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HomeMy WebLinkAbout12-0271t to PARKER McCAY P.A. By: Katherine Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. C--a C ,, C= COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment by Default in favor of Plaintiff, Consumer Solution, LLC and against Defendants, Patricia A. Kuhn and Mervin Kuhn, for failure to file an Answer on Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: I(,, Go PA ATTV 3'7y701 ?, x19 13/ . As set forth in Complaint $78,763.91 Interest $17.25 per diem 12/31/2011 to 02/29/2012) $1,052.25 Corporate Advance $2,035.92 TOTAL $81,852.08 Together with interest at the contract rate after the date of judgment, and costs. I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT IN MORTGAGE FORECLOSURE AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT IN MORTGAGE FORECLOSURE. I hereby certify that the attached Notices of Intention to Take Default were forwarded to Defendants more than ten (10) days ago. PARKER McCAY P.A. Dated: February 29, 2012 By: Katherine Knowlton, Esquire Attorney for Plaintiff Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 February 17, 2012 File No. 14569-11-03414 Via Certirted Mail, R.R.R. & Rezular Mail Patricia A Kuhn . ' ' • 16 Peach Orchard Road 7146 4006 4111 4481 5736 Newville, PA 17241 R0912 - Re: Consumer Solutions, LLC, ads Kuhn, Patricia A. and Mervin January Term 2012; Case No. 2012-00271 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Very truly yours, MW/se Enclosures File No. 14569-11-03414 PARKER McCAY P.A. By: Mary Wu, Esquire Attorney ID# 209171 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attornevs for Plaintiff Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-271 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 CIVIL ACTION MORTAGE FORECLOSURE Defendants. NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 DATE OF NOTICE: February 17, 2012 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE: YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE- A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. PARKER Mc P.A. Dated: February 17, 2012 By: Mary Wu squire Attorne or Plaintiff VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL 7196 9008 9111 4461 S736 TO: Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 SENDER: SE REFERENCE: 14871-11-03414 10 days RETURN Postage RECEIPT Certified Fee { SERVICE Retum Receipt Fee .0 Restricted Delivery 0.00 i Total Postage & Fees US Postal Service® i v n? , POSTMARKa /yf Receipt for '" FEB t 2012 f Certified Maii No Insurance Coverage Provided Do Not Use for International MaA x p l CD rn Z) .. ... w ?. a a- tv EL c .. 0 a. d 2f=- I Lla a :a a 0 US PO STAGE $ 01 15 . Mai From 08054 1 ATTORNEYS AT LAW February 17, 2012 Foreclosure/Bankruptcy Dept. P: 856-810-5815 F: 856-596-3427 . - 5143 Jo. 14569-11-03414 Via Certified Mail, R R R& Regular w e el 11 4 01 Mervin Kuhn 1196 9?vO 16 Peach Orchard Road Newville, PA 17241 Re: Consumer Solutions LLC ads Kuhn Patricia A. and Mervin January Term 2012; Case No. 2012-00271 Dear Sir/Madam: Enclosed herewith please find a Notice of Intention to file Praecipe for Entry of Default Judgment. If you should have any questions, please do not hesitate to contact our office. THIS LETTER IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Ve y urs, ARY MW/se Enclosures File No. 14569-11-03414 PARKER McCAY P.A. By: Mary Wu, Esquire Attorney ID# 209171 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attornevs for Plaintiff Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-271 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 CIVIL ACTION MORTAGE FORECLOSURE Defendants. NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 DATE OF NOTICE: February 17, 2012 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE, YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (800) 822-5288 / (717) 243-9400 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. PA C P.A. Dated: February 17, 2012 By: ,Esquire Mary Attorney for Plaintiff VIA CERTIFIED MAIL, R.R.R. AND FIRST CLASS MAIL 7196 9008 9111 4481 5743 TO: Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 SENDER: SE REFERENCE: 14871-11-03414 i RETURN Postage RECEIPT Certified Fee i SERVICE Return Receipt Fee 0.00 Restricted Delivery 0.00 Total Postage & Fees US Postal Service® P OSTMAF Receipt for , Certifies! !IT" 0 FEB 17 2012 ' No Insurance Covsrap Provicled Do Not Use for bftmoftnsd MaN e f a 0 0 W co C n DD CD :3' --a N i-++ Y '- o w n. 3 ? . 3 "o ,d gq 0 o ?w;? o n n °?. CD x y ~- oa pl 'Y m a t'" n s ^? a N ? ? .m a SO 3 b N b N a m m - m m n CD c N ® ?n 'US POSTAGE .......... . $ 01.15 Mailed rom 08054 031A 0005180085 PARKER McCAY P.A. By: Katherine Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATION I, Katherine Knowlton, Esquire, do hereby certify that the Defendants, Patricia A. Kuhn and Mervin Kuhn, were served with the Complaint in Mortgage Foreclosure in this action, by the Cumberland County Sheriff on January 24, 2012. A true and correct copy of the Cumberland County Sheriffs Return of Service is attached hereto as Exhibit "A". PARKER McCAY P.A. Dated: February 29, 2012 By: Katherine Knowlton, Esquire Attorney for Plaintiff EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF" of THE SHERIFF Consumer Solutions, LLC vs. Patricia A. Kuhn (et al.) Case Number 2012-271 SHERIFF'S RETURN OF SERVICE 01/24/2012 07:30 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 24, 2012 at 1930 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit:-Patneia n, by making known unto herself personally, at 15, Peach Orchard, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY 01/24/2012 07:30 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 24, 2012 at 1930 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mervin Kuhn, by making known unto himself personally, at 16 Peach Orchard,-Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $56.00 January 26, 2012 STEPHEN BENDER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ;c Count, Suite Sheriff. Te eosoft. inc. PARKER McCAY P.A. By: Katherine Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 Plaintiff, V. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 CIVIL ACTION MORTGAGE FORECLOSURE Defendants. VERIFICATION OF NON-MILITARY SERVICE I, Katherine Knowlton, Esquire, hereby certify that I represent Plaintiff in the above entitled case; that I am authorized to make this Verification on behalf of Plaintiff; that the above- named Defendants, Patricia A. Kuhn and Mervin Kuhn, are over 18 years of age; that the address of the Defendants, Patricia A. Kuhn and Mervin Kuhn, is 16 Peach Orchard Road, Newville, PA 17241; that the occupations of the Defendants, Patricia A. Kuhn and Mervin Kuhn, are unknown; and that the Defendants, Patricia A. Kuhn and Mervin Kuhn, are not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I also certify that the address of the Plaintiff is 8742 Lucent Blvd., Suite 300, Highlands Ranch, CO 80129. I understand that the statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. PARKER McCAY P.A. Dated: February 29, 2012 By: ?--z'. ,?--?-? Katherine Knowlton, Esquire Attorney for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-28-2012 14:05:58 Last Name First[Middle Begin Date Active Duty Status Active Duty End Date Service Agency KUHN MERVIN 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). y6t 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 littp://www.defenselink.millfag/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 2/28/2012 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:329S49BAN6 https://www.dmdc.osd.mil/appj/scra/popreport.do 2/28/2012 Request for Military Status Department of Defense Manpower Data Center 4D Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-28-2012 14:08:09 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency KUHN PATRICIA Based on the information you have furnished, the DMDC does not possess A 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). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22,209-2593 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 littp://www.defenselink.i-nil/fag/i)is/PC09SLDR.htnil. 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 2/28/2012 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:V4190SF3M https://www.dmdc.osd.mil/appj/scra/popreport.do 2/28/2012 PARKER McCAY P.A. By: Katherine Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE Defendants. NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that To: Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 a JUDGMENT BY DEFAULT has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY KATHERINE KNOWLTON, AT TELEPHONE NO. (856) 810-5815 a NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Cumberland County, Prothonotary PARKER McCAY P.A. By: Katherine Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE Defendants. NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that To: Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 a JUDGMENT BY DEFAULT has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY KATHERINE KNOWLTON, AT TELEPHONE NO. (856) 810-5815 NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT: WE ARE ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Cumberland County, Prothonotary WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-271 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSUMER SOLUTIONS, LLC Plaintiff (s) From PATRICIA A. KUHN AND MERVIN KUHN (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: $81,852.08 L. L.: $.50 Interest from 3/1/12 AT THE PER DIEM RATE OF $17.25 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $207.25 Other Costs: Plaintiff Paid: Date: 4/9/12 Dav=Proth:no (Sea)) - Deputy REQUESTING PARTY: Name: KA'T'HERINE E. KNOWLTON, ESQUIRE Address: PARKER MCCAY P.A. 9000 MIDLANTIC DRIVE, SUITE 300 P.O. BOX 5054 MOUNT LAUREL, NEW JERSEY 08054 Attorney for: PLAINTIFF Telephone: 856-810-5815 Supreme Court ID No. 311713 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY •_x JANUARY TERM 2012 c NO. 12-00271 r ., to r 'jo CIVIL ACTION '^` MORTAGE FORECLOSURE ° c ;- c PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly issue writ of execution in the above matter directed to the Sheriff of Cumberland County. Kindly index this Writ against the Defendants as follows: Patricia A. Kuhn and Mervin Kuhn. Real Property involved: 16 Peach Orchard Road, Newville, PA 17241. Amount due $81,852.08 Interest from 3/1/12 (at the per diem rate of $17.25) $ Costs $ Total $ Katherine E. Knowlton, Esquire Attorney for Plaintiff Date: March 27, 2012 0 ?. QD Mr- l a.spGY ? Sa. 40S a. ?. Sp LL C.N?t 3g?1 ?6 214 a73sa? I ?j f14 b ? 01 No. 12-00271 January Term, 2012 Consumer Solutions, LLC Plaintiff VS Patricia A Kuhn and Mervin Kuhn Defendants PRAECIPE FOR WRIT OF EXECUTION Dated: March 27, 2012 Attorney(s) for Plaintiff(s) PARKER MCCAY P.A. KATHERINE E. KNOWLTON, ESQUIRE 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, New Jersey 08054 (856) 810-5815 Legal Description ALL THAT CERTAIN tract of land situate in Penn Township, Cumberland Cowrty, PMsylvania, morn particularly bounded and described as follows- BEG NNING in an icon pin in the southwest corm of Lot No.1 and the line of lands of Lot No. 4 as shown on the horeindftw refarrod to subdivision plan; thence along Lot No. I Nw& 84 degrees 39 minutes 57 seconds East 175 foet to an iron pin; thwce continuing along said Lot No. 1 South 82 dcgroes 22 minutes 58 seconds East 199.14 feet to an iron pin in the line of Lot No. 4 as shown on the hcroinefter reffecred to subdivision plan; thence along said Lot No. 4 the following courses and distances: South 6 degr= 36 minutes 04 seconds West 146.76 foot to an iron pin; South 99 dgpves 03 minutes 03 xeconds West 176.65 feet to an iron pin; theam by a curve to the right having a radius of 175 foet and a chord bearing of North 48 degrees 8 minutes 30 seconds West a chord length of 237.84 feet to an iron pin at the place of BECONING. CoN TAINWO a total of 1.214 acres and being Lot No. 2 as shown on the laud subdivision for Robert L. Spahr prepared by Carl D. Nett, Professional Land Surveyor dated November 1, 2004 and recorded in Cumberland County Plan Book 90, Page 11. "Ar b2.tr tbuic, aria prarasl Og 3"d and ?? tgesrorreoo situate is tba 'aewwerrrh4M of I NMI COUWW of l?e?ri??tYatwd ? C?MMIIMI?t to and dis?,peeatd W ftx0l ft- Md UV" do "Sib" A& a DMee1 dated ftwow 241. 2CM abed rieoaee1 ' st 94, 2006 AU ft6exleard CM10 tee " b"d !lsob V*2=W 6289 Wave },=, gretat w read amwer" WA & bow % 'L. 040 =A nuncio L. eaweeir, 'b.tr? W"O. 71 1 ice! to a" sstw quad aneedit &"W as matt tesftn As PLIM seserie go, Mspa iY isawwa ? - a 011r a wen 666"U 04 z aUtIn to tba SO-!meet prirmsbip ft-69 fbetb tonsix- Y . fts so boot: poav aba xftbt of MW arersa Lab err. 4 win he *"a rM gloss *ad 1. 1 14 LUGV"&, mss, XM9x ? Is Md stbiU*V Laraat "LOM by zat an. $, 3 sad 4 t= sitw'te-26 t3y i+lt21+0t?t" 7=99D"- 2. Lot Xa. i OMU bawo rib Vi tat oW ems to thO 00-9"t MU b6 diveably gnu "MA M".? 4W OVIOM as L" 76Rt, 1 3. Fee tstle to the saw Witax the W900t PzLV t * r1out 49 MW shisU be VMt ne! L 6t t6. 4. " i. oa y Lot ¦os. 2, b and, 4 ahaU he &G=*ssd bt tts 59-9991 ClObt of MW 08 lags 04 it AM s paeivat M right at WW. S. ft* OnWo of Lot Nw, 3, S 40d 4 nth ahWo paApos?tloilal- to tbo i 0i'vilU eo v4 oast of ndaart*ooW4&, aLiatOaatOi{ aqp'L,# wt awl, Wn, 09 tbo Wo da ai4mp lact."tima ULi& ow Soot PrIve" sight of aw 800094U9 4o t" 3009th s>dd fewmtm" a! vsi. i. a* so-*act pcisabs at sag• ob&t aka a p"ve o atot at said tars SWA044F =? as subt as Al l a tiaw to ao t bo da 1 r of US • as a VubLta Road of own ftwes 3p Wd" it is flNdtowd, is !I I % j9AOSUMS and d9eft" tov da"02 LIM as a Pda" ft" hw SU VW bwwm of Let ft@. 2, 2 and 4. 7. an tong as th• So Coat pasaata t os ? zGe"A0 a Priaat. Um d, Rsnn ?e?? "U haws so &W. ENUMM i Uty ac 1tabiliur Neze#ive to a w aoeil1 004 dur r Mai Vowtv", ,.a ZWAUtJ+M att. &VI 120 eta of "M ! with "M so da0t VOL', s *i*ft of VW. S. Rai& dwd f* twmafts ex aoawaWmaa of tat Mips. 1. 7, 9 a" 4 sua:L cant&" &MW saMii "guaw ftwee +©o"Lut+m.. t. lbw sartftctlar e"/or Cmditioaaw abs" boo deowd to ba nw"pim s ==&L" , Lth Lot W". t, 2, S sae! 4. Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. ? I ? 4 1 ?{ }CTi J0 ii-t11 , i(_ ? f l i ?7 1 19 '?L `;i.' I'BERLi ND COUIN PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Consumer Solutions, LLC, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 16 Peach Orchard Road, Newville, PA 17241. 1. Name and address of Owner(s) or Reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 2. Name and address of Defendants in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 LVNV Funding LLC c/o Phillip C. Warholic, Esquire 1200 Camp Hill Bypass Camp Hill, PA 17043 Carmel Financial Corporation c/o Charles F. Bennett, Esquire 4650 Baum Boulevard Pittsburgh, PA 15213 Asset Acceptance LLC c/o Scott J. Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) ONLY THOSE LISTED ABOVE. 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania 333 Health and Welfare Building Department of Welfare Harrisburg, PA 17105 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: Tenants/Occupants 16 Peach Orchard Road Newville, PA 17241 ONLY THOSE LISTED ABOVE. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Katherine E. Knowlton, Esquire Attorney for Plaintiff Date: March 27, 2012 PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. `` H011 Cs TA t i2 AFR -9 Phi 1: 2 ' BERLAN D C0UN' T ` Pr==NSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE NOTICE OF SALE TO LIENHOLDERS OWNERS: Patricia A Kuhn and Mervin Kuhn PROPERTY: 16 Peach Orchard Road, Newville, PA 17241 IMPROVEMENTS: Single Family, Residential PARCEL ID NO.: 31-13-0112-288 Please be advised that the undersigned office represents, Consumer Solutions, LLC, in a mortgage foreclosure. The above-captioned property is scheduled to be sold by the Sheriff of Cumberland County on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) Our records indicate that you may hold a mortgage or judgment lien on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Katherine E. Knowlton, Esquire Attorney for Plaintiff Date: March 27, 2012 Legal Description ALL TEAT CERTAIN tract of land situate in Penn Township, Cumbe gland County, Pennsylvania, more particularly bounded and described as follows: EEGINMG at an iron pin in the southwest corner of Lot No.1 and the line of lands of Lat No. 4 as shown on the haucioafter referred to subdivision plan; thence along Lot No. I North 84 degrees 39 urinate=s 57 seconds Bea 175 fact to an iron pin; thence continuing along said Lot No. 1 South 82 dogcees 22 mirotes 58 seoouds East 198.14 foot to an iron pink tho line of Lot No. 4 as shown on the hcroimfter rcfared to subdivision plan; thence along said Lot No. 4 the following courses and distances: South 6 degrees 36 minutes 04 soaonds West 146.76 fiat to an iron pin; South 89 ftrees 03 minutes 03 seconds West 176.65 feet to an iron pin; theme by a curve to the night having a radius of 175 feet and a chord bearing of North 48 degrees 8 minutes 30 seconds West a chord length of 237.84 feat to an iron pin at the place of BEGMING. CONTAINING a total of 1.214 acres and being Lot No. 2 as shown on the land subdivision. for Robert L. Spahr prepared by Carl D. Nett, Professional Land Surveyor dated November 1, 2004 and recorded in Cumberland County Plea Book 90, Page 11. "Ar zxM 14 1011 AU ist asstods paroiel ear UM =A avea? _- "Nn" m esftat t6 in OW Blip or tao-a@ t etaaaW of Qar?at3? sad eQSrsvet sraag4?ls?13?a, cad dllr#,p?tsd as ? ?. i'?.-?1?7.i??? ? ??i few eia"W" lie a Dead dated JOUGOW 24, am Wd iwemdwd OtWMauT 1#, 1006 An ftaborlead awanW in V*W am& Vale 020 at *age LM, gz"tetid Md skmWepari vote 111mon, L. a" Do"s S. labr, bis weifa. 1C? w Vii! tD &U a ate 4CjQj@"1'LQ" W Mt IM IP34M 2"k go, go" It 4welvding x"Ot i s a W4W e0lit"" x"S to tba 50-fact pa. Va#ar atpht- 09' "of as met ftr* team&. %. fts 50 1406t petvate merit of MW air rat no. a e+ LU ba used rev terse and intm=1 ' aa " sa, eq=wx, x sa and sbiUtr 24=t•.iama by tat Was. p, 3 s'd 4 9= eft 'i?a?da¦tiip =M1& * ai pagw0m. 1. Zo€ Me. 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S. fte zeNtftatuas a War Caudi *as atoll be dewmd to ba was rMusiog ULth zat Vera . 1 F 2. 9 aaaA 4. Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. a r;r r, -9 pi. 1: 26 PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 The real estate located at 16 Peach Orchard Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $81,852.08 plus fees, costs and other charges obtained by Consumer Solutions, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Katherine E. Knowlton, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, New Jersey 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. 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 the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 2. You may be able to petition the court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day 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 of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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. Legal Description ALL TEAT CERTAIN traet of land situate in Penn Towasip, Cumberland County, Pennsylvania, more particularly bounded and described as follows. IEGE4MG at an iron pion in the southwest corner of Lot No. I and the line of lands of Lot No. 4 as shown on the hereinafter refwcd to subdivision plan; thence aloes Lot No.1 North 84 degrees 39 minutes 57 seconds Bea 175 feat to an iron pin; thence continuing along said Lot No. 1 South 82 degrees 22 minutes 58 seoonds East 198.14 foet to an iron pin ist the line ofLot No. 4 as shown on the heroinafter referred to subdivision plan; thence along said Lot No. 4 the following eourses and distances: South 6 degrees 36 minutes 04 saoouds West 146.76 fret to an iron*$ South 99 dcpx s 03 minutes 03 seconds West 176.65 feet to as iron pin; thence by a curve to the right having a radius of 175 feet and a ohord bearing of North 48 degrees 8 minutes 30 seconds West a chord length of 237.84 feet to an iron pin at the place of BEGINNING. CONTAINING a total of 1.214 nneres and being Lot No. 2 as shown on the land wbdivision for Robert L. Spahr prepared by Carl D. Bert, Professional Land Swft-lox dated November t, 2004 and recorded in Cumberland CoWq Plan Book 90, Page I I . i»x "A'M zom 17?MUMM AU tint as s puroal a3 UM and "NOM MA "t oats In 1?w !fir arlr llsss? ?` of &Aftwlaand and liorswrane #h ad f ssrd dws wtatud as iysasi. ft. U-U--Qtu-d$o Md a11 MaUT dwa r b W Am a Dand dated J=wmW 24 r 4008 &M - a, A I awman 24, UM As Ombs=U" dm.?W ft D"d Seek V*Zmm 0267 at !ate }.M, fit" "d am. net* A L. > "A D"10 Ii. WOMW , b" '1I!'b.d4. VIM im iI I ; ? NOR to a" vote& a" aasditiMW as met dud fLM 1twk 90, V"% 11 Asoludiug xwalwial3lO aWm 1tWo n =daft" to tM 50-rlaeb SoLv ?t o pc "t Of-mg as ?t ltofh bewMa. 2. ft* 50 Awt padvatss sett 69 MW awsr Lot bat. 4 w= ba saved few d and !s#?ssphot! Sri*,, mss, -, ON11815 sad a"U* iamtiom? by 4st Sm. 2, 1 *ad 0 twar s3t?ta-2'a?is? x4o ld"tiL a psrtga . 2. Lot No. I OMU bsm no riots =4 obi.9onLeas to the SO-goof x1ot of gray. daosss to bObA b""M of is on Lot No, 1 abei br d3.aa OMY base 1Miab Ondw" B01". 3. , 1" tit e to the as** witwz tdr SAD-Moot pftvaata s?iout a e ? sar Ai.3I be past at L6t so. 4.- 4. Otay Lot lbs. 2, 4 mA 4 shall be aeasosed bZ t* 30-goat c&ot of "yT as law to it is a JOLVaMA NLOM of WW. S. =10 OMWArit Off Zot Ron, 8, 3 Wd 4 Maul etor a qp- in tba sMpe/a}iY?31LUaw arse neat of e"et*WWbkr&r M iaI I I I I I III, qtr, MWN aslaaaal, Sul of the W-bod and do laallitlraa the Private siqbt of 600and" pr to do and Pefteat"a of M04. 0. rAs so-toot sci at MW do ZOIn a P"V4$4 aight at mw and Vem ' Ip ;t;2_1 bn io so ftbf or eb1L+0&*U w to aAo*t tbo dediLar?1cl+ewr *9 Vp cares 46 & VEMLO Wa ad of ftm WounsUP vtt a *t in f sd to Pam TWWMb* apsaL9 [asa and efffteE Sear' dwUmtim as a labs " RNA bw a3,]. tba Ow hom od Lbt IN". 2, 2 Brad 4. 7. An long ** 00 SO toot ptaLvats tight of uay z0fietos Q lriaats t??or?l,,y loan ? "an uve Ito +?a?. sssr 1r at l ab"Ll y was too a w aoaatavotAw ? asiterwe -000, r #NNW er r eta. astd t2rw aaab ttl?+eol' o& t aada? faexLlit? with the $0 !feet WLvatn tifft of ime. It. Met& do" AMW tam" OW eL Ltt Ubs. 1, 2, 3 OM 4 each c oaabel.w two VI+O%xlati? mWede C afttdaa. S. The xrratx*atLwr ondlcw Candttd ces slurp bar dea d to be eats =Md" ULIft Lot V" . L' 2, 1 am 4. Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. 110 0 _ 12 xw, - 9 PN I ?`. sw93- RLM; D COUNTY HEN.4SYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 The real estate located at 16 Peach Orchard Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $81,852.08 plus fees, costs and other charges obtained by Consumer Solutions, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Katherine E. Knowlton, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, New Jersey 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. 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 the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 2. You may be able to petition the court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day 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 of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Court Administrator Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 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. Legal Description ALL THAT CERTAIN tract of land situde in Penn Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at an iron pin in the southwest corner of Lot No. I and the line of lands of Lot No. 4 as shown on the hmioa fter refmcd to subdivision plan; thence along Lot No. I North 84 degrees 39 minutes 57 seconds East 175 feet to an iron pin; theca condnft along said Lot No. I South 82 doges 22 minutes 58 seconds East 198.14 fieet to an iron pia is the tine of Lot No. 4 as shown on the hctr.inafer refs "d to subdivision plan; thence aW ft said Lot No. 4 the following courses and distances: South 6 degrees 36 minutes 04 seconds West 146.76 feat to an iron pin; south 89 dagmas 03 minutes 03 seconds West 176.65 feet to an iron pin; thence by a curve to the right having a radius of 175 feet and a chord bearing of Noah 48 degas 8 minutes 30 seconds West a chord length of 237.84 feet to an iron pin at the place of BEGINNING. CONTAINING a toil o€1.214 acmes and being Lot No. 2 as shown on the land subdivision for Robert L. Spahr prepared by Carl D. >3+srt, Prothssional Land Survc)w dated November 1, 2004 and recorded in Cumberland County Plan Book 90, Pap 11. A= tilt a wtsis page" of laird and 1111 ?¦a11111 "NAM" sitrabs in the lrrrreaelieip or *=a# caua* of l:esbsatlaNeei and tbrsaaseerwssilh ad w3aveata, and etsftioaUnd as ftoml ft. 31-U-C&U-200 Gad s Reim daaa albW I& a Dead datad Jam aw 24, ION a" x m q I¦ I ONAM" 2#, "a A& 6066raisred lea MW in 0ssd sack 1102MM 0367 at. V"a 3334. 0i+a®t A God esoee aid naeiaer 10, 11% in. a#fo and DWI* I. "", k" 1"i. tKt JM ? to all s awe" DonditLuo as met toolb is ftsa Iwecth 9o, VMS 11 ianagdb q ,em. Owen aamlittoars vaatiwq to this So-feet PWLV*tsp MSght-ad-w" our rot ftr* beams. Y . !!ee 30 tart PftV ate sA8t of a>sW ewer rat MO. 4 xis ba told tar lsrss aged i s#sr>crr?Aese4 lalseesa, 69MEaa, x 1 p la s sad abilbtr Unatia" by zat MOO. #t, 3 oad 4 tw sing1*-9wwQ ? vasi after gospoa ". 2. Zot No. 1 e bsw no rots and e+bbligoLt ns to the 34-+leot "Pt of way. AMOS r?/.at1O b*tb ]"ras Of the *gdAW oa 16t 90, 1 W 3. F" utle aalL bey MMII {.E Moab Mad. ., yaty rivitt; cc war ahall be VMt lad Left W6. 4. 4. c Lot lbs . 2, 3 acrd 4 sha U be "wessed by tto 39-99on, right Of MW ss 100 60 it is a jWLV*t6 RLgkt at WW. S. The fMMVift of Z*t Xoa, fit, 3 aa+d d aball She" pa?it? in the d63Yd? a" next of aara?, a?ifatooia3 f s+ -ftrl ea-ii vowvwatl, is o. 99 tho readwW and dx&Lu a !val*ti" % the Moot Drive" riqbt of ava aaov"tx?gr to !dw umgm and d Wmataya oe Mo. 6. A* 50-foaRt privaba at war ab dal zounis a wtvaso xttot at MC WA Dean ' tp "au hW a VA draf cc daivAt" to t tbo dadiaM of us aaaan as s VakuLft wand of a? ftmnuv =A" :Lt in ANW" , to Pum f*WWLV 8""f#i gpa and 69 at" tar daUaatL= EMI a lady," bind by all Aba Ommm a! Lbt >aaa. 2, 2 ad 4. 7. an LM # tas So Cwt pmlvate At of ? sarafts # Maa to 4W 7trtod, Feaa !te hid Aatt barns ao lr Ififi- 1"biliIP Va to as ao 11+0 , ss tssa OS, I Sam r eta. mad tft aoab or =MI t aLut"W with the SO ftet wLvate tL*t of arm ft. UC& dood daa` "Nah- = vaasanw of Lot Mm. 1, 2, 3 a" 4 aba :L ocatal.s &si WAO"aUms muter ft"LUme. 1. sba zeatrlaftl=r aaddos Con" ba df*wd to ba awoom6wits rasutt" uLi t Lot S". t, 2, 2 wA l. Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 t- t L 'J Y F•?i'U TA A it j is ?' i1 r B' F ' 2 r) # RLA1 C? COUNTY P-P? 'SYLYANIA Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Posting 16 Peach Orchard Road Newville, PA 17241 The real estate located at 16 Peach Orchard Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on September 5, 2012 at 10:00 a.m., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (The specific room location will be posted at every entrance to the courthouse; or Deputies posted at each entrance may direct you to the room.) to enforce the court judgment of $81,852.08 plus fees, costs and other charges obtained by Consumer Solutions, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 1. This sale will be canceled if you pay the judgment to Katherine E. Knowlton, Esquire, 9000 Midlantic Drive, Suite 300, P.O. Box 5054, Mount Laurel, New Jersey 08054. To find out how much you must pay, you may call (856) 810-5815. 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. 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 the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 2. You may be able to petition the court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffs Office at (717) 240-6390 or Katherine E. Knowlton, Esquire at (856) 810-5815. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on the 30th day 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 of the preparation of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Court Administrator Cumberland County Courthouse 4`h Floor Carlisle, PA 17013 (717) 240-6200 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 Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. Legal Description ALL THAT CERTAIN tract of land situate in Penn Townsip, Cumberland County, Pamsylvaaia, more palieularly bounded and described as follows: DEG114NING at an iron pin in the southwest cornea of Lot No. l and the line of lands of Lot No. 4 as shown on the horeiaafter ref=*d to subdivision plan; thence along Lot No. I North 84 degrees 39 minutes 57 mconds Bast 175 feat to an iron pin; thence continuing along said Lot No. 1 South 82 degrees 22 mirmles 58 seoonds East 198.14 feet to an iron pin in the line ofLot No. 4 as shown on the hereinafter raferred to subdivision plan; thence along said Lot No. 4 the following eourses and dikes: South 6 degrees 36 minutes 04 seconds West 146.75 foot to an iron pin; South $9 degrees 03 minutes 03 seconds West 176.65 feet to an iron pin; thence by a curve to the right having a radius of 175 feet and a chord bearing of North 48 degrees 8 minutes 30 seconds West a chord length of 237.84 feet to an iron pin at the place of BEMN1NG. CONTAINING a total of 1.214 acres and being Lot No. 2 as shown on the land subdivision for Robert L. Spahr prepared by Carl D. Bert, Professional Laid Sarveyv dated November 1, 2004 and recorded is Cumberland County Plan Book 90, Page 11. KZN2M "A'R zMM %I00% tarty 'tit -Me ia "W" t! 2"d ad itsptlrp?aasasttts? "MUP M oit"te in IMM, Cmtft o arrd ONOirwwLU& of ? irau?a, mad &M- - s - m U-U-0M-S4* said aaN da33? da"Viked im • DANA tdat" Jx=NW dt, iM and auaaa el¦d ftftmq fit, "as " 6ab=%md tr mwW U bad fools ti4a wa 010 at Sags I4, gssabtad ssd ssoo? os! v>I?tts za"at L. =A ft"18 Z. 1 MM IttA1D itll>taj=? loo aU 104" #A" t>t M&t ftf as Mt AU PSAW awk 90, V"p lri Anal" x, m We a tmut/'ez 00"ItUnx elatd g to faun 30-lamb poivabo oo#p0,n-ef as sat lbrft ban"S. 1. 'Ara 80 !toot pst#uate siot st tW mar Lee as. 4 xLU 3m us" loser f? 4" i e#a , , V!, I bra, 003+sas4 a east sailiw*W 14aativms by Lat Mos. S, 3 tats4d 4 9= eingl'?r-ah¦pLi? =s1aftUal gosyiasaar. a2. Lob abr. 3 Off. bawd me riots =a abl.40MIM to tba 50-400t Csot of 86 be dt.? hew POaat t ,g of " me". of 00 ORRUM on 7 go. 2 AmU 3. , sum Utle to t2w aft* WitWx tbs Wt of PzWmt r tigut at ww alua11 be part Cd Lbt go. 4. i. only Lot lbs. 2, S and 4 Ww11 be "Websed bw tto Swat ftitst of "T as law as it La s ja'iwts right at MW. S. Me O M4 M of TA*t Noe. 2r 3 sad 4 "All abaLy paEnpMtloft l a is US p ?.a A ti 4aid a wt of 06da"44wova, .-pia ,en1, tr+ MWN ago. of tba 'P ae Ors? and daoNAUas fte& itAma UtIA the so-ftwat private riqbt at Uff mpr to dw UWqft and peoveat"a ae U". i. sfw 3d-ftaat VELV atr at war do" ?s a V"VWW aight of .ate a" Rand 3p aa? bore so ON* or tLbw to moot 06 didtoati tt. off Us pow " a VdbLL a Mad of ftm WeLmoUp =US *t is 1"Wor d to pow i40Mau Ur "p"SAaa#4aaa and ease" far dddt*WA= aar a too LU RNA by SU VW tars of Lbt 104. 2, 3 said 4. 7. An Ides so to So tvot parliate might of ? ZUNWA8 as ftIesto r >ilrloa ftuit X11 heMS rq amw. srea4hL3,l?bl oeC YtihllLOY Ve to 41' go- tip l90, Wr it r rr SNEW Wenev" r ota. mad tbo =at& f at the xoodmw sad falail itiaor with the 60 ftot p Lvais aitt at rq. I. 2at& deed dose twakaAw = couvarmaca at Lot Roa. 1, 3, 3 wd 4 ob"l owwabain dw • V104"dar ow6 t .UMN. 0. The srratftatLar and,/ac Condit shall. be damd to be a amats rsniut U th Lot I". t, 2, 3 sad 4, Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. :a 2 ?Jp --9 Fl' is i-7 - BERLAN10 COUNT'," PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE CERTIFICATION I, Katherine E. Knowlton, Esquire, hereby certify that a pre-foreclosure notice was sent to the Defendants on November 23, 2011, via certified and regular mail. As pursuant to the supplemental notice published in the Pennsylvania Bulletin, (41 Pa.B. 3943), Act 91 Notice is no longer required nor applicable to any mortgage foreclosure action filed August 27, 2011 or later. This certification is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Katherine E. Knowlton, Esquire Dated: March 27, 2012 PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 k i e ' i k.,:-.. c TON It'.? . . P 2 t Ctl i'l sE2!_ANO COUNT"' PENNSYLVANIA Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN ADDRESS STATE OF NEW JERSEY COUNTY OF BURLINGTON SS. BEFORE ME, the undersigned authority, personally appeared Katherine E. Knowlton, Esquire, who, being duly sworn according to law, deposes and says that to the best of her knowledge, information and belief that the last known address of Defendants, is 16 Peach Orchard Road, Newville, Pennsylvania 17241. Sworn to and subscribed to before ML/-) s a day of 2012 NOTARY PUBLIC DIANA HEWITT Notary Public State of New Jersey My Commission Expires Sept. 30, 2013 Katherine E. Knowlton, Esquire PARKER McCAY P.A. By: Katherine E. Knowlton, Esquire Attorney ID# 311713 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff File No. 14569-11-03414 C;i? ?? ae ;I. MBERLAND COUNTY PENNSYLVAP IA Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, V. Patricia A Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM 2012 NO. 12-00271 CIVIL ACTION MORTAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE BEFORE ME, the undersigned authority, personally appeared Katherine E. Knowlton, Esquire, who, being duly sworn according to law, deposes and says that to the best of her knowledge, information and belief, the Defendants, are not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and subscribed to before me this day of 2012 NOTARY PUBLIC DIANA HEWITT Notary Public State of New Jersey rAY Commission Expires Sept. 30, 2013 Katherine E. Knowlton, Esquire Attorney for Plaintiff Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Mar-28-2012 07:18:17 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency KUHN MERVIN 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). 14 Ljaj *f 101. J_ )6t 40(?V_ 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 littp://www.de.fenselink..i-ni]Jfag/iiis/PC09SL.DR.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 3/28/2012 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:EOG9880M2U https://www.dmdc.osd.mil/appj/scra/popreport.do 3/28/2012 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Mar-27-2012 13:41:18 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency KUHN PATRICIA Based on the information you have furnished, the DMDC does not possess A 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, NOAH, Public Health, and Coast Guard). 14. )6y, rot 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 I.ittp://www.de.fenselink.m.illfag/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 3/27/2012 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:PHVVIP84R9 https://www.dmdc.osd.mil/appj/scra/popreport.do 3/27/2012 Legal Description ALL TRAT CERTAIN bract of land situate in Penn Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: $ NMG at an iron pin in the southwest corner of Lot No. Land the line of lands of Lot No. 4 as shown on the bmioafter referred to subdivision plan; thence along Lot No, I North 84 degrees 39 mirafts 57 seconds Bed 175 feet to an iron pin; thence continuing along said Lot No. 1 South 62 degrees 22 minutes 58 seconds East 19$.14 Soet to an iron pin in the, line of Lot No. 4 as shovm on the hcrainatter mfwcd to subdivision pion; thence along said Lot No. 4 the following courses and distances: South 6 degrees 36 minutes 04 seconds West 146.76 feet to an iron pin; South 89 dagtes 03 minutes 03 seconds West 176.65 feet to an iron pin; theme by a curve to the right baying a radius of 175 feet and a chord bearing of North 49 degrees 8 minutes 30 seconds West a curd length of 237.64 feet to an iron pin at the place of BEGINNING. CONTAE41NG a total of 1.214 acres and being Lot No. 2 as shown on the land subdivision for Robert L. Spahr prepatod by Carl D. Nett, Professional Land Surveyor dated November 1, 2004 and recorded in Cumberland County Plan Book 90, pap 11. ]1= that Owtaia PUV" of lead and ilpraaaiautit l9MlsrMCra "talate 3a t6a '?' of tam?, Gwti * of C aatland and oawrr b of laegewNl4iwis, and Arrigast?¦d M Posen fir. 31-12-O& ,t!-tse Md so" ! T drs+a"brd 3a a Drrd Oat" &OOMW 24, 260 asd eeoa$¦d 2M, 2005 lase hard qtr is a*" Boot iln 4w 0269 at Way* M4, vz"t" and seaward UMM ]RIO -t T. "Wr aid ueais T'. Ojohr, his WL". IMEM 3t to a" ao"& *" COME"U"* as ,roe tea * is mum 2"k 90, Va" *t irAlidis' a mil ' -1 .e?Oeo Owen aladitta" x"at:ial to the se-ftwb SOLVata ?gltio-edCw? as met ton"S. Y , !bs 20 loot Paly ats slObit Ot MW *war Lot 1b. 4 WLU ba nsad few i'aeaYr 4" iabo , V 111 1 LOOM"We aysara, "loin 1 is ssd a"U* 14aatiams by X.at uos . 21 3 *ad S O r1tw1*-t n"y a+esidatUa , 2. Lot No. 1 "OU bay ae rights &" ab 4"tims to lases 50-"t 4441bt Of Aora* to both boxy" of ter d or bot go. 1 shall be divearbly ft M MMA OxdMd Mead. 3. , 1" ULU* to the arm witWx for Wftat ptvaate right of roar sbztl be gWt of tAt aa. 4.- d. Only Lot Uoe. 2, 3 and 4 rWl be aecemed by Wtoot cAot oe MW as law as it Le a jWLV trr right at NW. S. The Ow"M 09 Zot Sam. 3, 3 mod; 4 serail aka Fa?i? in t" -speas ut l l-Wsn shad Best of 0"86*006ka, I I *3r# mww i+aaawal, *to. 99 tho rosalrPM awd d ffae& .tAAm .ii A the 59-*o PrIvo" =Lgkt of as anaaa"', to tw .lasrget and paaeaaataagar of v.a. 0. r&* 50-^faat VCL air WW sb&U WENSLs a. *ac VftlW Xjjjkt of tda aff s " & s LO fted 09 own TMODUP =It ;L i iv a to ram Tomah* - Lf#S and afl"" fAV daaitdOWUM ars A Valrtila gatd fob 4U 4bb Ors of L*t ft@. 3, 3 sand At. 7. An long as tie so foot parivate >tiot of rWiwas a? lrIsaatm *oaad, fton TOWURAD a?iuati cy+s >ao ate. sa,aarra i7ibj ear li?abdlif 802s ve to aaag QOOl h1ORr , r aram a. Mad tke cos to at tbo X and 1ouiliti m Uith teas ta4 ftot V*Lvats *Lot of MV. I. dated ftV tWWWOW OX OMTGWMM Of bast Mesa`. 1, 2, 3 04 t oba1L *Data" eweaa Isawatimm NW* t C*0dLt . 6. ft* s*st#atiApr amdla>z C=ditLoans dual 3 bar 466 d to be tents =="W aarLth Laat V". 1, 2, 3 erase! 4. Tax Id No: 31-13-0112-288 For information purposes only - Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. PARKER McCAY P.A. By: Chandra M. Arkema, Esquire Attorney ID# 203437 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054 (856) 810-5815 Attorney for Plaintiff File #:14569-11-03414 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 v. Plaintiff, Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, P A 17241 Defendants. ~=6 ..~i ~~A~'~THU~NQ~'Ar~Y ~;; ~`'f2 AUG 20 PM 2: 3b ~rs~~~~aNn eouNrY r~ENNS YLVANiA COURT OF COMMON PLEAS CUMBERLAND COUNTY JANUARY TERM, 2012 NO.: 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO PaR.C.P. 3129.2 STATE OF NEW JERSEY SS: COUNTY OF BURLINGTON I, Chandra M. Arkema, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say, 1. True and correct copies of the Writ of Execution and Notice of Sheriffs Sale were served Defendants, Patricia A. Kuhn and Mervin Kuhn, by the Cumberland County Sheriff on June 18, 2012, 16 Peach Orchard Road, Newville, PA 17241, as is evidenced by the Sheriff's Return of Service which attached hereto and made a part hereof as Exhibit "A". 2. True and correct copies of the Sheriff's Handbill of Sale were posted on the premises at 16 Peach Orchard Road, Newville, PA 17241, on June 18, 2012, as is evidenced by Sheriff s Return of Service which is attached hereto and made a part hereof as Exhibit "B". 3. True and correct copies of the Notice of Sheriff s Sale of Real Estate to Lienholders, and applicable notices with reference to the scheduled Sheriff s sale, were sent to the following parties interest on April 10, 2012 via first class mail, postage prepaid with certificates of mailing which attached hereto and made a part hereof as Exhibit "C". Patricia A Kuhn 16 Peach Orchard Road Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Consumer Solutions, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 LVNV Funding LLC c/o Phillip C. Warholic, Esquire 1200 Camp Hill Bypass Camp Hill, PA 17043 Carmel Financial Corporation c/o Charles F. Bennett, Esquire 4650 Baum Boulevard Pittsburgh, PA 15213 Asset Acceptance LLC c/o Scott J. Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 333 Health and Welfare Building Harrisburg, PA 17105 Tenants/Occupants 16 Peach Orchard Road Newville, PA 17241 I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. ,f ..--4 CHANDRA M. ARKEMA, ESQUIRE Atty ID# 203437 Attorney for Plaintiff Sworn to and subscribed Before me this 1 ~p day of August 2012. i ~~ Nota y ublic 116E1.0aMIN8r~L f P~Ao if Nwr ~ ~ E~int N~t>~ ~ EXHIBIT "A" ~~' ~' . SHERIFF'S OFFICE OF CUMBERLAND COUNTY , Ronny R Anderson Sheriff Jody S Smith `~°`~~t~r ct t~~c~nb,r,~~rn~ Chief Deputy , ~~ , ~ Richard W Stewart ~ ` ~= ~•~ SOilCll`Or ¢FFI~E QF TwE $MERIFF Consumer Solutions, LLC Case Number vs. Patricia A. Kuhn (et al.) 2012-271 SHERIFF'S RETURN OF SERVICE 06/18/2012 06:07 PM -Deputy Michael Garrick, being duly sworn according to law, states service was performed k posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled actior upon the property located at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland County. 06/18/2012 06:07 PM -Deputy Michael Garrick, being duly sworn according to law, served the requested Real Est< Writ, Notice and Description, in the above titled action, by making known its contents and at the same 1 personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patric A. Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland Coy 06/18/2012 06:07 PM -Deputy Michael Barrick, being duly sworn according to law, served the requested Real Esta Writ, Notice and Description, in the above titled action, by making known its contents and at the same 1 personally handing a true copy to a person representing themselves to be the Defendant, to wit: Mervi Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland Count SHERIFF COST: $921.20 SO ANSWERS, July 17, 2012 RONNY R ANDERSON, SHERIFF (c} CountySuite Shenff. Teleosofl. Inc. EXHIBIT "B" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a~t~,, oC L~tegbrr/7 Jody S Smith ut f De Chi ~Q ~rb ~' "' ~ y p e /~~ -~ Richard W Stewart =~ '~"''" SOilCItOr OFFICE Q~ THE SHERIFF Consumer Solutions, LLC vs. Patricia A. Kuhn (et al.) Case Numk 2012-271 SHERIFF'S RETURN OF SERVICE 06/18/2012 06:07 PM -Deputy Michael Barrick, 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 acti n, upon the property located at 16 Peach Orchard Road, South Middleton Township, Newville, PA 1724 , Cumberland County. 06/18/2012 06:07 PM -Deputy Michael Barrick, being duly sworn according to law, served the requested Real E ate Writ, Notice and Description, in the above titled action, by making known its contents and at the sam time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Pat icia A. Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland C unty 06/18/2012 06:07 PM -Deputy Michael Barrick, being duly sworn according to law, served the requested Real E tate Writ, Notice and Description, in the above titled action, by making known its contents and at the sam time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Me in Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland Cou ty. SHERIFF COST: $921.20 SO ANSWERS, July 17, 2012 R ANDERSON, SHERI 4~, , (cj CountySuite Shenft. Teleosoft. Inc. EXHIBIT "C" ~. 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' ~~ D~iiver ° ° p ~ ~ $ ~~ ~ o s ~ z p w 8q C R. tun eceipt ~ ~ A ~ c ~~ ~m File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. OF THE PRO 4 hOt Gin \ t 20I KAY 27 AMI 0: 144 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE TO MARK JUDGMENT TO THE USE Kindly mark the judgment entered in the above captioned matter to the use of GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee, 60 Livingston Avenue, EP-MN-WS3D, St. Paul, MN 55107: 1. A true and correct copy of an Assignment of Mortgage from Consumer Solution, LLC into GRA Legal Title Trust II 2013-1, U.S. Bank, National Association, as Legal Title Trustee, dated November 14, 2013, is attached hereto and made a part hereof as Exhibit "A". 3. A true and correct copy of an Assignment of Mortgage from GRA Legal Title Trust II 2013-1, U.S. Bank, National Association, as Legal Title Trustee into GMAT Legal Title C# 5:6z73 e# -306c109 Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee, dated May 1, 2014, is attached hereto and made a part hereof as Exhibit "B". Date: May 2014 By: PARKER McCAY P.A. Richard J. Nalbandian, III, Esquire Attorney for Plaintiff EXHIBIT "A" Prepared By: LITA DUDLEY Meridian Asset Services, Inc. 780 94th Avenue N., Suite 102 St. Petersburg, FL 33702 When Recorded Mail To: DIANNE SHELHAMER C/O Meridian Asset Services Inc. 780 94th Avenue N. Suite 102 St. Petersburg, FL 33702 Loan#: 2179847 Servicer#: 1003046295 9 id1,r, Space above for Recorder's use ASSIGNMENT OF MORTGAGE For good and valuable consideration, the sufficiency of which is hereby acknowledged, Consumer Solutions, LLC, 9320 EXCELSIOR BOULEVARD, HOPKINS, MINNESOTA 55343, (ASSIGNOR). For VALUE RECEIVED, The undersigned hereby grants, assigns, and transfers to GRA LEGAL TITLE TRUST I I 2013-1, U.S. BANK, NATIONAL ASSOCIATION, AS, T,F(;AT, TTTT.F. TRUSTEE , (ASSIGNEE), all beneficial interest under that certain mortgage, together with the certain note(s) described therein with all interest, all liens, and any rights due or to become due thereon. Date of Mortgage: 3/29/2006 Original Loan Amount: $72,000.00 Executed by (Mortgagor(s)): MERVIN KUHN AND PATRICIA A KUHN Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC Filed of Record: In Book/Liber/Volume 1947, Page 1815, Document/Instrument No: N/A in the Office of County Recorder of CUMBERLAND County, PENNSYLVANIA, Recorded on 4/19/2006. Legal Description: SEE EXHIBIT "A" ATTACHED Property more commonly described as: 16 PEACH ORCHARD RD, NEWVILLE, PENNSYLVANIA 17241 IN WITNESS WHEREOF, the undersigned by its duly elected officers and pursuant to proper authority of its board of directors has duly executed, sealed, acknowledged and delivered this assignment. Date: ((—l4 -I3 CONSUMER SOLUTIONS, LLC, by MERIDIAN ASSET SERVICES, I , its Attorney -In -Fact B Karen Riffe President I hereby certify the precise address of the within named Witness Name: "--GOV1/4 \itAeOrk4V-4-1 (Assignee) is 2030060366730 PATRICIA KUHN GARR 13 KASOTA CONSUMERSOLUTIONS- PRIV Prepared By. LITA DUDLEY Meridian Asset Services, Inc. 780 941h Avenue N., Suite 102 St. Petersburg, FL 33702 When Recorded Mail To: DIANNE SHELHAMER C/O Meridian Asset Services Inc. 780 94th Avenue N. Suite 102 St. Petersburg, FL 33702 Loan#: 2179847 Servicer#: 1003046295 Space above for Recorder's use ASSIGNMENT OF MORTGAGE The Power of Attorney was filed in County, Pennsylvania on State of Florida} County of Pinellas} ss. On, i / ' ?! 3 , before me, Martha J. Nunn, a Notary Public, personally appeared Karen Riffe, President of/for E DIAN ASSET SERVICES, INC., AS ATTORNEY-IN-FACT FOR CONSUMER SOLUTIONS, LLC, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies) and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of Florida that the foregoing paragraph is true and correct. MARTHA J. NUNN MY COMM!SSIQN A FF 020562 EXPIRES: May 21, 2017 Bonded TMv Bunt Nary Swknt EXHIBIT "B" PREPARED BY: Rushmore Loan Management Services, LLC AFTER RECORDATION RETURN TO: Rushmore Loan Management Services, LLC 15480 Laguna Canyon Road, Suite 100 Irvine CA 92818 ASSIGNMENT OF MORTGAGE LOAN #: 7600024786 FOR VALUE RECEIVED: ASSIGNOR: GRA LEGAL TITLE TRUST II 2013-1, U.S. BANK, NATIONAL ASSOCIATION, AS LEGAL TITLE TRUSTEE ASSIGNOR ADDRESS: 60 LIVINGSTON AVENUE, EP-MN-WS3D, ST. PAUL, MN 55107 HEREBY GRANTS, ASSIGNS AND TRANSFERS TO: ASSIGNEE: GMAT LEGAL TITLE TRUST 2014-1, U.S. BANK, NATIONAL ASSOCIATION, AS LEGAL TITLE TRUSTEE ASSIGNEE ADDRESS: 60 LIVINGSTON AVENUE, EP-MN-WS3D, ST. PAUL, MN 55107 ALL OF ITS RIGHT, TITLE, AND INTEREST IN AND TO THE PROPERTY COVERED BY THAT CERTAIN MORTGAGE: DATED: 03/29/2006 ORIGINAL LOAN AMOUNT: $72,000.00 MORTGAGOR/BORROWER: MERVIN KUHN AND PATRICIA A. KUHN ORIGINAL MORTGAGEE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ("MERS"), AS NOMINEE FOR DECISION ONE MORTGAGE COMPANY, LLC, ITS SUCCESSORS AND ASSIGNS RECORDED IN THE OFFICIAL REAL PROPERTY RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA RECORDED: 04/19/2006 IN BQOKNOLUME/LIBER: 1947 PAGE: 1815 DOCUMENT: NIA PROPERTY SUBJECT TO LIEN: 16 PEACH ORCHARD RD, NEWVILLE, PA 17241 PA 0I/13 LOAN #: 7600023970 TOGETHER WITH THE PROMISSORY NOTE OR NOTES THEREIN DESCRIBED OR REFERRED TO THEREIN AND SECURED THEREBY, THE MONEY DUE AND TO BECOME DUE THEREON WITH INTEREST, AND ALL RIGHTS ACCRUED OR TO ACCRUE UNDER SAID MORTGAGE. IN WITNESS WHEREOF, ASSIGNOR HAS EXECUTED THIS INSTRUMENT AS OF THE rd's DAY OF _1 _, 2014. ATTESTED BY: BY: NAME: Michael Whitfield GRA LEGAL TITLE TRUST II 2013-1, U.S. BANK, NATIONAL ASSOCIATION, AS LEGAL TITLE TRUSTEE BY RUSHMORE LOAN MANAGEMENT SERVICES LLC, ITS APPOINTED ATTORNEY IN FACT 1, BY: /0 NAM l TITLE: Kevin Elliott Vice President Certificate of Residency 1, the undersigned, do certify that the assignee's precise address is 60 LIVINGSTON AVENUE, EP-MN-WS3D, ST. PAUL, MN 55107 Witness my hand this date: Kevin Elliott ACKNOWLEDGMENT STATE OF CALIFORNIA ) SS: COUNT ORANGE NGE On, AV U;2014 2014, before me, TAMARA SULEA Notary Public, personally appeared llPvin F IllOtt , who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Print Name: TAMARA SULEA TAMARA SULEA Commission # 2004187 Notary Public - California i Orange County _ M� Comm. Expires Feb 12,202 71 PA 01/13 File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff Consumer Solution, LLC 8742 Lucent Blvd., Suite 300 Highlands Ranch, CO 80129 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I hereby certify that on this /j9 day of May 2014 that a copy of the Praecipe to Mark Judgment to the Use herein described was sent to the following parties, via U.S. First Class Mail, postage prepaid: Patricia A. Kuhn 16 Peach Orchard Road Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 By: PARKER McCAY P.A. Richard J. Nalbandian, III, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY 1-3 NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: +K' Kindly issue writ of execution in the above matter directed to the Sheriff of Cumberland County. Kindly index this Writ against the Defendants as follows: Patricia A. Kuhn and Mervin Kuhn. Real Property involved: 16 Peach Orchard Road, Newville, PA 17241. Date: Jun Amount due $81,852.08 Interest from 03/01/2012 (at the per diem rate of $17.25) $ Costs $ Total 2014 CbtAL62s--s6pci at aC9 .60 car `(.l§c).91 (( 16. s6" Cb3/l0 s 06c).16 Pd aptNt- 30003 LI Richard J. Nalbandian, III, Esquire Attorney for Plaintiff 0 1)j'firte)i) LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Penn Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at an iron pin in the southwest corner of Lot No. 1 and the line of lands of Lot No. 4 as shown on the hereinafter referred to subdivision plan; thence along Lot No. 1 North 84 degrees 39 minutes 57 seconds East 175 feet to an iron pin; thence continuing along said Lot No. 1 South 82 degrees 22 minutes 58 seconds East 198.14 feet to an iron pin in the line of Lot No. 4 as shown on the hereinafter referred to subdivision plan; thence along said Lot No. 4 the following courses and distances: South 6 degrees 36 minutes 04 seconds West 146.76 feet to an iron pin; South 89 degrees 03 minutes 03 seconds West 176.65 feet to an iron pin; thence by a curve to the right having a radius of 175 feet and a chord bearing of North 48 degrees 8 minutes 30 seconds West a chord length of 237.84 feet to an iron pin at the place of BEGINNING. CONTAINING a total of 1.214 acres and being Lot No. 2 as shown on the land subdivision for Robert L Spahr prepared by Carl D. Bert, Professional Land Surveyor dated November 1, 2004 and recorded in Cumberland County Plan Book 90, Page 11. EXHIBIT "A" - LEGAL DESCRIPTION ALL that certain parcel of land and improvements thereon situate in the Township of Penn, County of Cumberland and Commonwealth of Pennsylvania, and designated as Parcel No. 31- 13-0112-288 and more fully described in a Deed dated January 24, 2005 and recorded January 24, 2005 in Cumberland County in Deed Book Volume 0267 at Page 1334, granted and conveyed unto Robert L. Spahr and Doris L. Spahr, his wife. UNDER AND SUBJECT to all notes and conditions as set forth in Plan Book 90, Page 11 including restrictions and/or conditions relating to the 50 -foot private right-of-way as set forth herein. 1. The 50 foot private right of way over Lot No. 4 will be used for free and interrupted ingress, egress, regress and utility locations by Lot Nos. 2, 3 and 4 for single-family residential purposes. 2. Lot No. 1 shall have no rights and obligations to the 50 -foot right of way. Access to both halves of the duplex on Lot No. 1 shall be directly from Peach Orchard Road. 3. Fee title to the area within the 50 -foot private right of way shall be part of Lot No. 4. 4. Only Lot Nos. 2, 3 and 4 shall be accessed by the 50 -foot right of way as long as it is a private right of way. 5. The Owners of Lot Nos. 2, 3 and 4 shall share proportionally in the responsibilities and cost of construction, maintenance, repair, snow removal, etc. of the roadway and drainage facilities with the 50 -foot private right of way according to the length and percentage of use. 6. The 50 -foot private right of way shall remain a private right of way and Penn Township shall have no duty or obligation to accept the dedication of the same as a Public Road of Penn Township until it is improved to Penn Township specifications and offered for dedication as a Public Road by all the Owners of Lot Nos. 2, 3 and 4. 7. As long as the 50 foot private right of way remains a Private Road, Penn Township shall have no duty, reasonability or liability relative to any construction, maintenance, repair, snow removal, etc. and the costs thereof of the roadway and drainage facilities with the 50 foot private right of way. 8. Each deed for transfer or conveyance of Lot Nos. 1, 2, 3 and 4 shall contain these Restrictions and/or Conditions. 9. The restrictions and/or Conditions shall be deemed to be covenants running with Lot Nos. 1, 2, 3 and 4. Tax Id No: 31-13-0112-288 For information purposes only- Property also known as: 16 Peach Orchard Road Newville, PA 17241 TITLE TO SAID PREMISES IS VESTED IN Mervin Kuhn and Patricia A. Kuhn, by deed from Robert L. Spahr and Doris M. Spahr, his wife, dated 3/29/2006 and recorded 4/19/2006 in Book 274, Page 438. EXHIBIT "A" File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. ,{II�I 1f 7.014 a/Pi _t} Fri C UMBE L A NDr PENNSYLVANIA ENNS 'LVA NIA` T , COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee, Plaintiff in the above action, comes by its attorney and sets forth, as of the date the Praecipe for Writ of Execution was filed, the following information concerning the real property located at 16 Peach Orchard Road, Newville, PA 17241. 1. Name and address of Owner(s) or Reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Patricia A. Kuhn 16 Peach Orchard Road, Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road, Newville, PA 17241 Name 2. Name and address of Defendants in the judgment: Address (if address cannot be reasonably ascertained, please so indicate) Patricia A. Kuhn 16 Peach Orchard Road, Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road, Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue, EP-MN-WS3D St. Paul, MN 55107 LVNV Funding LLC c/o Phillip C. Warholic, Esquire 1200 Camp Hill Bypass, Camp Hill, PA 17043 Carmel Financial Corporation c/o Charles F. Bennett, Esquire 4650 Baum Boulevard, Pittsburgh, PA 15213 Asset Acceptance LLC c/o Scott J. Watson, Esquire 24 Regency Plaza, Glen Mills, PA 19342 Name Name and address of the last recorded holder of every mortgage of record: Address (if address cannot be reasonably ascertained, please so indicate) GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue, EP-MN-WS3D St. Paul, MN 55107 5. Name and address of every other person who has any record lien on the property: Name ONLY THOSE LISTED ABOVE. Address (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate Big Spring School District Mable Stitt 2655 Walnut Bottom Road, Carlisle, PA 17015 Penn Township Tax Collector Mable Stitt 2655 Walnut Bottom Road, Carlisle, PA 17015 Cumberland County Tax Assessment 1 Courthouse Square, Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square, Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street, P.O. Box 320 Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 333 Health and Welfare Building Harrisburg, PA 17105 Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Dept. 28061 Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 Internal Revenue Service Federal Estate Tax Special Procedure Branch 1001 Liberty Avenue 13th Floor, Suite 1300, Pittsburgh, PA 15222 Commonwealth of Pennsylvania Department of Revenue Bureau of Individual Taxes P.O. Box 280509, Harrisburg, PA 17128-0509 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: Tenants/Occupants 16 Peach Orchard Road, Newville, PA 17241 ONLY THOSE LISTED ABOVE. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: Jun , 2014 By: PARKER McCAY, P.A. Richard J. Nalbandian, III, Esquire Attorney for Plaintiff File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. - ?Ol,UlfN -1 PH f: G �� RL AND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE ACT 91 CERTIFICATION I, Richard J. Nalbandian, III, Esquire, hereby certify that a pre -foreclosure notice was sent to the Defendants on November 23, 2011, via U.S. First Class Mail and Certified Mail. This certification is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. By: Date: Jun-,. 2014 PARKER McCAY, P.A. Richard J. Nalbandian, III, Esquire Attorney for Plaintiff File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. 01- 1j MONO Teti; 2014 JUN -14 PH 1: 50 CUMBERLAND COUNTY PENNS YL VA WA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN ADDRESS BEFORE ME, the undersigned authority, personally appeared Richard J. Nalbandian, III, Esquire, who, being duly sworn according to law, deposes and says that to the best of his knowledge, information and belief that the last known address of Defendants, Patricia A. Kuhn and Mervin Kuhn, is 16 Peach Orchard Road, Newville, PA 17241. Richard J. Nalbandian, IITEsquire Attorney for Plaintiff Sworn to and subsc ed to before me this _ day of June, 2014. NOTARY, PUBL DEBORAH A:BUCHANAN Notary Public `'" State..ot.New Jersey' My Con missiori'Expires August B, 2016 File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, III, Esquire Attorney ID# 312653 9000 Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 Defendants. • T1-10 N (- IA t 201 -' Fri' 15O Clit't ER L. A Ili CC/UN COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE BEFORE ME, the undersigned authority, personally appeared Richard J. Nalbandian, III, Esquire, who, being duly sworn according to law, deposes and says that to the best of her knowledge, information and belief, the Defendants, Patricia A. Kuhn and Mervin Kuhn, are not known to be in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and subscribed to before me this day of June, 2014 NOTARY PURL C DEBGRAH AA B3ltrH4NAN Notary Public` State.pf,New Jersey �.: r My Corrimissio4E)cPireMugust 3, 2016 Richard J. Nalbandian, III, Esquire Attorney for Plaintiff Department of Defense Manpower Data Center Results as of : May -30-2014 09:34:08 AM SCRA 3.0 Status Report Pursuant to Servicerneribcrs Civil Relief Act. Last Name: KUHN First Name: PATRICIA Middle Name: A Active Duty Status As Of: May -30-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ' •. _ .. No '• N. NA This response This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I - - NA ` 1 No S NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ....NA' ..... - . ,r ' Nof , • 1 NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Ma power.Data Center,' based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 r The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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 was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARS), -Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA; as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: BALA2303R09FWE0 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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 was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: YAMFR383009FI60 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net GMAT LEGAL TITLE TRUST 2014-1, U.S. BANK, NATIONAL ASSOCIATION, AS LEGAL TITLE TRUSTEE Vs. NO 12-271 Civil Term CIVIL ACTION — LAW PATRICIA A. KUHN AND MERVIN KUHN WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $81,852.08 L.L.: Interest FROM 3/1/2012 (AT THE PER DIEM RATE OF $17.25) Due Prothy: $2.25 Other Costs: Atty's Comm: Atty Paid: $1,702.66 Plaintiff Paid: Date: 6/4/14 (Seal) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: RICHARD J. NALBANDIAN, 111, ESQUIRE Address: PARKER MCCAY P.A. 9000 MIDLANTIC DRIVE, SUITE 300 P.O. BOX 5054 MOUNT LAUREL, NJ 08054-1539 Attorney for: PLAINTIFF Telephone: 856-810-5815 Supreme Court ID No. 312653 File No. 15065-11-03414 / 15065-0059 PARKER McCAY P.A. By: Richard J. Nalbandian, 111, Esquire Attorney ID# 312653 9000'Midlantic Drive, Suite 300 P.O. Box 5054 Mount Laurel, NJ 08054-1539 (856) 810-5815 Attorneys for Plaintiff GMAT Legal Title Trust 2014-1, U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 Plaintiff, v. Patricia A. Kuhn and Mervin Kuhn 16.Peach Orchard Road Newville, PA 17241 Defendants. FILED -OFFICE CF THE PRO T HOMO AR'1' 2BI4 HDV 17 PIS 12: 56 CUPEERLAND NNSYLVCOUNTY AN A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 12-00271 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO PaR.C.P. 3129.2 STATE OF NEW JERSEY SS: COUNTY OF BURLINGTON I, Richard J Nalbandian, Esquire, of full age, being duly sworn according to law, upon my oath, depose and say, 1. True and correct copies of the Writ of Execution and Notice of Sheriff's Sale were served on Defendants, Patricia Ann Kuhn and Mervin Kuhn, by the Cumberland County Sheriff on September 26, 2014, at the mortgaged premises of 16 Peach Orchard Road, Newville, PA 17241, as is evidenced by the Sheriff's Return of Service that is attached hereto and made a part hereof as Exhibit "A". 2. True and correct copies of the Sheriff's Handbill of Sale were posted on the mortgaged premises at 16 Peach Orchard Road, Newville, PA 17241 on September 26, 2014, as is evidenced by the Sheriff's Return of Service that is attached hereto and made a part hereof as Exhibit "A" referenced above. 3. True and correct copies of the Notice of Sheriff's Sale of Real Estate to Lienholders, and other applicable notices with reference to the scheduled Sheriff's Sale, were sent to the following parties of interest on July 18, 2014 via U.S. First Class Mail, postage prepaid with certificates of mailing that are attached hereto and made a part hereof as Exhibit "B": Patricia A. Kuhn 16 Peach Orchard Road Newville, PA 17241 Mervin Kuhn 16 Peach Orchard Road Newville, PA 17241 GMAT Legal Title Trust 2014-1 U.S. Bank, National Association, as Legal Title Trustee 60 Livingston Avenue EP-MN-WS3ll St. Paul, MN 55107 LYNV Funding LLC c/o Phillip C. Warholic, Esquire 1200 Camp Hill Bypass Camp Hill, PA 17043 Carmel Financial Corporation c/o Charles F. Bennett, Esquire 4650 Baum Boulevard Pittsburgh, PA 15213 Asset Acceptance LLC c/o St'ott J. Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Big Spring School District Mable Stitt 2655 Walnut Bottom Road Carlisle, PA 17015 Penn Township Tax Collector Mable Stitt 2655 Walnut Bottom Road Carlisle, PA 17015 Cumberland County Tax Assessment 1 Courthouse Square Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations 13 North Hanover Street P.O. 13ox 320 Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 333 Health and Welfare Building Harrisburg, PA 17105 Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Dept. 28061 Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 Internal Revenue Service Federal Estate Tax Special Procedure Branch 1001 Liberty Avenue 13th Floor, Suite 1300, Pittsburgh, PA 15222 Commonwealth "of Pennsylvania Department of Revenue Bureau of Individual Taxes P.O. Box 280509 Harrisburg, PA 17128-0509 Tenants/Occupants 16 Peach Orchard Road Newville, PA 17241 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. Richard J. Nalbandian, III, Esquire Attorney for Plaintiff Sworn to and subscribed to before me this 1c9N-k" day of November, 2014 WORM E41.1CHANAN Notary Pubic atateef New Jersey, My Commissien Expires Augutit3, 2016 FXHIBIT "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Qf+uS,',ERIFF GMAT Legal Title Trust 2014 US Bank National Assoc vs, Patricia A. Kuhn (et al.) Case Number 2012-271 SHERIFF'S RETURN OF SERVICE 09/26/2014 07:15 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 16 Peach Orchard Road, Penn - Township, Newville, PA 17241, Cumberland County. 09/26/2014 07:15 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Deochption, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia A. Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland County. 08/26C3014 07:15 PM - Deputy Shawn GudaheU, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Mervin Kuhn at 16 Peach Orchard Road, South Middleton Township, Newville, PA 17241, Cumberland County. SHERIFF COST: $1,407.30 SO ANSWERS, November 12, 2014 RONNVRANDERSON, SHERIFF ^ -. y,!; `' FXHIBIT "B" Name and Address of Sender PARKER McCAY, PA 9000 Midlantic Drive, Suite 300, P.O. Box 5054 Mount Laurel, NJ 08053 Line Article Number Check type of mail or service: 4 ❑ Registered ❑ Express Mail ❑ Insured ❑ Recorded Delivery (International) [j Certified ❑ Return Receipt for Merchandise Affix Stamp Here (If Issued as a certificate of mailing, or for additional copies of this bill) Postmadc and Date of Receipt U.S. POSTAGE» PITNEY BOWES ZiP2 1 YV 08054 $ 006.50° 0 000 834k:IUL18. 2014. tiloz 8 I �n i 4/ f, Addressee Name, Street, and PO Address Postage Fee Handling Charge 1 Actual Value I Insured f SH 2 4 6 !Patricia A. Kuhn 16 Peach Orchard Road Newville, PA 17241 !Mervin Kuhn 116 Peach Orchard Road 'Newville, PA 17241 GMAT Legal Title Trust 2014-1 U.S. Bank, National Association 60 Livingston Avenue EP-MN-WS3D St. Paul, MN 55107 LVNV Funding LLC do Phillip C. Warholic, Esquire 1200 Camp Hill Bypass 1Camp Hill, PA 17043 'Carmel Financial Corporation i do Charles F. Bennett, Esquire ;4650 Baum Boulevard Pittsburgh, PA 15213 ifReoisteredf Value 1 Fee RD 1 RR Fee i Fee 1 Total Number of Pieces Listed ,Total Number of Pieces !Postmaster, Per (Name ofreceeiving employee) by Sender [Received at, Post Office 5 g Pp The full declaration of value is required or, all domestic and international registered mal. The maximum indemnity payable faiths Ireconstruction of nonnegotiable documents under Express Mall document reconstruction insurance is $500 per piece subjeeie additional lunitations for multiple pieces lost or damages in a single catastrophic occurrence. The maximum indemnity payarifi on Expt a Mail !merchandise is 5500. but optional Express Mad Service merchandise insurance is available for up to 55000 to some, but not _1 coumrw. !The maximum indemnity payable Is $25,000 for registered mail. See Domestic Mail Manual R901 S913, and $924, tor limit.=rrons of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on imemational maf:. Speclaf%r ndling. i charges apply only to Standard Mail (A) and Standard Mail (B) parcels. - PS Form 3877, June 2004 Complete by Typewriter, Ink, or Ball Point Pen 15065-11-03414 Kuhn,Patricia AL Name and Address of Sender ;Check type of mail or service: PARKER McCAY, PA ! ❑ Registered ❑Express Mail 9000 Midlantic Drive, Suite 300, P.O. Box 5054 ! ❑ Insured ❑ Recorded Delivery (International) Mount Laurel, NJ 08053 ❑ Certified ❑ Return Receipt for Merchandise Line i Artide Number U.S. POSTAGE» PITNEY BOWES Affix Stamp Here ssuad as a a mailing, or for additional copes of this WO Postmark and Date of Recei Ar Ida® ZIP 08054 002a 02 00013.76(} 18. 2014. 3 Addressee Name, Street, and PO Address r Postage Fee Handling Charge I Actual Value i Insured I SH j RD I RR i F Registered } Value Fee Fee I Fee Commonwealth of Pennsylvania Department of Revenue Bureau of Individual Taxes P.O. Box 280509 Harrisburg. PA 17128-0509 Tenants/Occupants 16 Peach Orchard Road Newville. PA 17241 4 6 7 Total Number of Pieces Listed !Total Number of Pieces by Sender Received at Post Office 2 Postmaster, Per (Name of receiving employee) i ! !The toil declaration of value is required on all domestic and iMernaional registered mail. The maximum indemnity_payable for:ihe reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $500 per pial`h subjecto additiehal limitations for multiple pieces lost or damages in a single catastrophic occurrence. The maximum indemnity payab-u on Expt ua Mail !merchandise is $500, but optional Express Mail Service merchandise insurance is available for up to 55000 to sorry ., but nodai countrioxl. !The maximum indemnity payable is $25,000 for registered mail. See Comesec Mail Manual R900, S913. and S920or Ymitslions of coverage on insured and COD mail. See International Mail Manual for hmitaticns of coverage on international mar. -Spederiandling !charges appty only to Standard Mail (.y end Standard Mail (B) parcels. PS Form 3877, June 2004 Complete by Typewriter, Ink, or Ball Point Pen 15065-11-03414 Kuhn,Patricia AL Name and Address of Sender PARKER McCAY, PA 9000 Midlantic Drive, Suite 300, P.O. Box 5054 Mount Laurel, NJ 08053 Check type of mail or service: ❑ Registered ❑ Express Mail ❑ Insured ❑ Recorded Delivery (International) ❑ Certified ❑ Return Receipt for Merchandise Affix Stamp Here issued as a certificate of mailing, orfor additional copies ofd,ia bill) Postmark and Dale of Receipt U.S. POSTAGE»PITNEY BOWES ZIP 08054 $ 007.800 02 11N 0 244 JUL. 18. 2014. SdSi I t� 111.8 20141,.. ,c Lire Article Number 'Asset Acceptance LLC c/o Scott J. Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Big Spring School District Mable Stitt '2655 Walnut Bottom Road ,Carlisle, PA 17015 (Penn Township Tax Collector j Mable Stitt 12655 Walnut Bottom Road !Carlisle, PA 17015 7Cumberland County Tax Assessme 11 Courthouse Square Carlisle PA 17013 Cumberland County Tax Claim Bu 1 Courthouse Square ,Carlisle, PA 17013 !Cumberland County Domestic Rely 13 North Hanover Street I I P.O. Box 320 i ! )Carlisle, PA 17013 I ; Addressee Name, Street, and PO Address Postage 6 7I i Total Number of Pieces Listed by Sender 6 Total Number of Pieces Received at Post Office PS Form 3877, June 2004 Fee Handling Charge Value if Registered Val Fee !Postmaster, Per (Name of receiving employee) IThe full deaaratlon of value is required on all domestic and international registered mat. The �L' maximum indemnity,ga'yuble fedthe reconstruction of nonnegobaole documents under Express Mail document reconstruction insurance is $500 per pieu subjerty addaimval limitations for multiple pieces lost or damages in a single catastrophic occurrence. The ;eardrum indemnify payab'alon Expels Nail imerchandise Is 5500. but optional Express Mal Service merchandise Insurance is available for up to $5000 to soi4t but noe S muntri f&. ITT* maximum indemnity payable is 525,000 tot registered malt See Domestic Mall Manual R9oc. S913. and S9 i'!br lima .inns of ieoverage on insured and COO mall. See beematonal Mail Manual for limitations of coverage on international mal.' SpaeletJiandlirg !charges appy only to Standard Mae (Al and Standard Val (B) parcels. Complete by Typewriter, Ink, or Ball Point Pen 15065-11-03414 Kuhn,Patricia AL Name and Address of Sender PARKER McCAY, PA 9000 Midlantic Drive, Suite 300, P.O. Box 5054 Mount Laurel, NJ 08053 Line i Article Number 'Check type of mail or service: ❑ Registered 0 Express Mail Insured ❑ Recorded Delivery (Int)ernational) Certified ❑ Return Receipt for Merchandise Affix Stamp Here (Ir issued as a certificate of mailing, or fat additional copes al this bill) Posbnark and Dale of Receipt U.S. POSTAGE» PITNEY BOWES 0417,41/14._:„. AzirImiamism/Nalliff=f0 ZIP 08054 $ 005.20° 0001376244 JUL. 18. 2014. • UC 1g � it z204lc' Addressee Name, Street and PO Address ;Commonwealth of Pennsylvania 1 !Department of Welfare 1333 Health and Welfare Building Harrisburg, PA 17105 2 Commonwealth of PA IBureau of Individual Tax Inheritance Tax Division !6th Floor. Strawberry Square !Dept. 28061 I Harrisburg, PA 17105 ;Department of Public Welfare ITPL Casualty Unit !Estate Recovery Program IP.O. Box 8486 1 Willow Oak Building !Harrisburg, PA 17105 6 !Internal Revenue Service ,Federal Estate Tax Special Procedure Branch Postage Fee i Handling Charge Actual Value if Registered Insured Value SH i Fee 71 Total Number of Pieces Listed by Sender 4 Total Number of Pieces Received at Post Office 11001 Liberty Avenue ;13th Floor. Suite 1300. !Pittsburgh, PA 15222 !Postmaster. Per (Name of receiving employee) RD 1 RR Fee 1 Fee I. i r t .The lull declaration of value is required on all dcmeeic and International registered mall. The maximum indemnity_payable tbi the reconstruclbn of nonnegotiable documents under Express Mal document reconstruction insurance is $500 per piea subjec10 edd"dioiW limitations for multiple pieces lost or damages in a single catastrophic occurrence. The maximum Indemnity payeboion Espies Mail merchandise is S505, but optora Express Mail Service merchandise insurance is avadabte for up to $5000 to soar. but nol9 country. The maximum indemnity payaule is 525.000 for registered mall See Domestic Mal Manual 8900, S913, and Snti{cr anbdans of Cr coverage on insured ono COD malt. Sea International Mall Manual for limitations of coverage on international malt.. Speciut andlirg charges apply only to Standard Mail (A) and Standard Mail (a) parcels. PS Form 3877, June 2004 Complete by Typewriter, Ink, or Ball Point Pen 15065-11-03414 Kuhn,Patricia AL