The URL can be used to link to this page

Home My WebLink About11-8341r Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff .? :.?1; l }' _ A IU? ? COUNTY '- r"OSYLrANI CitiMortgage, Inc., V. PLAINTIFF, Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: ?- ?1 Vl I CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this compl& nT 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 of 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. S avvA $L 9 D. M 12 0?4 qo_-? r IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la cone en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 2 r Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 PLAINTIFF, CitiMortgage, Inc., V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257, DEFENDANTS Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, CitiMortgage, Inc., by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 2 Plaintiff, CitiMortgage, Inc., is a corporation, limited partnership, limited liability company, federal savings bank, or national banking association under and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 1000 Technology Drive, O'Fallon, MO 63368-2240. Defendants, Shannon Rae Sweeney and Michael J. Sweeney, are the real owners, mortgagors, and grantees in the last Deed of record to the real property located at 145 3 f Milky Way Shippensburg, PA 17257 and, if applicable, riparian rights appertaining thereto (hereinafter referred to as "Premises") . 3. On February 11, 2005, Defendants made, executed, and delivered a Mortgage to Mortgage Electronic Registration Systems, Inc. as nominee for Allied Home Mortgage Capital Corp. assigns (hereinafter referred to as "Originating Lender") as security for Defendants' payment and other obligations in consideration of a mortgage loan made to Defendants by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, in was recorded on February 17, 2005 in Carlisle County in Mortgage Book 1897, Page 2187 , and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The aforesaid Mortgage has not been re-recorded. 5. The aforesaid Mortgage has not been modified. 6. Plaintiff is the Originating Lender, a legal successor thereto, or an assignee of the Originating Lender through Assignment of Mortgage. 7. The address of the Premises is 145 Milky Way, Shippensburg, PA 17257. 8. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid Mortgage have not been made from September 1, 2010 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 9. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendants shall be liable for, inter alia, Plaintiffs costs and attorneys' fees. 10. The following amounts are due as of November 10, 2011: 4 Principal $ 207,657.61 Accrued Interest through November 10, 2011 $ 11911.21 Late Fees $ 425.36 Property Inspection $ 81.00 Corporate Advances $ 165.00 Escrow Advances $ 2864.61 Appraisal Fee plus Servicing Fees $ 454.46 5% of Principal for Attorneys' Fees $ 10382.89 Total $ 233,942.14 12 plus additional pre judgment and post judgment interest at the per diem rate of $25.60 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage. If the Mortgage is reinstated prior to a sheriff's sale, the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5%) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff's sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. Plaintiff is not seeking a judgment on personal liability (or an in personam judgment) against Defendants in this action but reserves the right to bring a separate action to establish that right, if such right exists. If Defendants received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish the personal liability that was discharged in bankruptcy, but only to foreclosure the Mortgage and sell the Premises pursuant to Pennsylvania law. 13. Plaintiff has demanded the total amount due from Defendants, but Defendants have failed and/or refused to pay the same. 14. Notice of Intention to Foreclose pursuant to Act 6 and/or Act 91 was sent in accordance with Pennsylvania law more than 34 days ago. WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendants, Shannon Rae Sweeney and Michael J. Sweeney, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 10., namely $233,942.14, plus additional pre judgment and post judgment interest at the per diem rate of $25.60 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & Date: l ! l By: Richard M /Squire, Esq. (PA I.D.# 04267) ?. Troy reedman, Esq. (PA I.D.# 85165) Chris ' a C. Viola, Esq. (PA I.D.# 308909) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rs uire @ squirelaw.com tfreedman@squirelaw.com cviola@squirelaw.com Attorneys for Plaintiff UNLESS YOU NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS 6 AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257, DEFENDANTS CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION p?,er hereby states that he/she is of CitiMortgage, Inc., Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information or belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: C> ?)- (o ( File #: CMI-891F S2 Name: Sernka Set Title: Name: Shannon Rae Sweeney and Michael J. Sweeney EXHIBIT "A" LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in the Southampton Township, County of Cumberland, Commonwealth of Pennsylvania. BEGINNING at an iron pin to be set at the northwestern corner of Lot No. 6; thence along the common line of Lot No. 5 and Lot No. 6, North 51 degrees 13 minutes 13 seconds East, 140.00 feet to an iron pin to be set at the northeastern comer of Lot No. 6; thence along lands now or formerly of Glenn S. Asper, South 38 degrees 46 minutes 47 seconds East, 80.00 feet to an iron pin to be set at the southeastern corner of Lot No. 6; thence along the common line of Lot No.6 and Lot No. 7, South 51 degrees 13 minutes 13 seconds West, 140.00 feet to an iron pin to be set at the southwestern corner of lot No. 6; thence along Milky Way, North 38 degrees 46 minutes 47 seconds West, 80.00 feet to an iron pin to be set, being the point and place of BEGINNING. CONTAING 11,200 square feet and being Lot No. 6 pursuant to the Hampton Hills, Phase I Final Subdivision Plan, dated February 2, 1996, and revised March 1, 1999, prepared by Martin and Martin, inc., and recorded on October 5, 2001 in the Office of the Register and Recorder of Deeds of Cumberland County, Pennsylvania at Volume 84, Page 14. SUBJECT to all rights-of-way, restrictions, easements, conditions, and set back lines of record, including but not limited to those stated in the aforementioned subdivision plan. BEING the same real estate which Hampton Hills Developments, a Partnership, by deed dated August 12, 2004 and recorded on September 1, 2004in the Office of the Register and Recorder of Deeds of Cumberland County, Pennsylvania in Deed Book Volume 264, Page 4999, granted and conveyed unto Eldon J. Martin, an adult individual, the Grantor herein. BEING known as 145 Milky Way, Shippensburg, PA 17257 BEING Parcel No. 39-14-0169-130. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor LED-OFi ICI- 2.011 NOV 30 AM 11: 40 ',UMBERLAND CQUN i' PENNSYLVANIA Citimortgage, Inc vs. Shannon R. Sweeney (et al.) Case Number 2011-8341 SHERIFF'S RETURN OF SERVICE 11/23/2011 06:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2011 at 1830 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michael J. Sweeney, by making known unto himself personally, at 106 Feather Drive, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. Request for service at 145 Milky Way, Shippensburg, Pennsylvania 17257 is vacant. ROBE T BITNER, DEPUTY 11/23/2011 06:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on November 23, 2011 at 1830 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shannon R. Sweeney, by making known unto herself personally, at 106 Feather Drive, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. Request for service at 145 Milky Way, Shippensburg, Pennsylvania 17257 is vacant. SHERIFF COST: $84.00 November 28, 2011 ROB RT BITNER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (r,i i--cut*6ulte Shenft. Teleosoft Inc. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West ) kvenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff n ? ?Q I a2 yn r d ,1 ) ? CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 PLAINTIFF, V. Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257, DEFENDANTS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 11-8341 Civil CIVIL ACTION PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Shannon Rae Sweeney and Michael J. Sweeney, Defendants, for his/her/its/their failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiffs damages as follows: Figures Good Through 2/28/2012 Principal Balance $207,657.61 Late Charges $425.36 Total Interest Amount $14,708.20 Paid Out School Taxes $2,248.40 Paid Out City Taxes $490.40 Additional Insurance Premium $55.00 Paid Out Hazard Insurance $852.81 Foreclosure Attorney Fees $3405.00 Inspections $216.00 Interest on Escrow Advance $4.44 ********TOTAL PAYOFF*********** $230,063.22 FAChents\Citi Alortgage\Sweeney, Shannon - 891F\defauh judgment.wpdLC a't'A %ll-Sb PA ° J C1?? a3s ? 4 ?1v7 Lo 9 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richar . Squire, Esq. (PA I.D.# 04267) M. oy Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsq.uire&sauirelaw. com tfreedmanna,sauirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED 7) P DATE: 6^000 PPRIjilij F:\Clients\Citi %lortgage\Sweeney, Shannon - 891 F\default judgment.wpdLC Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff PLAINTIFF, CitiMortgage, Inc. V. Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257, DEFENDANTS. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 11-8341 Civil CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) an address at 145 Milky Way, Shippensburg, PA 17257 and/or 106 Feather Drive, Shippensburg, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FAClients\Citi Mortgage\Sweeney, Shannon - 891 F\default judgment.wp&C RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richard . Squire, Esq. (PA I.D.# 04267) ?M. Tr Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire ksquirelaw.com tfreedmang sq uirelaw. com Attorneys for Plaintiff FAClients\Citi Mortgage\Sweeney, Shannon - 891 Mdefault judgment.wp'+LC Request for Military Status Department of Defense Manpower Data Center Aslshkk? Am& Military Status Report 1W Pursuant to the Service Members Civil Relief Act Page I of 2 Feb-03-2012 14:33:42 " , Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Based on the information you have furnished, the DMDC does not possess SWEENEY MICHAEL any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). y6t jn? jjojt4,A??- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fag/12is/PC09SLDR.htmi. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 2/3/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:458D4ITK45 https://www.drndc:.osd.mil/appj/scra/popreport.do 2/3/2012 Rdquest for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-03-2012 14:34:09 - Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency SWEENEY SHANNON Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 4bky, M Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fag/t)is/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dtndc.osd.mil/appj/scra/popreport.do 2/3/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:Q59QK8LNSC https://www.dindc.osd.mil/appj/scra/popreport.do 2/3/2012 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire [D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West .Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. TO: Michael J. Sweeney 145 Milky Way Shippensburg PA 17257 DATE OF NOTICE: December 29.2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 11-8341 Civil CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT .AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR \Aw CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Ww Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID., Nos. 04267 / 851.65 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Michael ,I. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. TO: Shannon Rae Sweeney 145 Milky Way Shippensburg PA 17257 DATE OF NOTICE: December 29, 2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 11-8341 Civil MORTGAGE FORECLOSURE CIVIL ACTION THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR. OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR \Aw CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 \Aw Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID.. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., V. PLAINTIFF, Michael .I. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. TO: Michael J. Sweeney 106 Feather Drive Shippensburg, PA 17257 DATE OF NOTICE: December 29.2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 11-8341 Civil MORTGAGE FORECLOSURE CIVIL ACTION THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR ww CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Ww Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID.. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff CitiMortgage, Inc., PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. TO: Shannon Rae Sweeney 106 Feather Drive Shippensburg, PA 17257 DATE OF NOTICE: December 29.2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 11-8341 Civil MORTGAGE FORECLOSURE CIVIL ACTION THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR \Aw CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Ww Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date CitiMortgage, Inc. V. PLAINTIFF, Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Pursuant to re uir ments of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on a judgment(decree)(order) was entered against you in this office in the proceeding as indicated above. WAR t rrf 0 onotary Deputy Prothonotary Date Mailed: F:\Clients\Citi Mortgage\Sweeney, Shannon - 891 F\default judgment.wALC Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date CitiMortgage, Inc. V. PLAINTIFF, Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 Pursuant to requir menu of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on , a judgment(decree)(order) was entered against you in this office in the proceeding a ' dicate above Prothonotary Deputy Prothonotary Date Mailed: FAClients\Citi M ng,age\Sweeney, Shannon - 891F\defau1t judgment.wtkLC Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 CitiMortgage, Inc. V. PLAINTIFF, Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. NOTICE TO: Michael J. Sweeney 106 Feather Drive Shippensburg, PA 17257 Date Pursuant to req irements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on "V 1 , a judgment(decree)(order) was entered against you in this office in the proceeding as indicated above. goo, x„ Pro onotary Deputy Prothonotary Date Mailed: FAChents\Citi Mortgage\Sweeney, Shannon - 891F\defau1t judgment.wp?1GC Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 CitiMortgage, Inc. V. PLAINTIFF, Michael J. Sweeney and Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANT'S. NOTICE TO: Shannon Rae Sweeney 106 Feather Drive Shippensburg, PA 17257 Date Pursuant to req ire nts of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that ')T on a judgment(decree)(order) was entered against you in this office in the proceeding as dica bo Prothonotary Deputy Prothonotary Date Mailed: FAChents\Citi Mortgage\Sweeney, Shannon - 891F\default judgment.wALC WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-8341 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC. Plaintiff (s) From MICHAEL J. SWEENEY, SHANNON RAE SWEENEY (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: $230,063.22 L.L.: $.50 Interest from 2/29/2012 to 9/5/2012 @ $25.60 PER DIEM - $4,864.00 Atty's Comm: ° a Due Prothy: $2.25 Atty Paid: $223.50 Other Costs: Plaintiff Paid: Date: 5/30/12 David D. Buell, Prothonotary (Seal) REQUESTING PARTY: Name: M. TROY FREEDMAN, ESQUIRE By: Address: RICHARD M. SQUIRE & ASSOCIATES, LLC 115 WEST AVENUE, SUITE 104 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Deputy Supreme Court ID No. 85165 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 1,4-j-j.j n COU1* T''' CitiMortgage, Inc. ' IN THE COURT OF COMMON i Lq§ V' PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-8341 Civil Michael J. Sweeney 145 Milky Way CIVIL ACTION Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 MORTGAGE FORECLOSURE DEFENDANTS. PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Kindly issue a Writ of Execution in the above matter. Amount Due $ 230,063.22 Interest From 02/29/2012 to 09/05/2012 @ $25.60 per diem 4,864.00 Total: $ 234,927.22 * plus fees and costs Date: May 16, 2012 E) S? a H'1 Q,?? 46,D?, 14. 00 f Ck P. W U,( 114.50``" it it C S'?e ?j• S? -PA, Q.Vrj CMI-891F S2/TMB '/1 ? ......... ... , By: Richar . Squire, Esq. (PA I.D.# 04267) Nklroy Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire a squirelaw.com tfreedmangsquirel aw. com Attorneys for Plaintiff Ct QZ36+ asvba -P.a 97s:`` Wr,k ?f R? pswed U 00 0 v O A a oQ a? O a Oo ?- U ? Q O Q U? Fx- ? ? ? i 0 A p p ,3 x ? C3 kr) U °kf) En b a? Q z 0 w w W W a W a O U O w bA O w a? Sao W W.?r a?o,r 'Y b ?? 3 0 0 c) bti OC ?u 00 ?o rx E?i f?. 0 H N w o, Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 CitiMortgage, Inc. PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. Attorneys for Plaintiff z 30 3 , ; Li LA{ D COUNT ?h?'NSY'LVANIA € IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO11-8341 Civil CIVIL ACTION CERTIFICATION M. Troy Freedman, Esquire, hereby verifies that he is an attorney for the Plaintiff in the above captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA Mortgage ( ) Non-owner occupied ( ) Vacant (X ) Act 91 Procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . .n Date: May 16, 2012 By: Ric W M. Squire, Esq. (PA I.D.# 04267) M. roy Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire a,squirelaw.com tfreedman u,squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire r d' E l I.D. Nos. 04267 / 85165 Tit? One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND, PENNSYLVANIA V. NO. 11-8341 Civil Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 CIVIL ACTION MORTGAGE FORECLOSURE Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129.1 CitiMortgage, Inc., Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 145 Milky Way, Shippensburg, PA 17257 Parcel No:.39-14-0169-130. 1. Name and last known address of Owner(s) or Reputed Owner(s): Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 FAChentsWiti Mortgage\Sweeney, Shannon - 891 F\WOE.wpd 2. Name and last known address of Defendant(s) in the judgment: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 Discover Bank 6500 New Albany Road New Albany, OH 43054 Target National Bank c/o Daniel Santucci, Esquire 1835 Market Street Suite 501 Philadelphia, PA 19103 Target National Bank 3901 West 53`d Street Sioux Falls, SD 57106 4. Name and address of last recorded holder of every mortgage of record: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 Mortgage Electronic Registration Systems, Inc. as nominee for Allied Home Mortgage Capital Corp P.O. Box 2026 Flint, MI 48501-2026 Allied Home Mortgage Capital Corp. 6110 Pinemont, Suite 215 FAChents\Citi Mortgage\Sweeney, Shannon - 891RWOE.wpd Houston, TX 77092 Citibank Federal Savings Bank 600 Pennsylvania Avenue SE Washington, DC 20003 Pennsylvania Housing Finance Agency 211 North Front Street, P.O. Box 15206, Harrisburg, PA 17105-5530 CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2204 Mortgage Electronic Registration Systems, Inc. as nominee for Allied Home Mortgage Capital Corp 1818 Library Road, Suite 300, Reston, VA 20190-6280 Mortgage Electronic Registration Systems P.O. Box 2026 Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: None other. 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: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square - Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn : Legal Department F:\Chents\Citi Mortgage\Sweeney, Shannon - 891 F\WOE.wpd Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 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: Tenant/Occupant 145 Milky Way Shippensburg, PA 17257 VERIFICATION 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. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: M. oy Freedman, Esquire 5 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: May 16, 2012 FAChents\Citi Mortgage\Sweeney, Shannon - 891RWOE.wpd LEGAL DESCRIPTION F:\Clients\Citi Mortgage\Sweeney, Shannon - 891 RWOE.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 CitiMortgage, Inc. PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS. Attorneys for Plaintiff 1'?? ? •7 L V ?„I 5EIRN '' N, D CCU IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO11-8341 Civil CIVIL ACTION AFFIDAVIT OF LAST KNOWN ADDRESSES I, M. Troy Freedman, Esquire, being duly sworn according to law, hereby depose and say that I am one of the attorneys for Plaintiff in the above matter and that the last known addresses for the Defendants herein are as follows: F Thents\Citi Mortgage\Sweeney, Shannon - 891RWOE.wpd Defendants: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Date:May 16, 2012 By: Richard quire, Esq. (PA I.D.# 04267) _4. Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire ,squirelaw.com tfreedman cr squirelaw.com F:\Clients\Citi Mortgage\Sweeney, Shannon - 891RWOE.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 CitiMortgage, Inc. PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANTS Attorneys for Plaintiff iii.,! ,,. COUNT'' p,?kIS Yl. VANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO11-8341 Civil CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE M. Troy Freedman, Esquire, hereby verifies that he is one of the attorneys for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Service Members Civil Relief Act of Congress of 2003, as amended. (b) that Defendants are over 18 years of age and resides at 145 Milky Way, Shippensburg, PA 17257 and/or 106 Feather Drive, Shippensburg, PA 17527. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated:May 16, 2012 By: shard M. Squire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquirensquirelaw.com tfreedman j squirelaw corn FAChentsWiti Mortgage\Sweeney, Shannon - 891RWOE.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire I.D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANT ?.' E`"' 31D :r to td t, ,€ i 8: ' iBEIRLAND CCU IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 11-8341 Civil CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Your house (real estate) at 145 Milky Way, Shippensburg, PA 17257 is scheduled to be sold at Cumberland County Sheriff Sale, 09/05/2012 at, Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $230,063.22 plus interest to the sale date obtained by CitiMortgage, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: FXIientsTiti Mortgage\Sweeney, Shannon - 891F\WOG.wpd 1. The sale will be canceled if you pay back to CitiMortgage, Inc., the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire or M. Troy Freedman, Esquire at (215) 886-8790. 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 on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland Sheriff s Office at 717-240-6100. 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 Cumberland County Courthouse at 717-240-6100. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. F:\Clients\Citi Mortgage\Sweeney, Shannon - 891nW0E.wpd Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F ThentsTiti Mortgage\Sweeney, Shannon - 891RWOE.wpd SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Citimortgage, Inc vs. Shannon R. Sweeney (et al.) 4ttsttl' ofi ?:raut:? yxjr .? ??1 ra X32 OCT 22 PM 12= 39 w TY Case Number 2011-8341 SHERIFF'S RETURN OF SERVICE 06/25/2012 07:10 PM - Deputy Robert Bitner, 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 145 Milky Way, Southampton Township, Shippensburg, PA 17257, Cumberland County. 06/25/2012 07:25 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Michael J. Sweeney at 106 Feather Drive, Southampton Township, Shippensburg, PA 17257, Cumberland County. 06125/2012 07:25 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Shannon R. Sweeney at 106 Feather Drive, Southampton Township, Shippensburg, PA 17257, Cumberland County. 09/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney M. Troy Freedman, on behalf of CitiMortgage, Inc., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $851.99 SO ANSWERS, r October 22, 2012 WON R ANDERSON, SHERIFF C^,tjStlti$ Sh8(,!t, T04EGS?n, 1r,C,_ ? ? ????? Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire I.D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND, PENNSYLVANIA V NO. 11-8341 Civil Michael J. Sweeney CIVIL ACTION 145 Milky Way Shippensburg, PA 17257 MORTGAGE FORECLOSURE Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129.1 CitiMortgage, Inc., Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praeeipe for the Writ of Execution was filed, the following information concerning the real property located at 145 Milky Way, Shippensburg, PA 17257 Parcel No:.39-14-0169-130. 1. Name and last known address of Owner(s) or Reputed Owner(s): Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 FAC1ients\Citi Mortgage\Sweeney, Shannon - 891 RWOE.wpd 2. Name and last known address of Defendant(s) in the judgment: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 Discover Bank 6500 New Albany Road New Albany, OH 43054 Target National Bank c/o Daniel Santucci, Esquire 1835 Market Street Suite 501 Philadelphia, PA 19103 Target National Bank 3901 West 53rd Street Sioux Falls, SD 57106 4. Name and address of last recorded holder of every mortgage of record: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 Mortgage Electronic Registration Systems, Inc. as nominee for Allied Home Mortgage Capital Corp P.O. Box 2026 Flint, MI 48501-2026 Allied Home Mortgage Capital Corp. 6110 Pinemont, Suite 215 F:\Clients\Citi Mortgage\Sweeney, Shannon - 891 RWOE.wpd Houston, TX 77092 Citibank Federal Savings Bank 600 Pennsylvania Avenue SE Washington, DC 20003 Pennsylvania Housing Finance Agency 211 North Front Street, P.O. Box 15206, Harrisburg, PA 17105-5530 CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2204 Mortgage Electronic Registration Systems, Inc. as nominee for Allied Home Mortgage Capital Corp 1818 Library Road, Suite 300, Reston, VA 20190-6280 Mortgage Electronic Registration Systems P.O. Box 2026 Flint, MI 48501-2026 5. Name and address of every other person who has any record lien on the property: None other. 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: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square - Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn : Legal Department FAChentsWiti Mortgage\Sweeney, Shannon - 891 RWOE.wpd Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 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: Tenant/Occupant 145 Milky Way Shippensburg, PA 17257 VERIFICATION 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. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: M. oy Freedman, Esquire 5 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: May 16, 2012 FAClientsWiti Mortgage\Sweeney, Shannon - 891 RWOE.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire I.D. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff CitiMortgage, Inc. PLAINTIFF, V. Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 Shannon Rae Sweeney 145 Milky Way Shippensburg, PA 17257 DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 11-8341 Civil CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Sweeney 145 Milky Way Shippensburg, PA 17257 and/or 106 Feather Drive Shippensburg, PA 17257 Your house (real estate) at 145 Milky Way, Shippensburg, PA 17257 is scheduled to be sold at Cumberland County Sheriff Sale, 09/05/2012 at, Courthouse, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $230,063.22 plus interest to the sale date obtained by CitiMortgage, Inc. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: F:UientsTiti Mortgage\Sweeney, Shannon - 891 RWOE.wpd 1. The sale will be canceled if you payback to CitiMortgage, Inc., the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire or M. Troy Freedman, Esquire at (215) 886-8790. 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 on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland Sheriffs Office at 717-240-6100. 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 Cumberland County Courthouse at 717-240-6100. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. E:\Clients\Citi Mortgage\Sweeney, Shannon - 891 RWOE.wpd Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 I'XiientsWiti Mortgage\Sweeney, Shannon - 891 RWOE.wpd ALL THAT CERTAIN lot or piece of ground situate in the Southampton Township, County of Cumberland, Commonwealth of Pennsylvania. BEGINNING at an iron pin to be set at the northwestern comer of Lot No.6; thence along the common line of Lot No.5 and Lot No.6, North 51 degrees 13 minutes 13 seconds East, 140.00 feet to an iron pin to be set at the northeastern corner of Lot No.6; thence along lands now or formerly of Glenn S. Asper, South 38 degrees 46 minutes 47 seconds East, 80.00 feet to an iron pin to be set at the southeastern corner of Lot No.6; thence along the common line of Lot No.6 and Lot No.7, South 51 degrees 13 minutes 13 seconds West, 140.00 feet to an iron pin to be set at the southwestern corner of lot No.6; thence along Milky Way, North 38 degrees 46 minutes 47 seconds West, 80.00 feet to an iron pin to be set, being the point and place of BEGINNING. BEING THE SAME PREMESIS BY DEED FROM ELDON J. MARTIN, AN ADULT INDIVIDUAL DATED 02/11/05 AND RECORDED 02/17/2005 IN DEED BOOK 267 PAGE 2874 GRANTED AND CONVEYED UNTO MICHAEL J. SWEENEY AND SHANNON RAE SWEENEY, HUSBAND AND WIFE. TAX PARCEL NO: 39-14-0169-130 BEING KNOWN AS 145 MILKY WAY, SHIPPENSBURG, PA 17257 f'XiientsTiti Mortgage\Sweeney, Shannon - 891 RWOE.wpd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-8341 Civil COUNTY OF CUMBERLAND) CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC. Plaintiff (s) From MICHAEL J. SWEENEY, SHANNON RAE SWEENEY (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: $230,063.22 L.L.: $.50 Interest from 2/29/2012 to 9/5/2012 @ $25.60 PER DIEM - $4,864.00 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $223.50 Other Costs: Plaintiff Paid: Date: 5/30/12 (Seal) REQUESTING PARTY Deputy Name: M. TROY FREEDMAN, ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES, LLC 115 WEST AVENUE, SUITE 104 JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 85165 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the of of said Court at Carlisle, Pa.?1 This day of 20 12 Prothonotary a . ?y On June 1, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, known and numbered 145 Milky Way, Shippensburg, PA 17257 more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 1, 2012 By: 0,110LU-Ckj1-m to) r-k Claudia Brewbaker, Real Estate Coordinator 14 UL 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 Q( patriot 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: 07/27112 08/03/12 08/10/12 2012 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES CUMBERLAND LAW JOURNAL Writ No. 2011-8341 Civil Term Citimortgage, Inc vs. Shannon R. Sweeney Michael J. Sweeney Atty.: M. Troy Freedman All That Certain lot or piece of ground situate in the Southampton Township, County of Cumberland, Commonwealth of Pennsylvania. BEGINNING at an iron pin to be set at the northwestern comer of Lot No.6; thence along the common line of Lot NO.5 and Lot NO.6, North 51 degrees 13 minutes 13 seconds East, 140.00 feet to an iron pin to be set at the northeastern corner of Lot NO. 6; thence along lands now or formerly of Glenn S. Asper, South 38 degrees 46 minutes 47 seconds East, 80.00 feet to an iron pin to be set at the southeastern corner of Lot No.6; thence along the common line of Lot NO.6 and Lot NO.7, South 51 degrees 13 minutes 13 seconds West, 140.00 feet to an iron pin to be set at the southwestern comer oflot No.6; thence along Milky Way, North 38 degrees 46 minutes 47 seconds West, 80.00 feet to an iron pin to be set, being the point and place of BEGINNING. BEING THE SAME PREMESIS BY DEED FROM ELDON J. MARTIN, AN ADULT INDIVIDUAL DATED 02/1 1105 AND RECORDED 02117/2005 IN DEED BOOK 267 PAGE 2874 GRANTED AND CONVEYED UNTO MICHAEL J. SWEENEY AND SHAN- NON RAE SWEENEY, HUSBAND AND WIFE. TAX PARCEL NO: 39-14-0169- 130. BEING KNOWN AS 145 MILKY WAY, SHIPPENSBURG, PA 17257. 101 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: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Y .. L'L'la Marie Coyne, E ' or SWORN TO AND SUBSCRIBED before me this 10 da of Au st 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which CitiMortga eg Inc. is the grantee the same having been sold to said grantee on the 5 day of September A.D., 2012, under and by virtue of a writ Execution issued on the 30 day of May, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 8341, at the suit of CitiMortgat?e Inc. against Michael J Sweeney and Shannon Rae Sweeney is duly recorded as Instrument Number 201232530. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of _ A.D. ReooNer d Deeds, Cumberland Coun<y, CO W% PA My Commission Fires the Frst Monday of Jan. 2014 2011-8341 Civil Term Citimortgage, Inc Vs Shannon R. Sweeney Michael J. Sweeney Atty. M Troy Freedman All That Certain lot or piece of ground situate in the Southampton Township, County of Cumberland, Commonwealth of Pennsylvania. BEGINNING at an iron pin to be set at the northwestern comer of Lot No.6; thence along the common line of Lot NO.5 and Lot NO.6, North 51 degrees 13 minutes 13 seconds East, 140.00 feet to an iron pin to be set at the northeastern corner of Lot NO.6; thence along lands now or formerly of Glenn S. Asper, South 38 degrees 46 minutes 47 seconds East, 80.00 feet to an iron pin to be set at the southeastern corner of Lot No.6; thence along the common line of Lot NO.6 and Lot NO.7, South 51 degrees 13 minutes 13 seconds West, 140.00 feet to an iron pin to be set at the southwestern comer oflot Nob; thence along Milky Way. North 38 degrees 46 minutes 47 seconds West, 80.00 feet to an iron pin to he set. being the point and place of BEGINNING. BEING THE SAME PREM1. SIS B` DEED FROM ELDON J. MARTIN, AN ADULT INDIVIDUAL DATED 02111105 AND RECORDED 02117/2005 IN DEED BOOK 267 PAGE 2874 GRANTED AND CONVEYED UNTO MICHAEL J. SWEENEY AND SHANNON RAE SWEENEY. HUSBAND AND WIFE. TAX PARCEL NO: 39-14-0169-130 BEING KNOWN AS 145 MILKY WAY, SHIPPENSBURG. PA 17257