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HomeMy WebLinkAbout11-9329SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FFILE0-0t= E Sheriff THE PROTHUNOTAFRY Vgtltt?r ?1 ?al?r?t?tr,,rtj? Jody S Smith 2012 JAN -3 A1410:35 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Aurora Loan Services, LLC Case Number vs. 2011-9329 Darryl J. Ryan (et al.) SHERIFF'S RETURN OF SERVICE 12/21/2011 07:14 PM - 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: Darryl J. Ryan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Darryl J. Ryan. Request for service at 110 Fairway Drive, Carlisle, Pennsylvania 17013 is vacant. Deputies were advised, Darryl J. Ryan is thought to be residing at 2050 Danbury Drive, Rockwell, Texas 75032. AEL BARRICK, DEPUTY 12/21/2011 07:14 PM - 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: Victoria S. Ryan, 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 Victoria S. Ryan. Request for service at 110 Fairway Drive, Carlisle, Pennsylvania 17013 is vacant. Deputies were advised, Victoria S. Ryan is thought to be resi ing at 2050 Danbury Drive Rockwell, Texas 75032. ICHAEL B RRICK, EPUTY -? 12/22/2011 07:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 22, 2011 at 1910 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Occupant of 504 Charles Street, Shippensburg, Pennsylvania 17257, by making known unto Anderson Eddy, current Occupant of 504 Charles Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. --V--` RYAN BURGETT, DEPT 12/30/2011 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: Darryl J. Ryan, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Darryl J. Ryan. Request for service at 504 Charles Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. 12/30/2011 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: Victoria S. Ryan, 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 Victoria S. Ryan. Request for service at 504 Charles Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. ,?! Gounf,SU1tP, Sw.ff. feros:'t.. I.^c. SHERIFF COST: $138.00 December 30, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ,c: Chun+y ? .. s;ntt sfla. fnr,. AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY r? AURORA LOAN SERVICES, LLC. C =D N PHS # 264602 rnCO -73C DEFENDANT SERVICE TEAM/ hzc DARRYL J. RYAN COURT NO.: 11-9329-CIVIL ??• 1V .,.. VICTORIA S. RYAN f" SERVE VICTORIA S. RYAN AT: TYPE OF ACTION d 2050 DANBURY DR XX Mortgage Foreclosure ROCKWALL, TX 75032-7277 XX Civil Action c-n SERVED Served and ma known to VICTORIA S. RYAN , Defendant on the LE day of sb, 201, at 15-D- o'clockY. M., atC145b Qtn6firuD . to the manner described below: Defendant personally served. I -M _ 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. l1 f G _ Other: f SPA Description: Age AQ5 Height Weight 1 5 Raj ex -F Other I, nth;, &k6, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this to day of M ^"k 20L. u?l-in ic?f IS ?b80 /0?3??'t Notary By: NOT SERVED 3 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 Service Refused Other: Sworn to and subscribed before me this day of -,20-. By: Notary: JACOB CAMBRON a MY COMMISSION EXPIRES AUGUST 12, 2013 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. Fiiakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 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 John M. Kolesnik, Esq., Id. No. 308877 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 r" C cJ PLAINTIFF AURORA LOAN SERVICES, LLC. DEFENDANT DARRYL J. RYAN VICTORIA S. RYAN SERVE DARRYL J. RYAN AT: 2050 DANBURY DR ROCKWALL, TX 75032-7277 PHS # 264602 Ca SERVICE TEAM/ hzc `ri 3 rri CO COURT NO.: 11-9329-CIVIL M -t T? T TYPE OF ACTION 1 - XX Mortgage Foreclosure "C t= XX Civil Action > C") SERVED ,?Sved and madgornown to DARRYL J. RYAN , Defendant on the M day of , 20 ;?, at -/ , o'clock F. M., a in the manner described below: _ Defendant personally served. Adult family member with whom Defendant(s) ride(s). Relationship is W1FF . V(CjVjZ(Q Kq&rN -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. - N czn fV A cn ,. 0 .gym, - Other: /i4`5pAn i C Description: Age Height 50"4'* Weight// RaceAym/Sex Other rOWk.. I, Aus+(/? a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner aAset forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 4 day Notar . By: NOT SERVED 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 Service Refused Other: Sworn to and subscribed before me this day of 20_. By: Notary: JACOB CAMERON * MY COMMISSION EXPIRES AUGUST 12, 2013 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 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY lq/s1/lj Cnrisovalante P. Fiiakos, Esq., id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 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 John M. Kolesnik, Esq., Id. No. 308877 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 :- r ;=fCE PHELAN HALLINAN & SCHMIEG,11LP, h j l G l0Te' t Attorney for Plaintiff Matthew Brushwood, Esq., Id. No.3105,g2 r, , n 1617 JFK Boulevard, Suite 1400 3 "l' 10• 6 `t One Penn Center Plaza ?; ?,0 ?# 11T'-' Philadelphia. PA 19103 f>? ???i''i y,? nlf 215-563-7000 AURORA LOAN SERVICES, LLC. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS DARRYL J. RYAN CIVIL DIVISION VICTORIA S. RYAN No. 11-9329-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DARRYL J. RYAN, and VICTORIA S. RYAN, 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 Plaintiffs damages as follows: As set forth in Complaint TOTAL 5163,374.89 $163,374.89 I hereby certify that (1) the Defendants' last known addresses are 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 and 2050 DANBURY DR, ROCKWALL, TX 75032-727 , and (2) that notice has been given in accordance with ule Pa.R.C.P 237.1. Date , att e Brushwood, Esquire Attorney for Plaintiff a t4 -r- CA ?1 Inn 3 Ito DAMAGES ARE HEREBY ASSESSED AS INDICATED. a?3-7710 tscRu 1V`Cu w4 DATE: •? PHS # 264602 PROTHONOTARY 264602 PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. VS. DARRYL J. RYAN VICTORIA S. RYAN : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 11-9329-CIVIL 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 DARRYL J. RYAN is over 18 years of age and resides at 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 and 2050 DANBURY DR, ROCKWALL, TX 75032-7277. (c) that defendant VICTORIA S. RYAN is over 18 years of age and resides at 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 and 2050 DANBURY DR, ROCKWALL, TX 75032-7277. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date q111 ? Matt Brushwood, Esquire Attorney for Plaintiff 264602 (Rule of Civil Procedure No. 236) - Revised AURORA LOAN SERVICES, LLC. VS. DARRYL J. RYAN VICTORIA S. RYAN CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No 11-9329-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Matthew Brushwood, 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 PREVIO USL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** AURORA LOAN SERVICES, LLC. Plaintiff DARRYI., J. RYAN VICTORIA S. RYAN Dt"IfsnaEmt(s'i TO VICTORIA S. RYAN 2050 DANBURY DR ROCKWALL., TX 75032-7277 DATE OF NOTICE: 1L- COURT OF COMMON PLEAS CIVIL DIVISON NO. 1.1-9329-CIVIL. CUMBERLAND COUNTY THIS FIRM IS A DEBT C:OI.,I...ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SEN'T' TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AM) 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 A'1"1'EVIPT TO COLLECT A DEBT, BUTONLY 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE, A I...AWYER, 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 TIIAT MAY OFFER LEGAL SERVICES TO El..,]GIBLL PERSONS AT A REDUCED FEE- OR NO FEE:. 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 CARLISLE, PA 1.7013 (717 249 3166 By: . . Troy Sellars, ;squire Attorney for Plaintiff Phelan 1-lallinan & Schmieg, L.LP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia; PA 19103 PHS # 264602 AURORA LOAN SERVICES, LLC. v Plaintiff COURTOF COMMON PLEAS CIVIL DIVISON NO. 11-9329 CIVIL DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) I'O: DARRYL I. RYAN 2050 DANBURY DR ROCKWALL, TX 75032-7277 DATE OF NOTICE: 112-- IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE. YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. II, YOL' DO NOT HAVE A LAWYER, GO TO OR TELEPHONF. THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT AIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFIC:F; MAY BE ABLE TO PROVIDE YOU WITII INFORMATION ABOUT AGENCIES THAT MAY OFFER ILGAL SERVICE S TO I?d.]GIBLE PERSONS AT A REDUCED FEE OR NO FFF?. Office of the Prothonotary Cuinberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SINT TO YOU IN AN ATTEMPT'TO COLLECI' THE INDEBTFI)NESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL, BF: 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 Al T'EMP'I` 'l'0 COLLECT A DEB"I', BUT ONLY AS ENFORCEMENT OF LIEN AGAINS'T' PROPERTY. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 ;717)w49-3166 By: Troy Sellars, 1 wire Attorney for Plaintiff Phelan Hallinan & Schmieg, L.LP 1617 JFK Boulevard, Suite. 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 26,4602 AURORA LOAN SERVICES, LLC. Plaintiff DARRYLJ.RYAN VICTORIA S. RYAN Defendant(s) TO: DAR.RYLJ.RYAN 504 CHARLES STREET SN.I:PPENSBURG, PA 1.7257-21.1.5 DATE OF NOTICE: 2-1 / I Z- COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-9:329-CIVIL. CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING T'O COLLECT A DEBT. THIS NOTICE IS SENI' TO YOU IN AN ATTEMPT' TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED 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 I.,IL'N AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE.. YOU HAVE FAILED TO ENTER A WRrrTF:.N APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRI'T'ING WI'T'H THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WTl'HLN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINSTYOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANTRIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TFLEPHONF, THE OFFICE SET FORTH BELOW. T IJIS OFFICE. CAN PROVIDE YOU WITH INFORMATION ABOUTHIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRI A LaAWYER, THIS OF11CE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV[CES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FETE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 C'UMBER.I..,A:'ND COUNTY BAR ASSOCIATION CUMBERLAND COl_JN'I`Y COURTLIOUSF. 2 LIBERTY AVENUE CARLISLE. PA 1.701.3 (7 7),49-1166 Bv, Troy Sellars, I.- quire Attorney for Plaintiff Phelan IIallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn CE:nter Plaza Philadelphia, PA 19103 PHS 4 264602 AURORA LOAN SERVICES, LLC:. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVLSON NO. 11-9329-CIVIL I:)AR.RYI,J. RYAN V IC'TORIA S. RYAN Defendant(s) l'O VICTORIA S. RYAN 504 CHARLES STREET SHIPPENSBURG, PA 17257-21.18 DATE OF NOTICE: 312-1 IMPORTANT NOTICE YOU ARE IN DF,FAUL.T 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 CLAMIS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF TI-TIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER LMPORTANT RIGHTS. YOU SHOIJI..,D 'CAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUTHIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL, SERVICES TO 13L1GII31 1 PERSONS AT A REDUCED FEE OR NO FEE, Office of the Prothonotary Cumberland County Courthouse t Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COI,LECT A DEBT. THIS NOTICE IS SENTTO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TI-I 'T 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 1_1EN AGAINS'T' PROPERTY. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY C Ot.!R'I'HOLJSE 2 LIBERTY AVENUE CARLISLE, PA 1.7013 17 1 1 249-3166 f-------_.....-- y -t Troy Sellars, quire. Attorney for Plaintiff Phelan Hallinan & Schmieg, L.L.P 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 264602. PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 AURORA LOAN SERVICES, LLC. Plaintiff v DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 04/14/2012 to Date of Sale ($26.86 per diem) TOTAL COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9329-CIVIL CUMBERLAND COUNTY tea: ,j $163,374.89; $3,894.70' $167,269.59 Lauren R. Tabas, Esq., Id. No.93337 Attorney for Plaintiff Note: Please attach description of property. PHS # 264602 4028.5o Pb A- r'1 138.00 Car U. oo •• l(O.50 a .5o V a'T?. 50 - PO A-TrY a. a 5 flue (i 'so LL e* I I'8 5sa3 0 (274038 PE L& H- J d c f? N N C4 O O 3 Z Q ¢ Z oU ?U Q Q o o ? W z a a w z a zw o a v? w? _ a M rn a H U O ° H ? a„o ?z 0o w z Cf) ? o w ?? o U z ' rx oo (A w cc o as O ? H U w U ? 'w ? o PHELAN HALLINAN & SCHMIEG, LLP Lauren R. Tabas, Esq., Id. No.93337 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff V DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9329-CIVIL 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 8 Pa. S. § 4904 relating to unsworn falsification to authorities. W W Phelan Hallinan & Schmie " Lauren R. Tabas, Esq., Id. No.93337 Attorney for Plaintiff " J <a MOO - CP ' ,' AURORA LOAN SERVICES, LLC. Plaintiff V. DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-9329-CIVIL CUMBERLAND COUNTY PHS # 264602 AFFIDAVIT PURSUANT TO RULE 3129.1 AURORA LOAN SERVICES, LLC., 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 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118. Name and address of Owner(s) or reputed Owner(s): 2. 3 Name Address (if address cannot be reasonably `u ascertained, please so indicate) UD C 1-'J. t-n -.. rr,;= `?- DARRYL J. RYAN 2050 DANBURY DR 7t -?o P J ROCKWALL, TX 75032-7277 J VICTORIA S. RYAN 2050 DANBURY DR y. c.; =K 77. ROCKWALL, TX 75032-7277 -- Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 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) AMERICAN EXPRESS BANK, FSB AMERICAN EXPRESS BANK, FSB C/O AMY F. DOYLE, ESQUIRE FIA CARD SERVICES, NA FIA CARD SERVICES, NA C/O DAVID J APOTHAKER, ESQUIRE 200 VESEY STREET NEW YORK, NY 10285 11 E MARKET ST STE 102 YORK, PA 17401 4161 PIEDMONT PARKWAY GREENSBORO, NC 27410 520 FELLOWSHIP RD # C306 MT LAUREL, NJ 08054 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) LEHMAN BROTHERS BANK, FSB, A 400 PROFESSIONAL DRIVE FEDERAL SAVINGS BANK SUITE 500 GAITHERSBURG, MD 20879 LEHMAN BROTHERS BANK, FSB, A 1229 EAST CHOCOLATE AVE FEDERAL SAVINGS BANK C/O HERSHEY, PA 17033 APPALACHIAN SETTLEMENT AGENCY, LLC LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK C/O AURORA LOAN SERVICES LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK C/O AURORA LOAN SERVICES, LLC MERS AS A NOMINEE FOR LEHMAN BROTHERS BANK, FSB, A FEDERAL SAVINGS BANK ATTN: WENDY WELTE 2530 S PARKER RD SUITE 601 AURORA, CO 80014 601 5TH AVE PO BOX 4000 SCOTTSBLUFF, NE 69363 P.O. BOX 2026 FLINT, MI 48501 MERS, INC. FORMERLY 3300 SW 34TH AVENUE, SUITE 101 OCALA FL 3 AS OF 12/6/10,1901 E. VOORHEES STREET, SUITE C DANVILLE, IL 61834 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 None. Address (if address cannot be reasonably ascertained, please indicate) 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 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 CITIMORTGAGE, INC. 1000 TECHNOLOGY DR MS321 O FALLON, MO 63368-2239 MERS, AS NOMINEE FOR CITIMORTGAGE, P.O. BOX 2026 INC. FLINT, MI 48501-2026 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 tration false at ents herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifi &1utho 'ties. Date: t B Y Ph an Hallinan & Schmieg, LLP Lauren R. Tabas, Esq., Id. No.93337 Attorney for Plaintiff AURORA LOAN SERVICES, LLC. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) : : NO.: 11-9329-CIVIL CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DARRYL J. RYAN VICTORIA S. RYAN 2050 DANBURY DR ROCKWALL, TX 75032-7277 "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 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 is scheduled to be sold at the Sheriffs Sale on 09/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $163,374.89 obtained by AURORA LOAN SERVICES, LLC. (the mortgagee) against you. In the event the sale is continued, an annouipem?_*t 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 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 THE FOLLOWING described real estate lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEING Lots 3 and 4, Block'C', on plan of lots known as Hallwood Heights, recorded in Cumberland County, Pennsylvania, Plan Book No. 3-113. SUBJECT to all conditions, restrictions, and reservations of record. TITLE TO SAID PREMISES VESTED IN Darryl J. Ryan and Victoria S. Ryan, h/w, by Deed from Brett Rininger and Sara 1. Rininger, dated 10/26/1999, recorded 10/28/1999 in Book 210, Page 596. PREMISES BEING: 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 PARCEL NO. 32-34-2413-186 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-9329-CIVIL AURORA LOAN SERVICES, LLC. vs. DARRYL J. RYAN VICTORIA S. RYAN owner(s) of property situate in the BOROUGH OF SHIPPENSBURG, Cumberland County, Pennsylvania, being (Municipality) 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 Parcel No. 32-34-2413-186 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $163,374.89 Phelan Hallinan & 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) COUNTY OF CUMBERLAND) NO. 11-9329 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AURORA LOAN SERVICES, LLC, Plaintiff (s) From DARRYL J. RYAN and VICTORIA S. RYAN (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: $163,374.89 L.L.: $.50 Interest from 4/14/12 to Date of Sale ($26.86 per diem) -- $3,894.70 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $277.50 Other Costs: Plaintiff Paid: Date: 6/1/2012 David D. Buell, Prothonotary (Seal) 1-13L Deputy REQUESTING PARTY: Name: LAUREN-R. TABAS, 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. 93337 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff vs. DARRYL J. RYAN VICTORIA S. RYAN Defendants H0,'~'0 TAi ,~,. r„ ~ ~ in ~ ~4 L~ u lJ,~~V . ~~~~~ ~~ ~Y~ ~ ~~'~f ~ r `r ~I~~q CUMBERLAND COUNTY COURT OF COMMON PLI CIVIL DIVISION NO.11-9329-CIVIL MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, LLP, petitions this Honorable for an Order directing service of the Notice of Sale upon the above-captioned Defendants, DARRYL J. RYAN and VICTORIA S. RYAN, by certified mail and regular mail to DARRY RYAN and VICTORIA S. RYAN at 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118, 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277 and posting 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 and publication pursuant to PA.R.C.P. 3129.2 (D) and in support thereof avers the following: 1. A Sheriffs Sale of the mortgaged property involved herein has been scheduled September 5, 2012. 2. Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 3129.2 requires that the Defendants be served with a notification of Sheriffs Sale at least thirty (30) J. prior to the scheduled sale date. 3. Attempts to serve Defendants, DARRYL J. RYAN and VICTORIA S. RYAN,j with the Notice of Sale at the mortgaged premises, 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118, have been unsuccessful, as indicated by Return of Service attached hereto as Exhibit "A", no service was made as the Defendants do not reside at the mortgaged premises. Attempts to serve Defendants, DARRYL J. RYAN and VICTORIA S. RYAN, with the Notice Sale at 110 FAIRWAY DRIVE, CARLISLE, PA 17015-9365 have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A", no service was made as the said address is vacant. Attempts to serve Defendants, DARRYL J. RYAN and VICTORIA S. RYAN, with the Notice Sale at 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277 have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A", no service was made as there was no response from the Defendants. 4. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendants. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". 5. Plaintiff contacted the Prothontary's Office and as of July 26, 2012, no Judge previously entered a ruling in this case. 6. In accordance with CUMBERLAND County Local Rule 208.3(9), Plaintiff se~.t a copy of its Proposed Motion for Special Service and Order to the Defendants July 26, 2012 and requested Defendants' concurrence. Plaintiff did not receive any written response from the Defendants. A true and correct copy of July 26, 20121etter and postmarked certificate of mailing pursuant to Local 208.3(9) attached hereto, made part hereof, and marked Exhibit "C". 7. Plaintiff submits that it has made a good faith effort to locate the Defendants, DARRYL J. RYAN and VICTORIA S. RYAN, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests that the allowance of service of the of Sale upon Defendants in accordance with Pa.R.C.P., Rule 430 by certified and regular mail DARRYL J. RYAN and VICTORIA S. RYAN at 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118, 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277 and posting 504 STREET, SHIPPENSBURG, PA 17257-2118 and by publication. ~/ Ph al ' & Schmieg, LLP DATE: `7i By: Ma a Brus od, Esquire Attorney for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLl vs. DARRYLJ.RYAN VICTORIA S. RYAN Defendants CIVIL DIVISION NO.11-9329-CIVIL PLAINTIFF'S MEMORANDUM OF LAW Pursuant to Pennsylvania Rule of Civil Procedure, Rule 3129.2, it is necessary a foreclosure action for the Sheriff or Process Server to serve upon the Defendants Notice of Sale of the mortgaged premises. Specifically, Pa.R.C.P., Rule 3129.2 (c) provides in part as follows: The written notice shall be prepared by the plaintiff, shall contain the same informatic as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the Notice shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed Rule 402 (a) for the service of original process upon a defenda~ or (B) by the plaintiff mailing a copy of the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in the subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court. Because the whereabouts of Defendants, DARRYL J. RYAN and VICTORIA RYAN, are unknown, a reasonable investigation of their last known address was made in accordance with Pa.R.C.P. 430(a). Pennsylvania Rule of Civil Procedure, Rule 430 (a) provides as follows: (a) If service cannot be made under the applicable rule the Plaintiff may n the court for a special order directing the method of service. The motion shall accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A Sheriff's Return or Affidavit of Service of "not found" or the f c1 that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs.Polis, 238 Pa.Super. 362, 3 7 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address. Ado tion of Walke , 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, frie and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records and motor vehicle rea As indicated by the attached Affidavit of Return of Service, marked hereto as Exhibit "A", the Process Server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendants has been as evidenced by the attached Affidavit of Reasonable Investigation, marked as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that the allowance of service of t~ Notice of Sale upon Defendants in accordance with Pa.R.C.P., Rule 430 by certified and re mail to DARRYL J. RYAN and VICTORIA S. RYAN at 504 CHARLES STREET, PA 17257-2118, 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277 and posting 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 and by publication pursuant to PA.R.C.P. 3129.2. (~~ Phel Hal n & Schmieg, LLP DATE: v By: Ma ew B shwo d, Esquire Att ev for 'tiff PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Plaintiff vs. DARRYLJ.RYAN VICTORIA S. RYAN CUMBERLAND COUNTY COURT OF COMMON PLl CIVIL DIVISION NO.11-9329-CIVIL Defendants CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion for Service of N of Sale Pursuant to Special Order of Court, Proposed Order, Memorandum of Law, of Service and Exhibits in the above captioned matter was sent by first class mail, postage prepaid to the following interested parties on the date indicated below. DARRYLJ.RYAN 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 VICTORIA S. RYAN 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 2050 DANBURY DRIVE ROCKWALL, TX 75032-7277 DATE: -V 2050 DANBURY DRIVE ROCKWALL, TX 75032-7277 Phelan Hallinan & Schmieg, LLP By: for Esquire EXHIBTT ~°A" AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY AURORA LOAN SERVICES, LLC. ' PHS # 264602 DEFENDANT SERVICE TEAM/ lxh DARRYL J. RYAN COURT NO.: 11-9329-CIVIL VICTORIA S. RYAN SERVE DARRYL J. RYAN AT: TYPE OF ACTION 504 CHARLES STREET XX Notice of Sheriff s Sale SHIPPENSBURG, PA 17257-2118 SALE DATE: September 5, 2012 SERVED Served and made known to DARRYL J. RYAN, Defendant on the _ day of , 20 , at ,o'clock _. M., at , in the manner described below: 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: Description: Age _ Height .Weight Race Sex Other I, , 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: NAME: PRINTED NAME: TITLE: NOT SERVED On the `b day of ~_, 20 ~? at ~-b'clock ~? M., Defendant NOT FOUND because: Vacant _ Does Not Exist _ Moved X 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 unsworn falsification to authorities. BY: E ~~ PRINTED NAME: 1 ~~ _ _ r 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. 'Labas, 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 John M. Kolesnik, Esq., Id. No. 308877 •PLAINTIFF AURORA LOAN SERVICES, LLC. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 264602 DEFENDANT DARRYLJ.RYAN VICTORIA S. RYAN SERVE VICTORIA S. RYAN AT: 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 SERVICE TEAM/ lxh COURT NO.: 11-9329-CIVIL TYPE OF ACTION XX Notice of Sheriff s Sale SALE DATE: September 5, 2012 SERVED Served and made known to VICTORIA S. RYAN, Defendant on the _ day of , 20 _, at o'clock _. M., at , in the manner described below: _ 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: Description: Age Height _ Weight Race Sex Other I, , 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: NAME: PRINTED NAME: TITLE: NOT SERVED On the ~ day of _~, 20 ~Z, at ~7~~'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 unsworn falsification to authorities. BY: ~ ~ ~~ PRINTED NAME: ~ ~` "`'~"'~~`^ ~1~~P ""`~"` ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele N[. 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 Mazio J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 r AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY AURORA LOAN SERVICES, LLC. ` PHS # 264602 DEFENDANT SERVICE TEAM/ Ixh DARRYL J. RYAN COURT NO.: 11-9329-CIVIL VICTORIA S. RYAN SERVE DARRYL J. RYAN AT: TYPE OF ACTION 110 FAIRWAY DRIVE XX Notice of Sheriff s Sale CARLISLE, PA 17015-9365 SALE DATE: September 5, 2012 SERVED Served and made known to DARRYL J. RYAN, Defendant on the _ day of , 20 , at o clock _. M., at , in the manner described below: 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: Description: Age Height Weight Race Sex Other I, , a competent adult, hereby verify that 1 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: NAME: PRINTED NAME: TITLE: (~ NOT SERVED On the P day of ~~' , 202, at"ItSo'clock . M., Defendant NOT FOUND because: X Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at , Service Refused at Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: ~ ~~ PRINTED NAME: Q' ~~~ 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. 3095]9 Melissa J. Cantwell, Esq., Id. No. 3089] 2 Mat-io J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 30887? PLAINTIFF AURORA LOAN SERVICES, LLC. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 264602 DEFENDANT DARRYL J. RYAN VICTORIA S. RYAN SERVE VICTORIA S. RYAN AT: 110 FAIRWAY DRIVE CARLISLE, PA 17015-9365 SERVICE TEAM/ lxh COURT NO.: 11-9329-CIVIL TYPE OF ACTION XX Notice of Sheriff s Sale SALE DATE: September 5, 2012 SERVED Served and made known to VICTORIA S. RYAN, Defendant on the _ day of , 20 , at ,o'clock _. M., at , in the manner described below: 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 Def'endant's company. Other: Description: Age Height .Weight Race Sex Other I, , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as se.t forth herein, issued in the captioned case on the date and at the address indicated above. 1 understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE: '~~,~p' ~[,~ NOT SERVED On the ~ day of ~. _ ~ , 2012; at~I o'clock M., Defendant NOT FOUND because: (Vacant _ Does Not Exist _ Mov~ _ Does Not Reside (Not Vacant) _ No Answer on at , Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: ~,~~ti ~~!f;~~- 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 John M. Kolesnik, Esq., Id. No. 308877 PLAINTIFF AURORA LOAN SERVICES, LLC. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 264602 DEFENDANT DARRYL J. RYAN VICTORIA S. RYAN SERVE DARRYL J. RYAN AT: 2050 DANBURY DR ROCKWALL, TX 75032-7277 SERVICE TEAM/ lxh COURT NO.: 11-9329-CIVIL TYPE OF ACTION XX Notice of Sheriff s Sale SALE DATE: September 5, 2012 SERVED Served and made known to DARRYL J. RYAN, Defendant on the _ day of , 20 _, at o'clock _. M., at , in the manner described below: 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. _ ManagerlClerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ stn officer of said Defendant's company. Other: Description: Age Height .Weight Race Sex Other I, , a competent adult, being duly sworn according to law, depose and state 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. Sworn to and subscribed ~~..~~. W ~'r~ ~'"'- "Q before me this day , hs` 1, Q H p ~,~,3 a ~0 O h of , 20_. ~i~C Notary: By: 0 `^" •~ ~ ~ ~~~~ ~ /- N-O~SERVE-D ~~~ ~ ~~~/ On the ~ day , 2~, at ~bt~lock rIVI., Defendant NOT FOUND because: _ Vacant Doe Not Exist _ ~I ed _ Does Not Reside (Not Vaparlt) xNo Answer on _~_at • / ~ (p ~ at ~ ~//~' '_` Service Refused , - ~~~a ` `O ~ ~' Other: 5 ~.~' S rn to and sub c d bef this ay f ,2 Notary: f ~ ~~ V 3,,iAN`."~E~l.S o '~ 1 ~t rah° f (lrii ~ .».+..n.a -~', 7 By: ~T~ORNEY 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 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 83921 Zachary J. Jones, Esq., Id. No. 310721 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 X `_~~-' ,Y~ 1'"~ ~„~P 1 ~~ ~~"~j PLAINTIFF AURORA LOAN SERVICES, LLC. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 264602 DEFENDANT DARRYL J. RYAN VICTORIA S. RYAN SERVE VICTORIA S. RYAN AT: 2050 DANBURY DR ROCKWALL, TX 75032-7277 SERVED o~~ By: Notary: .P~" `' ~.` t . JAhi 4JELt M _~ , ~` ! ~,~ r_,~;r~~mission Expites /~ ~;rtober 02, 2615 Mario J. Hanyon, Esq., Id. No. 203993 G Andrew J. Marley, Esq., Id. No. 312314 ~~ t Robert W. Cusick, Esq., Id. No. 80193 ~~ ` John M. Kolesmk, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 8392 Zachary J. Jones, Esq., Id. No. 310721 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Served and made known to VICTORIA S. RYAN, Defendant on the _ day of , 20 _, at o'clock _. M., at , in the manner described below: 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: Description: Age Height .Weight Race Sex Other I, , a competent adult, being duly sworn according to law, depose and state 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. Sworn to and subscribed before me this day of , 20_. Notary: By: NOT SERVED On the ~ day of ~_, 20~, at ~G'cloc _. M., Defendant NOT FOUND because: _ Vacant Does Not Exist _ Moved _ Does Not Reside (Not Vacant) X No Answer on ~l~at S: Is'~ ` at 7~ k ~/~S'~ 'L~Sp _ Service Refused ~~f //~ /" Other: V/~~ Jr', yQ 11m "' Swo to and s ibed < ._~ r, to ` . t' b e this ay Q ~ VvtClu~- SERVICE TEAM/ lxh COURT NO.: 11-9329-CIVIL TYPE OF ACTION XX Notice of Sheriff s Sale SALE DATE: September 5, 2012 ~jo~ Gr~sc~(,c. ~onuc. ATTORNEY FOR PLAINTIFF ll~.~ ~~ YlO{ ~ r ~` ~ Lawrence T. Phelan, Esq., Id. No. 32227 N - Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 /~~ Michele 1vI. 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. 946 Courtenay R. Dunn, Esq., Id. No. 206779 , l Allison F. Wells, Esq., Id. No. 309519 Melissa J. Cantwell, Esq., Id. No. 308912 ~ ~ ~ ~ v S i~ °~(' EXHIBIT "B" r AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 264602 Attorney Firm: Phelan, Hallman & Schmieg, LLP Subject: Darryl J. Ryan & Victoria S. Ryan Property Address: 504 Charles Street, Shippensburg, PA 17257 Possible Mailing Address: 2050 Danbury Drive, Rockwall, TX 75032 I. CREDIT Il`?FORMATION A. SOCT.AI., SECURITY NUMBF..R Our search verified the following information to be true and correct Darryl J. Ryan -xxx-xx-5447 Victoria S. Ryan -xxx-xx-6352 B. EMPLOYMENT SEARCH Darryl J. Ryan & Victoria S. Ryan - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Darryl J. Ryan & Victoria S. Ryan reside(s) a :110 Fairway Drive, Carlisle, PA 1.701.5. II. INQUIRY OP TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had. no listing for Darryl Ryan & Victoria S. Ryan, however did provide a listing for Anderson O. Edey at: 5i Charles Street, Shippensburg, PA 17257. On 07-02-12 our office made several telephone calls to the phone number (77.7) 300-3318 and received the followinng informaticm: answering machine. B. On 07-02-12 om• office searched directory assistance databases, which had no phor number for Darryl ). 1Zyan & Victoria S. Ryan. iIt. INQUIRY OF NEIGHBOI:S On 07-02-12 our offire made several phone calls in an attempt to contact Chenin N. Holloway (717) 530-5069, 509 Charles Street, Shippensburg, PA "17257: answering machine. On 07-02-12 our office made several phone calls in an attempt to contact William Y, Junior (717) 300-3361, 514 Charles Street, Shippenshu.zg, I'A 17257: answering machine. On 07-02-12 our office made several phone calls in an attempt to contact I-Ierbert E. Hays Jr. {717) 532-2991, 515 Charles Street, Shippensburg, PA 17257: answering machine. On 07-02-1.2 our office made several phone calls in an attempt to contact Cynthia A. Carmichael (972) 722-4982, 2070 Danbury Drive, Rockwall, TX 75032: no answer. ti On 07-02-12 our office made a phone call in an attempt to contact Amy Nix (214} 3786, 2090 Danbury Drive, Rockwall, TX 75032: not in service. On 07-02-12 our office made several phone calls in an attempt to contact Barbara A. Martinez (469) 338-5788, 2091 Danbury Drive, Rockwall, TX 75032: answering machine. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 07-02-12 we reviewed the National Address database and found the following information: Darryl J. Ryan & Victoria S. Ryan - 2050 Danbury Drive, Rockwall, TX 75032. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: 2050 Danbury Drive, Rockwall, TX 75032. V. OTHER INQUIRIES A. DEATH RECORDS As of 07-02-12 Vital Records and all public databases have no death record on file Darryl J. Ryan & Victoria S. Ryan. VI. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Darryl J. Ryan -1967 Victoria S. Ryan -1970 B. A.K.A. Darryl Victo Ryan Victoria G. Smith * Our accessible databases have been checked and cross-referenced for the ab named individual(s). * Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of knowledge, information and belief and that this affidavit of investigation. is made subject the penalties of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities. r'" s. ~,} Y..., t ~C rJ The above information is obtained from available public records and we are only liable for the cost of the affidavit. EXHIBTT "C" Name attd Phelan Hallitin dt Schmie0, LLP Addteas ~ 1617 lFK Bottbvacd, Suite 1400 Of Sender Oae Pam C,eoter Pba 1763hd.6d~i. P~ tO11M LXH Line Articb Ntmber Naau of - - - - - ud Poat OfDoe Addnaa 1 •••• DARRYL J. RYAN 50.45 o w 504 CHARLES STREET ~ ~~ SHIPPENSBURG PA 17257-2118 ~ z •••• DARRYL J. RYAN se.4s ~ ®; 2050 DANBURY DRIVE ~ ROCKW TX 75032-7277 ~ ' 3 •"• VICTORIA 3. RYAN SO.IS N 504 CgAgi.IiA $~ ~ ~T 3HIPPENS~BURC PA 17257 2118 ^' ° 00 VICTORIA S. RYAN 2050 DANBURY DRIVE ~~ 5 ROCKWAL TX 75032-7277 li ~~ -- s O' fp s a RE: DARRYL J. RYAN CUMBERLAND TEAM 4 P85'M 26x602 1 of 1 4i.76 d art Po~ser~Per(Hred 7L dwlee ngeYedatl ngredrd 71r pgehie Pieow Herd by 9.eder lleived etlW Osier Rsiauf8-ice) lorlb neorY~tYads~Yibim~rY ~drBgwtilYi',io~rino~wYw Y~we~Y pr l~rM~relrtdalaM~/~eoaoa'Maeteir~igP4'~~Yy~rrYtl iStae. ttr..i.~w~ib'Ie.wr,ataolearri+••+••4e.~wdsw+•+w..e.. arue.roie w.r aoo aru.a ani arliiYlesd LXH NOS CONCURRENCE CODE 1016 r~ `~ o~, ~O Z 7 2. ~~ L~ 264602 Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#:215-568-7616 E-mail lily.hainey@fedphe.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania and New J July 26, 2012 DARRYLJ.RYAN 2050 DANBURY DRIVE ROCKWALL, TX 75032-7277 RE: AURORA LOAN SERVICES, LLC. v. DARRYL J. RYAN and VICTORIA S. RYAN Premises Address: 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 CUMBERLAND County, No. 11-9329-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by August 2, 2012. hould you have any further questions or concerns, please do not hesitate to contact me. ,, please be guided accordingly. ,Y 1-1A1NEY, Legal Assistant Phelan, Hallinan &Schmieg LLP Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail lily.hainey@fedphe.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania and New Jers~ July 26, 2012 DARRYLJ.RYAN 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 RE: AURORA LOAN SERVICES, LLC. v. DARRYL J. RYAN and VICTORIA S. RYAN Premises Address: 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 CUMBERLAND County, No. 11-9329-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by August 2, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. ae; please be guided accordingly. ~,,' HAINhY,l~egal Assistant for helan, Hallinan &Schmieg LLP Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#:215-568-7616 E-mail lily.hainey@fedphe.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania and New Jersey July 26, 2012 VICTORIA S. RYAN 504 CHARLES STREET SHIPPENSBURG, PA 17257-2118 RE: AURORA LOAN SERVICES, LLC. v. DARRYL J. RYAN and VICTORIA S. RYAN Premises Address: 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 CUMBERLAND County, No. 11-9329-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by August 2, 2012. Auld you have any further questions or concerns, please do not hesitate to contact me. please be guided accordingly. yours, .... . , ..._o... . for 'helan; Hallinan &Schmieg LLP Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevazd, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail lily.hainey@fedphe.com LILY HAINEY, Legal Assistant, Ext. 1401 Representing Lenders in Service Department Pennsylvania and New J July 26, 2012 VICTORIA S. RYAN 2050 DANBURY DRIVE ROCKWALL, TX 75032-7277 RE: AURORA LOAN SERVICES, LLC. v. DARRYL J. RYAN and VICTORIA S. RYAN Premises Address: 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 CUMBERLAND County, No. 11-9329-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by August 2, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. se, please be guided accordingly. ery tr}iyy yours, ~1EY, Legal Assistant Hallinan &Schmieg LLP )-0FFICE Yi,i I~' ,0T?-ION0TAWt- 4 5 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff 7 A?' 3 ??' Allison F. Wells, Esq., Id. No.309519 'UMBERLANU COUNTY 1617 JFK Boulevard, Suite 1400 PENNSYLVANIA One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AURORA LOAN SERVICES, LLC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. DARRYL J. RYAN VICTORIA S. RYAN Defendant(s) CIVIL DIVISION No.: 11-9329-CIVIL 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 Certifi _ eturn Receipt stamped by the U.S. Postal Service is attached hereto E_ Allison F e wire Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 264602 oo (A A W W u a ? I I ' ti• :? x• ? ? ? x• :r x 2 .v ? C 00 C ) l y M 7 cn O C .? rc cr Jy' .Z. + + 6n "S Q G, a c?'i M C r ` ` r~•' r C rig tJ t7 + O, vroi ?;• b w d ? ?} x _ > co n -r oc .141 0 er = ; F, n??' prw r GO ? w r" 00 K > x , ' ' « cl t > co d c am ? c 00 VO h y y 00 T U x 1 2 r ? ? 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U; s'b r 2. x U) N o. 0 N Y N G N ?i eo AT C r'' +r A ..-.'~"~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AURORA LOAl'~i SERVICES, LLC. CIVIL DIVISION Plaintiff ~ t;., `j vs. _ NO. 11-9329-CIVI `-`:~ f:~;, ~~ .,.. DARRYL J. RYAN ~ ~ -- ~ ° ~~t x VICTORIA S. RYAN ~ ~'' ° ~'' ~~ r : - ~~ ~,~, - ~ ~~ Defendants ~c~a ~~ F-> ~~~`, ORDER ~ cm;; ~. ~ ~ ' ~n ,, AND NOW, this _ ~s'~L day of (.,~, U~,v~ , 2012, after consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is permitted on Defendants DARRYL J. RYAN and VICTORIA S. RYAN by: / REGULAR MAIL TO, DARRYL J. RYAN and VICTORIA S. RYAN at 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118, 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277, SERVICE BY MAIL IS COMPLETE UPON THE DATE OF MAILING CERTIFIED MAIL TO, DARRYL J. RYAN and VICTORIA S. RYAN at 504 CHARLES STREET, SHIPPENSBURG, PA 17257- 2118, 2050 DANBURY DRIVE, ROCKWALL, TX 75032-7277 , SERVICE BY MAIL IS COMPLETE UPON THE DATE OF MAILING / POSTING 504 CHARLES STREET, SHIPPENSBURG, PA 17257- 2118 / PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). BY THE COURT: . t~ J. PHS # 264602 /CC PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 DARRYL J. RYAN, and VICTORIA S. RYAN 504 CHARLES STREET, SHIPPENSBURG, PA 17257-2118 Campy ,,,~. /Pd ~/~G/~d ,~~~ ~: ~.i~-G~ ~ 1C Phelan Hallinan & Schmieg, LLP Attorney For Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ~~ 6 ~ ~~1~ 29 I~e~ 10~ d5 ui1hE8~RLAPiD COUNTY °~NN5YL N1A AURORA LOAN SERVICES, LLC. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County DARRYLJ•RYAN VICTORIA S. RYAN No. 11-9329-CIVIL Defendant PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute NATIONSTAR MORTGAGE, LLC as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: NATIONSTAR MORTGAGE, LLC is the current holder of the mortgage by virtue of that certain Assignment of Mortgage, which Assignment has been executed and sent for recording in CUMBERLAND County on or about 08/15/2012 Kindly amend the information on the docket accordingly. Date: _ F. ., Id. No.309519 Att rney laintiff PHS # 264602 p,~u~ ~q.S c~~~ ,~~t a~ )~ Q ~7/y 99~1y Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff AURORA LOAN SERVICES, LLC. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County DARRYL J. RYAN VICTORIA S. RYAN No. 11-9329-CIVIL Defendant PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of NATIONST. MORTGAGE, LLC, located 350 HIGHLAND DRNE LEWISVILLE, TX 75067 Date: PHELAN HALLINAN ~', LLP By: _ s, , Id. No.309519 Atto r Plaintiff PHS # 264602 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of NATIONSTAR MORTGAGE, LLC. Date: PHELAN HALLI IEG, LLP B• ' n F. ells, ., Id. No.309519 Attorney for Plaintiff PHS # 264602 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. Attorney For Plaintiff Plaintiff Court of Common Pleas vs Civil Division DARRYL J. RYAN CUMBERLAND County VICTORIA S. RYAN Defendant No. 11-9329-CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe to mark judgment to NATIONSTAR MORTGAGE, LLC and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: DARRYLJ.RYAN VICTORIA S. RYAN 110 FAIRWAY DRIVE CARLIS~LjE, PA 17015-9365 Date: '" Y~ ' on Well s . No.309519 Attorney for Plaintiff PHS # 264602