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Home My WebLink About11-9397UDREN LAW OFFICES P.C. BY: MARK J. UDREN, SQUIRE - ID #04302 STUART WINNEG, ESQ UIRE - ID #45362 LORRAINE DOYLE, ES QUIRE - ID #34576 ALAN M. MINATO, ESQ UIRE - ID #75860 SHERRI J. BRAUNSTEI , ESQUIRE - ID #90675 DANIEL S. SIEDMAN, I HEATHER RILOFF, ES PAIGE M. BELLING, E', LEE SCHOTTENFEL% HARRY B. REESE, ESQ WOODCREST CORPOI 111 WOODCREST ROA CHERRY HILL, NJ 0801 856-669-5400 pleadingsr Quicken Loans Inc. C/O Quicken Loans, Inc, 1050 Woodward Avenue, Detroit, MI 48226 Plaintiff V. DENNIS A. TRIMMER 29 WATSON DRIVE CARLISLE, PA 17015 Defendant(s) ATTORNEY FOR PLAINTIFF - ID #306534 UIRE - ID #309906 2UIRE - ID#309091 ;SQUIRE - ID#91654 IRE - ID#310501 &.TE CENTER SUITE 200 -3620 rs ? -+n MW q) M- - n C-) r -10m D -..t C3 x 'K ? 7r .? C'1'7'i I7'h ? 4 0 fi °r? rt - Ul COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 1 I 939 1 01-Vi( COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case ay proceed without you and a judgment may be entered against you by the Court without fort er notice for any money claimed in the Complaint or for any other claim or relief requested y the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE T IS 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 P OVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT 1-76 7y MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a ust4 en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, u?ted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace fal a ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en form escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que i usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requier4iedades usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus u otros derechos importantes para usted. LLEVE ESTA DEMAN A A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TI NE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCU NTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR A ISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 II NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the deb It is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any p?rtion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period! we will provide you with the name and address of the original creditor if different from ?he current creditor. If you notify us in wjriting within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it tol you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed III to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: ,II Assignor: Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for Quicken Loans, Inc. Assignee: Quicken Loans Inc. Date of Assignment: Recorded Date: Book/lnstrument Page: 2. Upon information and belief Defendant(s) and/or their predecessor: Dennis A. Trimmer (hereinafter "Defendants"), are the owners of property located at 29 Watson Drive, Carlisle, PA 17015, by virtue of Deed dated 07/08/2010 and recorded 08/12/2010 in Official Records Book Instrument # 201022220 at Page n/a of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property") 3. On 07/23/2010, Defendant(s) and/or their predecessor: DENNIS A. TRIMMER promised to pay to the order of Quicken Loans, Inc, the principal sum of $ 278,400.00 p?yable with interest thereon provided in the Note. 4. By Mortgage dated O/123/2010, Defendant(s) and/or their predecessor: DENNIS A. TRIMMER to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely) as a nominee for Quicken Loans, Inc., the Property which is the subject of thi action. The Mortgage was recorded on 08/12/2010 in Official Records Boo, 201022221 at Page n/a . Said Mortgage is incorporated herein by referenced inl accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 05/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after no4e, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as ollows: (a) By failing or (refusing to pay the installments of principal and interest when due in the amounts Indicated below; (b) By failing or, refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal. Balance $274,866.07 Accumulated interest $5,294.96 Accumulated Late Charges $128.94 Escrow Deficit/ Reserve) $626.15 Suspense Balance $-134.81 Corporate Advanc e $215.00 Attorney Fees $1,300.00 Title Report $325.00 Grand Total $282,621.31 The above figures are calculated as of 10/06/2011: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 3.75000 %. The per diem interest accruing on this debt is $28.23 and tat sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $64.47. I? 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage, The Permsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $282,621.31 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: ... C.>> rt a ci aicOrnan, FSquire PA, 1C> ikJG534 UDREN LAW OFFICES BY: MARK J. UDREN, F STUART WINNEG, ES( LORRAINE DOYLE, ES ALAN M. MINATO, ES( SHERRI J. BRAUNSTEI DANIEL S. SIEDMAN, I HEATHER RILOFF, ES PAIGE M. BELLING, E! LEE SCHOTTENFELD, HARRY B. REESE, ESQ WOODCREST CORPOI 111 WOODCREST ROA CHERRY HILL, NJ 0801 856-669-5400 vleadinus Quicken Loans Inc. Plaintiff V. DENNIS A. TRIMMER 29 WATSON DRIVE CARLISLE, PA 17015 Defendant(s) P.C. SQUIRE - ID #04302 UIRE - ID #45362 QUIRE - ID #34576 DIRE - ID #75860 J, ESQUIRE - ID #90675 SQUIRE - ID #306534 )UIRE - ID #309906 QUIRE - ID#309091 ESQUIRE - ID#91654 ARE - ID#310501 ATE CENTER ). SUITE 200 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION The undersigned st#s that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ?Iame: QTR y,,?•r. SiL 1 Title: pL?o1f- Say;c.} l?•?JPr Company: Quicken Loans Inc. MJU #: 11090430 CASE #:111090430-1 di ML IL EXHIBIT A - LEGAL DESCRIPTION Tax Id Nurnber(s):46-08-058406 Land Situated in the Township of West Pennsboro in the County of Cumberland in the State of PA ALL THAT CERTAIN PROPER SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMO EALTH OF PENNSYLVANIA, BEING DESCRIBED AS FOLLOWS: All. THAT CERTAIN TRACT OF LAND SITUATE IN EST PENNSBORO TOWNSVP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED W ACCORD CE WITH A PLAN PREPARED BY RODNEY LEE DECKER, R.P.L.S, DATED AUGUST 2, 1994 AND RECORDED IN CUM ERLAND COUNTY, PENNSYLVANIA, PLAN BOOK 72, PAGE 60, BEING LOT NO. 31, PHASE 2 ON PLAN OF CROSS OAD SCHOOL ESTATES. Commonly known as: 29 Wagon Drive, Carlisle, PA 17015 EM18rrA &J"WINOW s? r ???? Am-a-ze 1050 Woodward Ave., Detroit, MI 4$226 Date: August 5, 2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE n 18.69). This Notice cone representatives at the C explain it. You may al., association may be able important legal information. If you have any questions, isumer Credit Counseling Agency may be able to help want to contact an attorney in your area. The local bar help you find a lawyer. uounsenng Agency. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU D RECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE E CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION, INVIEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA OUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCION O ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MOR AGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA E LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S N' S : Dennis A Trimmer PROPERTY ADDRES$:, 29 Watson Drive Carlisle, PA 17015 LOAN ACCT. NO.: 3224404632 ORIGINAL LENDER: Quicken Loans CURRENT LENDERISERVICER: Quicken Loans HOMED R'S EMERGENCY MORTGAGE A SISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM I FORECLOSURE AND HELP YOU INTAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY ITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET 0 ER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOiUII?SING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. CONSUMER COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the d of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-ti)-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see fo o win pages for specific information about the nature of your default.) If you have tried and are unable to resolve progblem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency rtgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assis ce Program Application with one of the designated consumer credit counseling agencies listed at the end of this otice. Only consumer credit counseling agencies have applications for the program and they will assist you in su g a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or ed within thirty (30) days of your face-to-face meeting. YOU MUST FILE Y UR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OT IE TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YO HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DE D. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to ake a decision after it receives your application. During that time, no foreclosure proceedings will be pursued you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Ho ing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURREN Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONS ERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed ankruptey you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOM MORTGAGE DEFAULT Brine: it un to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 29 Watson Drive, Carlisle, PA, 17015 IS SERIOUSLY IN DEFAULT A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 5 payments @ $1682.01, $ 8,410.05 Late ChargeslAccrued Late Charges Due $ 128.94 Credit from Fort earane pytnt ($1,816,82) TOTAL AMOUNT PA ;T DUE: $6.722.17 (Plus any mortgage payments and late charges which become due during the 30 day period.) B. YOU HAVE FAILED TO TAE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE THE DEFA T --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TO AMOUNT' PAST DUE TO THE LENDER, WHICH IS 56,722.17, PLUS ANY MORTGAGE PAYME AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P meais must made either b cash cashier's check, certified check or money order made savable and sent to: Quicken Loans Inc 20555 Victor Parkway Livonia, MI 48152 II'? You can cure any other default by taking the fallowing action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) N A. IF YOU DO NOT C E THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the tende intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of ' debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installm ts. If full payment of the total amount past due is not made within. THIRTY (30) DAYS, the lender also intends t instruct its attorneys to start legal action to foreclose upon your mortgaged property- W THE MORTGAGE FO SED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings st you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $SflAO. owever, if legal proceedings are started against you, you will have to pay all reasonable attorneys fees actuall incurred by the lender even if they exceed $50.00. Any attorneys fees will be added to the amount you owe th lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY riod, you will not be required to pay attorney's fees, - The lender may also sue you personally for the unpaid principal balance and all other sums due tm er the mortgage. MILT TO CURE T DEFAULT PRIOR TO SHERIFFS SALE - if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at y time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any 1 e or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requiretnis under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to he same position as if you had never defaulted. EARLIEST POSSIB E S S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 4-5 months from the date of this Notice. A notice of the actual to of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will ' crease the longer you wart. You may find out at any time exactly what the required payment or action will be by co ting the lender. Name of Lender: Quicken Address: 20555 Victor Livonia, MI 4 Phone Number: 800-764-0822 Contact Person: Benjamin ASSUMPTION OF MORTGAGE - You may or may not be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. (Please contact toe lender to find out if this option is available to you under your mortgage and note.) YOU MAY ALSO HAVE THE MIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MOR (GAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU URE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAUL MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NO XISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUI INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OT R DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY 71-IE LENDER. I • TO SEEK PROTECTIO UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT CO SELING AGENCIES SERVING YOUR COUNTY *** SEE ATTACHED PAGE(s)... PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Rd. Harrisbirg, PA 17102 717-541-1757 fax-912-731-9589 Community Action Commission of the Capital Region 1514 Derry St_ Harrisburg, PA 17104 717-232-9757 fax-717-234-2227 financial Counseling Services of Franklin 31 West 3`d. St. Waynesboro, PA 17268 717-762-3285 ?rban League ofMetropolitan Harrisbur g 2107 North 6 h Street Harrisburg, PA 17101 I 717-234-5925 fax-717-234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 717-243-3818 fax-717-731-9589 The Pennsylvania Housing Finance Agency can be reached TOLL FREE at 500-342-2397 i:ILED-UFFICF F L, THE PROTHONOTARY UDREN LAW OFFIC: BY: MARK J. UDREP STUART WINNEG, E LORRAINE DOYLE, ALAN M. MINATO, I SHERRI J. BRAUNS] DANIEL S. SIEDMAr HEATHER RILOFF, ] PAIGE M. BELLINO, LEE SCHOTTENFEL HARRY B. REESE, E: WOODCREST CORP 111 WOODCREST R( CHERRY HILL, NJ 0? 856-669-5400 Dleadina S, P.C. ATTORNEY FOR PLAINTM DEC 2 7 AM 9: 4 4 ESQUIRE - ID #04302 QUIRE - ID #45362 CUMBERLAND COUNTY ;SQUIRE - ID #34576 PENNSYLVANIA SQUIRE - ID #75860 :IN, ESQUIRE - ID #90675 ESQUIRE - ID #306534 SQUIRE - ID #309906 :SQUIRE - ID#309091 1, ESQUIRE - ID#91654 QUIRE - ID#310501 IRATE CENTER AD. SUITE 200 Quicken Loans Inc. COURT OF COMMON PLEAS 1050 Woodward Avenue, Detroit, MI CIVIL DIVISION 48226 CUMBERLAND County Plaintiff V. NO. 1- C[ "17 C rv t 1 DENNIS A. TRIMMER' 29 WATSON DRIVE CARLISLE, PA 17015 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; III Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Daniel S. Siedman, Esquire; Heather Riloff, Esquire; Paige M. Bellino, Esquire; Lee Sc?ottenfeld, Esquire; Harry B. Reese, Esquire; on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, C. BY: Esquire Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F IL ED-LFFI?. Er 1, 1-1 y 0- 91-F i r: 2012 JAN 10 PM u 10 C&BERLAW COUNT{ \1 Quicken Loans, Inc. Case Number vs. 2011-9397 Dennis Alan Trimmer SHERIFF'S RETURN OF SERVICE 01/03/2012 05:04 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 3, 2012 at 1704 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dennis Alan Trimmer, by making known unto himself personally, at 29 Watson Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SH L, DEPUTY SHERIFF COST: $34.00 January 05, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ;c, couni;sude Sheriff. Tcv. oso`t. In-, ,UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Quicken Loans Inc. 1050 Woodward Avenue Detroit, MI 48226 Plaintiff V. DENNIS A. TRIMMER 29 WATSON DRIVE CARLISLE, PA 17015 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-9397 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: 7 G -a= rq C0 =m zX C.nr- r- z <t-- D x ?r r a 3 w Cn -_+ ;-rr Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), DENNIS A. TRIMMER; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $274,866.07 Interest Per Complaint $5,294.96 Additional Interest 10/07/2011 02/29/2012 $4,121.58 Late Charges Per Complaint $128.94 Additional Late Charges 10/07/2011 02/29/2012 $515.76 Escrow Per Complaint $626.15 Suspense Balance $-134.81 Corporate Advance $215.00 Attorney Fees $1,300.00 Title Report $325.00 Grand Total $287,258.65 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. AMY GLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: -3 i/ /o't ,u MJU#: 11090430 CASE#: 11090430-1 111 i +llo.so PQ Amt aga0? Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor a??ytt t 1t313?1p "l,?ft40 f( 'P Apr-ie? ?r ?rw ?iFr?iEr Quicken Loans, Inc. Case Number vs. 2011-9397 Dennis Alan Trimmer SHERIFF'S RETURN OF SERVICE 01/03/2012 05:04 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Januanj 3, 2012 at 1704 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dennis Alan Trimmer, by making known unto himself personally, at 29 Watson Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHA U, DEPUTY ,SWA SHERIFF COST: $34.00 January 05, 2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY SO ANSWERS, ?f RON R ANDERSON, SHERIFF (c,) Court,S1xV, Shenff, ieieO% , Inc, UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Quicken Loans Inc. Plaintiff V. DENNIS A. TRIMMER Defendant(s) TO: DENNIS A. TRIMMER 29 WATSON DRIVE CARLISLE, PA 17015 Date of Notice: January 24, 2012 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-9397 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 LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION' ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEB IDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 ST NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. LAW DICES, PC. BY: Plaintiff AMY GLASS, ESQ. PA BAR if 308367 NJ BAR # 13862010 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11090430 CASE#: 11090430-1 Request for Military Status Department of Defense Manpower Data Center "- Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-29-2012 07:04:38 Last First/Middle Begin Date Active Duty Status Active Duty End Date Service S Name Agency TRIMMER DENNIS Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). A 1/1 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 2/29/2012 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:QL2P8QUALG https://www.dmdc.osd.mil/appj/scra/popreport.do 2/29/2012 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Rleadin ,s@,,udren.com COURT OF COMMON PLEAS Quicken Loans Inc. CIVIL DIVISION Cumberland County c Plaintiff 3 V. MORTGAGE FORECLOSURE s- r- Dennis A. Trimmer pr i cn C:) Defendant(s) rr--X r. --4c-) c? NO. 11-9397 •C := -7' xc AFFIDAVIT OF NON-MILITARY SERVICE z» C-- UNDER Pa.R.C.P 76 -' AW THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), DENNIS A. TRIMMER, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MJU#: 11090430 CASE#: 11090430-1 PA BAR # 308367 NJ BAR # 13862010 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings audren.com Quicken Loans Inc. Plaintiff V. DENNIS A. TRIMMER Defendant(s) TO : Dennis A. Trimmer 29 Watson Drive, Carlisle, PA 17015 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-9397 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Judgment by Default ? Money Judgment ? Judgment in Replevin ? Judgment for Possession ? Judgment on Award of Arbitration ? Judgment on Verdict ? Judgment on Court Findings Prothonotamy IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CONTACT: Attorney for Plaintiff Udren Law Offices, P.C. Woodcrest Corporate Center I 1 I Woodcrest Road, Suite 200, Cherry Hill, NJ 08003-3620 Phone: (856) 669-5400 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-9397 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due QUICKEN LOANS INC., Plaintiff (s) From DENNIS A. TRIMMER (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: $287,258.65 L. L.: $.50 Interest from 3/1/12 to Date of Sale 6/6/12 Ongoin g per diem of $28.23 to actual date of sale including if sale is held at a later date ----- $2,766.54 Atty's Comm: % Due Prothy: $2.25 Atty Paid: '$173.50 Other Costs: Plaintiff Paid: Date: 3/1/12 J David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER I I1 WOODCREST ROAD, SUITE 200 CHERRY HILL, JU 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 308367 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s(&,,udren.com Quicken Loans Inc. Plaintiff V. Dennis A. Trimmer Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-9397 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 3/1/2012 to Date of Sale June 6, 2012 Ongoing Per Diem of $28.23 to actual date of sale including if sale is held at a later date (Costs to be added) $ 287.258.65 $ 2,766.54 ? a =rn n?.._ 9 -( c' -<> ca yr C Cn - 0 $a8.-ft PA ATTY $ W 001CES, P.C. ASS, ESQ. # 308367 # 13862010 MJU#: 11090430 CASE#: 11090430-1 y)?, o0 ?,; 3' '00 it g T V SU p,?? L1- 0 048as ?*a7/746 ks OLM 4 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings a*udren.com Quicken Loans Inc. Plaintiff V. Dennis A. Trimmer Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County rnm Z MORTGAGE FORECLOSURE 73 ! CG ? NO. 11-9397 ; C: rk CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: M Act 91 procedures have been fulfilled Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AMY GLASS, ESQ. PA BAR # 308367 NJ B rR 4 1386.":)10 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(&udren.com Quicken Loans Inc. V. Dennis A. Trimmer Plaintiff Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County -v3 ern 710 MORTGAGE FORECLOSURE=:,- A c-; NO. 11-9397! AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 N 4 w -M ti r T-1 -i C3 Quicken Loans Inc., Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 29 Watson Drive, Carlisle, PA 17015 1. Name and address of Owner(s) or reputed Owner(s): Dennis A. Trimmer 29 Watson Drive Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: Dennis A. Trimmer 29 Watson Drive Carlisle, PA 17015 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: Quicken Loans Inc. 1050 Woodward Avenue Detroit, MI 48226 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - 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: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 29 Watson Drive Carlisle, PA 17015 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDRF<-L 0', MJU#: 11090430 CASE#: 11090430-1 AMY CLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s(a)udren.com Quicken Loans Inc. Plaintiff V. DENNIS A. TRIMMER Defendant(s) ATTORNEY FOR PLAINTIFF r PIM COURT OF COMMON PLEAS MD. , CIVIL DIVISION Cumberland County < c.1 ?,. MORTGAGE FORECLOSURE ?j NO. 11-9397 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dennis A. Trimmer 29 Watson Drive Carlisle, PA 17015 Your house (real estate) at 29 Watson Drive, Carlisle, PA 17015 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00 am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $287,258.65, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: I . The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. T 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 LAND SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND IN THE STATE OF PA ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING DESCRIBED AS FOLLOWS: ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED BY RODNEY LEE DECKER, R.P.L.S., DATED AUGUST 2, 1994 AND RECORDED IN CUMBERLAND COUNTY, PENNSYLVANIA, PLAN BOOK 72, PAGE 60, BEING LOT NO. 31, PHASE 2 ON PLAN OF CROSS ROAD SCHOOL ESTATES. COMMONLY KNOWN AS: 29 WATSON DRIVE, CARLISLE, PA 17015 AS DESCRIBED IN MORTGAGE INSTRUMENT NO. 201022221 BEING KNOWN AS: 29 WATSON DRIVE, CARLISLE, PA 17015 PROPERTY ID NO.: 46-08-0587-106 TITLE TO SAID PREMISES IS VESTED IN DENNIS A. TRIMMER, A MARRIED MAN BY DEED FROM DENNIS A. TRIMMER AND AMY S. TRIMMER, HUSBAND AND WIFE DATED 07/08/2010 RECORDED 08/12/2010 IN DEED BOOK INSTRUMENT # 201022220. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s*,udren.com Quicken Loans Inc. Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Dennis A. Trimmer I MORTGAGE FORECLOSURE Defendant(s) ? C=- rn? NO. 11-9397 am 1 Cn r- ;:U (= ? AFFIDAVIT OF LAST KNOWN ADDRESS r- c) UNDER RULE 76 o = `.) The Defendant(s) last known address is as follows: c ` DENNIS A. TRIMMER 29 WATSON DRIVE CARLISLE, PA 17015 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. W OFFICES, P.C. for AMY OLKSS, ESQ. PA BAR # 308367 NJ BAR # 13862010 UDREN LAW OFFICES, P.C. WOODCOST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY DILL, NJ 08003-3620 856-669-5400 leadingscvudren.com Quicken L ans Inc. Plaintiff V. DENNIS AL TRIMMER, Defendant(s) ATTORNEY FOR PLAINTIFF a COURT OF COMMON PLEAS - CIVIL DIVISION :z 7) Cumberland County ? MORTGAGE FORECLOSURE , NO. 11-9397 AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on! the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: BY:--I- Attorneys W OFFICES, P.C. v PAIGE ^^ ??! I INO, ESQUIRE PA iU .109091 MJU#: 11090430 CASE#: 11090430-1 UDREN LAW OFFICES, P.C. WOODCR EST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY MILL, NJ 08003-3620 Plaintiff V. DENNIS Al.. TRIMMER; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 11-9397 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): DENNIS A. TRIMMER; PROPERTY: 29 Watson Drive, Carlisle, PA 17015 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/06/2012 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 11090430 CASE#: 11090430-1 EXHIBIT A v-0 CD Cl) O D? V ? V D w 0 co 4 CA) C c Q (D v o &a 3 0 3 'v CL f Oex O d 0 0 r c i t7? A _. W N . p co OD V p (A A W N ? 0 2 a mam ?o ?i (b D a N m c O co R N ?o QP Z3 -' 0 0"C T 0 D0C 4" ? m$ o ?? ?? ? o R 3 Z?: Z mc18 m CD a Z=?M 0 D c) ?o Ac ? n- r?n?o "n Mc M MrZ?yi0 m D CC AA m? M> 0-f o ?? r. w i MM cmn 4m e) n U DC m co --> $ o m 0 m r D !" pp ?1 Z 0 -1 m 4°CZ7 DX g M ;a 3 wrn °w ? Q ? I n w 1300c1300c) 3 c aw m )in+-f2?519?16 0 0 1.680- ??f ? 0 4,.;3 0!2 0 12 08003 Mailed From S POSTAGE - U 3 9g d m? ??f - rA 35 a r a c s 4 %CL ? off' ORE ?0g g ?j 50 c? - c (?pTp x l as• - C r_T O a o E C 3 -n ?o B= ? ? $ ? c oo ' ' EXHIBIT A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Quicken Loans, Inc, vs. Dennis Alan Trimmer ?4??rttp at t?tt?r?Grr?_i?`? OFFICE OF THE $t! ERIFF Case Number 2011-9397 SHERIFF'S RETURN OF SERVICE 03/21/2012 03:24 PM - Deputy Valerie Weary, 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 29 Watson Drive, West Pennsboro Township, Carlisle, PA 17013, Cumberland County. 03/21/2012 07:30 PM - Deputy Valerie Weary, 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 nicole adams - girl friend, who accepted as "Adult Person in Charge" for Dennis Alan Trimmer at 29 Watson Drive, West Pennsboro Township, Carlisle, PA 17013, Cumberland County. SHERIFF COST: $9015.20 April 13, 2012 SO ANSWERS, RON ' R ANDERSON, SHERIFF EXHIBIT B (,C) CountySuite Shetift. Teleosoit, uic. __ _ _ _ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ft. '' 1 °, r x. ~/. ~ i , ,tilt, -, ~ i 1. ~ ~~r, i~tC;' ~:~f7,'~'~ ~G~~~ ~'r`~`,~il~~A Quicken Loans, Inc. vs. Dennis Alan Trimmer Case Number. ?_01'1-9397 SHERIFF'S RETURN OF SERVICE 03/21/2012 03:24 PM -Deputy Valerie Weary, 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 29 Watson Drive, West Pennsboro Township, Carlisle, PA 17013, Cumberland County. 03/21/2012 07:30 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estatle 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 nicole adams ~- girl friend, who accepted as "Adult Person in Charge" for Dennis Alan Trimmer at 29 Watson Drive, West Pennsboro Township, Carlisle, PA 17013, Cumberland County. 05/02/2012 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/5/2012 08/24/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed"'„ per letter of instruction from Attorney. SHERIFF COST: $725.79 August 24, 2012 SO ANSWERS, )~~ RON ~ R ANDERSON. SHERIFF ~. ~,,, t..c ~ ,. - :, .- ~~ UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ~leadinas~ udren.com Quicken Loans Inc. Plaintiff v. ATTORNEY FOR PLA[NTIFF COURT OF COMMON PLEAS CNIL DIVISION Cumberland County Dennis A. Trimmer Defendant(s) MORTGAGE FORECLOSURE NO. 11-9397 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Quicken Loans Inc., Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 29 Watson Drive, Carlisle, PA 17015 1. Name and address of Owner(s) or reputed Owner(s): Dennis A. Trimmer 29 Watson Drive Carlisle, PA 1.7015 2. Name and address of Defendant(s) in the judgment: Dennis A. Trimmer 29 Watson Drive Carlisle, PA 17015 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: Quicken Loans Inc. 1050 Woodward Avenue Detroit, MI 48226 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 29 Watson Drive Carlisle, PA 17015 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale; Federal Tax Lien Holders -None Condo/Homeowners Association -None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: ~~.~ ~~~~~ ~ ~~ UDRE~ L VV'O~' ES, PAC'. ~~ BYI:' /- for Plaintiff MJti#: 11090430 CASE#: 11090430-1 AMY C3LASS, ESQ. PA BAR # 30836'7 ?tiT~ AF R #_ ; ? 8~~n ~ 0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin~s(a~udren.com __ ATTORNEY FOR PLAINTIFF Quicken Loans Inc. COURT OF COMMON PLEAS Plaintiff CNIL DIVISION ~~, Cumberland County DENNIS A. TRIMMER MORTGAGE FORECLOSURE. Defendant(s) NO. 11-9397 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dennis A. Trimmer 29 Watson Drive Carlisle, PA 17015 Your house (real estate) at 29 Watson Drive, Carlisle, PA 17015 is scheduled to be sold at the Sheriffs Sale on June 6, 2012 at 10:00 am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment''. of $287.258.65, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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 cancelled if you pay to the mortgagee the back payment, late charges. costs and re;asonablr attorney's fees. To find out how much you must pay, you may call: (8561 669-5400. 2. You maybe 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 <;ause. ~. ~'ou 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You rriay fmd out the price bid by calling 856-669-5400. 2. You maybe 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 856-669-5400. 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 maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 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 LAV1'YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 LAND SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND IN THE STATE OF PA ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF WEST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING DESCRIBED AS FOLLOWS: ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN PREPARED BY RODNEY LEE DECKER, R.P.L.S., DATED AUGUST 2, 1994 AND RECORDED IN CUMBERLAND COUNTY, PENNSYLVANIA, PLAN BOOK 72, PAGE 60, BEING LOT NO. 31, PHASE 2 ON PLAN OF CROSS ROAD SCHOOL ESTATES. COMMONLY KNOWN AS: 29 WATSON DRIVE, CARLISLE, PA 17015 AS DESCRIBED 1N MORTGAGE INSTRUMENT NO. 201022221 BEING KNOWN AS: 29 WATSON DRIVE, CARLISLE, PA 17015 PROPERTY ID NO.: 46-08-0587-106 TITLE TO SAID PREMISES IS VESTED IN DENNIS A. TRIMMER, A MARRIED MAN BY DEED FROM DENNIS A. TRIMMER AND AMY S. TRIMMER, HUSBAND AND WIFE DATED 07/08/2010 RECORDED 08/12/2010 IN DEED BOOK INSTRUMENT # 201022220. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111. WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin~s(d~udren.com _____..__ _ Quicken Loans Inc. 'COURT OF COMMON PLEAS Plaintiff ~ CIVIL DIVISION ~,. Cumberland County DENNIS A. TRIMMER i MORTGAGE FORECLOSURE Defendant(s) NO. 11-9397 SHORT DESCRIPTION FOR ADVERTISING ALL THAT CERTAIN LOT OF LAND SITUATE IN TOWNSHIP OF WEST PENNSBORO, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 29 Watson Drive, Carlisle, PA 17015 PARCEL NUMBER: 46-08-0587-106 IMPROVEMENTS: Residential Property P.C. tto~ey for laintiff SS, ESQ. PA BAR # 308367 NJ BAR # 13862010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-9397 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LA,W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due QUICKEN LOANS INC., Plaintiff (s) From DENNIS A. TRIMMER (]) 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: $287,258.65 L.L.: $.50 Interest from 3/1/12 to Date of Sale 6/6/12 Ongoing per diem of $28.23 to actual date of sale including if sale is held at a later date ----- $2,766.54 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $173.50 Other Costs: Plaintiff Paid: Date: 3/1/12 ~ ~-\ ~ ~L~~:~'s---` .~-l/./1 David D. Buell, Prothono (Seal) y: Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, JU 08003-3620 Attorney for: PLAINTIFF TRUE COPY FROM RECOF~D In Testimony , I here unto set m~ hand and the seal of said at p~ This ~_ ~ ~~~ (C. ~ P ry ~~ Te I eph one : 856-669-5400 Supreme Court ID No. 308367 On March 15, 2012 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, known and numbered 29 Watson Drive, Carlisle, PA 17013 more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 15, 2012 ,~ By: For Claudia Brewbaker, Real Estate Coordinator Writ No. 2011-9397 Civil Term Quicken Loans, Inc. vs. Dennis A. Trimmer Atty.: Amy Glass ALL that certain lot of land situ- ate in Township of West Pennsboro, Cumberland County, Pennsylvania: BEING KNOWN AS 29 Watson Drive, Carlisle, PA 17015. PARCEL NUMBER: 46-08-0587- 106. IMPROVEMENTS: Residential Property. AMY GLASS, ESQ. PA BAR # 308367 NJBAR# 13862010 UDREN LAW OFFICE Attorneys for Plaintiff 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 Laviv Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 27, May 4, and May 11, 2012 -~ Affiant further deposes that he is authorized to verify this statement by the Cum'berland' 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 ----~ isa arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this day of Ma..~12 1r' r~ ~~ Notary / ° ~°`°- NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2020 Technalog~i Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he ~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot 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 fihe Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and Mate aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1$th, 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 $tatement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recordiing of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/27/12 ~ti~j ~ Term 05/04/12 ~'"~ ~ 05/11/12 ALI, THAT ~N LGT OF IAND ......... ... ....... `. SITUATE IN T(1WNSj$p OF WEST r'~ / . . PENN3BUR0, CBRLAND COt1N1'Y,pENNSYLDAi~t(A: Sworn to a~ scribe efor e this.Z2of May, 2012 A.D. BEIIVG KNOWN AS 29 Watson Drive, / __ _ ' /~° Carlisle, PA 17015 ~~. -_~ , ? PA1tCEL 1w1UMBBR: 46-08587-106 ~' ~,~,.,(,1., f ~ ~ ` 4 ,_ ~ ', +, .~e_ '. ~~ R~aadentlalProperty c=-- --_ Notary Public _ for Plaintili' GLASS, ESQ, A BAR #~ 308367 N1BAR~ 13862010 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Public lower Paxton Twp., Dauphin County MY Commission Expires Nov. 26, 2015 J MEMBER, PENNSYLVANJA ASSOCIATION OF NOTARIES .- ,.. . _:... UDREN LAW OFFICES, P.C. ~ ~ ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER , ~ ~ ; ,' ~ ? J] ~~' ~ ~" 111 WOODCREST ROAD, SUITE 200 .:~ CHERRY HILL, NJ 08003-3620 ~"Y '. ~~~'+ € ' ~ ~ ~ ~' ~ ~~ ~ ` 856-669-5400 , `; ~~'. E ~`i°g.~_l~ ~~ pleadin s udren.com _ ______ _ Quicken Loans Inc. ~ COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION ~• Cumberland County DENNIS A. TRIMMER; et al MORTGAGE FORECLOSURE Defendant(s) NO. 11-9397 PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: `'~ ~ ~ ~~ "~ UDREN LAW OFFICES, P.C. Attorney for Plaintiff ~'~~f ~~ '~6 ~~ MJU#: 11090430 CASE#: 11090430-1