND COUNTY Plaintiff : vs. No: 11-7039 THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWTI AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 930 Gobin Drive Car isle, PA l 70l 3 will be sold by the Sheriff of Cumberland County on I, Date of Sale: 06/06/2012 '~, Time of Sale: 10.:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17113. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. ~ 1-7039 in the Cow-t of Common Pleas of Cumberland County by Americhoice Federal Credit nio:n, Plaintiff against The Estate of Carol M.Hench, Deceased and All Known and unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Firms, or .Associations, Claiming Right. Title or Interest from or tinder the F;state of Carol M. Hench, Defendant(s). Judgment was entered on December 30; 201 1 in the amount of $36,005.83. The properly was seized and taken in execution as the property of The Estate of Carol M.Hench, Deceased and All Known and Unknown Heirs, Successors and Assigns, Representatives, Devisees, and All Persons, Finns, or Associations, Claiming Right, Title or Interest from or ~lnder the Estatie o:E Carol M. Hench. The property to be sold at Sheriff s Sale is described as follows: ALL THAT CERTAIN lot or piece of ground situate in North Middleton 'T'ownship, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Northern side of Gobin Street which point is a corner of L~~t No. 64 on the hereinafter mentioned Plan of Lots; thence Northwardly along Lot No. 64 a di tance of 152.6 feet to a point in line of Lot No. 80; thence Eastwardly along Lot No. 80 a dista ce of 75.1 feet to a point in line of Lot No. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet to a point in the Northern side of said Gobin Street; thence Westwardly along jthe Northern side of said Gobin Street a distance of 75 feet to a point, the place of beginning. TAX PARCEL NUMBER: 29-19-1639-032 ~, IMPROVEMENT'S: Residential Dwelling '~~, A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff o later than 30 days after said sale, and distribution will be made in accordance with the schedu e unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cwnberland Count Civil Action No. 11-7039. You should check with the Sheriff's Office by calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the tiling of 1:he Schedule of Distribution will be~ given. '~, R. Thomas Kline, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEI_:, P,C, Martha E. Von Rosenstiel, Esquire % No. 52634 Jacqueline F. McNally, Esquire / No. 201332 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 #28557-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue.. Suites 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintilf~ AMERICHOICE FEDERAL CREDIT UNION Plaintiff VS. THE ESTATE OF CAROL M.HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS. SUCCESSORS AND ASSIGNS. REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE. OF CAROL M. HENCH Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-7039 LEGAL DESCRIPTION ', ALL THAT CERTAIN lot or piece of ground situate in North Middleton Township, Cumberland Coun~y, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Northern side of Gobin Street which point is a corner of Lot No. 64~ on t e hereinafter mentioned Plan of Lots; thence Northwardly along I,ot No. 64 a distance of 152.6 feet to a oint in line of Lot No. 80: thence Eastwardly along Lot No. 80 a distance of 75.1 feet to a point. in line of Lot (o. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet t:o a point in the Northern side of said Go yin Street; thence Westwardly along the Northern side of said Gobin Street a distance of 75 feet to a point, he place of beginning. TAX PARCEL NUMBER: 29-19-1639-032 IMPROVEMENTS: Residential dwelling !~ TITLE TO SAID PR:EMISES IS VESTED IN Carol Hench, single person, her heirs and assigns, by D ed from R. Scott Martin and Pamela S. Martin, husband and wife dated Si21/2008 and recorded Si23i700$ in the County of Cumberland in Instrument #200817243. '~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-7039 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICHOICE FEDERAL CREDIT UNION, Plaintiff (s) From THE ESTATE OF CAROL M. HENCH, DECEASED AND ALL KNOWN AND UNKNOWN HEIRS, SUCCESSORS ,AND ASSIGNS, REPRESENTATIVES, DEVISEES, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS, CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER THE ESTATE OF CAROL M. HENCH (1) ~'ou 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 GARNISIlEE(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) [f property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $36,005.83 L.L.: $.50 Interest FROM 12/31/11 to 6/6/12 AT 6%, ~- y `~~< <%~-~ Attv's Comm: % Due Prothy: $2.25 Atty Paid: $261.50 Other Costs: ~~ y~+l~ S ~ Lts f~ ti ~ f,.~(Y~ ~= ~ ~, Plaintiff Paid: Date: 1/9/12 David D. Buell Prothonotary (Seal) BY~ Deputy RIQUES1'ING PARTY: Name: JACQUELINE ~. ~L-Y4~~y, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19108 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court 1D No. 201332 TRUE COPY FROM RECD D M Testimony ~ ~ I hefe unto set m hand ~ ~Carlisie, P ~ a ~ , 20 Pro notary `-~n~,lc~ Q , ~ \~ On January 30, 2012 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, known and numbered as 930 Gobin Drive, Carlisle, PA 17013, more fully described on Exhibit"A" filed with this writ and by this reference incorporated hereina Date: January 30, 2012 By : L.~.~.~- `~ ~ ~ ~.w --- ~_m For Claudia Brewbaker, Real Estate Coordinator ~~ .. '. '.4.. ~ ly .... ~ .:~ .:W i `1- .. CUMBERLAND LAW JOURNAL Writ No. 2011-7039 Civil Term Americhoice Federal Credit Union vs. The Estate of Carol M. Hench, Deceased and All Known and Unlmown Heirs, Successors and Assigns, Representatives, Devisses, And All Persons, Firms, or Associations, Claiming Right, Title Or Interest From or Under the Estate of Carol :M. Hench Atty.: Martha E. Vora Rosentiel ALL THAT CERTAIN lot or piece of ground situate in North Middle- ton Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a :point in the Northern side of Gobin Street which point is a corner of Lot No. 64 on the hereinafter mentioned Plan of Lots; thence Northwazdly along Lot No. 64 a distance of 152.6 feet to a point in line of Lot No. 80; thence Eastwazdly along Lot No. 80 a distance of 75.1 feet to a point in line of Lot No. 66; thence Southwardly along Lot No. 66 a distance of 150.7 feet to a point in the Northern side of said Gobin Street; thence Westwardly along the Northern side of said Gobin Street a distance of 75 feet to a point, the place of beginning. TAX PARCEL NUMBER: 29-19- 1639-032 IMPROVEMENTS: Residential dwelling TITLE TO SAID PREMISES IS VESTED IN Cazol Hench, single per- son, her heirs and assigns, by Deed from R. Scott Maztin and Pamela S. Martin, husband and wife dated 5 / 21 / 2008 and recorded 5 / 23 / 2008 in the County of Cumberland in In- strument #200817243. 54 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 an State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La~ Journal, a legal periodical published in the Borough of Carlisle in the County and State afores: 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 regularl 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, April 27, May 4, and 11, 2012 Affiant further deposes that he is authorized to verify this statement by the Cuml Law Journal., a legal periodical of general circulation, and that he is not interested in the matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as t:o time, place and character of publication are true. ~~ .--- 1sa arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this ~--~1 day of Ma~2012 i~; ~ ~~~ ~~__ _ Notary ~ ~s NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 .,-,The Patriot-News Co. 2020 Technology Pkwy Suite' 300 Mechanicsburg„ PA 17050 Inquiries - 717-•255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~be~latriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn 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 Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 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 daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she n Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this 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 behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted see stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Record in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY ~~ +` Sworn to and sut)scribed be'fQre t ' ;.. f the i the -he Sunday :ate th, 1949, Heir regular r said tatement as :atement on orally by the ig of Deeds This ad ran on the date(s) shown below: 04/27/12 05/04/12 ~._ _~ this 72 da~of Mey, 2012 A D. -_ Notary Public COMMONWEALlIi OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public Lower Paxton iwp., Dauphin County My Commission Expires Nov. 26, 20]5 MEMBER, PENNSYLVANIA. ASSOCIATION OF NOTARIES 05/11/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert: P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify the Sheriff s Deed in which Americhoice Federal Credit Union is the grantee the same having beer sold to said grantee on the 6 day of June A.D., 2012, under and by virtue of a writ Execution issued on t~e 9 day of January, .A.D., 2012, out of the Court of Common Pleas of said County as of Civil. Term, 12 X11 Number 7039, at the suit of Americhoice Federal Credit Union against Estate of Carol M. Hench is~ duly recorded as Instrument Number 201224356. IN TESTIMONY WHEREOF, I have hereunto set my hand _- and seal of said office this 1~.3 ___ _da~ of jF1 ~/ ~- ~' Recorder of ~I~eeds R of Cumberland Courtly, C,~rfisle, PA My Comm' an Expires the F~sl Monday p~ Jan. 2014 ,._____ a t~tw 7ann tM~lon Gr~idlt Yi ~Khewn ate' .._ ~asa0rs and TMsv Sabi b(C~a ~'~ E y~Dq ~nMal ~' T lotorpiece o ~' fo ~amdea aad d~bed as Bl G1NN,WG ata paint i~ the Nortdem si of~poiatisacomer ~ At No. ti4 ~ the b~eioafter mentioned of Lots; tkrnne Np~p,~~, ~8 Lot fI.a' ~ ~~~8 r:ur i~(o. 80 a distaeee of75.I feet to a point in line of LotNo. lily t2ieate Southa+ardly Lot Nd 66 a diatanoe~ of 1s0.7feet a point in the Northern side cad ~ Street; thence ~~rtheln side of said~Stree a aC75iF~Eb~pio~t,:tbep~e of bed;; s3 , r`~ PARCE(; R: 29-19-1639-032 ~~+ VESTED and ~ bushaod and wjfe sated sn>~ ~~~ s m #~g ~~' ~~+~rland m 1nsWment