HomeMy WebLinkAbout11-8329I'1 r l ? 1
1A
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 J' FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
l?
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ CIVIL ACTION - LAW
DEFENDANT MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
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 claims or relief requested by the
Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
P#aloln???
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objectiones a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
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.
SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30)
DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL
ASSUME THE DEBT TO BE VALID.
IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN
VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE
COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST 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 THE 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 REQUESTS 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/OR RECEIVED A DISCHARGE, THIS
IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1 sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
COMPLAINT
AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1
1. Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Margaret Mary Spatz a/k/a Margaret M. Spatz, ("Defendant"), is an adult
individual having a last known address of 3463 Chestnut Street, Camp Hill,
PA 17011.
3. On or about April 1, 2008, Defendant borrowed from and agreed to repay to
Members 1 s' TWENTY-FIVE THOUSAND THREE HUNDRED SIXTY-
FOUR AND 92/100 ($25,364.92) DOLLARS (the "Loan"). The Loan is
evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement
dated April 1, 2008 (the "Note") executed and delivered to Members 1st by
Defendant. A copy of the Note is attached hereto as Exhibit "A" and made
part hereof.
4. As security for the Loan, Defendant executed and delivered to Members 1 st a
mortgage ("Mortgage") also dated April 1, 2008, on all that certain
condominium situate in the Borough of Camp Hill, Cumberland County,
Pennsylvania, known and numbered as 3463 Chestnut Street, Camp Hill, PA
17011 (the "Property"). At all times relevant hereto, Defendant has been and
continues to be the record and sole owner of the Property. A description of the
Property is attached hereto as Exhibit "B" and made part hereof.
5. On or about April 11, 2008, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office at Instrument Number: 200811521. A true
2
and correct copy of the Mortgage is attached hereto as Exhibit "C" and made
part hereof.
6. The Note and the Mortgage have never been assigned by Members 1St and
remain held by it as a valid and subsisting obligation of Defendant.
7. Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1St bi-weekly installments of principal and interest in the amount of
at least $171.15, which bi-weekly payment amount was subsequently changed
to $170.83 each commencing on April 23, 2008 and continuing every two (2)
weeks thereafter.
8. Defendant is in default of Defendant's obligations under the Note as a result
of Defendant's failure to make payment to Members 1 st of the bi-weekly
payments due to Members 1 st as set forth in the Note in the amount of $170.83
each for July 13 and 27, 2011, August 10 and 24, 2011, September 7 and 21,
2011 and October 5 and 19, 2011 as more particularly set forth and described,
in part, in the Notice provided to Defendant under Act 6 attached hereto as
Exhibit "D" and made part hereof.
9. On or about September 14, 2011, Members 1St provided to Defendant via
regular, US certified mail, postage prepaid, return receipt requested, written
notice addressed to Defendant at Defendant's last known address, being the
Property, of its intent to foreclose Pursuant to the Act of January 30, 1974,
P.L. 13, No. 6, 41 P. S. section 101, et. M., ("Act 6") and in particular section
403 thereof. A copy of the said notice is attached hereto as Exhibit "D" and
made part hereof.
10.
II
12
13
14.
Pursuant to notice published by PHFA in the Pennsylvania Bulletin (41 Pa.B.
2789), Members 1St is not required to provide to Defendant notice of
Defendant's rights in accordance with the Homeowners' Emergency
Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S.
Section 1680.401(c), et. sec. ("Act 91").
US Postal form 3877 evidencing the mailing of said Notices is attached hereto
as Exhibit "E" and made part hereof.
Simultaneously, Members 1St forwarded to Defendant the same Notice as set
forth in paragraph 9 above addressed to Defendant by United States mail, first
class, postage prepaid, bearing the return address of Members 1St. The Notice
forwarded to Defendant in said manner has not been returned to the offices of
Members 1 st as undeliverable or otherwise.
Defendant is indebted to Members 0 in the amount of TWENTY-ONE
THOUSAND ONE HUNDRED FORTY-SIX and 46/100 ($21,146.46)
dollars itemized as follows:
a. Outstanding principal $19,567.54
b. Interest to October 31, 2011 719.14
c. Late fees 59.78
d. Attorney fees and expenses 800.00
e. Total due to Members 1St as of 10/31 /2011 $21,146.46
Defendant also agreed under the terms and conditions of the Mortgage that in
the event of default there under Defendant would pay, in addition to the
4
amounts set forth in paragraph 15 above, costs incurred by Members 1St as a
result of the institution of these legal proceedings.
15. The obligation owed to Members 1 st continues to accrue interest at the rate of
$5.4896 per day, through the date of payment and continues to accrue late
charges and attorney's fees.
16. Members 1St is not seeking a judgment of personal liability (or an in personam
judgment) against Defendant; however, Members 1St reserves the right to
bring a separate action to establish that right, if such right exists. If one or
more of Defendants have received a discharge of personal liability in a
bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt
to reestablish such personal liability discharged in bankruptcy, but only to
foreclose the mortgage and sell the Property in accordance with Pennsylvania
law.
17. As set forth above, Members 1 st has made demand upon Defendant to cure
the default under the Mortgage and the Note. However, as of the date hereof,
Defendant continues to fail and refuse to cure the default.
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment,
In Rem, against Defendant, Margaret Mary Spatz a/k/a Margaret M. Spatz, in the
amount of TWENTY-ONE THOUSAND ONE HUNDRED FORTY-SIX and 46/100
($21,146.46) dollars plus interest at the rate of $5.4896 per day, through the date of
judgment and at the legal rate thereafter until the date of payment, additional attorney's
fees and costs of suit as well as other costs and charges collectable under the Mortgage
and for foreclosure and sale of the mortgaged property.
5
Respectfully submitted,
Date: ta?T' ri1
r!'' p
Karl M. Ledebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
1ST CLOSED-END NOTE, DISCLOSURE,
11 IIIIII110-SELI&LI)
5000 L.oulse Drive, P.O. Big, 40 BCNROMER'9 NAME AWADDREBS (AjiRFFMENT
Mechanicsburg. PA 17055 MARGARET M SPATZ
MEMBERS 1' 3483 HE 7N ST
n.r•wamlrar C.IDp 170)1
M NUMBER
1-03
_ 102 4% D.nx.Ir:OWlR'a NAME
PAI AMOUNT
U FIXED U VAR LE
ANNUAL PERCENTAGE FI=it Ca?
fFnarllxd: Tne amoum of Fjay? ayls: The Bmounl
RATE: The coal W your uedit as a Th
cred p ovided to you or on your Yeany hie. cosbehalL ve id aver you haw
nts as athe0uled.
10.24 % S $ 25,384.92 CIO".61
mon union wl /dd bm•ryM a b Ins i:OM value. I roe vAR eha • q ^W naesn du,tripe Icon of Iles Uanwdan if Ina ( 1^dltha 1ss. Tne
low, and a MeI nevi e Its. than Arty lXer,sl rate IntfaaNS will r wR 1 Poe Met day of the mmtn. The r,le to
never ea hlpher Nan in,
Marini refs allowed by mentray monNS and Ba Annual Percentage Reb nalafed by 2% afl°r one Yea, lee bmPa our ban would Minal Inere..O toy For monlryale. if your loco was for (5.000 at
15% for 4B
Automatic Payment DjS,Svm1W Rai; Bluui- ew A?w epraed to melee
rill Your ANNUAL PERCENTAGE RATE Me bean yOUhffvlatl by.t to TM
a.e Aua'"i Payment Dtaeounisd Roe. This Isle will
cover le Increase by .20%N oub
the 0.00 o" la PayveeMS. In such a case, one affect of the kKaaase Nip be
V
on a a i able Rat* mf d0 MOWN and you cob" ON wbmaUC payment arralpal
Vk 0is Rate PnAmd Loons, If your ban N a voidable late ben and you quell
Mferred ANNUAL PERCENTAGE RATE wl then "q bmldbrg to change
PERCENTAGE RATE is 12% at lee Unla You WW T Na ban, your hil pnfared A
RATE WR then very aeooldlnp to Ibe IMl as disclosed In the Variable fil pro
FII PERCENTAGE RATE doMdo?eI Your tan Is. a Glad role ban
ebb 1a and YWWeWyfa
bnp.as proaesd saWSremain
Nummr oe Paymenls Amounl of Payrni PaYmsnl Frequency
Yal r I 259 $171.15 el-Welly - Beginning
weaft wB a: 1 $170.76 Final Due. On
Security: Cdaabnl aeferillp e1Mrl0ma M,WI Y'b Credk n
YAY r 0 cease Nis ban. You are Ne B
your Glens antra °6Pdik in the yl iont urity rMaest in_ bong punna
Puru
Credit
and:
Lau Ctury•: II a paymend baINavacby 10srJledrys a moo you WI Raqutnd D•poalt
b° cluNeO a lea Ma of s%
AMOUNT GIVEN TO YOU DIRECTLYS
AMOUNT PAID ON YOUR ACCOUNTS
PREPAID FINANCE CHARGE S
MAKE MODEL
OTHER (Describe): 3463 CHESTNUT ST
JMUK PERT" OERATE WadWO?NA ?IgvU??NUAL PERCENTAGE call n
RATE Do?is
1 the euloma0c P6Ymam anngemaM or Wt to manMln sufficient funds in your 44xunl to
Umd tiro tam 9 your loan. For %""Via. It VOW Automatic Payment Olacounted Rats is 10%
erne. Yaw rib wa Went" b 10.20%, resulng M I additional paymel
or a preferred roe, yew pretend disrcunl b taken at he lime you take wt III ben. TNI
n the Ildaa (n ch"cia d above), For axe", X a ",table rile Joel Inlal ANNUAL
NUAL PERCENTAGE RATE vOl be N/A%. Your initial preferred ANNUAL PERCENTAGE
Non Some.
#Wmd rate' Your ANNUAL PERCENTAGE RATE VIN be the preferred ANNUAL.
n effect.
When Payments Are Due Property Insurance: You may oDan properly
nsurance tram anyone you Want that is acoeoable to
M312008 the gqrtldfl union. if You pet the insurance from the
and I union you vA pay
0312MO10 $ N/A
25284,921 AmoUnl Pant to other, on your behal
$7,321*90 To a00sY RANAI
0.00 s3,0411 To CUMBERLAND COU
To
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14,793.44 S To
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TYPE VALUE
and/or Deposits or I = w'• ACCOUNT NUMBER AMOVNT -?•
TO. ACCOUNT NUMBER
w that me lerms and do Non, M Ne 3
inm one benow•r wa agree trial ON IM co d ° eau MA°^I aria Na ban and lorrky epeemmM beaja on
received c of lee Initial nfcm cf fns loan and sew gevemm peas 2 of Iles d6aArbM sha8 ePl+1y b Ulf loan. If tiMre is moo
tpy Meanly agMernenls and disclosure abl" 69reemenis p sus an shat apply to both join ill and aewnlly. You elduleW
c ORRO en taaD6 . mbnl. Co-slprbr. II yW we eIgnin9 as co-spot, you uknowle a 6090 that you have
ORROWERS 2SIGNATURE dP recerpl of the nI 10 w-slpner
iOATE
X (SEAL) C MAKER U -OTHER OWNER •• -SIGNE..
-SIGNER DATE IX0 (SEAL)
(SEAL) CO-MAKER •O7HER OWNER C) ^CO-SIGNER DATE
CO-MAKER •OTHEq OWNER Q •-COSIGNER DATE CO-MAKER (SEAL)
(SEAL) O 'OTHER OWNER C) ••CO-SIGNER DATE
'ems aelsa:.srr..,.sa a..arr.y wrwrl I•rl,e own r.,wrr le•r1 r (SEAL)
N.
a.fil ?l.,a..•r.y-Mr.w,wrM a,.rlnYwlr...I?rlM tr,. a.wuy Aa•.r,+t .. aal
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. ••Nn aw1 •'•• b•wrK Pr••.nr ••,. w.w•..nlw? y.M Y.,?wM aw w,a?.r?r,r
Y
You are tlairlp asked to patwrerNee this debt. Think carol NOTICE 70 C0.SIGNER _
PTYif You have to, and th YOM wane to accept pons ldeh(oly. You do. II the b0nower doefln'1 pay the debt, you ell haw to. urn afford Ir
Y may haw td Pay up to the full amorrq of he deb f b Be sure you
if the Dorraver does not
The. creditor can CDIbU "S debt fr PBY You may also hew 10 PAY Isla 1003 or Collection costs, whim increase this
can be used apalnst the burr °mI swithout uing f(r,l trying b Collect From the borrower. The creditor can use the some copedbn methods ainst you that
. This nplice is rat the o"rer' su a YOU- gamisNn0 your wages, etc. If this debt is ever in default, that record tact ma
contred Ihals aulrlp makes You liable for Ule debt. ceap0
y become a pan opains credit
Pape 1 of 2
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ALL THAT CERTAIN unit in the property known, named and identified as Chestnut
Street Condominium, located In the Borough of Camp Hill, Cumberland County,
Pennsylvania, which has been submitted to the provisions of the Pennsylvanla Uniform
Condominium Act 68, Pe.C.S. Section 3101, at. seg., by the recording In the Recorder of
Deeds Office of Cumberland County, Pennsylvania, a Declaration of Condominium, dated
June 12, 1997, in Record Book 549, Page 898, being Unit 4, together with a proportionate
undivided Inttlal Interest In the Common Elements, as defined in the Declaration of
Condominium, of 19.28% as shown on Exhibit "B" of the Declaration of Condominium.
BEING A PART of the same premises which The McNaughton Company, by its
Deed dated January 27, 1999 and recorded January 28, 1999 in the Office of the Recorder
of Deeds in and for Cumberland County, Pennsytvenla in Book 193, Page 356, granted and
conveyed unto Jeanne M, Alvord, The said Jeanne M. Alvord died intestate on September
3, 2004 and Donna Keammerer was appointed Administratrix for the Estate, docketed to No,
2004-00851 by the Register of Wllls of Cumberland County.
UNDER AND SUBJECT TO:
(a) Any and all easements, licenses, exceptions, reservations, Covenants,
agreements, conveyances and restrictions which affect the premises and are visible by
Inspection of the premises.
(b) Any and all easements, licenses, exceptions, reservations, covenants,
agreements, conveyances and restrictions contained In any and all prior agreements leases,
instruments, deeds, grants and conveyances affecting the oremises. ,
Said premises is known as 3463 Chestnut Street, Camp Hill, PA 17011
Being the same premises which Donna Keammerer, Administratrix for the Estate of
Jeanne Marie Alvord, by her deed dated January 18, 2005 and recorded in the
Cumberland County Recorder of Deeds Office at deed book 267, Page 1034 granted and
conveyed onto Margaret Mary Spatz, a widow.
k
Exhibit 66B99
PROM :CUMBERLAND FAX NO. :7172459661
Prcpatnd By: Members Ist PCl1
5000 Louisu Drive
Mechanicsburg, PA 17055
Return To: When recorded mail to:
F lTlii IN•S`UI'tAANGE
IIRST AMENCAN
1, N,j),6 S ADVANT AGE
tiUO SUPBR1O,RAVENUE, SUi 20'
CI.EVELANA, OHIO 44114
/ I ATTN.- ,P'TI120
MORTGAGE
Madc 04/0117.008. .
l r?" , ? Iletween
MARGARET MARY SPAT7.
Aug. 31 2009 07:29AM P1
na ca ORM
And
MEMBERS Or FEDERAL CREDrf uNION (hereinafter callcd "Mortgagee")
Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note's of avert date herewith, payable to the order of Mortgagee in the principal sum of
= 25, lawful money of the United States of America, and hax Ven vided therein
fix payment of any mopeys loaned or advanced thereundtr by Mortgages, together with
interest thereon at the raw provided In the Note, in the manner and at the times thore:in act forth, and
containing certain other terms and conditions, all of which are FpecMcally incorporatud herein by
rtfcrcnce;
Now, Therefore, Mortgagor, in consideration of said debt or principal sutra and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mat8agee,
All that oerWn property ofdw Mortgagor located in CAMP HILL
BOROUGH Cum land -Bounty, Pennsylvania
SEE EXHIBIT "A"
Which currently has the address of 3463 C1113-.S'1'NIIf S7
CgMR OR Pennsylvania 17011
[City) )Zip Code)
Awt No
Apptr) 25341703
009P 1 of 4
0&31/2009 8:01.47 AM Exhibit "C"
Inst i! 901101 1.591 . Psann I of f
FROM :CUMBERLAND FAX NO. :7172459661 Aug. 31 2009 07:30AM P2
'T'"er with the buildings and improvements erected thereon, the appurkmances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof
fo Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However, That If Mortgagor =hall pay to Mortgagee the aforesaid debt or principal man,
including additional loans or advances and all other sums ptlyablc by Mortgagor to Mortgagee ftwounder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covtahanta, conditions and agreements hereinafter sea forth, then this Mortgage and the estate hereby
granted seal conveyed shall become void.
This Murtgage is executed and delivered subject to the following covenants, conditions and
Agramnents:
(1) The Note secured hereby shall evidence and this Mextgagc shall cover and be security for any
future loans or advances that may be made by MOKVVgeAe to Mortgagor at any tltne or times hereafter and
intendod by Mortgagor and Mortgagee to be so evidaeoed and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time utttil said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, what and as the same shall become due and payable, all taxes, assesamemmts, sewer and water
rents, and all other charges and claims assessed or levied Fran time to time by any lawful authority upon
any part of the mortgaged promises and wft shall I or might have priority in lien or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged promises and pay and discharge all
m vitanios' liens which may be filed against said prmnises and which shall or might have: priority in lien
or payment to the debt secured hereby, (c) pay and discharge; any documentary stamp or other tax,
including interest and penalties thmorh If any, now or hereafter becoming parable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and c:ha pea thereon such policies of llttazard and liability insurance as Mortp$pe may from time to time
require upon the buildings and improvements now or hereafter erected upon tier; mortgaged premises,
with loss payable classes in favor of Mortgagor and Mortgages as their respective interests may appear,
and (c) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
ohapea; provided, however, that Mortgagee may at its option require that scans sufficient to discharge
the Foregoing charges he paid in instalfmutts to Mortgagee.
(3) Mort or ahall maintain all buildings and improvements subject to this Mortgage in good and
substantial ear, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
AoatW Appm 25341703 aape2ar4
08/3112000 8:01;47 AM CUMBERLAND COUNTY
fn.st.# 200811521 • Page 2 of E
FROM :CUMBERLAND
FAX NO. :7172459661 Aug. 31 2009 07:30AM P3
(4) In the event M or ""loots or refiuft to
maintain the buildi ry the charg" mOWoneA at he above, or fails h
principal debt secu d hereby, s eSantaaij , Mortgagee gee may do as,, add the cost thereof to the
&'?Y, and colle Dollect the same as a part of said principal debt
Mo ( 6d pmt covenants and agrcoa not to create, nor permit to accrue, upon all or
t3 any debt, lien or charge which would be prior to, or on a Parity with any part of the
jee,
with,
the lien of this
(6) In case default be made for the space of thirty (30) days in the
principal or interest pu?pt to the terms of the Nutt, or in the per payment of any in r of any of other obligations of the Note or this M p forntanw by Mortgage of any of the
laen_a ar +,dv o?4 the emirs unpaid balance of said princip? sum, additional
ancos and all other Rums, Paid by Mott?co pursuant to the terms o,C jhe i to aI r this
Mortgage, together with unpaid interest thereon, stall at the option ofMortgagee and without notice
becumu immediately due and paynb* and fioreelosura proceed
Mortgage and prasecu? to judgment, execution and sale for may be brought forthwith on this
casts of suit and an the ooilcc?ion of the sarr,e, together with
0, larger costs whichever is the attorney's M lion ? collecticm of five poteent (3%) of the total indebtedness or
to o n inss, waives stay ofexeeutjpn, theme gA of inc" sition and ext1 engion f tt?? all n said
to codgnnation of any party levied upon by virtue "ferry such execution, and waives apayment, l xemo games
from lery and sale oPany property that nwow is or hereailar may be exempted law.
(7) Upon payment of ail sums secured by this Mortgage, this
Mortgage terminate and become void. Allan such occurrence, Mortgagee shallc ant de estate conveyed shall
Mortgagor shall pay any recordation costs. Mortgagee may char satisfy this Mortgage. role In Marc, but only if the fee is paid to a third party for serviovs rendered and the cchha 8
ng of the feol3
permitted under Applicable Law
The covenants, conditions and agreements contained in this Mortgage shall bind, and the boncfits shall
inure to, the res,peotivo parties hereto and their reapeedivc heirs, executnrg admini
asstg bns, e jsadohnif this Mortgage is cxccutad by more than one party, the under
shall be
and several. talctnga lla?f;,lity p? chnd
Am No
ApplD 25341703
polio 3 of 4
31/2000 8;01:41 AM
CUMSFRI ANr1 O..rn urrv
FROM :CUMBERLAND
FAX NO. :7172459661 Aug. 31 2009 07:30AM P4
Witness the due excwtion horoof the day and year flrat above writtcat,
E Y SPATx
Conunonwealth of Pennsylvania
County of (l1iHRFRLANTI ) as:
On this, the day of APR ,2008 ?fprti
^n CAL Salo r?,. , the und?rsrgn o ccr, pernall
Y appeared
ss?t ctorily proven to mo to the
acknow n s whose names)is/are ye ar
acknowledged that he/she executed
t e' wr in Mortgage, and
me, ?c for tho purposcs (herein oontained two
In Witness Wbereor, T hcrcuntO set my hand and official seal.
MY commission expires:
nr_t1 m
Members 14T Federal Credit Union, Mortgagee within
is 5(X)0 Louise I)rive, Mechanicsburg, PA 17055. hereby certifies that fts residence
By . Q4
Aa,No_ Appn 25341703
Not?ipl S" ...`.`II
LMan A H OF PE y`yq?
loodeso T
,
sbs? ?Ecpiras Alu, 19, 2600
lderrlber P 0gtV' Ivr+.n:g ^^a. ip`an of Notafies
Pa<p 4 0t 4
3712009 8:01:47 /M CU1NRh'Rr ANh rrn ru'rv
FROM :CUMBERLAND FAX NO. :7172459661 Aug. 31 2009 07:30AM P5
EXHIBIT A
All that certain property siL.uated in the Borough of Camp
Hill, in the County of Cumberland, Commonwealth of
Pennsylvania , and being described as follows: 01-21-0275-057
U4, Being more fully described in a deed dated January 18,
2005 and recorded January 19, 2005, among the land rocords of
the County and State set forth above, in Deed Volume 267 and
Page 1034:
Permanent parcel Number: 01-21-0275-057 U4
MARGARET MARY SPATZ, WIDOW
3463 CHESTNUT STRaHT, CAMP HILL PA 17011
Loan Reference Number . 253417
First American Order No: 14400397
Identifier: L/FIRST AMERICAN LENDERS ADVANTAGE
11111111 1? Ili VATZ
PA
FIRST AMERICAN ELS
MoRTOAM
QIIIA?INNNiIIMI111N1 I?IAII?I?Y
/31/2009 13:01:47 AM
CUMBERLAND COUNTY
Ines ti illIlAl lr.o1 - Onivn R of a
-ROM :CUMBERLAND FAX NO. :7172459661 Aug. 31 2009 07:31AM P6
ROBERT P. ZIEGLER
''CORDER OF MEDS
CUMBEM AND COUNTX
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-20.6370
lustrumeat Number - 240811521
Recorded On 411 W008 At 1:08:35 PM
Instrument Type - MORTGAGF.
Invoice Number - 18521 User I1D - Kw
f Mortgagor - SPATZ, MARGARET MARY
* Mortgagee - MEMBERS 1ST IREDERAL CR UN
* Customer - FIRST. AMERICAN
STAT$ WRIT TAX $0.50
STATE'ics/ACCESS TO $10.00
JUSTICE
RECORDING >us - $13.50
ARCOTORR OF DEEDS
AFFMDABLZ HOUSING $11.80
COUNTY ARCHIVES M $2.00
ROD ARCHIVES FEE $3.00
'T'OTAL PAID $40.50
* Total pages - b
Certification Page
DO NOT DETACH
This page Is now part
of this legal document.
I CerdfY this to be recorded
in Cumberland County PA
RRCORDFR OF D rneS
" - Informsdon devoted by vv asterisk may chance during
the verif nVon procpw and may not be refleLud an this pW
31/2009 8:01:47 AM
C1JMAFi21 Aun (-no iklTv
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Members lst Federal Credit Union (hereinafter we, us or ours) on your property
located at 3463 CHESTNUT ST, CAMP HILL,PA 17011 IS IN SERIOUS DEFAULT [because you have
not made the bi-weekly payments of $170.83 for 07113111, $170,83 for 07127111, $170.83 for 08110111,
$170.83 for 08124111, $170.83 for 09107111
.and/or because
The total amount now required to cure this default, or in other words, get caught up in your payments, as of
the date of this letter, is $854.15
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $854.15, plus any additional bi-weekly payments and late charge which may fall due during this
period. Such payment must be made either by cash, cashier's check, certified check or money order, and
made at:
Attn: Collections Department
c/o Memberslst Federal Credit Union
P.O. Box 40
5000 Louise Drive.
Mechanicsburg, PA 17055
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be
considered due immediately and you may lose the chance to pay off the original mortgage in monthly
installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also
intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheri„ to pay off the mortgage debt. If we refer
your case to our attorneys, but you cure the default before they begin legal proceedings against you, you
will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal
proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over
$ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable
costs. If you cure the default within the thirty day period, you will not be required to pay attorney's.fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have
begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the
Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus
any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the
foreclosure sale [and perform any other requirements under the mortgage ]. It is estimated that the earliest
date that such a Sheriffs sale could be held would be approximately six months from now. A notice of the
date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time exactly what the required payment will be
by calling us at the following number: (717) 795-5165. This payment must be in cash, cashier's check,
certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sherifl?s sale, a lawsuit could be started to evict
you.
Exhibit "D"
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO
SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU
MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT,
PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES
AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS
UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS
DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
Ifyou cure the default, the mortgage will be restored to the same position as if no default had occurred
However, you are not entitled to this right to cure your default more than three times in any calendar year.
Certified Mail: 91 7199 9991 7030 0943 7500
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4130/2007)
Notice Disclosure Office of Housing
Legal Rights and Protections Under the S RA_
Servicemembers on "active duty" or "active service," or a dependent of such a
servicemember may be entitled to certain legal protections and debt relief pursuant to the
Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA).
31ho May Be Entitled to Legal Protections Under the SCRA?
Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard;
Active service members of the commissioned corps of the National Oceanic and
Atmospheric Administration;
Active service members of the commissioned corps of the Public Health Service;
United States citizens serving with the armed forces of a nation with which the
United
States is allied in the prosecution of a war or military action; and
Their spouses.
What Legal Protections Are Servicemembers Entitled To Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or servicemember and
spouse
jointly, prior to entering military service shall not bear interest at a rate above 6
percent during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is
filed during, or within 90 days after the servicemember's military service, a court
may stop the proceedings for a period of time, or adjust the debt. In addition, the
sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or
within 90 days after the servicemember's military service unless the creditor has
obtained a court order approving the sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home
loans.
How Does A Servicemember or Dependent &guest Relief Under the SC A?
In order to request relief under the SCRA, a servicemember or spouse, or both,
must
provide a written request to the lender, together with a copy of servicemember's
military orders. The Lender providing this Notice is Members 1" Federal Credit
Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg,
Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
The U. S. Department of Defense's information resource is "Military
OneSource".
Website: hhgptt ://www.militgE onesource.com
The toll free telephone number for Military OneSource are:
o From the United States: 1-800-342-9647
o From outside the United States (with applicable access code): 800-
3429-6477
o International Collect (through long distance operator): 1-484-530-5908
Servicemembers and dependents with questions about the SCRA should contact
their unit's Judge Advocate, or their installation's Legal Assistance Officer. A
military legal assistance office locator for all branches of the Armed Forces is
available at http://Iegalassistance.law.af mil/content(locator.php
OCT-21-2011 18'22 Prom•11E112Ep9 19T 7177995207
• Form 3877
mauers Nameano Aaaress; Permit NUmi
Membw,4V deral Credit Union 9223844001
5000 Louise Or Sequence
MECKMICSBURG, PA 17055 CM0850
To • 7179321x317 P-9/9
Page.I
MAC Cert Ver. Num.
SendSulte • MAC v6.25.6.25.L
PC, ID#/ Addr--wee Norm Pia ES ES Inwtod Due Total
Article # Detivory Address Type Fee V&%m Sender Charge
[9000000'0424 _ Spot 0.440 C 2.850 D.00 4.440
9171999991703009437 aw ERR 1.150
Cmnp A 17011
< , .?
Page Totals: 14
6.160 56:liQR?,?: .
Cum Totals: 1$ 7.920 72.000 t?
Form 3877 (Facsimile) SendSuite • MAC v6.25.6.25I ti
62.160
79.920
Exhibit "E"
10/25/2011 13:46 7179320317 KARLLEDEBOHM PAGE 08/08
MEMBERS 1' FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
TN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA.
NO.:
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT : CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
VERIFICATION
I, Laura Hoke, Business Collections .Specialist for Members 1-"Federal Credit
Union, being authorized to do so on behalf of Members I't Federal Credit Union, hereby
verify that the statements made in the foregoing pleading are true and correct to the best
of, my information knowledge and belief. I understa0d that false statements are made
subject to the penalties of 1. S Pa. C.S.A. Section 4904, relating to unworn falsification to
authorities.
Members 1" Federal Credit Union
By:
Laura Hoke, Business Collections
Specialist
7
rD
-7 --t ,
N
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF/MOVANT
Vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 2011- 8329
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
MEMBERS 1sT FEDERAL CREDIT UNIONS'S MOTION FOR ALTERNATE
SERVICE PURSUANT TO RULE OF CIVIL PROCEDURE 430
AND NOW, comes Members 1St Federal Credit Union, by and through its
attorney, Karl M. Ledebohm, Esq., and respectfully avers the following in support of this
Motion for Alternate Service:
1. Pursuant to Local Rule 208.3(a)(2), no judge has ruled upon any other issue in the
same or related matter.
1
2. No attorney has entered an appearance in this matter on behalf of Defendant and;
therefore, Local Rule 208.2(d) does not apply in seeking the concurrence of
opposing counsel is not possible.
3. Movant is Members 1st Federal Credit Union ("Members 1St"), a National Federal
Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg,
PA 17055.
4. Defendant/Respondent, Margaret Mary Spatz a/k/a Margaret M. Spatz,
("Defendant"), is an adult individual having a last known address of 3463
Chestnut Street, Camp Hill, PA 17011.
5. On or about November 3, 2011, Members 1St filed a complaint in mortgage
foreclosure (the "Complaint") to the above captioned matter with regards to the
real estate and improvements erected thereon owned by Defendant at 3463
Chestnut Street, Camp Hill, PA 17011 (the "Property").
6. On December 5, 2011, the Sheriff for Cumberland County, through his deputy,
reported to Karl M. Ledebohm, Esq., attorney for Members 1 st, that on November
8, 2011, the Sheriff s Deputy attempted service of the Complaint upon Ms. Spatz
at the Property at which time Mrs. Spatz, known to the Deputy due to prior
service of process, opened the door at 3463 Chestnut Street, Camp Hill, PA
17011, and, upon seeing the Sheriff's Deputy, slammed the door and yelled,
"Come back tomorrow!"
7. The Deputy for the Sheriff further reported that seven (7) separate attempts to
serve the Complaint upon Defendant at 3463 Chestnut Street, Camp Hill, PA
17011 were made after November 8, 2011 with no success.
2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smit 4?y?tr pi Cu?nbrx/;?
h
Chief Deputy O??_ .yr
Richard W Stewart
Solicitor OFHGE OF THE 81'EIRIFF
Members 1st FCU
vs.
Margaret Mary Spatz
Case Number
2011-8329
SHERIFF'S RETURN OF SERVICE
12/05/2011 11:30 AM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on December
5, 2011 at 1130 hours, he was unable to serve a true copy of the within Complaint In Mortgage
Foreclosure, upon the within named defendant, to wit: Margaret Mary Spatz. After several attempts the
tenants of 3463 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011 are avoiding
service and will not answer the door.
SHERIFF COST: $73.44 SO ANSWERS,
December 05, 2011 RON R ANDERSON, SHERIFF
Exhibit "A"
1246912611 16:45 7179320317 KARLLEDEBOHM PAGE 06/08
A1H'F1[13,A WT
1, Arlainda Dintaman, Collateral Liquidation Specialist for Members 1't Federal.
Credit Union ("Members 1't" ), do hereby report the following information in support of
Members 1't Federal Credit Union's Motion For Alternate Service Pursuant to Rule of
Civil Procedure 430 ("Motion for Alternate Service:
1. The only addresses which Members 0 possesses with regards to the Defendant is
the property identified in the Motion For Alternate Service immediately preceding
this Affidavit known as 3463 Chestnut Street, Camp Hill, PA 17011 (the
"Property"). The Motion for Alternate Service is incorporated herein. by rcference
as if set firth herein, in full.
2. On or about December 5, 2011, Members 1't, through its attorney, Karl M.
Ledebohm, Esq., contacted the Cumberland County Sheriffs Office and was
informed that on November 8, 2011, the Sheriffs Deputy attempted service of the
Complaint upon Defendant at the Property at which time Ms. Spatz, being known
to the Deputy due to previous service of process, opened the door at 3463
Chestnut Street, Camp Hill, PA 17011, and, upon seeing the Sheriff's Deputy,
slammed the door and yelled, "Come back tomorrow!"
3. Karl M. Ledebohm was further informed by the Cumberland County Sheriffs
office that since November 8, 2011, seven (7) attempts to serve the complaint
upon Ms. Spatz at the Property were made by the ShediTs office without success.
4. On December 9, 2011, Members 14, through its attorney, Karl M. Ledebohm,
Esq., contacted the Cumberland County Tax Assessment Office and confirmed
that real estate tax bills for the Property continue to be sent to the Property
addressed to Defendant.
5. On. December. 9, 2011, Members I", through its attorney, Karl M. Ledebohr»,
Esq., contacted directory assistance for Camp Dill, Pennsylvania and. was
informed that there is no listing for Defendant in Camp Hill, Pennsylvania.
6. On December 9, 2011, Members I', through its attorney, Karl M. Ledebohm,
Esq., contacted the Cumberland County Bureau of Voter Registration and
Elections and was informed that the only address on file for Defendant is the
Property at 3463 Chestnut Street, Camp Mill, PA 17011.
Exhibit "B"
. 1240-9/2011 16:45 7179320317 KARLLEDEBOHM PAGE 07/08
6 (,4dber )9, Zol
7. On or about Do-- Hb0N9, , Mem l l obtained a Transunion Consumer
Credit Report which reflected the current address for Defendant as being the
Property at 3463 Chestnut Street, Camp Hilldw PA 17011.
.DccCr,1 ? IZZv?1
8. On or about JuTy , Members 1 '` co da search of utility records
which confirmed that Defendant's current address is the Property at 3463
Chestnut Street, Camp Hill, PA 17011.
9. On or about December 9, 2011, Members 1" received the S.herifirs Return of.
Service dated December 5, 2011, a copy of which is attached to the Motion and
made part hereof by reference, which indicates that after several attempts to serve
the Complaint upon Defendant at the Property, it was detembed that the
occupants of the Property, "... are avoiding service and will not answer the door."
10. For the reasons set forth herein and in the Motion for Alternate Service, Members
13t has reason to believe that Defendant continues to reside at the Property and is
deliberately and improperly avoiding service.
Respectfully submitted,
Date: 12-1 Arlanda Dintaman, Collateral
Liquidation Specialist, for Members
I" Federal Credit Union
Sworn and subscribed fore me,
a Notary Public, this '1n day of December, 2011.
- (Notary)
My commission expires: )Vd r. 12 Z d 17,
J
?OMMONWEALTH OF PENNSYLVANIA
Notarial $aal
Daniel F Summers, Notary Public
Swatare Twp., Dauphin County
My Commission Expires Nov. 12, 2012
Mombar, %r.Lnsyivania Association of Notaries
2
12/09/2011 16:45 7179320317 KARLLEDEBOHM PAGE 05/08
MEMBERS OT FEDERAL
CREDIT UNION
PLAINTIFF/MOVANT
Vs.
MARGARET MARY SPAT? a/k/a
MARGARET M. SPAT?
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO.: 2011- 8329
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
VERIFICATION
I, Arlanda Dintaman, Collateral Liquidation Specialist for Members 1'` Federal
Credit Union, being authorized to do so one behalf of Members 0 Federal Credit Union,
hereby verify that the statements made in the foregoing pleading are true and correct to
the best of my information knowledge and belief. I understand that false statements are
made subject to the penalties of 18. Pa. C.S.A. Section 4904, relating to unsworn
falsification to authorities.
Members I' Federal Credit Union
?ex" ce??
"y:
sir
A:r anda -„__
Di , Collateral
Liquidation Specialist
4
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 J' FEDERAL
CREDIT UNION
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2011-8329
Vs. :
MARGARET MARY SPATZ a/k/a CIVIL ACTION -LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 10h day of December,
2011, I served a true and correct copy of the foregoing Members I' Federal Credit
Union's Motion for Alternate Service Pursuant to Rule of Civil Procedure 430 and
proposed Order upon the defendant by first class mail, postage prepaid, addressed as
follows:
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
Date: December 16, 2011
Attorney for Plaintiff
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF/MOVANT
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 2011- 8329
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
ORDER
AND NOW, this sr day of eLeM 6f-C , 2011, upon
consideration of Members 1St Federal Credit Union's Motion for Alternate Service
Pursuant to Pennsylvania Rule of Civil Procedure 430, it is hereby
ORDERED THAT Members 1" Federal Credit Union shall make service of the
Complaint, and any and all subsequent and/or additional documents required to be served
upon Defendant pertaining to the foreclosure action filed to the above captioned matter
by posting the Property and by certified and regular U.S. Mail, postage prepaid,
addressed to Defendant at the Property known and numbered as 3463 Chestnut Street,
Camp Hill, PA 17011.
By the Court:
Notice addresses:
Attorney for Plaintiff/Movant:
? Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
Defendant/Respondent:
Margaret Mary Spatz
3463 Chestnut Street,
Camp Hill, PA 17011
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PROTHONOTAR f
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
G012 JAPE -5 AM 10.35
U PENNSYLVANIA TY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2011-8329
CIVIL ACTION -LAW
: MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
To the Prothonotary:
Please reinstate the complaint filed in the above captioned matter.
submitted,
Date: January 3, 2012
earl M. `Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
144q
? ? ala9ya`{
iLED-OFFICE
r` TEL PROTHONOTARY
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
2012 JAN 12 PM 1: 15
CUMBERLAND COUNTY
PENNSYLVANIA
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2011-8329
MARGARET MARY SPATZ a/k/a CIVIL ACTION -LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
RETURN OF SERVICE
To the Prothonotary:
As required by the Order of Court dated December 21, 2011, a true and correct
copy of the complaint filed in this matter was served upon the defendant, Margaret Mary
Spatz a/k/a Margaret M. Spatz, on January 10, 2012, by regular mail and certified mail
addressed to defendant at 3463 Chestnut Street, Camp Hill, PA 17011, as set forth on
U.S. Postal Forms 3800 and 3811 attached hereto as Exhibit "A" and made part hereof.
Respectfully
Date: January 10, 2012
Karl M' Ledebohm, Esq. d,
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
w
¦ Complete items 1, 2, and 3. Also complete A. Signature
item 4 if Restricted Delivery is desired. ? Agent
¦ Print your name and address on the reverse X ? Addressee
so that we can return the card to you. g, Received by (Printed Name) C. Date of Delivery
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1 Article Addressed to:
Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
G amp Hi 11. PA 17011
D. Is delivery address different from item 1? ? Yes
If YES, enter delivery address below: ? No
3 Service Type
Certified Mail ?
Express Mail
? Registered /
.? ?geturn Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number
(Transfer from servicetabe)) 7010 2780 0002 6547 4706
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
postal CERTIFIED
Provided
-n (Domestic Maii On1Y; No insurance Coverage 0
a
a
Postage $
r
Certified Fee ^
+ ?` ??ostmar
ru " q? Hers
Return Receipt Fee 7
Ca (Endorsement Required)
Restricted Delivery Fee?? ^
a
(Endorsement Required) _
O
CO,
Total Postage & Fels
ru Sent o Margaret Mary Spatz a/k/a
_ _--. Margaret M. Spatz
Street, Apt -[W.'
o.;
C3 or Po Box No. 3463 Chestnut Street
17' city, sure, ziP+a Camp Hill, PA 17011
WIM
A
Exhibit "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
V at CURIb"'fjr
?. 3? PF;07Udtii'AR`
2012 .SAM 17 AM 11: 16
Richard W Stewart
Solicitor
'?.:E . ...ERIFF
CUMBERLAND COUNTY
PENNSYLVANIA
Members 1st FCU
vs Case Number
.
Margaret Mary Spatz 2011-8329
SHERIFF'S RETURN OF SERVICE
01/10/2012 12:51 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
January 10, 2012 at 1251 hours, she served a true copy of the within Complaint in Mortgage Foreclosure,
upon the within named defendant, to wit: Margaret Mary Spatz, pursuant to order of court by posting the
premises located at 2463 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011 with a
true and correct copy according to law. M\ JA???
MICHELLE GUTSHALL, DEPUTY
SHERIFF COST: $49.44
January 11, 2012
SO ANSWERS,,
RON R ANDERSON, SHERIFF
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F53 15'°
"!..'11BER .,,
Karl M. Ledebohm, Esquire n' r S Y p `'t
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO. 11-8329 Civil
Vs.
MARGARET MARY SPATZ a/k/a CIVIL ACTION -LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter judgment in the above captioned proceeding in favor of Members 1 St
Federal Credit Union, Plaintiff, and against the Defendant, Margaret Mary Spatz a.Wa
Margaret M. Spatz, in the amount of TWENTY-ONE THOUSAND SEVEN
HUNDRED THIRTY-THREE AND 85/100 DOLLARS ($21,733.85) plus interest at the
legal rate on and after entry of judgment until the date of payment, additional attorney's
fees and costs of suit and for foreclosure and sale of the mortgaged property. Judgment is
entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Defendant,
Margaret Mary Spatz a/k/a Margaret M. Spatz, to Plaintiff's Complaint within twenty
(20) days of service thereof and after a 10-day Notice was sent.
aM\'%N V•'-0Pd O11-3
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Date: February 14, 2012
Respectfull ubmitted,
j
Karl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notice of intent to take default judgment was forwarded to
Margaret Mary Spatz aWa Margaret M. Spatz by United States Mail, first class, postage
prepaid on January 31, 2012. The aforesaid notice was contained within an envelope
bearing the return address of the undersigned. The notice has not been returned to the
undersigned as undeliverable or otherwise. A copy of the notice and Postal Form 3817
are attached hereto and marked Exhibit "A".
r
Karl M. Ledebohm, Esquire
Kti irl M_ I.edehohm_ Esquire
1' (). I3os 17
New C'umherland- PA 17070-0 17
(717)938-6929
MEMBERS I" FEDERAL.
CREDIT t1NION
I'l AINTIFI
IN THE COURT OF COMMON PLEAS
CI IMBER1, AND COi1NTY.
PENNSYLVANIA
No. 2011-83129
V 's.
MAROARE"I'MARY SPA`1'Z a/k/a :CIVIL ACTION - LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGt; FORF,CLOSIIRI?
IMPORTANT NOTICE
Date: January 31, 2012
I O: %largarct Mary Spatz a/k/a
Margaret M. Spatz
x,46 i Chestnut Street
(Vamp Dill, PA 17011
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT T141S OFFICE IS A DEBT
COLLECTOR AND THIS LETTER AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL 13E USED FOR THAT
PURPOSE.
YOU ARE IN DEFAUL1'BECAUSE. YOU IIAVE FAILED 'I'O FNIVR A
WR1T"ITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
\VRITING WITI I THE COURT YOUR DEFENSES OR OBJEC'TIONS T'O 'I"IIE;
C'LAIlt1S SET FORTH AGAINST YOU. UNLESS YOI I AC'"I'WI"I-F-IIN TIN DAY'S
FROM I IIE DATI: OF 1'1-IIS NOTICE', A Jl1DCiMEN'I' MAY BL: EN"IT RIJ
AGAINS"I- YOt -WLI"HOU'I" A I-FEARING AND YOU I MAY I,OSI YC)UR
PROPLR"n' OR O"LI I -'R IMPORTANT RIGI I"TS.
Exhibit «A"
Y'OLl SHOULD TAKE TH1S PAPER "1'O YOUR LAWYER AT ON(-'[". IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELFPI TONE THE OFI?1( F:; SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOCT HIRING A 1,AWYF,R.
IF YO(' CANNOT AFFORD TO HIRE: A 1,AWYFR, THIS OFFI('F MAY BE
ABLE 10 PROVIDF YOU WITH INFORMATION ABOU 1 A(JENCIES FIIA F tit,Y
OFFER LEGAL SERVICES TO FLIGIBIT: PERSONS AT A REDUCED FFF. OR NO
Date: .lan uary 31, 2012
CUMBERLAND COUNTY BAR ASSOCIATION-
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)99(1-9108
Respcgtully submitted,
'Karl M. Ledebohm Lscy
Supreme Court ID 459012
/ P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
FR FIF- OF-M
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Karl M. Ledebohm, Esq
P.O. Box 173 m J
New Cumberland, PA 17070-0173
I Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
-- - Camp Hill, PA 17011
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Karl A Ledebohm, Esquire 'T
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P.O. Box 173
New Cumberland, PA 17070 ?aUMBERLAND COUNTY
(717)938-6929 PENNSYLVANIA
MEMBERS I'" FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO. 11-8329 Civil
Vs.
MARGARET MARY SPATZ a/k/a CIVIL ACTION -LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned hereby swears and affirms on behalf of Members 1St Federal
Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff s
knowledge, Margaret Mary Spatz a/k/a Margaret M. Spatz is not currently on active
military service.
submitted,
Date: February 14, 2012
Carl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8329 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION,
Plaintiff (s)
From MARGARET MARY SPATZ a/k/a MARGARET M. SPATZ
(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: $21,733.85 L. L.: $.50
Interest from 2/15/12 at the legal rate
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $274.13 Other Costs:
Plaintiff Paid:
Date: 2/29/12 ?? -
David D. Buell, Prothonota
(Seal)
Deputy REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
NEW CUMBERLAND, PA 17070-0173
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 11-8329 Civil
CIVIL ACTION - LAW
: MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER,
a
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Amount Due: $21,733.85 ?S? ? ? ??
Interest from: 2/15/12 at the legal rate ?-5 CBF
Attorney's fees $ to be added 7Q ,qq „
„
Costs $ to be added U00
11. 17.5
(1) Directed to the Sheriff of Cumberland County, Pennsylvania; It, .50
a.so y
(2) against Margaret Mary Spatz a/k/a Margaret M. Spatz, 3463 Chestnuet Street, a - plo pp AY1y
Camp Hill, PA 17011, defendant;
(3) and against N/A Garnishee (s);
(4) and index this writ against Margaret Mary Spatz a/k/a Margaret M. Spatz, 3463
Chestnut Street, Camp Hill, PA 17011, defendant;
(a) against N/A Garnishee (s), 4a-as Die ('.o
L
•5o LL
.
and levy upon and seize the following real property of Defendant and index this writ
against the following real property of Defendant as a lis pendens:
* (503
117 fn58
QE t0ri oP
All that certain real estate and improvements erected thereon situate in Camp Hill
Borough, Cumberland County, Pennsylvania, known and numbered as 3463 Chestnut
Street, Camp Hill, PA 17011 and as more particularly set forth and described on Exhibit
"A" attached hereto and made part hereof by reference.
1
Dated: February 27, 2012 f-
Karl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
C New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN unit in the property known, named and identified as Chestnut
Street Condominium, located in the Borough of Camp Hill, Cumberland County,
Pennsylvania, which has been submitted to the provisions of the Pennsylvania Uniform
Condominium Act 68, Pa.C.S. Section 3101, et. sea., by the recording in the Recorder of
Deeds Office of Cumberland County, Pennsylvania, a Declaration of Condominium,
dated June 12, 1997, in Record Book 549, Page 898, being Unit 4, together with a
proportionate undivided initial interest in the Common Elements, as defined in the
Declaration of Condominium, of 19.28% as shown on Exhibit "B" of the Declaration of
Condominium.
SAID PREMISES is known and numbered as 3463 Chestnut Street, Camp Hill,
Pennsylvania 17011.
BEING THE SAME premises which Donna Keammerer, Administratrix for the Estate of
Jeanne Marie Alvord, by her deed dated January 18, 2005 and recorded in the
Cumberland County Recorder of Deeds Office in Deed Book 267, Page 1034 granted and
conveyed unto Margaret Mary Spatz, widow.
BEING TAX PARCEL # 01-21-0275-057-U4
Exhibit "A"
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Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS I" FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 11-8329 Civil
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1St Federal Credit Union, 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 in Camp Hill Borough, Cumberland County,
Pennsylvania, known and numbered as 3463 Chestnut Street, Camp Hill, PA 17011.
1. Name and address of owner(s) or reputed owner(s):
Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
2. Name and address of defendant(s) in the judgment:
Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Members 1St Federal Credit Union
Attn.: Arlanda Dintaman, CLS
5000 Louise Drive
Mechanicsburg, PA 17055
Camp Hill Borough
2145 Walnut Street
Camp Hill, PA 17011
Camp Hill Borough
c/o Scott A. Dietterick, Esquire
Smith, Dietterick & Connelly, LLP
P.O. Box 650
Hershey, PA 17033
Penn Waste, Inc.
85 Brickyard Road
York, PA 17402
Penn Waste, Inc.
c/o Neil A. Slenker, Esquire
221 West Philadelphia Street, Suite 600
York, PA 17401-2994
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
Attn.: Arlanda Dintaman, CLS
5000 Louise Drive
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record lien on the property:
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:
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:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
Inheritance Tax Bureau
Commonwealth of PA
Department of Revenue
Bureau of Individual Taxes
Dept. 280601
Harrisburg, PA 17128-0601
Occupant
3463 Chestnut Street
Camp Hill, PA 17011
Chestnut Street Condominium
c/o McNaughton Company
4400 Deer Path Rd., Suite 201
Harrisburg, PA 17110
Edward Blasco
3501 Beech Run Ln.
Mechanicsburg, PA 17055
John Blasco
3501 Beech Run Ln.
Mechanicsburg, PA 17055
John Blasco & Edward Blasco
c/o Christopher Rice, Esquire
10 East High Street
Carlisle, PA 17013
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
C-? 1,,
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MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
IN THE COURT OF COMMOP1i,Eg
CUMBERLAND COUNTY,;
PENNSYLVANIA --a --
.n
NO. 11-8329 Civil
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN
BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO
FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE.
Your house (real estate) at 3463 Chestnut Street, Camp Hill, PA 17011, as more
particularly set forth and described on Exhibit "A" attached hereto and made part
hereof, is scheduled to be sold at Sheriff's Sale on June 6, 2012 at 10:00 a.m. in the
Office of the Sheriff, Cumberland County Courthouse, South Hanover Street,
Carlisle, PA 17013 to enforce the court judgment in the principal amount of
$21,733.85 plus interest at the legal rate, legal fees, costs and other costs and charges
collectible under the mortgage and foreclosure and sale of the mortgaged property
obtained by the above named Plaintiff against you.
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NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount of the judgment plus costs, interest and additional reasonable legal fees or the
back payments, late charges, costs and reasonable attorney's fees, if any, due. To
find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at
(717)938-6929
2. You may be able to stop the sale by filing a petition asking the Court to strike or
open the judgment, if the judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings. You may need
an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below to find out how to obtain an
attorney.
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your house (real estate) will be sold to the
highest bidder. You may find out the price bid by calling the Sheriff at the
County Courthouse.
2. You may be able to petition the Court to set aside the sale if the bid price was
grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due
in the sale. To find out if this has happened, you may call the Sheriff at the
County Courthouse, which number is listed below.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain
the owner of the house (real estate) as if the sale never happened.
5. You have a right to remain in the house (real estate) until the full amount due
is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,
the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house
(real estate). A schedule of distribution of the money bid for your house will
be filed by the Sheriff on or before July 6, 2012 (within thirty (30) days after
the Sheriff Sale). This schedule will state who will be receiving that money.
The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the schedule of distribution is filed by the
Sheriff.
7. You may also have other rights and defenses, or ways of getting your house
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
The Sheriff s phone number is: (717)240-6390.
(f
arl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN unit in the property known, named and identified as Chestnut
Street Condominium, located in the Borough of Camp Hill, Cumberland County,
Pennsylvania, which has been submitted to the provisions of the Pennsylvania Uniform
Condominium Act 68, Pa.C.S. Section 3101, et. sea., by the recording in the Recorder of
Deeds Office of Cumberland County, Pennsylvania, a Declaration of Condominium,
dated June 12, 1997, in Record Book 549, Page 898, being Unit 4, together with a
proportionate undivided initial interest in the Common Elements, as defined in the
Declaration of Condominium, of 19.28% as shown on Exhibit "B" of the Declaration of
Condominium.
SAID PREMISES is known and numbered as 3463 Chestnut Street, Camp Hill,
Pennsylvania 17011.
BEING THE SAME premises which Donna Keammerer, Administratrix for the Estate of
Jeanne Marie Alvord, by her deed dated January 18, 2005 and recorded in the
Cumberland County Recorder of Deeds Office in Deed Book 267, Page 1034 granted and
conveyed unto Margaret Mary Spatz, widow.
BEING TAX PARCEL # 01-21-0275-057-U4
Exhibit "A"
Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 J' FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
: NO. 11-8329 Civil
: CIVIL, ACTION -LAW
MORTGAGE FORECLOSURE
AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO
Pa. R.C.P. 3129.2 (c)
I, Karl M. Ledebohm, Esquire, hereby swear and affirm that on the 19th day of
April, 2012, I served the attached NOTICE OF SHERIFF'S SALE OF REAL
PROPERTY pursuant to Pa. R.C.P. 3129.2(c) in the above captioned matter upon the
individuals/entities by first class mail, postage prepaid as set forth on the PS Form
3817, copies of which are attached as Exhibit "1" and made part hereof.
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.
Date: April 25, 2012
a
Re ctful sub itte ,
arl M. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohin, Esquire
P.O. Box 173
New Cumberland, PA 1 7070-0 1 73
(717)938-6929
MEMBERS I" FEDERAL
CREWT UNION
IN THE COURTOF COMMON PLEAS
CUMBERLAND COUNTY.
PENNSYLVANIA
PLAINTIFF'
Vs.
NO. 11-8329 Civil
MARGARET MARY SPATZ a/k/a CIVIL ACTION -LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
Owner(s): Margaret Mary Spatz a/k/a Margaret M. Spatz.
Property: 3463 Chestnut Street
Camp Hill, PA 17011 (Legal description attached)
Improvements: Being Unit 4 in the Chestnut Street Condominium, Borough of
Camp Hill
.Judgment Amount: $21,733.85
The above-captioned property is scheduled to be sold at the Cumberland County
Sheriff Sale on June 6, 2012 at 10:00 a.m in the Office of the Sheriff, Cumberland
County Courthouse, One Courthouse Square, South Hanover Street, Carlisle, PA
17013.
Our records indicate that you may hold a mortgage, judgment, or other interest
with respect to the property which may be extinguished by the sale. You may wish to
attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date specified by the
Sheriff not later than 30 days after the sale. Distribution will be made in accordance
with the schedule unless exceptions are filed thereto within 10 days after the filing of
the schedule.
If you have any questions regarding the type of lien or the effect of the Sheriff
Sale upon your lien, I urge you to CONTACT YOUR OWN ATTORNEY as I am
not permitted to give you legal advice.
Date: April 19, 2012
fitted.
Karl M. Ledebohm, Esq:
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff'
ALL THAT CERTAIN unit in the property known, named and identified as Chestnut
Street Condominium, located in the Borough of Camp Hill, Cumberland County,
Pennsylvania, which has been submitted to the provisions of the Pennsylvania Uniform
Condominium Act 68, Pa.C.S. Section 3101, et. seq ., by the recording in the Recorder of
Deeds Office of Cumberland County, Pennsylvania, a Declaration of Condominium,
dated June 12, 1997, in Record Book 549. Page 898, being Unit 4, together with a
proportionate undivided initial interest in the Common Elements, as defined in the
Declaration of Condominium, of] 9.28% as shown on Exhibit "B" of the Declaration of
Condominium.
SAID PREMISES is known and numbered as 3463 Chestnut Street, Camp Hill.
Pennsvlvania 17011.
BEING THE SAME premises which Donna Keammerer, Administratrix for the Estate of
.leanne Marie Alvord, by her deed dated January 18, 2005 and recorded in the
Cumberland County Recorder of Deeds Office in Deed Book 267, Page 1034 granted and
conveyed unto Margaret Mary Spatz, widow.
BE[NG TAX PARCEL # 01-21-0275-057-U4
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This certificate of Mailing provltles evidence that ma.l has been presented to JS?S?' fol maliny ?
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- PA). Box 173
New Cwnberland, PA 1 7070-0 1 73
T -- Perm Waste, Inc.
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221 West Philadelphia St., Suite 600
York, PA 1 740 1-2994
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S Form 3817 Anne ?i?n7 FI(4n nnn-ona,
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff "a
ri[y i
Jody S Smith
Chief Deputy
Richard W Stewart
f ' ?ai`riLrv
Solicitor SFr 1'Lti 7(--,
ra.lsr'.
Members 1st Federal Credit Union Case Number
vs. 2011-8329
Margaret Mary Spatz
SHERIFF'S RETURN OF SERVICE
03/23/2012 On 3/23/12 Real Estate Writ, Notice and Description were sent to defendant via Regular U.S. Mail,
postage prepaid.
03/24/2012 08:55 AM - Deputy Dennis Fry, 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: Margaret Mary
Spatz, pursuant to Order of Court by "Posting" the premises located at 3463 Chestnut Street, Camp Hill
Borough, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law.
03/24/2012 08:55 AM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Sale Writ, Notice, Description, and Sale Handbill in the
above titled action, upon the property located at 3463 Chestnut Street, Camp Hill Borough, Camp Hill, PA
17011, Cumberland County.
04/16/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Real
Estate Writ, Notice of Sheriff's Sale and Legal description by certified mail, return receipt requested, to the
within named defendant, to wit: Margaret Mary Spatz, by mailing a copy of the within documents to her
last known address of 3463 Chestnut Street, Camp Hill, PA 17011 on April 1, 2012. The unopened letter
was returned to the Cumberland County Sheriffs Office on April 15, 2012 marked "Undeliverable as
Addressed, Unable to Forward." The unopened letter is hereto attached.
05/01/2012 07:53 PM - Sheriff Ronny R. Anderson, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Margaret Mary Spatz, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Real Estate Sale Notice, Writ
and Description as "Not Served" at 3463 Chestnut Street, Camp Hill, PA 17011, current occupant refuses
to answer the door, unknown if occupant is the named defendant.
06/04/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1,232.56 SO ANSWERS,
June 04, 2012 RON R ANDERSON, SHERIFF
:r, cOl 1 511 f; f'( -ff. i ?lam 9 /
t
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS F FEDERAL
CREDIT UNION
PLAINTIFF
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 11-8329 Civil
Vs.
MARGARET MARY SPATZ a/k/a CIVIL ACTION - LAW
MARGARET M. SPATZ
DEFENDANT MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1" Federal Credit Union, 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 in Camp Hill Borough, Cumberland County,
Pennsylvania, known and numbered as 3463 Chestnut Street, Camp Hill, PA 17011.
1. Name and address of owner(s) or reputed owner(s):
Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
2. Name and address of defendant(s) in the judgment:
Margaret Mary Spatz a/k/a
Margaret M. Spatz
3463 Chestnut Street
Camp Hill, PA 17011
r
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Members I st Federal Credit Union
Attn.: Arlanda Dintaman, CLS
5000 Louise Drive
Mechanicsburg, PA 17055
Camp Hill Borough
2145 Walnut Street
Camp Hill, PA 17011
Camp Hill Borough
c/o Scott A. Dietterick, Esquire
Smith, Dietterick & Connelly, LLP
P.O. Box 650
Hershey, PA 17033
Penn Waste, Inc.
85 Brickyard Road
York, PA 17402
Penn Waste, Inc.
c/o Neil A. Slenker, Esquire
221 West Philadelphia Street, Suite 600
York, PA 17401-2994
4. Name and address of the last recorded holder of every mortgage of record:
Members 1 s` Federal Credit Union
Attn.: Arlanda Dintaman, CLS
5000 Louise Drive
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record lien on the property:
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:
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:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
Inheritance Tax Bureau
Commonwealth of PA
Department of Revenue
Bureau of Individual Taxes
Dept. 280601
Harrisburg, PA 17128-0601
Occupant
3463 Chestnut Street
Camp Hill, PA 17011
Chestnut Street Condominium
c/o McNaughton Company
4400 Deer Path Rd., Suite 201
Harrisburg, PA 17110
Edward Blasco
3501 Beech Run Ln.
Mechanicsburg, PA 17055
John Blasco
3501 Beech Run Ln.
Mechanicsburg, PA 17055
John Blasco & Edward Blasco
c/o Christopher Rice, Esquire
10 East High Street
Carlisle, PA 17013
F
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.
Date: February 27, 2012 Respectfully submitted,
Karl M. Ledebohm, Esq.
Supreme Court ID #: 59012
/ P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8329 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION,
Plaintiff (s)
From MARGARET MARY SPATZ a/k/a MARGARET M. SPATZ
(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: $21,733.85 L.L.: $.50
Interest from 2/15/12 at the legal rate
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $274.13 Other Costs:
Plaintiff Paid:
Date: 2/29/12 ?f
David D. Buell, Prothonota
(Seal) ---&
Deputy
REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
TRUE COPT( FROM RECORD
In Testimony whereof, l here unto set my hand
NEW CUMBERLAND, PA 17070-0173
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
and #0 seal of satd Court at Cartisle, Pa.
This Asy oh' !U , 20 1,0_
'?/ ?1 P4 Prothonotary
On March 2, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Camp Hill Borough, Cumberland County, PA, known and
numbered 3463 Chestnut Street, Camp Hill, PA 17011
more fully described on Exhibit"A" filed with this writ and
by this reference incorporated herein.
Date: March 2, 2012
BY:
A
For Claudia Brewbaker, Real Estate Coordinator
Writ No. 2011-8329 Civil Term
Members 1st Federal Credit Union
VS.
Margaret Mary Spatz a/k/a
Margaret M. Spatz
Atty.: Karl M. Ledebohm
ALL THAT CERTAIN unit in the
property known, named and iden-
tified as Chestnut Street Condo-
minium, located in the Borough of
Camp Hill, Cumberland County,
Pennsylvania, which has been sub-
mitted to the provisions of the Penn-
sylvania Uniform Condominium Act
68, Pa.C.S. Section 3101, et. seq.,
by the recording in the Recorder of
Deeds Office of Cumberland County,
Pennsylvania, a Declaration of Con-
dominium, dated June 12, 1997, in
Record Book 549, Page 898, being
Unit 4, together with a proportion-
ate undivided initial interest in the
Common Elements, as defined in
the Declaration of Condominium, of
19.28% as shown on Exhibit "B" of
the Declaration of Condominium.
SAID PREMISES is known and
numbered as 3463 Chestnut Street,
Camp Hill, Pennsylvania 17011.
BEING THE SAME premises
which Donna Keammerer, Adminis-
tratrix for the Estate of Jeanne Marie
Alvord, by her deed dated January
18, 2005 and recorded in the Cum-
berland County Recorder of Deeds
Office in Deed Book 267, Page 1034
granted and conveyed unto Margaret
Mary Spatz, widow.
BEING TAX PARCEL # 01-21-
0275-057-U4
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:
April 27, May 4, and May 11, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
for
i a Marie Coyne,
94
SWORN TO AND SUBSCRIBED before me this
11 daXof Maw 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
14( Pahiot 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 of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY
This ad ran on the date(s) shown below:
04127/12
05104112
05111112
Sworn t r ubs ribed be ore a Is 22 d of ay, 2012 A.D.
X4114 L.
Notafv Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L. Owens, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Nov. 26, 2015
MEMBER, PENNSYLVANIA ASSOCIATnON OF NOTARIES
20ii-m9 Cbii Term
Members 1st Federei
Credit Union
vs
Margaret Mary spatL ViVa
Margaret Ms
Anye Keg, M. Patz
. Lftlebohm
THAT CERTAIN unit in the
ALL property known
as Chest d idened
located in the Beet undo munum
,
rou
Cumberland Co 8h of Came Hill,
has been submitt my Pennsylvania, which
Penn ed tO the Provisions of the
sYl S. Uniform Condominium Act
re8 ordi, S Section 3101, et. seq, by the
of Cum g m the rland oun COtder of Deeds ce
Be Cty Pennsy]v
Dec] azai Condo a a
minium G
1211 7, in n R a ecord ated June
Bodk 549, ag 898,
and d ed initial - Stith a Proportionate
Elements, as de interest in the Commnn
fined in the of
Exhibit ExCondominium of 19.28% as shokn
t undominium °f the Declaration of
.
SAID 61 PChes ES is known and numbered
tnut'Street
Penn ves, Carne Hill,
BEING Gina 17011.
G
Donna I{e eS rremises which
the Estate of Jeanne Mahe deed dated January ig he All-,d' by her
n the Cumberland Coun and recorded
Deeds office . Deed B ty 7, er of
granted and conveyed untok 267, Page 1034
S 'atz, widow. Margaret Mary
BEING TA7{
057-U4 pARCEL # 01-21-0275-
?,. ,y fy' 1
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 13' FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
MARGARET MARY SPATZ a/k/a
MARGARET M. SPATZ
DEFENDANT
. if L ? 4
1JI
PFPINSYL%''ANl
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 11-8329 Civil
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
PRAECIPE TO SATISFY JUDGMENT
To the Prothonotary:
Please mark the judgment entered in favor of Members 15` Federal Credit Union
in the above captioned matter satisfied.
Date: June 4, 2012
Karl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
49. r6-A(,.A41J
cj?_ ILUD
Jz.xt- a7GY3?