HomeMy WebLinkAbout11-8347r ?L ??t Gii(tl?
1 i 11 ii
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
JARED M. BAHR
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: ?I-s3?? Ci?ir
STACEY L. SCHAFFNER a/k/a
STACEY SCHAFFNER CIVIL ACTION - LAW
DEFENDANTS 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 S
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 objections 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 0 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 17070-0173
(717) 938-6929
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.:
JARED M. BAHR
STACEY L. SCHAFFNER A/K/A
STACEY SCHAFFNER
DEFENDANTS : 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
Plaintiff, Members 1St Federal Credit Union ("Members 1 Sr°), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Defendants, Jared M. Bahr and Stacey L. Schaffner, A/K/A, Stacey Schaffner
(collectively "Defendants"), are adult individuals having a last known address
of 192 Faith Circle, Carlisle, PA 17013.
3. On or about June 6, 2007, Jared M. Bahr, borrowed from and agreed to repay
to Members 1St TWENTY THOUSAND AND 00/100 ($20,000.00) dollars
(the "Loan"). The Loan is evidenced by a Note dated June 6, 2007 (the
"Note") executed and delivered to Members 1St by Defendants. A copy of the
Note is attached hereto as Exhibit "A" and made part hereof.
4. As security for the Loan, Defendants executed and delivered to Members 1St a
mortgage ("Mortgage") on all that certain real estate and improvements
erected thereon situate in North Middleton Township, Cumberland County,
Pennsylvania, known and numbered as 192 Faith Circle, Carlisle, PA 17013
(the "Property"). At all times relevant hereto, Defendants have been and
continue to be the record and sole owners of the Property. A description of the
Property is attached hereto as Exhibit "B" and made part hereof.
On or about June 28, 2007, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office at Mortgage Book 1997, Page 2888. A true
and correct copy of the Mortgage is attached hereto as Exhibit "C" and made
part hereof.
2
6. The Mortgage has never been assigned by Members 1St and is still held by it
as a valid and subsisting obligation of Defendants.
7. Pursuant to the terms and conditions of the Note and the Mortgage,
Defendants agreed to pay to Members 0 monthly installments of principal
and interest in the amount of at least $250.89, which amount was subsequently
adjusted to $250.59 per month, each beginning on July 10, 2007 and
continuing on or before the tenth (10'`) of each month thereafter.
8. Defendants are in default of Defendants' obligations under the Note and the
Mortgage as a result of Defendants' failure to make the monthly payments due
to Plaintiff as set forth therein in the amount of $250.59 each for the months
of June through October, 2011, as more particularly described, in part, in the
Notices under Act 6 and Act 91 attached hereto collectively as exhibit "D"
and made part hereof.
9. Members 1St gave written notice 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., and in
particular section 403 thereof, and of Defendants' 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. SeMc ., by letter dated
August 11, 2011,(the "Notices") addressed to Defendants via certified mail,
return receipt requested. A copy of the said notices are attached hereto
collectively as Exhibit "D" and made part hereof.
10. Simultaneously, Members 1 st forwarded to Defendants the same Notices as
set forth in paragraph 9 above addressed to Defendants by United States mail,
first class, postage prepaid, bearing the return address of Members 0. The
11
12
13.
14
Notices forwarded to Defendants in said manner have not been returned to the
offices of Members 1St as undeliverable or otherwise.
Defendants are indebted to Members 1St in the amount of SIXTEEN
THOUSAND THREE HUNDRED NINETY-THREE AND 11 /100
($16,393.11) dollars itemized as follows:
a. Outstanding principal $14,919.87
b. Interest to November 4, 2011 610.59
c. Late fees 62.65
d. Attorney's fees and expenses 800.00
f. Total due to Members 0 as of 11/4/2011 $16,393.11
Defendants also agreed under the terms and conditions of the Note that in the
event of default there under Defendants would pay, in addition to the amounts
set forth in paragraph 11 above, costs incurred by Members 1St as a result of
the institution and prosecution of these legal proceedings.
The obligation owed to Members 1St continues to accrue interest at the rate of
$3.5726 per day, through the date of payment and continues to accrue
attorney's fees and costs.
Members 1St is not seeking a judgment of personal liability (or an in personam
judgment) against Defendants; 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
4
to reestablish such personal liability discharged in bankruptcy, but only to
foreclose the mortgage and sell the Property in accordance with Pennsylvania
law.
15. As set forth above, Members 1St has made demand upon Defendants to cure
the default under the Mortgage and the Note. However, as of the date hereof,
Defendants continue to fail and refuse to cure the default.
WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment,
In Rem, against Defendants, Jared M. Bahr and Stacey L. Schaffner, A/K/A, Stacey
Schaffner, in the amount of SIXTEEN THOUSAND THREE HUNDRED NINETY-
THREE AND 11 /100 ($16,393.11) DOLLARS plus interest at the rate of $3.5726 per
day through the date of judgment and at the legal rate thereafter, 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.
Respectfully submitted,
Date: i r f -3/i
l Xarl . Ledeb ohm, Esq. e Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
?St
5000 Louise Drive, P.0 Box 40
Mechanicsburg. PA 17055
MEMBERS P
PRIP AM-0
CLOSED-END NOTE, DISCLO
BORROWER'S .. 1E AND ADDRESS
JARED M BAHR
192 FAITH CIRCLE
CARLLSLE PA 17013
ACCOVM NUMBER
C060FIROWER3NAME
STACEY SCHAFFNER
CO-BORROWER'S NAME
dXt FIXED M VARIABLE
UtkIWZUU1
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: The amount of Total of Payments: The amount
RATE: The cost of your credit as a The dollar amount the credit will credit provided to you or on your you will have paid after you have
l
h
d
e
.
edu
yearly rate. ' cost you. behalf, made all payments as sc
674 % e $ 10,106.()8 e $ 20,000.00 e $ 30,106.06 e
tren6acl)on K 11M (Index) changes. The
ring the
ta
ns of h
is
Increase
du
may
Rate
Percentage
above the
Annual
indicated
variabl
rule a3
your loan
hag
e
V
a
riable
Rate:
If
a
, The
we
never
be
rate
the
month.
The
day of
l hrgher
fast
monthly on the
change
role will
ndex
value. The
than for the $5
000 at maximum rol rate efors
i
will
add a
margin
of
to the
ae
dh
union
to by 15% 40
l
F
E
if
,
xamp
your
or
e,
can was
law, and It will never be less than . Any Interest rate Increases will result in more payments of tin same amount.
months end the Annual Percentage Rote Increased by 2% after one year, the term of your loan would increase by two monihs
'Preferred Rate: If checked, the following ispres to your loan:
® Automatic Payment Discounted Rate: Because you have • reed to make your required monthly Daym making through it automatic deduction from your CheckinglSavings
PERCENTAGE MTE disclosed above in the ANNUAL PERCENTAGE RATE box Is
A
L
Account, your ANNUAL PERCENTAGE RATE has been discounlad by .20%. The ANNU
the Automatic Payment Discounted Rate. This rate will Increase by .20% If you cease the automatic payment arrangement or tell b maintain sufficient funds in your account to
cover the automatic payments. In such a case, the effect of the Increase will be to extend use term of your loon. For example, If your Automatic Payment Discounted Rate is 10%
your rata will Increase to 10.20%, torturing in I additional payment.
ment arrangement
the outontauo
a
l
f
nth
d
9
,
p
y
you coast
oan
s en
on a $5,000.00
or
0 mo
Variable Rate Preferred Loans. If your loan Is a variable rate loan and you quality for a preferred rate, your preferred discount Is taken at the time you take out your Wan. This
according to changes In the Index (as disclosed above). Fat example, 11 8 variable rate loan's Inlual ANNUAL
d ANNUAL PERCENTAGE RATE will then va
i
i
l
f
i
ry
pre
erre
t
a
n
PERCENTAGE RATE Is 12% at the time you take the loan, your initial preferred ANNUAL PERCENTAGE RATE will be N/A%. Your Initial preferred ANNUAL PERCENTAGE
RATE will then very according to the Index, as disclosed in the "Variable Rate' provision above.
Fixed Rate Prefemd Loans. 11 your loan is a fixed rasa ban cared you gwllry to a preferred rote, your ANNUAL PERCENTAGE RATE will be the preferred ANNUAL
.
PERCENTAGE RATE disclosed above for as Ion as ur re brted atotus romalns In effect
—
Number of Payments Amount of Paymtnte Payment Frequency When Payments Are Due Property Insurance: You may obtain property
insurance from anyone you want that Is acceptable to
89 Monthly - Beginning 07/1012007
119 $250
P
y e the credit union. If you get the insurance from Iho
i
i
i
.
n1
a
smedwe
wel r: 1 $250.15 Final Due - On 06/10/2017 t un
on you w
ll pay
cred
S N/A
Stcudly: Collateral occur" other loans with the credit union the goods or properly Other
w81 also secure this ban. You are 9IVkV a security interest In being purchased. (Describe):
your shares anddor deposit In the credit union, end:
Late Charge; 11 a payment is late by 10 days or more you will Required Deposlt Balances The Annual Percentage Rate does Flling Fees: Non-Flling Insurance:
s fee of 5% of your scheduled payment. not take Into account your required deposit balance, If any. $ NIA $ N/A
be charged a lot
ad?tIpra?d tMroMe stew/ nalPaYnbm, anY reWked nWYr^a'u in fur be are
u
Y' rManeYrnMwtkNU ply suit/'. You wis riot mw to pay a p"" an a?ypeuyed da'yle oar. par PrePayfar nlaN any ralurrda
tltaM1l Yid
1 I tmlLJk I IVrv ur
AMOUNT FINANCED S
20,000.00
Amount Paid to others on your behalf (Describe)
AMOUNT GIVEN TO YOU DIRECTLY $ 2.854.02 $0.0' To Minn°sola Lire
$0.00 To kken wls cat $ 6,250.38
S To DISCOVER CARD
To
_
AMOUNT PAID ON YOUR ACCOUNT $ $4.111.43 TO WASHINGTON MDT
BANK OF AMERIC
78377
4 $
$ 0.o0 To
Files
T
-
PREPAID FINANCE CHARGE $ 0.00 $
.
To
$ To Need Sotubon $ o
To Al-W 59kluonx
SECURITY INFORMATION
OTHER (Describe): 192 FAITH CIRCLE
and/or Deposits of I S I $
Yqu agree that the ferns and conditions In the disclosure statement and the loan and security agreements located on page 2 of this document shall apply to this loan. If there h more
than ona bo'w'er, we agree that all the conditions of the loan and security agreements governing this ban shall apply to both (olnay and severally. You acknowledge that you have
received a oopy of he loan and security a eetllente and disclosure statement. Co-slpner if you are signing es co-signer, you acknowledge receipt of the nonce to co-signer
comsirrd on sage 2.
e R 1 DATE/ C AKER ? 'OT 1E O ER "CO NER DATE/
ISM) (SEAL) 06 t7 6
0-MAK HER OWNER ? "CO-SIGNER DATE CO-MAKER 'OTHER OWNER -SIGNER DATE
X (SEAL) X (SEAL)
? CPMAKER ? 'OTHER OWNER ? "CO-SIGNER DATE ? CO-MAKER ? -OTHER OWNER 0 "COSIGNER DATE
X (SEAL) X (SEAL)
oTaER oMMEk Mr Fr.M rah. fur • eee.rtr InM.en iww aran as a renw M marl k p.aese bWIM• yp..,rel.Iarr M. TN sat serer', waa.a . We..a-,nos.,, Y M WIp iaa 4 W y xrs anal eu we.ranee Vw
cMM cob„ N...eY,IN try,' M IN een.enl a ae+.k.e is Yr seuny Apnarr?d.'CgatglRx; Upon s'te'al Or snb tnLn may eM Ins,rdrr p.yr,er,t tram Ur prnnk.r a r,ry .red .a was M en Y,e do TN
wsrenrs wehe. N nails to Mad' N w sN wuY aNenlr M MIYa W Yr.
t tin) undaeisn0 NW sra pu or- of into insurance Y volumery and nil required In crow to nation cndl and off I (wa) may lartmat• x al any 11,10.1 (M0) VKW t" that I joint tie 'insurance
If seeded, wo
nxW be lowy and ir.WO.Wy Rates undw VW No., arts that co.spneM1 and glreemofs ere lip eligible lot Insurance. APPLICA C( J,APMICAW
TM IploMng quesdom. 1 end 2, must be anewo ed to delemyha my low) eaglbatty star ltarrsnca- IIT.[I 1)L,?$jJl
(AppkabN to If• taumm. cower." MM WW Wu b• under age 70 an the acMUukd Makedry Nis of you den?
you prp•rlVy E 11
?''1
1. 0 on 10 -mid. yaw IW,M ?ryMgae V Pdit our 30 fbu or mW\ Per 7we" fro he" been W wW1Ylp? jar, X day, 01 mars beWn Nit d.W7 working
El ? LJ ? your con AND - M add st- fl yourloan •xc..da s 25,000.00 nit bKOwlna,gwsUon meal aIw a .nu'rs'ed In «de le aarml10 .uybey. 11 ? ? ?
3 ,Ourlnop Mahal M1. navpp.r rly?Iy d p treated 1& >•r hOW an or araary nary dkaaso ctoks,
wmWt. Atpiredt Der ayMarr Ba NOS Congas I?.RCR
fin 1 Wr) engines W like above puasummu Ye true to pr qY W foy, ovl wbASaoaa arrd benA n co- am or I aruwer'No* to quesuon t a 21 we undpratand Irot uus persm Is not 094A 1a In.-. and
wa ru be Insured R mi, Ix?apprlr+m or I answer Yo' to question ?. cos uraerakYW Inn wv ors ail gua a Irtaumce tP to w amount not ?casal $1.00.
The ggKb a dale of my (du) I"rp" wits a ter data of dun ppgqloon. Arty parson who Nrowlngly and with Imam to dehaud any mounnes co parry a other parson aIr an sppllr_ for Insurance
statement of palm containing any materially Mae InforeWlao or cCfterk for he purpose of mklearayg, Informatlpn opnumub any lace mahNl Vkaralo cpmniltr a naudulenl In.-ca act
winch k a acme and sub)ecp such parson to cHmwl and cM1 pared Ws. Do not elon h4 appUUUm K arty apWlcabN apac•s •n a4nk Tnls ppllyuon MII noi be used In catkq If an apphca0l,
Wank spaces have nor bin computed, he debla has not algned and dated the appicadun card a tlr• app 1Ur has not Wen witnessed.
CREDfT INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
? Yes Q No Single Credit Life Total Premium ? Yea Q No Credit Disabilry Total Premium
? Yes - Q No Joint Credit Life
Irbkele which epplkent(.): ? Applicant ? Co-Applkanl $ 0.00 Indicate which applicants). ? Applicant ? Co-Appl-I $ 0.00
rev r. oil Wunriaia car soar of p 901 .core. I. hulloned on nit ..mlaeon.
APPLICANTS SIGNATD TE OF GIRT DATE
/r
reoout-?AtTt EFICIARY (CO-APPLI T)
kn/C:9s.43ea.37 A
PAW,97.6200. 37 LAWA-WARD F..3709 Ref 1101 Exhibit "A"
06/06/2007
JARED M BARAHR
NAMEOA9 BORROWER(S)THE WORDS 'CREDIT UNIOM MEANS MEMBERS i$T FEDERAL CREDIT UNION. THE WORDS 'YOU.' 'YOUR' AND 'YOURS' MEAN THOSE
S
LOAN AGREEMENT
PaymentsYFinance Charges: For value received, you promise to pay, at
the Credit Union's orrice, ati amounts due. NI payments shall be made
pursuant to the disclosure statement on ape this document. You
understand that the finance charge and total o 1fof pa menu shown on page 1 are
all Ins willbbe madenonntft sccheduled dueadsaatee and ,cif you havtall quallfled fur rats
preferred rate that you continue to sallsfv the conditions of that preferred
rate. It you fall to pay any installment by a time It is due, you will pay
additional Interest on the overdue amount.
Allocation of Payments and Additional Payments: Payments and
credits shall be applied in the following order: any amounts past due; any
fees or charges owing, Including any insurance premiums; accrued Interest
or finance charges; outstanding principal. Payments made In addition to
regularly scheduled payments shag be applied in the same order,
Preferred Rate: It you quagN for a preferred rate as disclosed on Paapoe 1 of
1Ns document or In a severe lle preferred role addendum You undarcfand
that you must most the conditions disclosed to you In order to qualify for the
preferred rate and must continue to meet those conditions In order to keep
your preferred rate. 0 you fag to meat those conditions, your rate will
increase, therebyy extending the terms of your loan. You promise to continue
making payments and to moot all obligations under this Agreement even If
you no longer receive the preferred rate.
Lets Charges: If u make a lets pa M, you agree to pay a late charge
g one is disclosed on page 1 of this document,
Property Insurance: If you obtain a ban secured by a motor vehicle or
other tangible property, you must obtain Insurance whbh protects the credit
union from financial Was. The amount and coverall of the property
Insurance must be acceptable to the credit union. 5uch a policy must
Pn rovide at least fire, then, combined additional coverages and collision
surance. It must contain a Loss Payable clause endorsement naming the arn yyoo r holce as diret t a agent to send the c edituunion from copy of the of
Debtor Responslblitty: You promise to notify credit union of any charge in
policy
your name address or empbyymer>< You promise not to apply for a ban N
you know Were is a reasonable probability haft you wig be unable to repay
Your obligation acgording o the terms of l o credit extension. You promise tio
which toppmeey your obligation. You promrqsa notttto submit take w sInaacccurate glty to
nlormatbn or Mlifully conceal imormalbn regarding your creditworthiness,
credit standing, or credit capacity.
Statutory Lien: If you are in default, federal taw gives me creea union are
right to the balance of shares and/or dividends in our accounts at
the Urn of default to sattsN thk loan. Once you are In detaun, the cre t
union may exercise this rig wdtrtout further notice to you.
Delay In Enforcement: Credit Union may delay enforcing any of the credit
union rights ardor this agreement withoulosing them, yme
Irregular Payments: The credit union ens Iy n fu 1 pwNrle ioul bait acr of thael
payments, even thouvh marked *paym
fetid union rights undorlothis agreement.
,a equaW relpyn slble von h tfibo o7 agreement creddtunion may sued to
either or both opyou. The Crednt union b not have to -Wr you that this
agreement etda release any plselocunhewithout nom may oo releasing you from
responsibility on this agreement,
Contractual Pledes of Shares: You pledge all your shares and deposits In the
credh union, Including future additions, es security for this ban. In use you
default, the credit union may apply these shares and doposas to the payment
of sit sums due at the time of default, Including costs of collection and
reasonable attorney's fees, that the credit union may Incur, up to 20% of the
unpaid principal and Interest. No lien or right to Impress a Hen on sham and
deposits shell apply to spry of your shares which may be hold In an'IndWtdual
Retirement Account' or "Keogh Plan."
51002/99
NOTICE TO COSIGNER
You are being asked to guarantee this debt. Think carefullypgfore you do. If the bOrOwer doesn't pay the debt, you will have to. Be sure you can afford to
pay if you have to, and that you want to accept this responsibility.
You may have to pay up to the full amount of the debt if the borrower does not pay. You may also have to pay late fees or Collection coals, which increase this
amount.
The creditor can collect this debt from you without firet trying to collect from the borrower. The creditor can use the same collection methods against you that
can be used against the borrower, such as suing you, 9aamshinnng your wages, etc. If this debt Is ever in default, that fact may become a part of your credit
record. This nonce Is not the contract that makes You IWble for a debt.
SECURITY AGREEMENT
1. To secure payment of thla ban end
for this lean or for any
AZ--ri princfitpal ieiklinie 1unless th-, p-=pe rreescla alon fiodces en
os
h
s
s
rowe e aho audit r ts '. requlfemonts are *albeaA), or are non•puro
y cha o?dapoo?
2. You idln utnrnga d the lon of 'sll or transfer the collateral unless you have
9. You warrant blhel you have oped tee to the coWwW, free atoll security Interests
esupl that givveen W trehes crodit unbn enc. axcppt la any Interest f e nco-
make owner o1 the cc Moral who has Signed the agreement In t?a Indicated
place
4. You war pay a?ll taxes assessnerW. no Bern aparmt or attached to the pr rty
described ZZ hrN er cures b keg P one g In ood condition, housed n a
suitable shelter. VVote wt?a to?easapulo breclnp ?IalYemales rd NcvdtY
rty Gelmreda vnbn'a request and wit derena the property
agreement amendm??UU
against adverse 1INNrr el
$, You Val maintain insurance to cover any vehicle o o?rrr props In whbh the
credit untort n?ues a sect rrwlad. Trek Insumr% suet lea k+ a En ?rtl an
amount aelkfaM l aadN unbn. Yau suet W y nit cn0 a proof
of such Insuranceryy d r>q owtp to aadll Un are aseund bny n this with props are r Dar. YoY red to maawkr such arsurarwa, credit union may but
k t W eMatn tneurartos Or our own and add tin coal of ,on ro the
sums owed. This cast war bear line $1 at the contact n4o umd p?ld. You further
east .an to the credit union the rf hl to faceWe the & of any nsurance on
such propary andd dlrect any IMU1sr to pay those procieso proceeds dkac6y to credit
unfon You aulfil ze the credit unbn to erdone any check of Qnti provbed as
the proceed of such Insurance, and apply those proceeds to the sums owed to
the credit vn?on
You further authorize ft credit union b pprrovide your Insurance Service Center
with the necessary Information for verili Hart of adequate coverage.
You ackravAsdae litre Insurance or am extsmbn tM?o1, ?lecheed bct the credit
urtbo is wit beneM to you Indlvku le ly but k prlrnarey ro t praebn of ins
cretin ,kn.tru
6, Should Ihqq credit tendon teal at tlmp Utat the s ray pesented has
dbNnialed M value, or for a?ny mason led thgt addabnar =,, la re?lulredh ou
aline ro Nsqn l0 ends unbn within ten If tf day. atewr se ,dote sew
the credit unbn fade to neusesry to protect 1M crad t unbn agelnst possl0ls
lose.
F. 43768 1102
APPRO system. Inc . n+tofe
Page 2 or 2
The Gsda union Is Mreppyy 9ppdNed as your Atlomi-W.Facl to perform enY
ncl the collateral and the
teals wh',ah the credit terabit lials an necessary to uad
security kderest which this agreement cm
If then Is mom than aro borrower. Your obliaetons under this agreement are
Wnr W sa"ral, each being equally nsponsftd@ o N151 Na terra of this
This sovr%,ejroment not only binds you, but your executors, administration,
holn; and
ALL THAT CERTAIN, tract or parcel of land and premises, situaAre, lying and being in
the Township of North Muacton, County of Cumberlai4 and Commonwealth of
Pennsylvania, more particularity described as follows;
,6EING Lot No. 38 on the Plan of Kingsbroolk Section "3 ", as recorded in the Office of
the Recorder of Deeds for Cuntberhvo County in Plan Book ,3 7, Page 130; containing
60.00 feet along the Fast along Faith Circle; containing 2611.00 feet along the North
along Lot No. 37 on said Plan; containing 60.00 feet along the West along lands now or
formerly of Hooke, Lebo & Hooke; and containing 260.011 feet along the South along Lot
No 39 on said Plan; and containing 15,600 square feet.
SUBJECT TO the building and use restrictions as recorded in the Recorder of Deeds
Office in Miscellaneous Book 184, Page 763.
BEING: improved with a dwelling known as 192 Faith Circle, Carlisle 17013.
BEING the same premises which David J. Tatem and Kimberly B. Tatem, husband and
wife, by their deed dated October 21, 2006 and recorded in the Cumberland County
Recorder of Deeds Office in Book 277, Page 2237 granted and conveyed unto Jared M.
Bahr and Stacey L. Schaffner, single individuals.
TAX PARCEL #29-14-0868-127
Exhibit "B"
11/03/11 15:09 FAX 7172438955 Douglas Law Office
prepmrad By: Membms 1 st l7M
5000 Louise Drive
Mecbm?icabtiag, PA 17055
When roocabd mail to:
PMT AMERICM TIM IMUR"CE
LMOMADVANTAGE
1 X003UPERONAVENUZ; SUTTE 300
CLOW AND, OX70 44114
A TIM Fn 1210
ROBERT P. ZIEGLER
; 9.*V ER OF DEEDS
Cu u 9ERLAND COUNTY-:1
Zwi JYN .8 Ali 9 39
MORTGAGE 1 Z... ?? e 3 3
Ma& _06^MR007
smtwa.•
JARED M BAHR AM STACEY SCHAFFNER
And
MEMBE s 1ST FEDERAL CREDIT UNION (bmkafbw called "MortpWN)
tool
has amcutcd and ddi"n d to a oa?hin Nod
called 'Tloun) of wm dde bomdd,, payable to So 1 rtRa?eellfo is 68 aam of
S hiwliod money of d,e Um1ed SON of ASKIM MaAa. to?lMe°r ?aein
my m K
ummmu,
and
aos?n, lsanad airas IMP iase,est m mm st the raie nmvidod in the Note, in the mm m amd at tbm t, Npa?e=nds sst 6orth, Wilh
doing certain owes tams and conddims, all of wlrich erne Vvv&o @Uy moorporated bm m by
rdmvm;
Ngw, lrh afera, IK ,m eomsidKgb= of said debt or prior ' span mad as security for the
payma,t of the amore and iaWenest m afi0m d, t0VdW W* all 0-- sums payabb beneander or wader
the tamers of titre NOW, does !lt and anew MID MWVK9M
All that Mtsin property of am Mmtgagor located is NORTH id?DLE1?QsN
SEE EXHIBIT W
04- 0U'4 - 0124-0=p000 -a_g
which cur =dy has the address of 192 FAM CMCLE
Carlisle PWOWINW" 17013
Icbyl [zip COI
Acm No AppID 20737701 Pape 1 Of 4
Exhibit "C"
P% 3 A;
CID
t WIN
Irfl-
a a r? a.SF ?de ? . I
N
N
?A
w
0
r?
r•
n
m
0
0
N
M
O
0
m
V
0
A
lfD
Ifs
cm
00
M
N
O
.-I
41
its
'? 6ay°g _?g E g 3
lit M
N
If
m
11/03/11 15:11 FAX 7172438955 Douglas Law Office
2004
Wtbwu the due e:ecation hereof die dry aad yrar written.
STACEY
Ccao mwmith of Pmusylvania
county of Cumberland
On Ibis, the 6th day of June 2007 , before me,
o cM pera=M appeand
m mG W be Ito pawns a aee to a , "
aclmowled hdahe mecded ft game for the patposee dmumb omatin &
L Wham MermC I hereunto set my htmd and oofficcud ad.
My
ttltlr?so
tlaMsaL. ttaaas? t+tomay wb?o
tltr:?,OpM
Members Pr Federal Credit Unioa, Mottgadee within named, hereby certifies that its residence
is 5000 Louise Drive, l osburt PA 17055. -l ... . I" By
AM No Appp 70737701 Pqp 4 d 4
191 7PG2$9.J
11/03/11 15:11 FAX 7172438955 Douglas Law Office
10005
r'
L.E"L DESCRIPTION
A PARCEL 03' LAlm 82TMM 3N TOM 8' &M OF IMMMMUK, COLVVY OF
CU , mzvR l1 samar 7OCMIOIi ADDIS= OF 192 NUIR CYR;
CU MINA, VA 17013-8870 C CB W am= x mm Am 82ACMY
L BCRAR R HAVING A TAX M00399 CMICM NUMBER OF
14-0868-0127-0000000-29 MW !ORTM DROC IBSD AS LOT 38 SMC 5 PS
37 PG 130 .
14-0868-0127-0000000-29
192 FAITH CIR; CA=WA, PA 17013-8870
207377 r ow PA
33479893/f FIRST 0"Imm Loom
rANTORM
'J isi15 iC be recordCd
i_ x., uerland County PA
RCCI)rder of Deeds
m t"M 2
Date: August 11, 2011
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default. and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The name, address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any questions. you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717)80-1869).
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Exhibit "D"
HOMEOWNER'S NAME(S): JARED M BAHR
STACEY SCHAFFNER
PROPERTY ADDRESS: 192 FAITH CIRCLE
CARLISLE, PA 17013
LOAN ACCT. NO.:
0001
ORIGINAL LENDER: Members 1" Federal Credit Union
CURRENT LENDER/SERVICER: Members 1" Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE, YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on
your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you
must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS
NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE,
CONSUMER CREDIT COLINSEL.ING AGENCIES -- If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county
in which the propeM is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face
meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this
Notice (see following pages for specific information about the nature of your default.) You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign
and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency, To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
and received within thirty (30) days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
Page 2 of 5
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by
the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued
against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(if you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at:
192 FAITH CIRCLE
CARLISLE PA 17013
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: $250.27 due for 06/10/11, $250.59 due for 07/10/11, $250.59 due for 08/10/11 and $250.59
that will b
Other charges (explain/itemize):
TOTAL AMOUNT PAST DUE: $1 002.04
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable):
HOW TO CURE THE. DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1.002.04 ,
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either cash cashier's check certified check or money order made payable and
sent to:
Members I" Federal Credit Union, ATTN: Alli
5000 Louise Drive
Mechanicsburg PA 17055
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do
not use if not applicable.)
Page 3 of 5
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGES FORF.C .OS .D UPON -- The mortgaged property will be sold by the Sheriff to pay off the
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to
$50,00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. If von cure the default within the THIRTY (30) DAY period. you will
not required to po aty torneX's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the
THIRTY (30) 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 Sale You may do so by paving the total amount then past
due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other
requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
FARLIFST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of
the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A
notice of the actual date of the Sheriffs 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 or action will
be by contacting the lender.
Name of Lender* Members 1" Federal Credit Union
Address@ 5000 Louise Drive
Mechanicshurg, PA 17055
Phone Number: (717) 795-5277 or (800) 283-2328 Ext. 277
Fax Numbers (717) 795-5207
Contact Person: AM
F.-Mail Address: hurlberta anmemberslst.org
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or XX may not (CHECK ONE) sell or transfer your home 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 of the mortgage are satisfied.
Page 4 of 5
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4/30/2007)
Notice Disclosure Office of Housing
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).
Who Mav 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.
"ghat 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 Request Relief Under the SCRA?
• 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.
How Does a Servicemember or Dependent Obtain Information About the SCRA?
The U. S. Department of Defense's information resource is "Military OneSource".
Website: http://www.militaaonesource.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://legalassistance.Iaw.af.mi]/content/]ocator,php
form HUD-92070
(2/2007)
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 1128/2011 8:36:10 AM
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Capital Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17266
717.762.3285
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
10/27/2011 09:56 7179320317 KARLLEDEBOHM PAGE 07/07
MEMBERS 1sT FEDERAL
CREDI'T' UNION
PLAINTIFF
Vs.
JARED M. BAHR
STACEY L. SCHAFFNER
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO..
CIVIL ACTION-LAW-MORTGAGE
.FORECLOSURE
VERIFICATION
1, Dan Summers, Collections Manager for Members 13t Federal Credit Union,
being authorized to do so on behalf of Members 11 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
By: VZV*
Dan Summers, Collections
Manager
6
to
FILED-OH IC:
20 11 DEC 14 PM 12: 59
CU,1BERLAND COUN `
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
V.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 11-8347 Civil Term
: CIVIL ACTION -LAW
: MORTGAGE FORECLOSURE
PRAECIPE
Please enter judgment ink above captioned proceeding in favor of Members 1"
Federal Credit Union, Plaintiff, and against the Defendants, Jared M. Bahr and
Stacey L. Schaffner a/k/a Stacey Schaffner, in the amount of Sixteen Thousand
Five Hundred Thirty-six and 01/100 ($16,536.01) Dollars, plus interest at the rate
of $3.5726 per day from December 13, 2011 through the date of judgment and at
the legal rate thereafter until the date of payment including on and after ru ry of
judgment, additional attorney's fees and costs of suit as well as other charges
collectable under the mortgage 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 Jared M. Bahr and Stacey L. Schaffner a/k/a Stacey
1 y 00 PO orl
C# N17
P-#,:2 c86°4
>&l ahz'Q /VIR"Gee?'
Schaffner to Plaintiff s Complaint within twenty (20) days of service thereof and
after a 10-day Notice was sent.
Res 1 s mitt ,
Date: December 13, 2011
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 notices of intent to take a default judgment were forwarded to
Jared M. Bahr and Stacey L. Schaffner a/k/a Stacey Schaffner by United States Mail,
First Class, postage prepaid on November 29, 2011. The aforesaid notices were each
contained within an envelope bearing the return address of the undersigned. The notices
have not been returned to the undersigned as undeliverable or otherwise. A copy of the
notice and Postal Forms 3817 are attached he7m"-; it "A".
i
hm, Esquire
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
v:
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
Date: November 29, 2011
TO: Jared M. Bahr
Stacey L. Schaffner
192 Faith Circle
Carlisle, PA 17013
: NO.: 11-8347 Civil Term
: CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS 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 BE USED FOR THAT
PURPOSE. IF YOU ARE IN BANKRUPTCY OR HAVE RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT BUT TO ENFORCE A LIEN UPON REAL ESTATE.
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
Exhibit "A"
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 PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
` OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
submitted,
Date: November 29, 2011
Karl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
v S POSTAL SERVICE CERTIFICATE OF MAILING
M
MAyBEUSE()'?F? )MESIICANC) IN TERNATIONALMAIL DOES N•)' o `"o
>
PROVIDE FOP NCUR.ANCE POSTMASTER O
?
M
(y
RB.-.eweO 4Jr^ ``, ?I
1 y
Kk..
Y ir1'
Karl M. Ledebohm, Esq. i
P.O. Box 173
New Cumberland
PA 17070-0173
,
\ Crime 7ece .?. ,a..... .,- ovine>sec aI N'J H.D
fD°.roac
vF??+ ...1 .oF- U
?
Stacey L. Schaffner m
D n
192 Faith Circle 'D
Carlisle, PA 17013
U POSTAL SERVICE
CERTIFICATE OF MAILING
MA• 9E J jE G L:, G pnME S TAI, aN71 N TE RMA T Z ONAL MAIL DOES NOT
PRn.IDE :QP INC.?RANCE POST MANEP
R a.:.e.•, ea JR,
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173 s
?r ?,ece ;, ;o ..o o evv'esseo Ic w>
Jared M. Bahr
192 Faith Circle ` --- -
Carlisle, PA 17013
38,,
O I' p
? b
N
..;,.
tea, ? ,
=o
ILED-OF ICE.
THE PRCTHCN0 TA.?-_,'
2011 DEC 14 PM 12: 59
CUMBERLAND COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 J' FEDERAL
CREDIT UNION
PLAINTIFF
V.
JARED M. BAHR
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 11-8347 Civil Term
STACEY L. SCHAFFNER CIVIL ACTION -LAW
a/ka STACEY SCHAFFNER
DEFENDANTS MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-NULITARY SERVICE
The undersigned hereby swears and affirms on behalf of Members 1" Federal
Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff s
knowledge, Jared M. Bahr and Stacey L. Schaffner a/k/a Stacey Schaffner are not
currently on active military service.
Date: December 13, 2011
Kul M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY,
: PENNSYLVANIA
PLAINTIFF
V. : NO.: 11-8347 Civil Term
JARED M. BAHR
STACEY L. SCHAFFNER CIVIL ACTION -LAW
a/ka STACEY SCHAFFNER
DEFENDANTS MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM
REQUIRED TO INFORM YOU THAT THIS NOTICE AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE
TO: Jared M. Bahr
192 Faith Circle
Carlisle, PA 17013
Stacey L. Schaffner a/k/a Stacey Schaffner
192 Faith Circle
Carlisle, PA 17013
You are hereby notified that on I J,C /y , 2011 the following
judgment has been entered against you in the above captioned case:
Judgment in favor of Members 0 Federal Credit Union, Plaintiff, and against the
Defendants, Jared M. Bahr and Stacey L. Schaffner a/Wa Stacey Schaffner, in
the amount of Sixteen Thousand Five Hundred Thirty-six and 01/100 Dollars
($16,536.01), plus interest at the rate of $3.5726 per day from December 13, 2011
through the date of judgment and at the legal rate thereafter until the date of
payment including on and after entry of judgment, additional attorney's fees and
costs of suit as well as other charges collectable under the mortgage 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 Jared M. Bahr and
Stacey L. Schaffner a/k/a Stacey Schaffner to Plaintiffs Complaint within twenty
(20) days of service thereof and after a 10-day Notice was sent.
441
Dated: f 2 / l? rothonotary
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
is: Jared M. Bahr
Stacey L. Schaffner
192 Faith Circle
Carlisle, PA 17013
A: Jared M. Bahr and Stacey L. Schaffner
Por este medio se le esta notificando que el de
2011, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el
caso mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direction as la del defendido/a segun indicada en el certificado
de residencia:
Jared M. Bahr
Stacey L. Schaffner
192 Faith Circle
Carlisle, PA 17013
Dated: December 13, 2011
Berl Ledebohm, Esquire
Suprea 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) NO 11-8347 Civil
COUNTY OF CUMBERLAND) 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 JARED M. BARR, STACEY L. SCHAFFNER A/K/A STACEY SCHAFFNER
(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: $16,536.01 L.L.: $.50
Interest FROM 12/14/11 AT THE LEGAL RATE
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $187.44 Other Costs:
Plaintiff Paid:
Date: 1,11/.2012 L
David D. B ell, Prothonotary.-
(Seat) B .
Deputy
REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: P.O. 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
V.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
r"LED-OFFICE
1 ? pROTHONOTARY
2412 JAN I I PM i *-"
cUM NHS LVANiUA TY
P
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO.: 11-8347 Civil Term
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER,
Amount Due: $16,536.01
Interest from: 12/14/11 at the legal rate
Attorney's fees $ to be added
Costs $ to be added
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Jared M. Bahr, 192 Faith Circle, Carlisle, PA 17013, defendant;
(3) against Stacey L. Schaffner a/k/a Stacey Schaffner, 192 Faith Circle, Carlisle,
PA 17013, defenant;
(4) and against N/A Garnishee (s);
(5) and index this writ against:
(a) Jared M. Bahr, 192 Faith Circle, Carlisle, PA 17013, defendant;
(b) Stacey L. Schaffner a/k/a Stacey Schaffner, 192 Faith Circle, Carlisle,
PA 17013, defendant;
Sa. N4 C13F
(c) against N/A Garnishee (s),
and levy upon and seize the following real property of Defendants and index this writ
against the following real property of Defendants as a lis pendens:
All that certain real estate and improvements erected thereon situate in North Middleton
Township, Cumberland County, Pennsylvania, known and numbered as 192 Faith Circle,
Carlisle, PA 17013 and as more particularly set forth and described on Exhibit "A"
attached hereto and made part hereof by reference.
Dated: January 9, 2012 ?^ c
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 tract or parcel of land and premises situate, lying and being in the
Township of North Middleton, County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEING Lot No. 38 on the Plan of Kingsbrook, Section "5", as recorded in the Office of
the Recorder of Deeds for Cumberland County in Plan Book 37, Page 130; containing
60.00 feet along the East along Faith Circle; containing 260.00 feet along the North along
Lot No. 37 on said Plan; containing 60.00 feet along the West along lands now or
formerly of Hooke, Lebo & Hooke; and containing 260.00 feet along the South along Lot
No. 39 on said Plan; and containing 15,600 square feet, more or less.
SUBJECT TO the building and use restrictions as recorded in the Recorder of Deeds
Office in Miscellaneous Book 184, Page 763.
BEING improved with a dwelling known as 192 Faith Circle, Carlisle, PA 17013.
BEING the same premises which David J. Tatem and Kimberly B. Tatem, husband and
wife, by their deed dated 10/21/06, and recorded in Cumberland County Deed Book 277,
Page 2237, granted and conveyed unto Jared M. Bahr and Stacey L. Schaffner, single
individuals.
TAX PARCEL # 29-14-0868-127
Exhibit "A"
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS I" FEDERAL
CREDIT UNION
PLAINTIFF
V.
JARED M. BAHR
"FIa ED~O1• FICE
THETROTNONOTiARY
1011 JAN I I PM 1: 13
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 11-8347 Civil Term
STACEY L. SCHAFFNER CIVIL ACTION -LAW
a/ka STACEY SCHAFFNER
DEFENDANTS 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 North Middleton Township, Cumberland County,
Pennsylvania, known and numbered as 192 Faith Circle, Carlisle, PA 17013.
1. Name and address of owner(s) or reputed owner(s):
Jared M. Bahr
192 Faith Circle
Carlisle, PA 17013
Stacey L. Schaffner a/k/a Stacey Schaffner
192 Faith Circle
Carlisle, PA 17013
2. Name and address of defendant(s) in the judgment:
Jared M. Bahr
192 Faith Circle
Carlisle, PA 17013
Stacey L. Schaffner a/k/a Stacey Schaffner
192 Faith Circle
Carlisle, PA 17013
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.: Dan Summers
5000 Louise Drive
Mechanicsburg, PA 17055
Target National Bank
3701 Wayzata Blvd.
Mailstop 3C-G
Minneapolis, MN 54416
Amy F. Doyle, Esquire
Mann Bracken LLP
Attorney for Target National Bank
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
Attn.: Dan Summers
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
"LED
-OFFICE
: w THE PROTHONOTARY
?012 JAN I I PM 1: 13
CUMBERLAND COUNTY
PENNSYLVANIA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS I"' FEDERAL
CREDIT UNION
PLAINTIFF
V.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 11-8347 Civil Term
: CIVIL ACTION -LAW
: MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Jared M. Bahr
192 Faith Circle
Carlisle, PA 17013
Stacey L. Schaffner a/k/a Stacey Schaffner
192 Faith Circle
Carlisle, PA 17013
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 192 Faith Circle, Carlisle, PA 17013, 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 courtjudgment in the principal amount of
$16,536.01 plus interest at the legal rate until the date of payment, 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.
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.
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 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 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 on or before July 6, 2012 or 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.
GM ?+
Karl 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 tract or parcel of land and premises situate, lying and being in the
Township of North Middleton, County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEING Lot No. 38 on the Plan of Kingsbrook, Section "5as recorded in the Office of
the Recorder of Deeds for Cumberland County in Plan Book 37, Page 130; containing
60.00 feet along the East along Faith Circle; containing 260.00 feet along the North along
Lot No. 37 on said Plan; containing 60.00 feet along the West along lands now or
formerly of Hooke, Lebo & Hooke; and containing 260.00 feet along the South along Lot
No. 39 on said Plan; and containing 15,600 square feet, more or less.
SUBJECT TO the building and use restrictions as recorded in the Recorder of Deeds
Office in Miscellaneous Book 184, Page 763.
BEING improved with a dwelling known as 192 Faith Circle, Carlisle, PA 17013.
BEING the same premises which David J. Tatem and Kimberly B. Tatem, husband and
wife, by their deed dated 10/21/06, and recorded in Cumberland County Deed Book 277,
Page 2237, granted and conveyed unto Jared M. Bahr and Stacey L. Schaffner, single
individuals.
TAX PARCEL # 29-14-0868-127
Exhibit "A"
Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
V.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
;
NO.: 11-8347 Civil Term
r
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 27th day of
February, 2012, I served the attached NOTICE TO LIENHOLDERS AND OTHER
PARTIES IN INTEREST 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.
The notice sent to Mann Bracken LLP was returned stating "Forward Time
Expired, Return to Sender," a copy of the envelope is attached as Exhibit "2" 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: February 27, 2012
Marl M. Ledebolim, Esq.' _.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm. Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
X717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY.
PENNSYLVANIA
PLAINTIFF
V.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANTS
NO.: 11-8347 Civil Term
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa. R.C.P. 3129.2(c)
To: (Addressee on PS Forms 3817)
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the
Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of
Cumberland County, directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, PA 17013
on June 6, 2012 at 10:00 a.m., the following described real estate which Jared M.
Bahr and Stacey L. Schaffner a/k/a Stacey Schaffner are the owners and reputed
owners and on which you may hold a lien or have an interest which could be affected
by the sale of:
192 Faith Circle
Carlisle, PA 17013
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT 'A")
The said Writ of Execution has been issued on a judgment in the action of
MEMBERS I`` FEDERAL
CREDIT UNION
PLAINTIFF
v.
JARED M. BAHR
STACEY L. SCHAFFNER
a/ka STACEY SCHAFFNER
DEFENDANT S
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY.
PENNSYLVANIA
NO.: 11-8347 Civil Term
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
at Ex. No. 11-8347 Civil in the amount of $16,536.01 plus interest, additional
attorney's fees and costs.
Claims against property must be filed at the Office of the Sheriff before above
sale date.
Claims to proceeds must be made with the Office of the Sheriff before
distribution.
Schedule of Distribution will be filed in the Office of the Sheriff no later than
thirty (30) days from the sale date.
Exceptions to distributions or a Petition to Set Aside the Sale must be filed with
the Office of the Sheriff no later than ten (10) days from the date when Schedule of
Distribution is filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriff's Sale or this
Notice, you should contact your attorney as soon as possible.
Date: January 26, 2012
&'s ect lly su ii to 1,
i 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 tract or parcel of land and premises situate, lying and being in the
Township of North Middleton, County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEING Lot No. 38 on the Plan of Kingsbrook, Section -5", as recorded in the Office of
the Recorder of Deeds for Cumberland County in Plan Book 37, Page 130, containing
60.00 feet along the East along Faith Circle; containing 260.00 feet along the North along
Lot No. 37 on said Plan; containing 60.00 feet along the West along lands now or
formerly of Hooke, Lebo & Hooke; and containing 260.00 feet along the South along Lot
No. 39 on said Plan, and containing 15,600 square feet, more or less.
SUBJECT TO the building and use restrictions as recorded in the Recorder of Deeds
Office in Miscellaneous Book 184, Page 763.
BEING improved with a dwelling known as 192 Faith Circle, Carlisle, PA 17013.
BEING the same premises which David J. Tatem and Kimberly B. Tatem, husband and
wife, by their deed dated 10/21/06, and recorded in Cumberland County Deed Book 277,
Page 2237, granted and conveyed unto Jared M. Bahr and Stacey L. Schaffner, single
individuals.
TAX PARCEL # 29-14-0868-127
Exhibit "A"
?-'
UNITED STnTE2
ERVlCEr Certificate 1
Mailir > Z
PUST/?L S
From
_ K10 N1. i.?d?hohm.
1'.l ). 13t,X ? 7 i
- Nc??? ?'umherl?md. 1'A l7070-017>
~- Mann Bracken LLP
Blvd., Suite 500
702 King Farm 20850-5775
Rockville, MD
PS Form 381. April 2007 PSN 7530-62 000-9065
7
rn
T } C
Q m s?
2?Cd ?- ?
_Y--.? c7
r - iT7•
pNJCg1>
)
- CJOm?•CD
W. y• J_DC)O
-._-- r L31
N -? D
m
.
a
UNITED STATES Certificate
J POSTAL SERVICE: Maili
This Ce ate of 1, aid no L ov ,es a ,den- in a[ mar h,, b. en prF.,e it?d t- ' S''-° Pn rn, o
h S f(t'. a`: ?P )? b io ,,-,!,c "m ^( r1.3(I::na 11"11 .. h ?
From m
o O
O a ?
c
Karl M. Ledehohm. Esq.
_ 1.0. Box 173
_
New Cumherlaiid, P.A 17070-017;
-n C
To Daniel Santucci, Esquire am_`1
---- N??? ONVCA I>>.
Blatt, Hasenmiller, Leibsker & J??M -.0
Z- .-ir-o
Moore, LLP DUn N C7 p??)
-- 1835 Market Street, Suite 501 -- m
:D
Philadelphia, PA 19103
PS Forrn 3817, Apri 2007 PSN 7530 02-000 9065
Exhibit "199
x
!1l1
r
R-\
r4
? ?.t pct ?:*
Y"4i
V-i 4,
H.,
` t
4 l
,,
p
?
?I 0
3
J 4.
CsQn-Z
-
s-
W J to t4 H H
T,C `fi?`ifVfiR
i
O L 6K0
c0
Cc M
Cc
LL
J
c C Ls
E
0 O
+ w
?-+
U
Q? Q
m
ti
0
0
r-
0
in
Q
w
E o
0 o
a? ti a?
J Q 7
?co0
?O
Y a Z
Exhibit "2"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
t
ei }
'1 p a, a d .
..i F s ,
~ ` ~r a~
...~i,;.1 .... J~,,.
Members 1st Federal Credit Union
vs.
Jared M Bahr (et al.)
Case Numbe
2011-8347
SHERIFF'S RETURN OF SERVICE
03/19/2012 04:22 PM -Deputy Valerie Weary, being duly sworn according to law, states service was performed b~
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled actin ,
upon the property located at 192 Faith Circle, Carlisle, PA 17013, Cumberland County. ',
03/19/2012 04:22 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Esta e
Writ, Notice and Description, in the above titled action, by making known its contents and at the same .ime
personally handing a true copy to a person representing themselves to be jared bahr -boyfriend (aic),
who accepted as "Adult Person in Charge" for Stacey L. Schaffner at 192 Faith Circle, North Middleto
Township, Carlisle, PA 17013, Cumberland County.
03/19/2012 04:22 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Esta e
Writ, Notice and Description, in the above titled action, by making known its contents and at the same :ime
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jare M
Bahr at 192. Faith Circle, N. Middletcn Twp., Carlisle, PA 17013, Cumberland County.
06/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice ad
been given according to law, he exposed the within described premises at public venue or outcry at th ,
Cumberland County Courthouse, Carlisle, PA on June 6, 2012 at 10:00 a.m. He sold the same for the
sum of $16,536.01 to Jeremy Hindes, 110 Greebwood Drive, New Cumberland, PA 17070 on behalf o~,
James Halkias, 1330 Quail Hollow Road, Harrisburg, PA 17112, being the buyer in this execution, pai to
the Sheriff the sum of $ 1654.00
06/26/2012 Sheriffs Terms were not conformed to and Balance Due not received by Close of Business day from gird
party bidders, Jeremy Hindes and James Halkias, the property will be re-sold on June 27, 2012 at 10: 0
a.m. in the Cumberland County Sheriffs Office. I,
06/27!2012 As directed by Karl M. Ledebohm, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/27/2012 ~,
06/27/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice
been given according to law, he exposed the within described premises at public venue or outcry at th
Cumberland County Courthouse, Carlisle, PA on June 27, 2012 at 10:00 a.m. He sold the same forth
sum of $1.00 to Attorney Thomas Flower, on behalf of the Bank of Members First Federal Credit Unio i,
being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $1,494.65 SO ANSWERS,
July 05, 2012 RON R ANDERSON, SHERIFF
~~ ~~% ,~~r C~
r_ f tf .~ 7~/ ,j~
SCHEDULE OF DISTRIBUTION
Date Filed: 6/27/12
Writ No. 201 1-8347 Civil Term
Members 1'` Federal Credit Union
-vs-
Jared 1V1. Bahr
Stacey L. Schaffner, a/k/a Stacey Schaffner
192 Faith Circle
Carlisle, PA 17013
Sale Date: June 6, 2012
Buyer: Members ls` Federal (~'redit Union
Bid Price: $ 16,536.01
Real Debt: ~ 16,536.01
Interest: 475.69
Attorney Writ Costs: 187.4
Total Due: 'b 17,199.14
DISTRIBUTION:
Receipts:
Cash on Account (01/26/2012)
Cash on Account (06/06/2012)
$ 1,500.00
1,654.00
Total Receipts: $
3,154.00
Disbursements:
Sheriffs Costs
Legal Search
North Middleton Twp
Refund to Attorney Karl Ledebohm
Total Disbursements:
Balance for distribution:
So Answers. ~ ~~~'•
Onny R. AnderSOn
Sheriff
$ 1,194.65
300.00
159.35
1,500.00
($3,154.00)
00.00
~ s
h~~rl M. I,edeb~~hm_ t~syuirc
I'.~ } Rux 17>
Nr~~~ Cumberland, Pn 17070-U 17
71 ?)`)38-69?~)
V11:ML3ERS 1 ~ ~ 1~ 1:1)IRA1.
C1ZI~ I)["f lJ~llO~
PL.~~,Iti~l~ll~l~
IN ~hII}~ COURT OI~ COMMUIti I'1 L.~S
C1~M13F;RI,ANI) COUN"I~Y.
PL:NNSYf.V,~MAA
JARED M. BAIfR
"fACE~:1'~ L. SCHAhFNEK
~Uka STAC'1_Y SC1{AI~FNI~,R
NO.: I l-R~47 Civil "l~crm
CIVIL. AC°CION -LAW
MUR'LGAGL FORI~.CL(~SI;KI
AFF'IUAVI'I' PURSUANT TO R~~LE 3129.1
Members I" Federal Credit Union, plaintiff. in the above action. sets li~rth as of~
the date the praecipe I~~r the writ of execution was tiled the Iollowing information
concerning the real prope-1y Located in North Middleton Township, Cumberland County.
Pcnnsvlvania, known and numbeb~ed as 19? Faith Circle, Carlisle. PA 1701;x.
1. ~I~aillc' and address of owner(s) or reputed owner(s):
Jared M. Bahr
1 ~)'_' f=aith Circle
C'at-lisle. Pit 1701
Stacey 1.. Schaffner a'kia Staccv Schaffner
19? Faith Circle
Carlisle_ PA 1701
?. ~an1C and address ofdefrndant(s) in the judgment:
Jared M. Bahr
19'? faith Circle
Carlisle. P:~ 1701
Stacey L. Schaffner a/k/a ;Macey Schaffner
~)? l~~aith Circle
Carlisle. 1'A 1701 i
~. Narne and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Members 1" Federal Credit Union
.Attn.: Dan Summers
X000 Louise Drive
Mechanicsburg, P,~1 17U5~
Target National Bank
3701 Wayzata Blvd.
Mailstop 3C-G
Minneapolis, MN 54416
Am_y F. Doyle, F,syuire
Mann Bracken LL P
<~ttorney for Target National Bank
4660 "hrindle Rd.. Suite 300
C~:ulip Hill. PA I ;'01 1
4. name and address of the last recorded holder of every mortgage o[~ record:
Members 1`` Federal Credit onion
Attn.: Dan Summers
~00U 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
~~~ho 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 Kelations
Cumberland County Courthouse
One Courthouse Square
Carlisle. PA 1701
Occupant
192 faith Circle
Carlisle. N.A 1701
Department of Public Welfare
l~Nl. Casualty Unit
1-atate Recovery Program
N.O. Box 8486
Willow Oak Building
I iarrisburg, PA 1'7105-8486
Inheritance Tax Bureau
Commonwealth of PA
Department of Revenue
Bureau of Individualfaxes
Dept. 280601
I~arrisburg. PA 17128-0601
1 verily that the statements made in this affidavit are true and correct to the best of
my personal knowledge or information and belief. 1 understand that false statements li
herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to ',,
unsworn falsification to authorities. ~!
Date: January 9, 2012 Res,peetfully_submitted.
..
F~,
Karl M. Ledebohm Esc{.
Supreme Court ID #: 5901 ~ I
N.O. Box 173 '~~~
New Cumberland, N,~ 17t)7O-0 17 ~ ~I,
(717)938-6929 I
Attorney for Plaintiff ~I
Karl M. Ledebohm, L=squire
P.O_ Sot 17 3
Ncw Cumberland. PA 1 7070-0 1 73
(7 1 7 19 3 8-69? ~)
YIEMBE;RS 1~' FEDERAL
CREDLI~ UNION
IN ~1'IIE COURT OF COMMUN PLEAS
CUMBERLAND COUN~'Y~
P>~:NNSYLVANIA
PI_A]N"MIFF
~"-
NO.: l 1-8347 Civil "I~erm
J;~KED M. BAHR
Sl ACEY I,. SCHAFFNER :CIVIL ACTION - I:AW
a"ka S7~ACEY SCHAFFNER
I)EFENDAN"TS MOR"hGAGE FOREC'LOSL!RE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
T~~: Jared M. Bahr
192 Faith Circle
Carlisle, PA 17013
Stacey L. Schaffner a/k/a Stacey Schaffner
192 Faith Circle
Carlisle. PA 17013
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, 1 AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT'
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT 7~'O COLLEC"I'
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR'hHA'T
PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR [N
BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT' AN EFFORT TO
FORECLOSE THF, LIEN OF A MORTGAGE ON REAL ESTATE.
Your house (real estate) at 192 Faith Circle, Carlisle, PA 17013, as mur~•
particularly set Iorth anti described on Exhibit "A" attached hereto and made dart
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 ot~
$16,536.01 plus interest ai the legal rate until the date of payment, legal fees. costs
and other costs and charges collectible under the mortgage and foreclosure:. anti sale of ',
the mortgaged property obtained by the above named Plaintiff against you. ~'
NOTICE OF OWNER'S FTIGH"TS
YOU MAY BE ABLE TO PREVF:N'l~ "[HIS S}lERll~'F'S SAI.F?
~I~u Prevent this Sheriff's Sale, you must take immediate action:
1. The Sheriff Sale will be cancelled if you pay to the above named Plaintift~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. l~o
find out how much you must pay, you may call Karl M. I,edebohm, Esquire, at
(717)9;18-6929_
?. You may be able to stop the sale by tiling 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. YoL- 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
attorne~~ .
YOU MAY STILL BE AB1,E TO SAVE YOi IR PROPERTY ANC) ~'OU HAVE
O"CI{ER RIGNCS EVEN IF THE SHERIFF'S SALE; DOES TAKC PLACE.
l . 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 Sheriff at the Ct~~unt~~
Courthouse.
_. You may be able to petition the Court to set aside the sale if the hid price was
grossly inadequate compared to the value of your property.
~. 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 Sl~-eriff at the
Countti Courthouse, which number is listed below.
~. 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.
~. 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.
b. You may be entitled to a share of the money which was paid for yoiu- house.
A schedule of distribution of the money bid for your house will be tiled by the
Sheriff on or before July 6, 2012 or within thirty (30) days after the Sheriff
Sale. ~Chis schedule will state who will be receiving that money.. The. money
~-vill be paid out in accordance with this schedule unless exceptions treasons
~n~hv the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after the schedule of distribution is tiled b_y the Sherifi~.
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 PAPF,R TO YOUR LAWYER A"l~ ONCE.
[F Y"OU DO NO'1, HAVE A LAWYER OK CANNOT AFFORD UNE. GO "1~0
OK TELEPHONE THE OFFICE LISTED BELOW "hO FIND OU"I~ W[IERh:
YO1; CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAK ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
T'he Sheriff s phone number is: (717)240-6390.
,r
~' Karl M. Ledebohm, Esquire
Supreme Court ID #5901 "?
p.0. I3ox 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALI. "hHA"l~ CERTAIN tract or parcel of land and premises situate, lying and heing in the
"township of North Middleton, County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEING Lot No. 38 on the Plan of Kingsbrook, Section "5'', as recorded in the Office of
the Recorder of Deeds for Cumberland County in Plan Book 37, Page 130; containing
60.00 feet along the East along Faith Circle; containing 260.00 feet along the N~~rrh along
Lot No. ~7 on said Plan; containing 60.00 feet along the West along lands now or
i~~rmerly of Hooke. Lebo & Hooke; and containing 260.00 feet along the South along Lot
Flo. ~9 on said Plan: and containing 15,600 square feet. more or less.
SUBJECT TO the building and use restrictions as recorded in the Recorder of~ Deeds
Office in Miscellaneous Book 184, Page 763.
BEING improved with a dwelling known as I92 Faith Circle, Carlisle, PA 1701 ~.
BEWG the same premises which Uavid J. Tatem and Kimberly B. Tatem. husband and
wife, by their deed dated 10/21/06, and recorded in Cumberland County Deed Book 277.
Page ?? ~7, granted and conveyed unto Jared M. Bahr and Stacey L. Schaffner, single
individuals.
1AX PAR(~'I~L # 2y-14-0868-127
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMON W.F,raLTN OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO II-8347 Civil
CIVIL ACTION -LAW
"I'O THE S1[ERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UN10N,
Plaintiff(s)
From JARED M. BAHR, STACEY L. SCHAFFNER A/K/A STACEY SCHAFFNER
(1) ti'ou are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(?) 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 oft"he defendant (s} and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3 j 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: $16,536.01
Interest FROM 12/14/11 AT THE LEGAL RATE
Attv's Comm:
Attv Paid: 5187.44
Plaintiff Paid:
Date: 1/11/2012
L.L.: 5.50
Due Prothy: 52.25
Other Costs:
~a ~«,
David D. Buell, Protho
(Seal)
Deputy
REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: P.O. BOX 173
NEW CUMBERLAND, PA 17070-0173
Attorney for: PLAINTIFF
Te I epho n e: 717-938-6929
Supreme Court ID No. 59012
TRUE COPY FROM RECOR
In Testimony whereof, I here unto set m hand
and the seal of said Court at Carlisle, Pa
This ~ day of _~_, 20
P otho otary
ao~euipaoo~ a~.~~.s3 ~~ea~ 'aa~~gnnaa8 ~ipne~~ ~o~
_...~ .
~. ~
ZZOZ 'SZ ~~~nuer :a~~e~
Wuiaaaq pa~~aodao~ui a~uaaa~.aa s!q~.
~q pug ~,!ann s!q~ u~!M pal! „V„ ~.!q!t~x3 uo paq!a~sap ~Iln~
aaoua `a!s!!a~~ `a!~a!~ q~!~~ Z6Z s~ paaaquanu pug unnou~j
'dd `~~uno' pu~!aaquun0 'd!gsunnol uo~a!pp!W u~~o~
u~,~~~~n~.~°s' ~~a`adoad N~aa a~~ u! ~.saaa~.u! s,~.u~pua}ap
~~~ uodn pa!na! ~~!.~aqS aq~ ZZOZ '9Z ~a~nu~C, u~
CUMBERLAND LAW JOURNAL
Writ No. 2011-8347 Civil Term
Members 1st Federal Credit Union
vs.
Jared M. Bahr, Stacey L. Schaffner
a/k/a Stacy Schaffner
Atty.: Karl M. Ledbohm
ALL THAT CERTAIN tract or par-
cel of land and premises situate, lying
and being in the Township of North
Middleton, County of Cumberland
and Commonwealth of Pennsylva-
nia, more particularly described as
follows:
BEING Lot No. 38 on the Plan of
Kingsbrook, Section "5", as recorded
in the Office of the Recorder of Deeds
for Cumberland County in Plan Book
37. Page 130; containing 60.00 feet
along the East along Faith Circle;
containing 260.00 feet along the
North along Lot No. 37 on said Plan:
containing 60.00 feet along the West
along lands now or formerly of Hooke,
Lebo & Hooke; and containing 260.00
feet along the South along Lot No. 39
on said Plan: and containing 15,600
square feet, more or less.
SUBJECT TO the building and
use restrictions as recorded in the
Recorder of Deeds Office in Miscel-
laneous Book 184, Page 763.
BEING improved with a dwelling
known as 192 Faith Circle, Carlisle,
PA 17013.
BEING the same premises which
David J. Totem and Kimberly B. To-
tem, husband and wife, by their deed
dated 10/21/06, and recorded in
Cumberland County Deed Book 277,
Page 2237, granted and conveyed
unto Jared M. Bahr and Stacey L.
Schaffner, single individuals.
TAX PARCEL 29-1~-0868-127
Exhibit "A"
35
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COiTNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County an
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La'
Journal, a legal periodical published in the Borough of Carlisle in the County and State afores~
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularl
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
1 27, May 4, and May 11, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumber
Law Journal, a legal periodical of general circulation, and that he is not interested in the subj
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.
Lis M rie Coyne, Edit
SWORN TO AND SUBSCRIBED before me this
1 da of Ma 2012 ,-
5' ~~ ~ i
- Notary ~•~., __
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
COMMONWEALTH OF PENNSYLVANIA
COiINTY OF CUMBERLAND
} SS:
I. Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify
the Sheriff s Deed in which Members 1st Federal Credit Union is the grantee the same having been sold
to said grantee on the 6 day of June A.D., 2012, under and by virtue of a writ Execution issued on the 11
day of Ja_ nuary, .A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term,
Number 8347, at the suit of Members 1st Federal Credit Union against Jared M. Bahr and
Schaffner a/k/a Stacey Schaffner is duly recorded as Instrument Number 201224355.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this da ~ of
--------
-, i
'~N~.; ~,
Recorder of~l eeds
Recorder of Imo, curt~rtand Courm, ~, Pa
MI+ Commission E~gDires the First MO of ,Ian, 2!)t 4
~ f'~147
~1-6 N'i tit ot.
l~yq~ ~
`,
KartlN
~~~
B N~
Ny
°f'~ ~brd~r offor
130; ~
t~Nar~ ~ ~.bpttner
~~~ on
mw,~
No~.a~°f~Oke ,
Ply ~,[~ feet
S oU~~~°D~~815,tpp~8aid
restricp~ ~ ,the ~
~8e 77 ~aaeo~r °f
184,
a
BAG ~ Ca~_.` ~ Gaya as
J.~~~~
~ wde, (~}• ~ d
~~~ '~.
TAX P u°~ua-s. ~ 'L.
ambit `A'~CF1.29']4•pg6g~~27
~:
The Patriot-News Co.
2020 Technalogy Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
~e ~latriot News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin;} ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot Nc:ws Co., a corporation organized and existing under the laws pf the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, ih the
Township of Hampden, County of Cumberland, State oi` Pennsylvania, owner and publisher of The Patriot-News and fihe Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and Mate
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 nth, 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 se~jerally 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:
04/27/12
05/04/12
'01~'
~ - ~~ z, ~ - ,, 05/11/12
,r
....... ..r ~_.....
Sworn to an~.sta scribed b for 1T1e this 2Z~ay of May, 2012 A.D.
~~c~ ~ ~.
Notary Public
COMMpNWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L. Owens, Notary Public
Lower Paxton 7wp., Dauphin County
My Commission Expires Nov. 26, 2015
MEMBER, PfNNSYLVANI' q q$SpciA7I0N OF NOTARIES