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HomeMy WebLinkAbout11-9240SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F171 ED-OFFICE Sheriff anti"t? a; ?uutbrrf?re ?T THE PRO- THOPIOTARl Y Jody S Smith Chief Deputy 2012 JAN 13 PIS 3: 02 Richard W Stewart Solicitor F `E `"4 'Fr CUMSERLANOCOON Y PENNSYLVANIA The Bank of New York Trust Company Case Number vs. 2011-9240 Mary Jane Guise SHERIFF'S RETURN OF SERVICE 12/15/2011 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Mary Jane Guise, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/16/2011 02:22 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 16, 2011 at 1422 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mary Jane Guise, by making known unto Earl Guise, Son of Defendant at 800 Pamelas Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY 12/21/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Mary Jane Guise, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Mary Jane Guise. Request for service at 301 Acron Circle, Lebanon, Pennsylvania 17042 the Defendant was not found. Deputies were advised, Mary Jane Guise currently resides at 800 Pamelas Lane E, Mechanicsburg, Pennsylvania 17055. SHERIFF COST: $63.00 SO ANSWERS, January 05, 2012 RON R ANDERSON, SHERIFF C GounfySU10 SherK, Tkec.<,oft. Inc. COMPLAINT IN MORTGAGE FORECLOSURE No. 11-9240 Return to (Cumberland County) The Bank of New York Mellon Trust Company, National Association F/K/A The Bank of New York Trust Company, N.A. As Successor To JPMorgan Chase Bank N.A. As Trustee For Ramp 2005RS6 VS. Mary Jane Guise STATE OF PENNSYLVANIA } COUNTY OF LEBANON } SS: PHELAN HALLINAN & SCHMIEG, LLP Sheetal R. Shah-Jani, Esquire One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Docket Page 35481 Basil Achey, Deputy Sheriff, being duly sworn according to law, deposes and says that after due and diligent search by him having been made in his bailiwick, and after having exhausted all known facets to locate DEFENDANT, as stipulated under Rule of Civil Procedure, Rule 430, "good faith effort," he was unable to find MARY JANE GUISE, the within named DEFENDANT, and he therefore returns "NOT FOUND," as to the said MARY JANE GUISE. Note: The Defendant address is 800 Pamelas Lane E., Mechanicsburg, PA 17055. Sworn to and subscribed before me This 21" day of December, 2011 SO ANSWERS, Is Public DEPUTY SHERIFF By Authorization Of. Is SHERIFF SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced Costs paid on 12/16/11 Check No. 1136660 Amount $ 100.00 Costs Incurred: Amount $ 73.06 j A?Amount $ 26.94 Amount of Refund: Check No. 3 All Sheriffs Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 NOTARIAL SENL Lynnette Smith, Notary Public Lebanon City, Lebanon Co?mty My Commission Expires April 23, 20 12 1 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST CUMBERLAND COUNTY COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COURT OF COMMON PLEAS COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE CIVIL DIVISION FOR RAMP 2005RS6 VS. MARY JANE GUISE No. 11-9240 CIVILTE XM z:;o cn rte; PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO c-, ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: N N cry S¢ s Fri C:) C) i ---i r Kindly enter judgment in favor of the Plaintiff and against MARY JANE GUISE, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $216,957.59 $216,957.59 I hereby certify that (1) the Defendant's last known address is 800 PAMELAS MECHANICSBURG, PA 17050-2362, and (2) that notice has been giv ccoy ce with Rule Pa.R.C.P 237. 1. Date Allison F1QWt*, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: pt..5o PAAn`/ PHS # 257020 PROTHONOTARY Cif 11(0101W p a'lay3? N ee MW10l 257020 PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 VS. MARY JANE GUISE Attorney for Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 11-9240 CIVILTERM AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant MARY JANE GUISE is over 18 years of age and resides at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362. This statement is made subject to the penalties of 18 Pa. C.S. relating to unsworn falsification to authorities. I Date Attorney for Plaintiff 257020 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff V. MARY JANE GUISE Defendant(s) TO: MARY JANE GUISE 800 PAMELAS LANE MECHANICSB( RG, ' 17050-2.3 i? DATE OF NOTICE: COURT OF COMMON PI-EA.S CIVIL DIVISON NO. 11-9240 CIVILTER.M CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DE'BT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEB'T'EDNESS REFERRED TO HEREIN, AND ANY INFORMATION OB'T'AINED FROM YOU WILL, BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE T14IS 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 'T'HAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO ITE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE C'AR?17013 P249 166 By: _.m .....__ _ illiarn F. Miller, Esquire Attorney for Plaintiff Phelan Hallinan & Schmieg, I.,I.,P 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS 4 257020 (Rule of Civil Procedure No. 236) - Revised THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 11-9240 CIVILTERM VS. MARY JANE GUISE Notice is given that a Judgment in the above captioned matter has been entered against you on J!.5 /o By: 34 If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LIT Allison F. Wells, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-9240 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff (s) From MARY JANE GUISE (I) 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: $216,957.59 L.L.: $.50 Interest from 3/16/2012 to Date of Sale ($35.66 per diem) - $6,204.84 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $202.50 Other Costs: Plaintiff Paid: Date: 5/17/12 (Seal) REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 PHILADELPHIA. PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308877 PRAECIPE FOR WRIT OF EXECUTION-(MORT( P.R.C.P. 3180-3183 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff v MARY JANE GUISE Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: -AGE FORECLOSURE) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9240 CIVILTERM CUMBERLAND COUNTY u Amount Due $216,957.59 n Interest from 03/16/2012 to Date of Sale $6,204.84 ($35.66 per diem) C--, ?? r TOTAL $223162.43 P #06n Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff Note: Please attach description of property. PHS # 257020 La/ ?g.M C? q a. oo "" 14, Stu It a Soy," a aoa . sb ? 2?5 ?e ?0 50 1»033 q ?.? 9 -7 ssoo Tssue4d o CD N ^ tZrJ td I-D .? `° K tr1 0 ?o to ? CD as ;? ? ? ? ? d H mC? °r on zb ? t? ?°? "d0 o ?t?rJ ?y? Z'ZC n 00 r N O ? yy ?O rn H Cn ?o oz o a z? C17 C> ° H Z CD oy Y ??? ,H., arm ? OOz Y Y ? x o ? ? rH.r N ? Z O zy z x LEGAL DESCRIPTION ALL THAT CERTAIN PEICE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA BEING KNOWN AND DESIGNATED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST), WHICH POINT IS THE LINE DIVIDING LOTS NO. 167 AND 168 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SAID LINE NORTH 85 DEGREES 40 MINUTES EAST, ONE HUNDRED TWENTY (120) FEET TO THE LANDS OF W.R. KEELEYAND AND ANN L. KEELEY; THENCE ALONG THE SAID LANDS SOUTH 10 DEGREES 28 MINUTES EAST, SEVENTY-TWO AND FIFTY-TWO ONE HUNDREDTHS (72.52) FEET TO A POINT ON THE DIVIDING LOT NO. 167 AND LOT NO. 82, OF A PREVIOUS PLAN; THENCE ALONG THE SAID LINE SOUTH 72 DEGREES 04 MINUTES 19 SECONDS WEST, ONE HUNDRED TWENTY-FOUR AND NINETY-ONE ONE HUNDREDTH (124.91) FEET TO A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST); THENCE ALONG PAMELA'S LANE (EAST) IN A NORTHERLY DIRECTION ON A CURVE TO THE RIGHT HAVING A RADIUS OF 202.34 FEET, AN ARC DISTANCE OF FIFTY AND SEVENTY-EIGHT ONE-HUNDREDTHS (50.78) FEET TO A POINT' THENCE CONTINUING ALONG THE SAME NORTH 04 DEGREES 20 MINUTES WEST, FIFTY- ONE AND TWENTY-TWO ONE-HUNDREDTHS (51.22) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 167, PLAN NO. 9, OF THE VILLAGE OF WESTOVER, WHICH PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE ON PLAN BOOK 30, PAGE 83, HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 800 PAMELA'S LANE (EAST). TITLE TO SAID PREMISES VESTED IN EARL R. GUISE AND MARY JANE GUISE, HIS WIFE, AS TENANTS BY THE ENTIRETIES AND EARL GUISE, II, JOINTLY HELD AS TENANTS IN COMMON WITH THE RIGHT OF SURVIVORSHIP to EARL R. GUISE AND MARY JANE GUISE, HIS WIFE dated 12/29/99, recorded 1/10/2000 in book 214 and page 763. EARL R. GUISE was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of EARL R. GUISE's death on or about 04/08/2005, his ownership interest was automatically vested in the surviving tenant by the entirety, Jane Guise. PREMISES BEING: 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 PARCEL NO. 10-18-1323-041 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorneys for Plaintiff r- ?, 17 1`110, qtr; THE BANK OF NEW YORK MELLON TRUST C04'WYUVA IA : COURT OF COMMON PLEAS NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN : CIVIL DIVISION CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff NO.: 11-9240 CIVILTERM V. MARY JANE GUISE Defendant(s) : CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Ph an Hallinan & Schmieg, LLP n Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff V. MARY JANE GUISE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: I1-9240 CIVILTERM CUMBERLAND COUNTY PHS # 257020 AFFIDAVIT PURSUANT TO RULE 3129.1 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably - ascertained, please so indicate) .t r`t MARY JANE GUISE 800 PAMELAS LANE MECHANICSBURG PA 17050-2362 'J- --. 2. Name and address of Defendant(s) in the judgment:? " Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) KILEY W. BIXLER 10 DIVEN DRIVE YORK HAVEN, PA 17370. KILEY W. BIXLER C/O SHAUN J MUMFORD, ESQUIRE KILEY W. BIXLER C/O SHAUN J. MUMFORD, ESQUIRE LEOGRANDE JEFFREY C/O ERIE INSURANCE GROUP UNITRIN AUTO & HOME INSURANCE COMPANY SUB 51 S DUKE ST LANCASTER, PA 17602 3510 TRINDLE RD CAMP HILL, PA 17011-4439 PO BOX 2013 MECHANICSBURG, PA 17055-0710 5784 WIDEWATERS PARKWAY DEWITT, NY 13214 UNITRIN AUTO & HOME INSURANCE 51 S DUKE ST COMPANY SUB CIO SHAUN J. MUMFORD, LANCASTER, PA 17602 ESQUIRE UNITRIN AUTO & HOME INSURANCE 3510 TRINDLE RD COMPANY SUB C/O SHAUN J. MUMFORD, CAMP HILL, PA 17011 ESQUIRE 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 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: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE WILLOW OAK BUILDING RECOVERY PROGRAM HARRISBURG, PA 17105 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 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.A. § 4904 relating to unsworn falsification to authorities. Date: V7 Ift j O By. / P n Hallinan & Schmieg, LLP On Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff THE BANK OF NEW YORK MELLON TRUST COMPANY, COURT OF COMMON PLEAS NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO CIVIL DIVISION JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 NO.: 11-9240 CIVILTERM Plaintiff CUMBERLAND COUNTY VS. , MARY JANE GUISE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY = , f .M .- r TO: MARY JANE GUISE -b r. ; 800 PAMELAS LANE •' = MECHANICSBURG, PA 17050-2362 M` * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 is scheduled to be sold at the Sheriff's Sale on 09/05/2012 at 10:00 AM in the to enforce the court judgment of $216,957.59 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 also 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 on page two on how to obtain an attorney.) i YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN PEICE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA BEING KNOWN AND DESIGNATED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST), WHICH POINT IS THE LINE DIVIDING LOTS NO. 167 AND 168 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SAID LINE NORTH 85 DEGREES 40 MINUTES EAST, ONE HUNDRED TWENTY (120) FEET TO THE LANDS OF W.R. KEELEYAND AND ANN L. KEELEY; THENCE ALONG THE SAID LANDS SOUTH 10 DEGREES 28 MINUTES EAST, SEVENTY-TWO AND FIFTY-TWO ONE HUNDREDTHS (72.52) FEET TO A POINT ON THE DIVIDING LOT NO. 167 AND LOT NO. 82, OF A PREVIOUS PLAN; THENCE ALONG THE SAID LINE SOUTH 72 DEGREES 04 MINUTES 19 SECONDS WEST, ONE HUNDRED TWENTY-FOUR AND NINETY-ONE ONE HUNDREDTH (124.91) FEET TO A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST); THENCE ALONG PAMELA'S LANE (EAST) IN A NORTHERLY DIRECTION ON A CURVE TO THE RIGHT HAVING A RADIUS OF 202.34 FEET, AN ARC DISTANCE OF FIFTY AND SEVENTY-EIGHT ONE-HUNDREDTHS (50.78) FEET TO A POINT' THENCE CONTINUING ALONG THE SAME NORTH 04 DEGREES 20 MINUTES WEST, FIFTY- ONE AND TWENTY-TWO ONE-HUNDREDTHS (51.22) FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 167, PLAN NO. 9, OF THE VILLAGE OF WESTOVER, WHICH PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE ON PLAN BOOK 30, PAGE 83, HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 800 PAMELA'S LANE (EAST). TITLE TO SAID PREMISES VESTED IN EARL R. GUISE AND MARY JANE GUISE, HIS WIFE, AS TENANTS BY THE ENTIRETIES AND EARL GUISE, II, JOINTLY HELD AS TENANTS IN COMMON WITH THE RIGHT OF SURVIVORSHIP to EARL R. GUISE AND MARY JANE GUISE, HIS WIFE dated 12/29/99, recorded 1/10/2000 in book 214 and page 763. EARL R. GUISE was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of EARL R. GUISE's death on or about 04/08/2005, his ownership interest was automatically vested in the surviving tenant by the entirety, Jane Guise. PREMISES BEING: 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 PARCEL NO. 10-18-1323-041 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-9240 CIVILTERM THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 vs. MARY JANE GUISE owner(s) of property situate in the TOWNSHIP OF HAMPDEN, Cumberland County, Pennsylvania, being (Municipality) 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 Parcel No. 10-18-1323-041 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $216,957.59 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 DEFENDANT MARY JANE GUISE SERVE MARY JANE GUISE AT: 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 PHS # 257020 c a , a r rn tTt C r SERVICE TEAM/ lxh w p COURT NO.: 11-9240 CIVILTER p CD © 't TYPE OF ACTION 3:0 C" XX Notice of Sheriffs Sale ' C') = C :9 = t r SALE DATE: September 5, 2012 C7 Served and made known to MARY JANE GUISE, Defendant on the I&day of rlu ow Fz 20 GL, at I ! 13 , o'clock _f. M., at $OC ?ItNPAss LAw&, M&Fh*IcSivtt{-, in the manner described below: j/ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. - an officer of said Defendant's company. Other: SERVED Description: Age Height '46 " Weight 1 ? Race _ N Sex P Other I, `y!c l , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ( I I NAME: PRINTED NAME: Ronald MOIL TITLE: Process Server NOTSERVED On the day of , 20_, at o'clock _. M., Defendant NOT FOUND because: _ Vacant _ Does Not Exist _ Moved - Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 13.c O-OFFICE Ro HONOTARI" PHELAN HALLINAN & SCHMIEG, LLP Attorney for Pl rf UG 13 AM 10: 45 John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 i,. UMBERLANO COUNTY One Penn Center Plaza CFNNSYLVANIA Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : No.: 11-9240 CIVILTERM V. MARY JANE GUISE Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached q gx iibit "A". Date: ehael Kolesnik, Esquire for Plaintiff IMPORTANT NOTICE: This property is s6ld at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 257020 m J O? V? A W N ?+ 7• r? a? Q 5 a '?• 7y --I rA m x '9 N '?S b CG ?A ?'J `.„' 00 ?r "d o n pr?0 n n d awc0 M -3 V a-.o?br? 0 ???7cp ? o? m z d= t? d-3 >v ? aj mr IV 5, hoc>. ..px4 ?z34 row, -z ?' t?cn mr. -3rb 0 r w > n a --oo>z ?? bs ?Nr?a3 C,?z x>a z Q 3 ? g 7d° c?-3v r C?zr-?o> E-CriZ 7cr r>- v,x-3O cN3z v' ? trx'?ry w xtna,..] c?00x(=4 OtC)-CO soap -? a °' ? C)Ay(.7!??'? x z? ? >n a > .?> > x ova - mz> p° C ? 74 M o Ncm ? ?o "?zp yv C 2 CC 0. ? 0 til -3 n ?? cNiCr1? v°, [-? rnHZ < - 00 o o ? ??,C 7y r > -"e >? o n % ? o to M N .3 C N C? 3? ? zlk? w ° tz ?' A a ? a 3n c ?3 y o a a °' v a a a ro H N o a n' rv ? a ?.w `yo= n rw:. Ow w o e °° o 0 0 ? a y o n rv ? SD C i 3 x 'o °' a 3 ? ? s 33 0 _. rt w y ? rv m ? a - o• n ? 0 3 t> a O i c N ? 3 -' m c ? p w S1 3 13 yy oaz " n w C/) a CD N a 1 S O (D C (D CD s ? x w w C) co a O w a ? owcn? Ar o t- o a N 4l 'z a O ?C O LA N _O N a r w a? o" d Oaw CD u a coo _? a N w x co x x a' cc n u? 'OrC?'''Trrl"X ?ow :jO csu ?o X n uwi Z z t=f o?oZ [r1p O9 ?, r zU) d trsl eev a"d C) m CD ^z ??7x0PYC? ?M b^ x?Z?nXZ"?dZZo7 rlC MwWGdpya"? a o w t. - tri ;o CD co 0n c. r.OC7??3C,--"??C k2 ?r ev 9 a .ti t?'a a p W? O C?r7 a w Y tn'b C? t? ca ?° w n a?oa Q,?M?4d 'sl q; 7J? .L7.Uyow 3 n-•dR° pTJ?O ?o n J -s 25 N a C ?, v, A r s 3 m re !7? n w :Z 5 p °o r 10 a Y it, `0 ?. 3 z a TA o p a as 0 3 d o y b : z z z A z _ C O 4 cif ? ? W b ? ? n m ^ cau ?' ? ? p 0 O_ to x Q n °- N o. ?. S 7 d 07 ? ?,' ? N?".a? z z o a o ?o ao y "A o d ro °p c c a? o f .? 0. 41 m a 41 11 J C 7 d. O E ^ ° _.rn 0.d 3 ° 5- ? n ? ° d ? n N -.c n ¢ W w ? O m n ? x o °-' w c m 3 m ? f o OO `o :.. Y? t ?pro ? € q[t }.p c SH~~1FF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~ ~ ~'~~~~_~~~ ~~~ Sheriff i.1, TNT F' n ~4~r~xi~' at ~t~,g6rr~~~~0 ~{3TNON~tAnY Jody S Smith ~. - _ 1011 OCT 29 ~~ I£~. ~~ Chief Deputy ~ ~-~, ~ ~- . Richard W Stewart `` C(f~~E~~A~~ ~~~~~,~ solicitor ``,~`,`'~ r';`~"`~,F~ PEI~NSYLYAIYIA Bank of New York Mellon Trust Case Number vs. Mary Jane Guise 2011-9240 SHERIFF'S RETURN OF SERVICE 06/22/2012 06:38 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 800 Pamelas Lane, Mechanicsburg, PA 17050, Cumberland County. 06/26/2012 Robert Bitner, Deputy Sheriff, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Mary Jane Guise at 800 Pamelas Lane, Mechanicsburg, Cumberland County. 09/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $758.15 October 29, 2012 SO ANSWERS, ,»- RON R ANDERSON, SHERIFF r~~ ~~v ~,r • Q~-le a. as.Pd . ~, . s~ ~,~ ~ ~~ ~ a g-~y~7 Vic! CeumySurte Sheriff, 1'eieosofl. Inc. ~i THE BAND OF N1N~W ~012,K MELLUN TRUST COMPANY, NATIONAL ASSOCIATION"F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff v. MARY JANE GUISE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9240 CIVILTERM CUMBERLAND COUNTY PHS # 257020 AFFIDAVIT PURSUANT TO RULE 3129.1 THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) MARY JANE GUISE Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) KILEY W. BIXLER 10 DIVEN DRIVE YORK HAVEN, PA 17370. KILEY W. BIXLER C/O SHAUN J. MUMFORD ,ESQUIRE KILEY W. BIXLER C/O SHAUN J. MUMFORD ,ESQUIRE LEOGRANDE JEFFREY C/O ERIE INSURANCE GROUP UNITRIN AUTO & HOME INSURANCE COMPANY SUB 51 S DUKE ST LANCASTER, PA 17602 3510 TRINDLE RD CAMP HILL, PA 17011-4439 PO BOX 2013 MECHANICSBURG, PA 17055-0710 5784 WIDEWATERS PARKWAY DEWITT, NY 13214 UNITRIN AUTO & HOME INSURANCE 51 S DUKE ST COMPANY SUB C/O SHAUN J. MUMFORD , LANCASTER, PA 17602 ESQUIRE UNITRIN AUTO & HOME INSURANCE 3510 TRINDLE RD COMPANY SUB C/O SHAUN J. MUMFORD , CAMP HILL, PA 17011 ESQUIRE 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 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: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE WILLOW OAK BUILDING RECOVERY PROGRAM HARRISBURG, PA 17105 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 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.A. § 4904 relating to unsworn falsification to authorities. Date: 7 2 By: P n Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff THE BANK OF NEW YORK MELLON TRUST COMPANY, COURT OF COMMON PLEAS NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO CIVIL DIVISION JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 NO.: 11-9240 CIVILTERM Plaintiff CUMBERLAND COUNTY vs. MARY JANE GUISE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MARY JANE GUISE 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 **THLS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANHItUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 is scheduled to be sold at the Sheriff s Sale on 09/05/2012 at 10:00 AM in the to enforce the court judgment of $216,957.59 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 also 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 on page two on how to obtain an attorney.) YOU MAC STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffls Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 ca11215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 THE BANK (~~' NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TR~JST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9240 CIVILTERM Plaintiff CUMBERLAND COUNTY vs. MARY JANE GUISE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MARY JANE GUISE 800 PAMELAS LANE MECHANICSBURG, PA 17050-2362 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 is scheduled to be sold at the Sheriffs Sale on 09/05/2012 at 10:00 AM in the to enforce the court judgment of $216,957.59 obtained by THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may call: 215-563-7000 21230. 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 also 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 on page two on how to obtain an attorney.) U MAY STILL ~E ABLE TO SAVE YOUR PROPERTY AND YOU HAVE ~~v rF T~ ~HF:T~2iFF'S SALE DOES TAKE PLACE. 1. 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 215-563-7000. 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 cal1215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 R LEGAL DESCRIPTION ALL THAT CERTAIN PEKE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA BEING KNOWN AND DESIGNATED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST), WHICH POINT IS THE LINE DNIDING LOTS NO. 167 AND 168 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SAID LINE NORTH 85 DEGREES 40 MINUTES EAST, ONE HUNDRED TWENTY (120) FEET TO THE LANDS OF W.R. KEELEYAND AND ANN L. KEELEY; THENCE ALONG THE SAID LANDS SOUTH 10 DEGREES 28 MINUTES EAST, SEVENTY-TWO AND FIFTY-TWO ONE HUNDREDTHS (72.52) FEET TO A POINT ON THE DNIDING LOT NO. 167 AND LOT NO. 82, OF A PREVIOUS PLAN; THENCE ALONG THE SAID LINE SOUTH 72 DEGREES 04 MINUTES 19 SECONDS WEST, ONE HUNDRED TWENTY-FOUR AND NINETY-ONE ONE HUNDREDTH (124.91) FEET TO A POINT ON THE EASTERN LINE OF PAMELA'S LANE (EAST); THENCE ALONG PAMELA'S LANE (EAST) IN A NORTHERLY DIRECTION ON A CURVE TO THE RIGHT HAVING A RADIUS OF 202.34 FEET, AN ARC DISTANCE OF FIFTY AND SEVENTY-EIGHT ONE-HUNDREDTHS (50.78) FEET TO A POINT' THENCE CONTINUING ALONG THE SAME NORTH 04 DEGREES 20 MINUTES WEST, FIFTY- ONE AND TWENTY-TWO ONE-HUNDREDTHS (51.22} FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 167, PLAN N0.9, OF THE VILLAGE OF WESTOVER, WHICH PLAN IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE ON PLAN BOOK 30, PAGE 83, HAVING THEREON ERECTED A DWELLING KNOWN AND NUMBERED AS 800 PAMELA'S LANE (EAST). TITLE TO SAID PREMISES VESTED IN EARL R GUISE AND MARY JANE GUISE, HIS WIFE, AS TENANTS BY THE ENTIRETIES AND EARL GUISE, II, JOINTLY HELD AS TENANTS IN COMMON WITH THE RIGHT OF SURVIVORSHIP to EARL R GUISE AND MARY JANE GUISE, HIS WIFE dated 12/29/99, recorded 1/10/2000 in book 214 and page 763. EARL R. GUISE was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of EARL R. GUISE's death on or about 04/08/2005, his ownership interest was automatically vested in the surviving tenant by the entirety, Jane Guise. PREMISES BEING: 800 PAMELAS LANE, MECFIAIVICSBURG, PA 17050-2362 PARCEL NO.10-18-1323-041 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-9240 CIVILTERM THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 vs. MARY JANE GUISE owner(s) of property situate in the TOWNSHIP OF HAMPDEN, Cumberland County, Pennsylvania, being (Municipality) 800 PAMELAS LANE, MECHANICSBURG, PA 17050-2362 Parcel No. 10-18-1323-041 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $216,957.59 Phelan Hatlinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-9240 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL ASSOCIATION F/K/A THE BANK OF NEW YORK TRUST COMPANY, N.A. SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 Plaintiff (s) From MARY JANE GUISE (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 properly 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: $216,957.59 L.L.: $.50 Interest from 3/16/2012 to Date of Sale ($35.66 per diem) - $6,204.84 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $202.50 Other Costs: Plaintiff Paid: Date: 5/17/12 (Seal) REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 PHILADELPHIA. PA 19103 Attorney for: PLAINTIFF Te 1 ephon e: 215-563-7000 Supreme Court ID No. 308877 TRUE COPY FROM Ri`CORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlist 20P~ This ~Z.day of ProthoLn~o On May 22, 20-12 the Sheriff levied_upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as, 800 Pamelas Lane, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22, 2012 By: Real Estate Coordinator L ~ ~~ °~- I ~ ~'~~P kd 710't CUMBERLAND LAW JOURNAL Writ No. 2011-9240 Civil Term Bank of New York Mellon Trust vs. Mary Jane Guise Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 11-9240 CIVILTERM, THE BANK OF NEW YORK MELLON TRUST COMPANY, NATIONAL AS- SOCIATION f/k/a THE BANK OF NEW YORK TRUST COMPANY, N.A. AS SUCCESSOR TO JPMORGAN CHASE BANK N.A. AS TRUSTEE FOR RAMP 2005RS6 vs. MARY JANE GUISE owner(s) of property situate in the TOWNSHIP OF HAMPDEN, Cum- berland County, Pennsylvania, being 800 PAMELAS LANE, MECHANICS- BURG, PA 17050-2362 Parcel No. 10-18-1323-041. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $216,957- .59. 50 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Cazlisle 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 regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ------ ~~' V~ Lisa arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 10 day of August, 2012 Notary N07ARIAl SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commisalon Ezpiras Apr 28, 2014 The Patriot-News Co. 2020 Technology Pi~wy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 901t-Y4~0 grM'tktt~ °~ Nsw ~ ~Mrlon-Trust ~~ ii- THB BANIt'~rp' 1+UR~€M~U.ON TRUST COQ, Npj, ~~fJN Fgu Tf~E BAN[( .OF NEW l~0$B TRUST E~1-lpANY, ~ AS 1RL>Si~ FOR vs. M~Y~GUtSE ,~°~~~ dune is the C~mhe Got~atq~~' • bei~ MBQL#~it~'i~H~G, PA 2745D-2362 Parc;elNa ~.l&3~C{.pt; (ecu ~ ~ DWELLAYTG RES ~'~'•4iV10llIVT`, 6216,95759 This ad ran on the date(s) shown below: 07/27/12 08/03/12 08/10/12 ',Sworn to ~he~atriot•Ne~us Now you know me this 17 Notary Public of ~ugust, 2012FA.D. ~~~~~~ ~ ~ ~ 1'J__~1__~~' , COMMONWEALTH GF PENPlSYLVANIA ~ notarial Seal Snerrie L. Vwer~::, Notary ?ublic L.ca~Ar Pzxton ~ wp , uauphir~ Counr~ i ~My t.on mission Expires fdov. 26, 2015 MEMBER. PE ~N YL1/.4("?A A.SM~ ik1T..Oh 7f- NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which The Bank of New York Mellon Trust Company F/K/A The Bank of New York Trust Company is the grantee the same having been sold to said grantee on the 5th day of September A.D., 2012, under and by virtue of a writ Execution issued on the 12th day of April, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 9240, at the suit of The Bank of New York Mellon Trust Com~any F/K/A the Bank of New York Trust Comnany against Mary Jane Guise is duly recorded as Instrument Number 201233347. IN TESTIMONY WHEREOF, I hay eunto set my hand and seal of said office this / day of of Deeds My Corrvn E,~,'r M ~Y~ Cernsle, PA ondey of Jan. 2014