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HomeMy WebLinkAbout11-8629IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 NO.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL #01-22-0535-042 Plaintiff, Defendant. TO: DEFENDANT(S) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM SIVICE HF OR A DEFAULT JUDGMENT MAY BE TEED A INST YOU. AFT'ORN5V FZ51Z" IsLATNTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 2145 Walnut Street Camp Hill, PA 17011 AND THE DEFENDANT(S): 2179 Yale Avenue Camp 11 ATTO LAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS p Hill, PA 17011 JEATTY e n Cam R PLAINTIFF ? C1j -? fTi d i (? c` (t1 NO.: $?as C(vt TYPE OF PLEADING: CIVIL ACTION - WRIT OF SCIRE FACIAS FILED ON BEHALF OF: Camp Hill Borough, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 JAMES, SMITH, DIETTERICK & CONNELLY, LLP au}$a?60t-A CL a? e V-V l4 as IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 ; Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. Writ of Scire Facias in the amount of $4,859.21 By: Scott A. Dietterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the By: -_n?? -"? Scowk Nktterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 WRIT OF SURE FACIAS TO: PHILLIP J. HELMS WHEREAS, Camp Hill Borough, on October 19, 2011, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 11-7970 MLD, for the sum of $4,859.21, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Camp Hill Borough, said Claim filed against property owned by you in Camp Hill Borough, located at 2179 Yale Avenue, Camp Hill, PA 17011, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as Instrument Number 200741824, Tax Parcel #01-22- 0535-042, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof. >EAL) y 4j'. z F a 0-1 at ?, oo So-4 7?w2 T SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE Jody S Smith Lt CF THE PROTHDNO TAR` Chief Deputy 1411 DEC 22 PM 2; 29 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNSYLVANIA Camp Hill Borough Case Number vs. Philip J. Helms 2011-8629 SHERIFF'S RETURN OF SERVICE 12/16/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on December 16, 2011 at 1415 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Philip J. Helms. After several attempts the Complaint and Notice has expired. SHERIFF COST: $88.00 SO ANSWERS, December 16, 2011 ROM R ANDERSON, SHERIFF sun+y .i :" r s "t fra;. CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011, Plaintiff V. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042, Defendant 000 NkI, 2t IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT NO. 2011-8629 CIVIL TERM IN RE: MOTION FOR SPECIAL SERVICE RT ORDEROFCOU AND NOW, this day of February, 2012, upon consideration of Plaintiff's Motion for Special Service, it is ordered and directed that service of the Writ of Scire Facias in this case upon the Defendant, Phillip J. Helms, may be made (1) by First Class and Certified Mail, return receipt requested, no signature required at the last known address, 2179 Yale Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid Chestnut Street address, with service to be deemed complete upon mailing. BY TH Thoma . Placey, C.P.J. Distribution: V Scott A. Dietterick, Esq. t. l -..4 James Smith Diettrick & Connelly Mau MM -? , P.O. Box 650 v? to Hershey, PA 17033 --? ma, (-e d 21'7// j, "> Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Plaintiff, Defendant. CIVIL DIVISION No.: 11-7970 MLD No.: 11-8629 CIVIL C5 PRAECIPE TO REISSUE WRIT OF SCIRE FACIAS o x ? rntv d? TO THE PROTHONOTARY: c? s Please mark the Writ of Scire Facias filed at the above-captioned =:Z= term and number reissued. JAT BY PA I.D. # 55650 Kimberly A. Bonner, Esquire PA I.D #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 NELLY LLP 4??) alter A. w-I spd at (I 1r 1688`] J 20- a-7 I( U b )2-e-i ss[A ed WRIT OF SCIRE FACIAS TO: PHILLIP J. HELMS WHEREAS, Camp Hill Borough, on October 19, 2011, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 11-7970 MLD, for the sum of $4,859.21, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Camp Hill Borough, said Claim filed against property owned by you in Camp Hill Borough, located at 2179 Yale Avenue, Camp Hill, PA 17011, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as Instrument Number 200741824, Tax Parcel #01-22- 0535-042, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof. (SEAT.) Nt6THFONOT4Y qrd a! VI, k a .q ?t,bo Sai Pie R Z).OD ZXA& 6. TRUE COPY FROM RECORD In Tes*nony whwed, 1 two unto sit my hand MW u0 "d of aid CMA at CMMds' Pa. TNs ?LS.a.sr f ?P 2 L eop W;w -be L? ;3K,a c.= - M O z c _. t SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy t _ Richard W Stewart Solicitor c.c Camp Hill Borough vs. Philip J. Helms SHERIFF'S RETURN OF SERVICE PM 3: 4 1 Ct,1MBERL, ?iiD CGuh' )" FEN1114SYt,VAMA Case Number 2011-8629 02/22/2012 01:11 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2012 at 1311 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Philip J. Helms, pursuant to order of court by posting the premises located at 2179 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy according to law. SHERIFF COST: $55.00 February 23, 2012 TIM LA K, DEPUTY SO ANSWERS, RON ~ R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 NO.: 11-7970 MLD Plaintiff, vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL #01-22-0535-042 Defendant. TO: DEFENDANT(S) YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED WRIT WITHIN TWENTY (20) DAYS FROM S1 VICE H OF OR A DEFAULT JUDGMENT MAY BE NTERtED A INST YOU. NO.: ' ? ?(-Daq TYPE OF PLEADING: CIVIL ACTION - WRIT OF SCIRE FACIAS FILED ON BEHALF OF: Camp Hill Borough, Plaintiff' COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 2145 Walnut Street Camp Hill, PA 17011 JAMES, SMITH, DIETTERICK & CONNELLY, LLP AND THE DEFENDANT(S): 2179 Yale Avenue Camp H' 11 ATTO LAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 2179 Ya e n Camp Hill, PA 17011 ATT NEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD Defendant. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. PRAECIPE TO ISSUE WRIT OF SCIRE FACIAS TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the above-captioned Matter. By Scott'A. Dietterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF J ?? ?? CNLC (??"` CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. TO: PROTHONOTARY SIR/MADAM: Please issue a Writ of Scire Facias in the s yrr o? up may ? ao 5? .??? due s Ov Z) LL t C(). By: A`-4, Scott?A. Diktterick, Esquire Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 TRUE COPY FROM RECORD a?ndT u?arosdhand Tftrl--10:?)7m ? ?=iz t??;- ;i: ?a? a,.,?rt 4 .?i?a?.<a-t,e? Yn??;??T' eN os: ,_,...,...,,.., b 1ab........swr #(%J, sXNmQA WRIT OF SCIRE FACIAS TO: PHILLIP J. HELMS WHEREAS, Camp Hill Borough, on October 19, 2011, filed its claim in our Court of Common Pleas of Cumberland County at Municipal Claim No. 11-7970 MLD, for the sum of $4,859.21, plus additional attorneys fees and costs incurred thereafter, for sewer rents due the said Camp Hill Borough, said Claim filed against property owned by you in Camp Hill Borough, located at 2179 Yale Avenue, Camp Hill, PA 17011, as more particularly described in said Claim, and said property being further described in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, as Instrument Number 200741824, Tax Parcel #01-22- 0535-042, owned or reputed to be owned by you; AND WHEREAS, we have been given to understand that said Claim is still due and unpaid, and remains a lien against the said property; NOW, you are hereby notified to file your Affidavit of Defense to said Claim, if defense you have thereto, in the Office of the Prothonotary of our said Court, within twenty (20) days after the service of this Writ upon you. If no Affidavit of Defense is filed within said time, Judgment may be entered against you for the whole Claim, and the property described in the Claim be sold to recover the amount thereof (SEAL) PROTHONOTARY ??,J? ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. NO.: 11-7970 MLD NO.: 11-8629 CIVIL ISSUE NO.: TYPE OF PLEADING: R' aF F71 -? CD C-j AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS PURSUANT TO Pa.R.C.P., 430 SPECIAL ORDER OF COURT CODE: FILED ON BEHALF OF: Camp Hill Borough, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA I.D. # 55650 James, Smith, Dietterick & Connelly LLP P.O. BOX 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD VS. No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS ON DEFENDANT I, Scott A. Dietterick, Esquire, attorney for Plaintiff, Camp Hill Borough, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Writ of Scire Facias on Defendant, Phillip J. Helms, as follows: 1. On or about February 7, 2012, an Order of Court was entered granting Plaintiff's Motion for Service of Writ of Scire Facias Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof. 2. Pursuant to said Order, on or about February 23, 2012, the counsel for Plaintiff served Defendant with a true and correct copy of Plaintiff's Writ of Scire Facias, via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the address of 2179 Yale Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of the Certified Mail receipt and Certificate of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about February 22, 2012, the Sheriff of Cumberland County, posted the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011 with a true and correct copy of Plaintiff's Writ of Scire Facias. A true and correct copy of the Sheriff's Return of Service is marked Exhibit "C", attached hereto and made a part hereof. 4. Pursuant to said Order on or about February 27, 2012, Plaintiff published a Notice of Municipal Action once in The Sentinel for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "D", attached hereto and made a part hereof. 5. Pursuant to said Order on or about March 2, 2012, Plaintiff published a Notice of Municipal Action once in the Cumberland Law Journal for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "E", attached hereto and made a part hereof. Respectfully submitted, JAMES, SMI-ft DIIVTTARICIV & CONNELLY LLP DATED:--') I BY: Scott A. iet rick, Esquire Attorneys for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Sworn to and subscribed before me this a.1 t n day of March, 2012. Notary Public MY COMMISSION EXPIRES: NOTARIAL SEA CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Jun 23, 2012 EXHIBIT "A" CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 170111 Plaintiff V. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042, Defendant lab IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT NO. 2011-8629 CIVIL TERM IN RE: MOTION FOR SPECIAL SERVICE ORDER OF COURT AND NOW, this day of February, 2012, upon consideration of Plaintiff's Motion for Special Service, it is ordered and directed that service of the Writ of Scire Facias in this case upon the Defendant, Phillip J. Helms, may be made (1) by First Class and Certified Mail, return receipt requested, no signature required at the last known address, 2179 Yale Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid Chestnut Street address, with service to be deemed complete upon mailing. Distribution: Scott A. Dietterick, Esq. James Smith Diettrick & Connelly P.O. Box 650 Hershey, PA 17033 Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 BY THE Thoma . Placey, C.P.J. rn - '"" EXHIBIT "B" CERTIFIED T • (Domestic i i sxom us t www b it t our w s For delivery information v '1 ?, p . s e a e f N ?- Postage $ (. f C) ; `? 1 C3 1 (, Certified Fee r =1 /? _/ C J? r C3 E3 Return Reoeipt Fee (Endorsement Required) GA, ? I O O Restricted Delivery Fee (Endorsement Required) ? ° r-1 Total Postage & Fees $ Lo 1 r? J , C3 It , °------ '------- ' -- --------- ----- lM l? 1 i State, lP+4 I -------------------------------- _ ' t i PS Form 3800, August 2006 ons See Reverse for Instruct -MW UNITED STATES POSMSERYICE• Certificate Of Mailing ?S®for mailing. JAMES, SMITH, DIETTERICK & CONNELLY LLP ATTN: CHRIS SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 To: t( d II PS Form 3817, April 2007 PSN 7530-02-000-9065 'mil j f ' P.k-*\- CICtLA- To pay tee, affix stamps or meter postsoa here. ti Ef' EXHIBIT "C" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff v?``?tit nt+unr f,r?r? Jody S Smith Chief Deputy j Richard W Stewart Solicitor 'r`'f-` OF 6 s?("atFF Camp Hill Borough vs. Philip J. Helms Case Number 2011-8629 SHERIFF'S RETURN OF SERVICE 02/22/2012 01:11 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2012 at 1311 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Philip J. Helms, pursuant to order of court by posting the premises located at 2179 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy according to law. SHERIFF COST: $55.00 February 23, 2012 TIM L K, DEPUTY SO ANSWERS, RONKY R ANDERSON, SHERIFF ;c: Ccu.; vSu!.tc Sne94, Teleos.:it Ins. EXHIBIT "D" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 27, 2012 COPY OF NOTICE OF PUBLICATION IN THE COURT OF COI MON PLEAS OFCUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACVI®N - LAW NO,:2011,8629 CML TERM ;he/she is not NOTICE'OfUt! IPAL ACTION - ter of the a went, and that . CAMP HILL BOROUGH, Plaintiff, s ig statement as vs: )f publication PHILLIP J. HELMS, Defendant. TOi Phillip J. Helms PRESENTLY OR FORMERLY of 2179 Yale Avenue, Camp Hill, PA 17011. A lawsuit has been filed againstoyou at ssessmentcharges for the property ' a because you have failed to make.payment of the definx*nt:sewer PA 17011, to.Plaintiff. Thdiawsuit is filed In, r the Cumberland Count yCourt of Common Camp H91 e A Y 1 , venu , e a 2179 Pleas, at the above term and number: ; A copy of the W dt of Scire Facias filed inthe lawsuit will be sent toyou upon request to the Attorney for the Plaintiff, Scott PA 17038. Phone (717) 533-3260. Hershey 650 , , A. Dletterick; Esquire, P.O. Box IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE YOUR DEFENSE:S'OR OBJECTIONS IN WRITING SE MAY PROCEED WITHOUT WITH AND A JJUDGM NT MAY BE ENTEREDT IF are me this YOU FAIL TO DO SO, THE CA AGAINST YOU WITHL7UT FURTMER'NQTICEFQR RIEF REQUESTED BY THE PLAINTIFF: YOU MAY LOSE IMPORTANT TO YOU . MONEY OP PROPERTY OR OTHER BIGHTS AFFORD ONE, GO TO THlSNQTIE TO YbUR,LAWYER AT-ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT YOU SHOULD TAKE ONE THE QFFICE:SETFORTH BELOIM O FIND OUT WFIERE YOU CAN GET LEGAL HELP. NOTI E IQDE E &A?WYER REFERRAL RV Cumberland County Bar Association 2 Li MM Avenue Carlisle,; A17013 Public Phone (717)'249-3166 Toll Free (800) 990.9108 My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public C-,RLISLE BOROUGH, CUMBERLAND CNTY Commission Expires Jan 27, 2014 EXHIBIT "E" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz March 2, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r )/' ('ex - Li Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 2 day of March, 2012 Notary / NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28. 2014 CUMBERLAND LAW JOURNAL NOTICE OF MUNICIPAL ACTION In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO.: 2011-8629 CIVIL TERM CAMP HILL BOROUGH, Plaintiff vs. PHILLIP J. HELMS, Defendant TO: Phillip J. Helms PRESENTLY OR FORMERLY of 2179 Yale Avenue, Camp Hill, PA 17011. A lawsuit has been filed against you because you have failed to make payment of the delinquent sewer assessment charges for the property located at 2179 Yale Avenue, Camp Hill, PA 17011, to Plaintiff. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term and number. A copy of the Writ of Scire Facias filed in the lawsuit will be sent to you upon request to the Attorney for the Plaintiff, Scott A. Dietterick, Esquire, P.O. Box 650, Hershey, PA 17033. Phone (717) 533-3280. IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUT YOU AND A JUDG- MENT MAY BE ENTERED AGAINST YOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 Mar. 2 8 r i "TAR" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA J C 0 U }i `t 'A, 1A CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID#01-22-0535-042 Defendant. I Hereby certify that the last known address Defendant(s) is/are: 2179 Ya Av ue A;, Camp , ,w 011 CIVIL DIVISION No.: 11-8629 CIVIL TERM No.: 11-7970 MLD TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Municipal Lien) FILED ON BEHALF OF: Camp Hill Borough, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: /Lz JAMES, SMITH, DIETTERICK & CONNELLY, LLP Pa. I.D. #55650 Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 an4+ zj&.sopci ah? vK/f //9?1 pµ a7 3/??Aa3 I A . 1-. n,, 1 Ill/A:,1 ///Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY SIRJMADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant, Phillip J. Helms, in the amount of $4,859.21, plus interest, penalties, and Quarterly bills after the 1" Quarter 2012, and additional attorneys' fees and costs reasonable and actually incurred. JAMES, SMITH, ff TT ICK & CONNELLY, L / A By: / _ Scott A. Diett rick, E Attorney for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 23781, astvide?ced by the attached copies. Scott A. Sworn to and subscribed before me this 16th day of April, 2012. Czh A J -??b f) I WocK-- Notary Public My Commission Expires: F OTARIAL SEAL TINE L SPURLOCK Notary Public N BORO, DAUPHIN COUNTY My Commssion Expires Jun 23, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 : Defendant. No.: 11-8629 CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: PHILLIP J. HELMS ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on J 171 -Lo/- , 2012. ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $4,859.21 plus interest, penalties, and Quarterly bills after the 1St Quarter 2012, plus additional attorneys' fees and costs reasonable and actually incurred and nM%foreure ale of the P ises. rothonotary ?.,?? ? .. ?? ?: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. IMPORTANT NOTICE TO: Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 DATE OF NOTICE: March 27, 2012 No.: 11-8629 CIVIL YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. AVISO IMPORTANTE CIVIL DIVISION No.: 11-7970 MLD No.: 11-8629 CIVIL A. Phillip J. Helms FECHA DEL AVISO: March 27, 2012 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 JAMES S DATE: March 27, 2012 FIRST CLASS U.S. MAIL, POSTAGE PREPAID & CONNELLY LLP Sc9ftjA. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire PA I.D. #89705 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, Vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. NO.: 11-7970 MLD NO.: 11-8629 CIVIL ISSUE NO.: TYPE OF PLEADING: ?r a J AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS PURSUANT TO Pa.R.C.P., 430 SPECIAL ORDER OF COURT CODE: FILED ON BEHALF OF: Camp Hill Borough, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire PA I.D. # 55650 James, Smith, Dietterick R. Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD No.: 11-8629 CIVIL Defendant. AFFIDAVIT OF SERVICE OF WRIT OF SCIRE FACIAS ON DEFENDANT PURSUANT TO ORDER OF COURT I, Scott A. Dietterick, Esquire, attorney for Plaintiff, Camp Hill Borough, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Writ of Scire Facias on Defendant, Phillip J. Helms, as follows: 1. On or about February 7, 2012, an Order of Court was entered granting Plaintiffs Motion for Service of Writ of Scire Facias Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof. 2. Pursuant to said Order, on or about February 23, 2012, the counsel for Plaintiff served Defendant with a true and correct copy of Plaintiff s Writ of Scire Facias, via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the address of 2179 Yale Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of the Certified Mail receipt and Certificate of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about February 22, 2012, the Sheriff of Cumberland County, posted the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011 with a true and correct copy of Plaintiffs Writ of Scire Facias. A true and correct copy of the Sheriff s Return of Service is marked Exhibit "C", attached hereto and made a part hereof. 4. Pursuant to said Order on or about February 27, 2012, Plaintiff published a Notice of Municipal Action once in The Sentinel for Cumberland County, Pennsylvania.. A true and correct copy of the Proof of Publication is marked Exhibit "D", attached hereto and made a part hereof. 5. Pursuant to said Order on or about March 2, 2012, Plaintiff published a Notice of Municipal Action once in the Cumberland Law Journal for Cumberland County, Pennsylvania. A true and correct copy of the Proof of Publication is marked Exhibit "E", attached hereto and made a part hereof. DATED:--' Sworn to and subscribed before me this 4-)' i1 day of March, 2012. Respectfully submitted, JAMES, SMTIf, D & CONNELLY LLP BY: ? Scott A. iet rick, Esquire Attomeys for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Notary Public MY COMMISSION EXPIRES: NOTARIAL SEAL CHRISTINE L SPURLOCK Notary Public HUMMELSTOWN BORO, DAUPHIN COUNTY My Commission Expires Jun 23, 2012 EXHIBIT "A" CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011, Plaintiff V. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042, Defendant vF 40 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT NO. 2011-8629 CIVIL TERM IN RE: MOTION FOR SPECIAL SERVICE --7 ORDER OF COURT AND NOW, this ? ? day of February, 2012, upon consideration of Plaintiff's Motion for Special Service, it is ordered and directed that service of the Writ of Scire Facias in this case upon the Defendant, Phillip J. Helms, may be made (1) by First Class and Certifed Mail, return receipt requested, no signature required at the last known address, 2179 Yale Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid Chestnut Street address, with service to be deemed complete upon mailing. Distribution: Scott A. Dietterick, Esq. James Smith Diettrick & Connelly P.O. Box 650 Hershey, PA 17033 Phillip I Helms 2179 Yale Avenue Camp Hill, PA 17011 BY THE MI IRTI 4.A Placey, C.P.J. EXHIBIT "B" Postal • Cti Ln rum' Postage $ Certified Fee 0 Retum Receipt Fee < 17-1 (Endorsement Required) ED Restricted Delivery Fee (Endorsement Required) r-R Total Postage & Fees lark r'?. ? r 0 J -- ------- - ----- j 17 --1 e`? ` S ---------------------------- Q f ggqf ":y4 r - --- - r? Q1T B ° ` ?k --------_u-C f t State. 'IP+? '1rIz? UNITEDSTATET PO?? SV?E• To pav tee, all, stamps or Certificate Of Maifin meter ostatie here ' 'for mailing L JAMES, SMITH, DIETTERICK & CCNNELLY LLP ATTN: CHRIS SPURLOCK .,? w~ a P.O. BOX 650 ?Qj2; HERSHEY. PA 17033P? To ?.--> L1 l ( P--I la, PS Form 3817. April 2007 PSN 7530-02-000-9065 ? I- JL A- I EXHIBIT "C" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ; l`?ttitt ai ?trti.trr/,T? Jody S Smith Chief Deputy 1 Richard W Stewart Solicitor Camp Hill Borough I Case Number vs. 2011-8629 Philip J. Helms SHERIFF'S RETURN OF SERVICE 0212212012 01:11 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2012 at 1311 hours, he served a true copy of the within Writ of Scire Facias, upon the within named defendant, to wit: Philip J. Helms, pursuant to order of court by posting the premises located at 2179 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 with a true and correct copy according to law. SHERIFF COST: $55.00 February 23j, 20112 TIM LA K, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF EXHIBIT "D" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox Sales Director, of The Sentinel, of the Countv and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 131h, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): February 27, 2012 COPY OF NOTICE OF PUBLICATION IN THE COURT OF COMMON PLEAS F CLIMB LAW ERLAND CO I ACT CIVIL NTY, PENNSYLVANIA N0.:2011-8629.CIVILTERM :he,/ she is not NOTICE OF MUNICIPAL ACTION ter of the ment, and that CAMP HILL BOROUGH, Plaintiff, i(Tstatement as vs. ,)f publication PHIL'LIP J. HELMS, Defendant. TO: Phillip J. Helms PRESENTLY OR FORMERLY of 2179 Yale Avenue, Camp Hill, PA 17011. A lawsuit has been filed against you ssessment charges for the property located at ?VKi because you have failed to make payment of the delinquent sewer a it is filed in the Cumberland County Court of Common l awsu 2179 Yale Avenue, Camp Hill, PA 17011, to Plaintiff. The Pleas, at the above term and number. it of Scire Facias filed in the lawsuit will be sent to you upon request to the Attorney for the Plaintiff, Scott 280 W r . A copy of the Dietterick, Esquire, P.O. Box 650, Hershey, PA 17033. Phone (717) 533-3 A . YOU ISH TO DEFEND, Y MUST ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY IF D FI E YOUR DEFENSES OOR OBJECTIONS N WRITING WITH THE COURT. YOU ARE WARNED THAT IF AND A JUDGMENT MAY BE ENTERED e this this )re N A YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU OUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF: YOU MAY LOSE ' AGAINST YOU WITH MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. OT / ?i I Il?? YOU SHOULD TAKE THIS NOTICE TO TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GO TO OR E E f' , AFFORD ON GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE t jig l/ Cumberland County Bar Association 2 Liberty Avenue Cordele, PA 17013 l'U H lc Phone (717) 249-3166 Toll Free (800) 990-9108 My commission expires: NO A"'dAL SEAL BAN151 ANN HECKDZ090 Notary Public C il_ISLE BOROUGH, CUMBERLAND CNTY C0Tnm1',sion Expires Jan 27, 2014 EXHIBIT "E' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz_ March 2, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement. and that all allegations in the foregoing statements as to time, place and character of publication are true. 1-4 Marie Coyne, 9ditor SWORN TO AND SUBSCRIBED before me this 2 day of March. 2012 Notarv ?- NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY IVi?, Commission Expires Apr 2E. 2014 CUMBERLAND LAW JOURNAL NOTICE OF MUNICIPAL ACTION In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO.: 201 1-8629 CIVIL TERM CAMP HILL BOROUGH, Plaintiff vs. PHILLIP J. HELMS, Defendant SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (717) 249-3166 Toll Free (800) 990-9108 Mar. 2 TO: Phillip J. Helms PRESENTLY OR FORMERLY of 2179 Yale Avenue, Camp Hill, PA 17011. A lawsuit has been filed against you because you have failed to make payment of the delinquent sewer assessment charges for the property located at 2179 Yale Avenue, Camp Hill, PA 17011, to Plaintiff. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term and number. A cor)v of the Writ of Scire N'acias filed in the lawsuit will be sent to you upon request to the Attorney for the Plaintiff, Scott A. Dietterick, Esquire, P.O. Box 650. Hershey, PA 1703". Phone (717) 533-3280. IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUT YOU AND A JUDG- MENT MAY BE ENTERED AGAINST YOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS NC9- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE 8 IN THE COURT OF CC44:)N PIEA,S OF a MBERUM COUNTY, P046nVANIA Camp Hill Borough v Phillip J. Helms (Plaintiff) CIVIL DIVISION (Defendant(s) TO THE PROOiONOTARY OF THE SAID COURT: File No. 11-7970 MLD / 11-8629 Civil Term : Amount Due $ 4,859.21 • Interest from to $ date of sa e : Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR E)a=ON Issue writ of execution in the above matter to the Sheriff of Cumberlandc-) County, for debt, interest and costs upon the following described property of of -- rl-a defendant(s) See Exhibit "A" attached. v>r°' ? r PRAECIPE FOR ATTACHMENT EXBCLMON :7 Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) real estate of the defendant(s) described in the attached exhh ,it DATE: April 16, 2012 5 s ?D it A, aq 00" 19•vo (. 1 5? a 1 S6 4 a. s Signature: Print Name: Address: James Smith Dietterick & Connelly LLP P O Box 650, Hershey PA 17033 Attorney for: Telephone: Plaintiff (717) 533-3280 o2S Supreme Court ID No.: 55650 Ula° ? . SbLL 01 7 '3 V, LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22°d Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wife, by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" J FF y ?1 pp I a ? t i0 p1 IN THE COURT OF COMMON PLEAS OF L,'v t I r ?`4? -F P'11 CUMBERLAND COUNTY, PENNSYLVANIA,, ,fE;'fi E? L,° ,yD C0U?,ITy 2145 WALNUT STREET CAMP HILL, PA 17011 : Plaintiff, No.: 11-7970 MLD VS. No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. CAMP HILL BOROUGH CIVIL D vJm vAU)A AFFIDAVIT PURSUANT TO RULE 3129.1 Camp Hill Borough, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011: 1. Name and Address of Owner(s) or Reputed Owner(s): PHILLIP J. HELMS 2. 3 4 2179 Yale Avenue Camp Hill, PA 17011 Name and Address of Defendant(s) in the Judgment: PHILLIP J. HELMS 2179 Yale Avenue Camp Hill, PA 17011 Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: CAMP HILL BOROUGH 2145 Walnut Street Camp Hill, PA 17011 Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK N.A. 3476 Stateview Boulevard Fort Mills, SC 29715 5. 6 7 Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM Cumberland County Courthouse BUREAU One Courthouse Square Carlisle, PA 17013 Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: DEPARTMENT OF REVENUE COMMONWEALTH OF PA UNKNOWN SPOUSE OF PHILLIP J. HELMS PA Inheritance Tax Division Department 280601 Harrisburg, PA 17128-0601 Department of Welfare P.O. Box 2675 Harrisburg, PA 171.05 2179 Yale Avenue Camp Hill, PA 17011 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 DOMESTIC Cumberland County Courthouse RELATIONS OFFICE One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. JAMI & CO DATED: April 16, 2012 BY: Scott A. Driett6rick, Es Pa. I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEA$r.gF c? 17 P,s 1: tt 'i 11 3t JS CUMBERLAND COUNTY, PENNSYLVANIA JM53FERL? ND r0UNT`s' CAMP HILL BOROUGH CFNgq§I%"* 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. No.: 11-8629 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8629 Civil Term No. 11-7970 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Phillip J. Helms A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PR OPF.R TY _ It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff s Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAME" & COIN DATED: April 16, 2012 BY: Scott A Pa. I.D. Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 VIA ORDER OF COURT LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22"a Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wife, by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-8629 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAMP HILL BOROUGH, Plaintiff (s) From PHILIP J. HELMS (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: $4,859.21 L.L.: $.50 Interest Atty's Comm: % Due Prothy: $2.25 Atty Paid: $2SO. 95 Other Costs: Plaintiff Paid: Date: APRIL 17, 2012 ]) ? l ? VL a uA David D. Bu 11, Prothonota (Seal) L_ ?/j/1c T Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: JAMES SMITH DIETTERICK & CONNELLY LLP P. O. BOX 650 HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 55650 C) IN THE COURT OF COMMON PLEAS OF r ! . CUMBERLAND COUNTY PENNSYLVANIA , CAMP HILL BOROUGH, CIVIL DIVISION Plaintiff, NO.: 11-8629 CIVIL = Cn -" c? c? bra vs. ISSUE NO.: PHILLIP J. HELMS, TYPE OF PLEADING: Defendant. Pa.R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: Camp Hill Borough, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD No.: 11-8629 CIVIL Defendant. Pa.R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Scott A. Dietterick, Esquire, attorney for Camp Hill Borough, Plaintiff, being duly sworn according to law depose and make the following Affidavit regarding service of Plai Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties Interest as follows: 1. Defendant, Phillip J. Helms, is the record owner of the real property. 2. Pursuant to Order of Court dated February 7, 2012, on or about August 3, 2012, Defendant, Phillip J. Helms, was served with Plaintiffs Notice of Sheriffs Sale of Real Pursuant to Pa.R.C.P. 3129, by first class mail, at the address of the mortgaged premises, being 2179 Yale Avenue, Camp Hill, Pennsylvania 17011. A true and correct copy of said Order, Notice and Certificate of Mailing are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about August 3, 2012, Plaintiff's counsel served all other parties in with Plaintiff's Notice of Sheriff s Sale according to Plaintiff's Affidavit Pursuant to Rule 3129. 1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that Defendant/Owner and all Other Parties Interest were served with Plaintiffs Notice of Sheriff s Sale of Real Property in accordance Pa. R.C.P. 3129.2. JAMES, SMITL K & CONNELLY Dated: 8-7-2012 BY: Scott,J=tterick, Esquire Pa.6 0 ff P.O. V 6V0 Hershey, PA 17033 (717) 533-3280 Sworn to and subscribed before me this da f August, 2012. o Public MY COMMISSION EXPIRES: COMMONWEALTH 017 PENNSYI VANIA NOTARIAL SEAL DENISE L. FOSTER, NOTARY PUBLIC CITY OF HARRISBURG, DAUPHIN COUNTY ?Y COMMISSION EXPIRES MARCH 05, 2013 EXHIBIT "A" UNfrEDSTATO POSMSERWE• Certificate OfAftiti _?-- - for mails JAMES, SMITH, DIETTERICK & QUA 5 CONNELLY LLP ATTN: CHRISTINE SPURLOCK P.O. BOX 650 c HERSHEY, PA 17033 F To:ti;? L19 ycal-< Av.eM:y?-e- OL' r `, i 4 Y PS Form 3817, April 2007 PSN 7530-02-000-9065 tAc'wV CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011, Plaintiff V. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042, Defendant pvw- jW 5-ww? IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT NO. 2011-8629 CIVIL TERM IN RE: MOTION FOR SPECIAL SERVICE ORDER OF COU -19- AND NOW, this -7 day of February, 2012, upon consideration of Plai Motion for Special Service, it is ordered and directed that service of the Writ of Scire Facias in this case upon the Defendant, Phillip J. Helms, may be made (1) by First Class and Certified Mail, return receipt requested, no signature required at the last known address, 2179 Yale Avenue, Camp Hill, Pennsylvania 17011, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 2179 Yale Avenue, Camp Hill, Pennsylvania 17011; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendant at the aforesaid Chestnut Street address, with service to be deemed complete upon mailing. Distribution: Scott A. Dietterick, Esq. James Smith Diettrick & Connelly P.O. Box 650 Hershey, PA 17033 Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 BY THE ,- Thoma . Placey, C.P.J. =Y -7 r n, 771 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. No.: 11-8629 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Phillip J. Helms 2179 Yale Avenue Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on Wednesday, September 5, 2012, at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County The JUDGMENT under or pursuant to which your property is being sold is docketed to; No. 11-8629 Civil Term No. 11-7970 MLD THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Phillip J. Helms A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental o corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalitie that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas C Cumberland County, South Hanover Street, Carlisle, Pennsylvania 17013. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR HONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GF FREE LEGAL ADVICE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 (800) 990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the persc or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Comm Pleas of Cumberland County to set aside the sale for a grossly inadequate price for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the credit or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. JAMES, SMITH, DIETTERICK & CONNELLY, LLP DATED: April 16, 2012 BY: Scott A. Dietterick, Esquire Pa. I.D. #55650 Attorneys for Plaintiff P.O. BOX 650 Hershey, PA 17033 (717) 533-3280 VIA ORDER OF COURT LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point beir 163.54 feet measured along the South side of Yale Avenue from the East side of South 22» a Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minute West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern lin of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wi by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" EXHIBIT "B" UNrrEDSTATES ?POSTTALSERME• CertificateOf'Mailifi P?for mail ?0 JAMES, SMITH, DIETTERICK & a' CONNELLY LLP- rk r '_`' z ATTN: CHRISTINE SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 A ? TO: ?.?. Ao.MA a wyt,_ Coe y { ttic e - PS Form 3817, April 2007 PSN 7530-02-000-9065 E (c-? w"s UNl7EDSUM P VALSERME• Certificate Of Metiir" ;" .a?vor maai f JAMES, SMITH, DIETTERICK CONNELLY LLP cc ATTN: CHRISTINE SPURLOCK. P.O. BOX 650 - HERSHEY, PA 17033 '/ C. oU Sc_ w t Yv???l_L? ?{ ?VIA J Z1jyalee,Iny?? c = c' 1Aa PS Forth 3817, April 2007 PSN 7530-02-000-9065 K'-1 wvs UNiTEDSTATES POlSTALSERWE° Certificate OfJ01illi? TI (L `r mail TI F, JAMES, SMITH, DIETTERICK CONNELLY LLP w P . us ATTN: CHRISTINE SPURLOCK '' P.O. BOX 650 HERSHEY, PA 17033 ?S -- PS Form 3817, April 2007 PSN 7530-02-000-9065 Hr1wL; c= 510 U, w Pt? UNnwSTAM ?/P?7ntSaRV1CE"_ Certificate JAMES, SMITH, DIETTERIC CONNELLY LLP LU ATTN: CHRISTINE SPURLOCK "- P.O. BOX 650 /} 1 HERSHEY, PA 17033 ,x` 70: ! 1A?Jp['./f La. \ ?.. M 1lA ni ! 1I A L,4r?lslfl-? ?? 1 I Cj? PS Form 3$17, April 2007 PSN 7530-02-000-9065 11 ? V?1 5 a uNnwSTATES PMALSOM' Certificate of Mai iS® for m JAMES, SMITH, DIETTERICK CONNELLY LLP W ATTN: CHRISTINE SPUR-LOCK X P.O. BOX 650 ?` HERSHEY, PA 17033 t?I'? ?vtlu v i? tic---Tc?'X b J c? r PS Form 3817, April 2007 PSN 7530-02-000-9065 PC57U ' Certificate Of iii i for JAMES, SMITH, DIETTERICK CONNELLY LLP z ATTN: CHRISTINE SPURLOCK P.O. BOX 650 HERSHEY, PA 17033 r-A VYt, t ( s . `3C. 2 `i -7 1 `o Fr"eu. 01 Cx? (? r F 0 r; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. ANT TO: WELLS FARGO BANK N.A. 3476 STATEVIEW BOULEVARD FORT MILLS, SC 29715 No.: 11-8629 CIVIL 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, vs. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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 Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMIT I?j(TTERICK & CONNELLY L ?1 Dated: 8-3-2012 By: Scott A. Die to k PA ID #5565, Attorney for Print P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22'd Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wife by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, vs. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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 Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SM IETTERICK & CONNELL L ?a,, Dated: 8-3-2012 By: Scott A. Di teri , I PA ID #55650 a Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22nd Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wife by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD vs. No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 : Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: DEPARTMENT OF REVENUE PA INHERITANCE TAX DIVISION DEPARTMENT 280601 HARRISBURG, PA 17128-0601 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, VS. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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. JAMES, SMIT , E TERICK & CONNELLY Dated: 8-3-2012 By. Sc tt . ie , PAID # 5 5 Attorney or lai till P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22nd Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wife by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD VS. : No.: 11-8629 CIVIL PHILLIP J. HELMS 2179 YALE AVENUE, CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 : Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: COMMONWEALTH OF PA DEPARTMENT OF WELFARE, P.O. BOX 2675 HARRISBURG, PA 17105 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, vs. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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 continents with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, D ERI K & CONNELLY LLJ Dated: 8-3-2012 Sc A. D' PA ID #550 Attorney for Plaintil P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22nd Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and W by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH CIVIL DIVISION 2145 WALNUT STREET CAMP HILL, PA 17011 Plaintiff, No.: 11-7970 MLD VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. No.: 11-8629 CIVIL NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: UNKNOWN SPOUSE OF PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, VS. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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 Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SMITH, TTERICK & CONNELLY LL . Dated: 8-3-2012 By: Scott A. Die c PA ID #556 Attorney for in if P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22°a Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and Wi by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAMP HILL BOROUGH 2145 WALNUT STREET CAMP HILL, PA 17011 CIVIL DIVISION Plaintiff, No.: 11-7970 MLD VS. PHILLIP J. HELMS 2179 YALE AVENUE CAMP HILL, PA 17011 PARCEL ID #01-22-0535-042 Defendant. No.: 11-8629 CIVIL NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 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, Pennsylvania 17013 on September 5, 2012 at 10:00 a.m., the following described real estate which Phillip J. Helms is the owner or reputed owner and on which you may hold a lien or have an interest which could be affected by the sale of: 2179 Yale Avenue Camp Hill, Pennsylvania 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The said Writ of Execution has been issued on a judgment in the action of CAMP HILL BOROUGH, Plaintiff, VS. PHILLIP J. HELMS, Defendant. at EX. NO. 11-8629 in the amount of $4,859.21, plus interest 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 with 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 Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. JAMES, SM T DIETTERICK & CONNELLVI Dated: 8-3-2012 By, PA IDA556 Attorney fo 1 ntii P.O. Box 6 0 Hershey, PA 17033 (717) 533-3280 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Camp Hill Borough, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Yale Avenue (50 feet wide) said point being 163.54 feet measured along the South side of Yale Avenue from the East side of South 22nd Street; thence South 03 degrees 51 minutes East, a distance of 135 feet to a point; thence North 86 degrees 09 minutes East, a distance of 78 feet to a point; thence North 03 degrees 51 minutes West, a distance of 135 feet to the Southern line of Yale Avenue; thence along the Southern line of Yale Avenue South 86 degrees 09 minutes West, a distance of 78 feet to a point, the place of BEGINNING. HAVING thereon erected a one story brick and frame dwelling house known and numbered as 2179 Yale Avenue, Camp Hill, Pennsylvania. BEING the same premises which Phillip J. Helms and Lori A. Helms, Husband and W by their Deed dated October 26, 2007, and recorded on November 5, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, as Instrument Number 200741824, granted and conveyed unto Phillip J. Helms. Parcel No.: 01-22-0535-042 Exhibit "A"