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HomeMy WebLinkAbout12-0301SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 4j'tp or curub", ?r { v: 2019. FEB -6 AM 9: 12 PENNSYLVANIAN Members 1st FCU vs. Taunya Lynn George (et al.) Case Number 2012-301 SHERIFF'S RETURN OF SERVICE 01/30/2012 03:40 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2012 at 1540 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert William George, by making known unto himself personally, at 298 Frost Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. rlie, vilroz TIM BLACK, DEPUTY 01/30/2012 03:40 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2012 at 1540 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Taunya Lynn George, by making known unto Robert W. George, Husband of Defendant at 298 Frost Road, Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. TIM K-NdK, DEPUTY 02/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 298 Frost Road, Gardners, Pennsylvania 17324, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. Request for service at 298 Frost Road, Gardners, Pennsylvania 17324 is only occupied by Robert and Taunya George, Husband and Wife. SHERIFF COST: $76.45 February 01, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (ci CcuntySuite Sheriff. T'eieosoft. (nc. Charles J. Hartwell. Esquire ID # 52655 1q M! ? -5 PM 1 ' 12 Dethlefs-Pykosh Law Group. LLC 9,U1L lii=? a 2132 Market Street Camp Hill. Pennsylvania 17011 ????'tL1?i? vi'i ?Telephone 7i 975-9446 PENNSYLVANI1\ Fax - (717) 975-2309 chartwell a,d plalaw.com Attorney for Defendants MEMBERS 1 FEDERAL COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No: 12-301 Civil Term TAUNYA LYNN GEORGE, a/k/a Civil Action - Law TAUNYA L. GEORGE, f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants ANSWER AND NEW MATTER AND NOW, comes Defendant, Taunya L. George, by and through her attorneys Dethlefs-Pykosh Law Group, LLC, by Charles J. Hartwell, Esquire, who answers the Plaintiff's Complaint, and aver as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, the alleged documents speak for themeselves. 5. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, the alleged documents speak for themeselves. 6. Denied. After reasonable investigation, answering Defendants are without information sufficient to form a belief as to the truth of this averment and the same are therefore denied. 7. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 8. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, answering Defendant is in the process of seeking hardship assistance through the Midwest Loan Services, Inc., Loss Mitigation Department. 9. Admitted in part and denied in part. To the extent that this paragraph avers that the identified documents are attached, the same is admitted. Insofar as this paragraph alleges the documents constitute legally sufficient notice, the same is denied as a conclusion of law. 10. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, answering Defendant is in the process of seeking hardship assistance through the Midwest Loan Services, Inc., Loss Mitigation Department. 11. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 12. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 13. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 14. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 15. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. WHEREFORE, the answering Defendant respectfully requests that Plaintiff s Complaint be dismissed with prejudice. NEW MATTER 16. The averments of paragraphs 1 through 15 are incorporated herein by reference as though set forth at length. 17. The Act 91 notice provided by Plaintiff was deficient in that it did not notify Defendants that they had thirty (30) days to have a face-to-face meeting with Plaintiff. 35 P. S. § 1680.40' c. 18. Accordingly, the Court lacks subject matter jurisdiction to entertain the instant mortgage foreclosure proceeding. i WHEREFORE, the answering Defendant respectfully requests that Plaintiff's Complaint be dismissed. Date: 0 ;'65 -/Z Respectfully Submitted, r ?. Charles J. Hartwell, Esquire I.D. # 52655 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Fax (717) 975-2309 See, Benefit Consumer Disc. Co. v. Vukmam, 2012 PA Super 18 (Pa. Super. Ct. 2012) MEMBERS 1" FEDERAL CREDIT UNION Plaintiff V. TAUNYA LYNN GEORGE, a/k/a TAUNYA L. GEORGE, f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 12-301 Civil Term Civil Action - Law VERIFICATION I, Taunya L. George, hereby verify that the statements of fact made in the foregoing documents are true and correct to the best of my personal knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. I? aunya L. eorge Date: ,,,? MEMBERS Isr FEDERAL CREDIT UNION Plaintiff V. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 12-301 Civil Term TAUNYA LYNN GEORGE, a/k/a Civil Action - Law TAUNYA L. GEORGE, Vk/a TAUNYA L. MOTTER and . ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant, Taunya L. George's, Answer and New Matter to Plaintiff's Complaint, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 Date: J\ am't` Respectfully Submitted, zo f Z- CIA-- Charles J. Hartwell, Esquire I.D. # 52655 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant Taunya L. George Q2 MAR 23 r l E?.? CUMBERLAND ;?? , PENNSYLVI?tiI" Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1" FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE PLAINTIFF'S PRELIMINARY OBJECTIONS TO DEFENDANTS' ANSWER AND NEW MATTER IN THE FORM OF A DEMURRER AND MOTION TO STRIKE PURSUANT TO Pa RCP 1028 (a)(4) FOR LEGAL INSUFFICIENCY OF THE PLEADING TO SET FORTH A DEFENSE OR STATE A CLAIM UPON WHICH RELIEF MAY BE GRANTED AND PURSUANT TO Pa R.C P (a)(2) FOR FAILURE OF PLEADING TO CONFORM TO LAW OR RULE OF COURT OR INCLUSION OF SCANDALOUS OR IMPERTINENT MATTER THIS DOCUMENT IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE BACKGROUND Plaintiff filed the instant complaint in foreclosure on January 24, 2012 (the "Complaint"). 2. Defendants filed their Answer And New Matter (the "Answer") to the Complaint in the above captioned matter on March 5, 2012, which Answer is incorporated herein by reference. II THIS COURT HAS PROPER JURISDICTION IN THIS MATTER IN SO FAR AS ACT 91 DOES NOT APPLY TO THE INSTANT FORECLOSURE 3. Paragraphs 1 and 2 are incorporated herein by reference as if set forth in full. 4. Effective August 27, 2011, and at all times relevant to the Complaint, Act 91 no longer applies to Plaintiff and, as of the date the Complaint was filed, Plaintiff remained free to file the instant foreclosure action without any further restriction or requirement of Act 91 pursuant to notice published by the Pennsylvania Housing Finance Agency in the Pennsylvania Bulletin (41 Pa.B. 3943) on July 16,2011. 35 P.S. Section 1680.409(c). 2 III EVEN IF ACT 91 DOES APPLY, WHICH IS DENIED, THE NOTICE UNDER ACT 91 IN THIS MATTER IS NOT DEFECTIVE 5. Paragraphs 1 through 4 are incorporated herein by reference. 6. Even if Act 91 applies to the instant matter, which is denied, contrary to Defendants' assertion, Act 91 does not require Plaintiff to notify Defendants that they have, "...thirty (30) days to have a face-to-face meeting with Plaintiff' (Defendant's New Matter, paragraph 17). Specifically, Act 2008-60 specifically amended 53 P.S. Section 1680.403c(b)(1) relied upon by Defendants to remove the requirement that the notice include the opportunity for a face-to-face meeting with the mortgagee. 2008 July 8, P.L. 841, No.60 Section 2, effective in 60 days[Sept.8, 2008]. 7. For some or all of the above reasons, Defendants' assertion at paragraph 18 of Defendants' New Matter that this Court lacks subject matter jurisdiction to entertain the instant mortgage foreclosure proceeding is without merit and contrary to law. For some or all of the above reason, paragraphs 16 through 18 of Defendants' New Matter ("Defendants' New Matter") and asserted legal insufficiency of the notice referred to in the second sentence of paragraph 9 of the Answer must be stricken for Defendants' failure to sufficiently plead a defense to the allegations set forth in the Complaint or a claim upon which relief may be granted pursuant to Pa. R.C.P Section 1028(a)(4). 3 9. For some or all of the above reasons, Defendants' New Matter and asserted legal insufficiency of the notice referred to in the second sentence of paragraph 9 of the Answer must be stricken for failure of the averments to conform to law or rule of court and/or said averments constituting scandalous or impertinent matter pursuant to Pa. R.C.P Section 1028(a)(2). WHEREFORE, Plaintiff, Members 1St Federal Credit Union, respectfully requests this honorable Court to: a. Strike, with prejudice, the allegations set forth in paragraphs 16 through 18 of Defendants' New Matter and the second sentence in paragraph 9 of the Answer; and, b. To order Defendants to reimburse Plaintiff for its reasonable legal fees incurred in connection with the prosecution of these Preliminary Objections. Respectfully submitted, Date: j- 2Z- ? ?_ r°'?`? ?-' U arl M. Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 4 03/13/2012 11:33 7179320317 KARLLEDEBOHM PAGE 06/06 MEMBERS 1 ST FEDERAL CREDIT UNION PLAINTIFF ` Vs. IN 'I'mo COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term TAUN YA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER a)id ROBERT WILLIAM GEORGE a/k/a ROBERT W., GEORGE DEFENDANT : CIM ACTION-LAW-MORTGAGE :FORECLOSURE V g,ZI+'ICATION I, Dan Summers, Collections Manager for Members I" Federal Credit Union, being authorized to do so on: behalf Of Members 1 °t Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief I understand that false statements are made subject to the penalties of 1.8 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. Members 1" Federal Credit Union By: Dan Summers, Collections Manager 5 Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS P ` FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 23`d day of March, 2012, I served a true and correct copy of the foregoing Plaintiff's Preliminary Objections to Defendants ' Answer and New Matter in the Form of a Demurrer and Motion to Strike upon the following by first class mail, postage prepaid, addressed as follows: Charles J. Hartwell, Esquire Attorney for Defendants 2132 Market Street Camp Hill, PA 17011 Date: March 23, 2012 )U1 Nd . Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 ? Q-'r s f rtN? tiOli?; IAA, Karl M. Ledebohm, Esquire i } P.O. Box 173 017)938 929 d, PA 17070-0173 C-101DERLAND COUNT( 'ENIHMANIA MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS CIVIL ACTION - LAW MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 23`d day of March, 2012, I served a true and correct copy of the Plaintiff's Preliminary Objections to Defendants' Answer and New Matter in the Form of a Demurrer and Motion to Strike filed on March 23, 2012 in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Carlisle, PA 17324 Date: March 23, 2012 Karl M. LedebohnT, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumbd, PA 17070-0173 (717)93$-0 99 r 2f3 ?j? •,?• 1% L) Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PRAECIPE FOR LISTING CASE FOR ARGUMENT To the Prothonotary of Cumberland County: List the within matter for the next Argument Court: MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE 1. Matter to be argued: Plaintiff's Preliminary Objections to Defendant's Answer with New Matter filed on 3/23/2012. 2. Identify all counsel who will argue cases: (a) Karl M. Ledebohm, Attorney for Plaintiff, P.O. Box 173, New Cumberland, PA 17070-0173. (b) Charles J. Hartwell, Attorney for Taunya L. George, 2132 Market Street, Camp Hill, PA 17011. 3. I will notify all parties in writing within two days that this case has been listed for argument. -> -) Jfo? ?- 7 -3 4. Argument Court Date: June 1, 2012. Date: March 28, 2012 arl M. ede ohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 } R.r' 0 f N, 0' Karl M. Ledebohm, Esquire F P.O. Box 173 `'?t? PRR r2 P 2: E e, New Cumberland, PA 17070-0173 "T IBERLAN COUNT' (717)938-6929 S.. PENNS YLV NIA MEMBERS FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. TAUNYAA LYNN GEORGE a/k/a TAL NYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term : CIVIL ACTION - LAW MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 30th day of March, 2012, I served a true and correct copy of the Praecipe for Listing Case for Argument filed on March 29, 2012 in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Charles J. Hartwell, Esquire Attorney for Defendant 2132 Market Street Camp Hill, PA 17011 Robert William George 298 Frost Road Gardners, PA 17324 Date: March 30, 2012 Karl {M. Ledebohm, Esq. ` Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 ??- Charles J. Hartwell, Esquire ID # 52655 r. •, 212 Ap -Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill. Pennsylvania 17011 ( ;'AI B E ?i l A. r '? J- C. ?J ? i (a i Telephone - (717) 975-9446 P E H N S Y LV ty N I F; Fax - (717) 975-2309 chartweli(W., ft1glaw.com Attorney for Defendants MEMBERS 1 FEDERAL COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. . No: 12-301 Civil Term TAUNYA LYNN GEORGE, a/k/a Civil Action - Law TAUNYA L. GEORGE, f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants AMENDED ANSWER AND NOW, comes Answering Defendant, Taunya L. George, by and through her attorneys Dethlefs-Pykosh Law Group, LLC, by Charles J. Hartwell, Esquire, who answers the Plaintiff s Complaint, and avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, the alleged documents speak for themeselves. 5. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By ways of further answer, the alleged documents speak for themeselves. 6. Denied. After reasonable investigation, answering Defendants are without information sufficient to form a belief as to the truth of this averment and the same are therefore denied. 7. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 8. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, answering Defendant is in the process of seeking hardship assistance through the Midwest Loan Services, Inc., Loss Mitigation Department. 9. Admitted in part and denied in part. To the extent that this paragraph avers that the identified documents are attached, the same is admitted. Insofar as this paragraph alleges the documents constitute legally sufficient notice, the same is denied as a conclusion of law. 10. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. By way of further answer, answering Defendant is in the process of seeking hardship assistance through the Midwest Loan Services, Inc., Loss Mitigation Department. 11. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 12. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 13. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 14. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. 15. Denied. The averments of the corresponding paragraph constitute conclusions of law to which no response is required. WHEREFORE, the answering Defendant respectfully requests that Plaintiffs Complaint be dismissed with prejudice. Respectfully Submitted, Date: C e -"- Charles J. Hartwell, Esquire I.D. # 52655 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 Fax (717) 975-2309 MEMBERS 1ST FEDERAL CREDIT UNION Plaintiff V. TAUNYA LYNN GEORGE, a/k/a TAUNYA L. GEORGE, Vk/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA No: 1.2-301 Civil Term Civil Action - Law VERIFICATION I, Taunya L. George, hereby verify that the statements of fact made in the foregoing Amended Answer are true and correct to the best of my personal knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. (??' 1""0' , Taunya L. G rge --?/ q /u, Date: MEMBERS 1sT FEDERAL COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No: 12-301 Civil Term TAUNYA LYNN GEORGE, a/k/a Civil Action - Law TAUNYA L. GEORGE, f/k/a . TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE Defendants CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant, Taunya L. George's, Amended Answer to Plaintiff's Complaint, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 Respectfully Submitted, Date: Charles J. Hartwell, Esquire I.D. # 52655 2132 Market Street Camp Hill, Pennsylvania 17011 Attorney for Defendant Taunya L. George T. Karl A Ledebohm, Esquire r i} Tr P.O. Box 173 R;s a New Cumberland, PA 17070-417i '' H: I 1 (717)938-6929 - Ida I MEMBERS 1 FEDERAL ` IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PLAINTIFF PENNSYLVANIA Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : NO.: 12-301 Civil Term : CIVIL ACTION -- LAW MORTGAGE FORECLOSURE NOTICE TO PLEAD To: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 You are hereby notified to file a written response to the enclosed Plaintiffs Motion for Summary Judgment as to Defendant Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter and for Judgment by Default as to Robert William George alk/a Robert W. George within thirty (30) days from service thereof or a judgment may be entered against you. _ Karl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff it • Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS I ST FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AS TO DEFENDANT TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER AND FOR JUDGMENT BY DEFAULT AS TO ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE 1 C AND NOW, comes Members 0 Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and moves this honorable Court, pursuant to Pa. R.C.P. et.seq. 1035.1 to enter summary judgment in favor of Plaintiff, Members 1St Federal Credit Union, for the relief requested in Plaintiff's complaint and avers in support thereof as follows: BACKGROUND Plaintiff, Members 1 st Federal Credit Union ("Members 1St"), filed its complaint in mortgage foreclosure (the "Complaint") in the above captioned matter against the above captioned defendants (collectively "Defendants") on January 24, 2012. 2. On February 22, 2012, Members 1St, through its attorney, provided to Defendants the notice of intent to enter judgment by default required under Pa. Rule of Civil Procedure 237.1. A copy of said notice and evidence of mailing is attached hereto as Exhibit "A" and made part hereof. 3. Defendant, Taunya Lynn George ("Defendant"), filed an Answer And New Matter (the "Answer") to the Complaint in the above captioned matter on March 5, 2012, to which Members 1St filed Preliminary Objections on March 23, 2012 (the "Preliminary Objections"). 4. In response to the Preliminary Objections filed by Members 1St, on April 9, 2012, Defendant filed an Amended Answer which no longer contains new matter (the "Amended Answer"). 2 5. As of the date hereof, co-defendant, Robert William George, ("Co- Defendant") has not filed any responsive pleading to the Complaint. II PLAINTIFF IS ENTITLE TO JUDGMENT IN THAT DEFENDANTS FAIL AND ARE UNABLE TO RAISE ANY DEFENSE TO THE ABOVE CAPTIONED ACTION IN MORTGAGE FORECLOSURE AND ADMIT EXPRESSLY OR BY IMPLICATION ALL MATERIAL ALLEGATIONS SET FORTH IN THE COMPLAINT 6. Paragraphs 1 through 5 are incorporated herein as if set forth in full. 7. Defendants fail and are unable to raise any defense what-so-ever to the cause of action and/or allegations set forth in the Complaint. 8. To the contrary, Defendant at paragraphs 2 and 3 of the Amended Answer specifically admits the following: a. That Defendants, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and Robert William George a/k/a Robert W. George (collectively "Defendants"), are adult individuals having a last known address of 298 Frost Road, Gardners, PA 17324; b. That she along with Co-Defendant on or about March 20, 2008 borrowed from and agreed to repay to Members 1 st ONE HUNDRED THREE THOUSAND AND 00/100 ($103,000.00) dollars (the "Loan"); c. That the Loan is evidenced by a Note executed and delivered to Members I" by Taunya George and Co-Defendant on March 20, 2008 (the "Note"); and, d. A copy of the Note is attached to the Complaint as Exhibit "A" and made part thereof. 9. Defendant fails to deny with any specificity what-so-ever and therefore admits by implication the averments set forth in the following identified paragraphs of the Complaint, all of which require a responsive pleading pursuant to Pa. Rule of Civil Procedure 1029(b): a. Paragraph 4: As security for the Loan, Defendants executed and delivered to Members 1St a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 298 Frost Road, Gardners, PA 17324 (the "Property"). A description of the Property is attached [to the Complaint] as Exhibit "B" and made part [t]hereof. b. Paragraph 5: On or about March 26, 2008, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office to Instrument No.: 200809009. A true and correct copy of the Mortgage is attached [to the Complaint] as Exhibit "C" and made part [t]hereof. c. Paragraph 6: The Mortgage has never been assigned by Members 1St and is still held by it as a valid and subsisting obligation of Defendant(s). d. Paragraph 7: The Mortgage is in default because Defendants have failed to deliver to Members 1St the monthly payments of principal, interest and escrow due thereon in the amount of $906.54 each for June, 2011 through 4 January, 2012, as more particularly described, in part, in the Act 91 Notice attached [to the Complaint] as Exhibit "D" and made part [t]hereof. e. Paragraph 8: Members 1St, through Midwest Loan Services, Inc., gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seg., and in particular section 403 thereof, and of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. SeMc ., by letter dated August 5, 2011, addressed to Defendants at the Defendants' last known address set forth in paragraph 2 [of the Complaint] via certified mail, return receipt requested. A copy of the said notice is attached [to the Complaint] as Exhibit "D" and made part hereof. £ Paragraph 9: Simultaneously, Members Is', through Midwest Loan Services, Inc., forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 8 [of the Complaint] by United States mail, first class, postage prepaid, bearing the return address of Midwest Loan Services, Inc. The Notices forwarded in said manner have not been returned to the offices of Midwest Loan Services, Inc., as undeliverable or otherwise. g. Paragraph 10: Simultaneously, Members 1st, through Midwest Loan Services, Inc., forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 8 [of the 5 Complaint] by United States mail, first class, postage prepaid, bearing the return address of Midwest Loan Services, Inc. h. Paragraph 11: Defendants are indebted to Members 1St in connection with the Mortgage in the amount of ONE HUNDRED FOUR THOUSAND EIGHT HUNDRED SEVENTY-FOUR AND 39/100 ($104,874.39) dollars itemized as follows: (i) Outstanding principal $97,722.95 (ii) Interest to January 17, 2012 5,120.60 (iii) Fees billed 2.50 (iv) Late Charge 248.99 (v) Defer Late Charges 284.56 (vi) Corporate Advance 716.74 (vii) NSF Check Fees 180.00 (viii) Less forbearance suspense (601.95) (ix) Attorney's fees 1,200.00 (x) Total due to Members 1st $104,874.39 i. Paragraph 12: Defendants also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendants would pay, in addition to the amounts set forth in paragraph 11 [of the Complaint], costs incurred by Members 1st as a result of the institution and prosecution of these legal proceedings. j. Paragraph 13: The obligation owed to Members 1st continues to accrue interest at the rate of $19.75 per day, through the date of payment 6 including on and after entry of judgment on this complaint and continues to accrue attorney's fees and costs. k. Paragraph 15: As set forth above, Members 1" has made demand upon Defendants to cure the default under the Mortgage. However, as of the date [of the Complaint], Defendants continue to fail and refuse to cure the default. 10. The averments set forth in paragraphs 4 through 15 of the Complaint are deemed admitted pursuant to Pa. Rule of Civil Procedure 1029(b) as a result of Defendant's failure to deny such averments with any specificity what-so- ever. 11. It is well settled that bald, unsupported denials of the amounts claimed to be due under the Mortgage in the context of the instant action in mortgage foreclosure do not suffice to avoid the granting of Members I"' s motion for summary judgment. New York Guardian Mortgage Corp. v. Deitzel, 362 Pa. S. Ct. 426, 429, 582 A. 2d 951, 952 (1987). 12. As set forth in the affidavit executed by Dan Summers, Collections Manager for Members I", attached hereto as Exhibit "B" and made part hereof and as set forth in the affidavit executed by Laura Zerbst, Director of Personal Relationships for Midwest Loan Services, Inc., attached hereto as Exhibit "C" and made part hereof (collectively the "Affidavits"), all averments set forth in the Complaint are true and correct. 7 13. As set forth in the Affidavits, the amount due to Members 1St under the Mortgage and the Note as of April 30, 2012 is $108,600.62 itemized as set forth in the Affidavits. 14. As set forth in the Affidavits, Defendants continue to be in default of their obligations under the Mortgage and the Note and continue to fail and refuse to pay to Members I"' s the amounts due under the Mortgage and the Note. 15. Members 1St is entitled to judgment against Co-Defendant for Co-Defendant's failure to timely file a responsive pleading to the Complaint within twenty (20) days of service of the Complaint and within ten (10) days after the notice of intent to enter default judgment required under Rule 237.1 was provided to Co-Defendant. 16. For some or all of the above reasons, Defendants fail and are unable to put forth any defense to the instant action in mortgage foreclosure and there exists no genuine issue of any material fact as to a necessary element of the instant foreclosure action which could be established by additional discovery or expert report and which would require any issue to be submitted to a jury. 17. The relevant pleadings in this matter are closed and the filing of this motion will not unreasonably delay trial. WHEREFORE, Plaintiff, Members 1St Federal Credit Union, requests this honorable Court enter judgment, In Rem, in favor of Members 1St Federal Credit Union and against Defendants, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter, and Robert William George a/k/a Robert W. George in the amount of ONE HUNDRED EIGHT THOUSAND SIX HUNDRED AND 62/100 ($108,600.62) 8 dollars plus interest at the rate of $19.75 per day from April 30, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. Respectfully submitted, f c .-7 f 3f r f Date: Al L." karl M. Le ebohm, Esq. Supreme Court ID 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 9 Karl M. Ledebohm. Esquire P.O. Box 173 New Cumberland, PA 1 7070-0 1 7 3 (717)938-6929 MFNIBF'RS I. FLDERAL CR1"D1I l N1ON PLAINTIFF Vs. IN 111E COURT OF COMMON PLEAS CUMBERLAND COUN Il PENNSYLVANIA NO.: 12-301 Civil Term "I AUNYA LYNN GEORGE a/k/a II'AUNYA L. GEORGE f/k/a 'I'AUNYA L. MOTTF:R and ROBER 1' W11_,LIAM GEORGE a/k/a ROBI"R1' W. GEORGE DEFENDANTS Date: February 22, 2012 CIVIL. ACTION - LAW N1OR'I'GACil FORLCLOSt.IRI_:' IMPORTANT NOTICE TO: 'I'aunya Lynn George a/k/a II aunva L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners. PA 17324 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 1 AM REQUIRED 1'0 INFORM YOU THAT THIS OFFICE IS A DEBT COLLECTOR AND THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. YOU ARE IN DEFAULT BECAUSE YOU ILAVE FAILED TO ENTFR A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN EXHIBIT "A" \VRITING WITII THE COURT' YOUR DEFENSES OR OBJECTIONS TO TIII,- CLAIMS SIA' FORI'11 AGAINS'l YOU. UNI.I.SS YOU ACT WITHIN TFN DAYS DRUM "I'HI: DATE OF THIS NOTICE, A JtJDGMEN-l MAY BE ENTI`RI_ D AGAINST YOU WITHOUT A HI?ARING AND YOU MAY LOSE YOt JR PROPI'Wl'Y OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TI-IIS PAPER TO YOUR LAWYER AT ONCI". 11 YOU DO NOT I-IAVF. A LAWYER, GO TO OR TELI:PHONL THE OFI IC1?: SI:,1I'ORTH BELOW. THIS OFFICE CAN PROVIDE YOU WIT11 INFORMATION ABOt' L HIRING ;1 L.AWYE:R. IF YOIJ CANNOT AEI ORD 1'0 HIRI: A LAWYER, THIS OI`FICE NIAI' BE AB -1_ 1'0 PROVIDE YOtJ WITH INFORMATION ABOt_JT AGENCIES "I'1IA'I'MAY OFFER I.EGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED 111" OR NO I? I-,' L'. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 Respectful(y submitted. rDate: I"6111ary 2-2.20 12 Karl M. Leda bohm 1=sy Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff - 1. ?z 0x ? 0 o 0 mN I: G y ? N Kart M. l,edebohni. Esq. P.O. Box 173 PA 17070-01 73 New Cumberland . ; . 1 0 ? C I o'VT DW 12? (n . N ONJOOD Robert William George a/k/a a) Z-.J:DOO ??C?f° George Robert W oLXJ N Z D m . 298 Frost Road =° 'Gardners, PA 17324 03 y O " O m N furl M. Ledebohm. f sq. P.O. Box 173 New Cumberland. PA 17070-O17 Fri 7- M t C o W C? w TaUnya Lynn George a/k/a N~? ONJCCID WCNO(T1.-'D Q7 ?? Z• J'L700 C?r Taunya L. George o?..f1 N A c5 :M" 298 Frost Road m Gardners, PA 17324 MEMBERS 1sT FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE AFFIDAVIT I, Dan Summers, Collections Manager for Members l St Federal Credit Union ("Members 1St"), the Plaintiff in the above captioned matter, being duly sworn, do hereby depose and say as follows: 1. That I have been an employee of Members 1St for five (5) years and am the account officer that is responsible for the collection of the loan (the "Loan") evidenced by the Mortgage (the "Mortgage") and the Note (the "Note") as set forth in the Complaint in Mortgage Foreclosure filed on January 24, 2012, in the above captioned matter (the "Complaint'). 2. That my responsibilities as Collections Manager include reviewing the records of Members 1St and its loan servicer, Midwest Loan Services, Inc., for the purpose of determining the amount due to Members 1St by a borrower. 3. That I have examined the records of Members 1St and Midwest Loan Services, Inc., in connection with the Loan and hereby certify that the complaint accurately set forth the amounts due to Members 1St at that time. 4. That the amount currently due to Members 1St under the Mortgage and the Note as of April 30, 2012 including interest, legal fees, costs and other charges is in the amount of $108,600.62, itemized as follows: a. Outstanding principal b. Interest to April 30, 2012 $97,722.95 7,179.11 1 EXHIBIT "B" c. Fees billed 2.50 d. Late Charge 0.00 e. Defer Late Charges 675.83 f. Corporate Advance 1,094.44 g. NSF Check Fees 180.00 h. Less forbearance suspense (601.95) i. Attorney's fees 2,347.74 j. Total due to Members 1St $108,600.62 5. That a true and correct copy of Members O's records evidencing the amount due under the Loan by Defendants as of April 30, 2012, exclusive of legal fees and costs of suit is attached hereto as Exhibit "A" and made part hereof. 6. That the debt due to Members 1St under the Mortgage and the Note continues to accrue interest at the rate of $19.75 per day through the date of payment and including on and after the entry of judgment on the Complaint and continues to accrue late charges, attorney's fees and other charges collectible under the Mortgage and the Note. 7. That, as of the date of the filing of the Complaint, Defendants were in default of their obligations under the Note and the Mortgage for, among other reasons, failure to deliver to Members 1St the monthly payments of principal, interest and escrow due thereon in the amount of $906.54 each for June, 2011 through January, 2012, as set forth in paragraph 7 of the Complaint. 8. That the Note and the Mortgage attached to the Complaint as Exhibits "A" and "C" respectively are true and correct copies of the Note and the Mortgage signed and delivered to Members 1St in connection with the Loan. 9. That, as of the date hereof, Defendants continue to be in default of their obligations under the Mortgage and the Note and continue to fail and refuse to pay to Members Is" s the amounts due under the Mortgage and the Note. 10. That all remaining averments set forth in, and exhibits attached to, the Complaint are true and correct. 2 Signed and sworn this Z 7 day of April, 2012. Sworn to and subscribed before me, the day and year aforesaid. E Notary Public My Commission Expires: Members 1St Federal Credit Union, By: 0- J - /? Dan Summers, Collections Manager COMMONWEALTH OF PENNSYLVANIA Notarlal Seal Laura L. Hoke, Publk Upper Allen Twp., Cumba and County MY Carnnfton Jan. 25, 2035 MEMBER, PENNSYLVANIA ASSOUATWN OF NOTARIES MEMBERS 1ST FCU c/o Midwest Loan Services, Inc. 616 Shelden Avenue, suite 300 PO Box "144 Houghton MI 49931-0144 (600) 262-6574 April 24, 2012 Payoff Statement Send to: MEMBERS 1ST DAN SUMMERS GARDNERS, PA 17324 Loan Number-70706 State-PA Loan Type-CONY UNIS Investor-599 Pool# I Please refer to our loan number on all correspondence. This statement reflects the amount needed to prepay this mortgage in full. ONLY CASHIERS CHECK OR WIRED FUNDS ARE ACCEPTABLE FOR FINAL PAYMENT. The monthly mortgage payments should be made in the normal manner as the fact that the loan is in the process of being paid in full does not affect the responsibility of making scheduled payments. WARNING: This loan is presently in foreclosure proceedings. ------------------------------------------------------------------------------- Mortgagor Name: TAUNYA L GEORGE Next Payment Due Date: 6/01/11 ROBERT W GEORGE Interest Paid To Date: 5/01/11 Property Addr: 298 FROST RD Mailing Addr: 298 FROST RD GARDNERS, PA 17324 GARDNERS, PA 17324 -------------------------------------------------------------------------------- * Statement of Account interest is collected to the date of the receipt of the payoff funds. Please allow for mailing time. Any funds over the payoff amount will be be applied to your escrow account, and be returned when we receive the cancelled documents from the investor. Unpaid Principal 97,722.95 Interest Due 7,179.11 (From 5/01/11. at 7.375%) Fees Billed of 2.50 Forebearance Suspense 601.95 Defer Late Charges 675.83 Corporate Advance 1,094.44 ------------------------------------ NSF Check Fees of 180.00 Prin and Int 711.40 Mthly Escrow Dep 195.14 Recording/Recon Fee 65.00 Quote Fee 30.00 ---------------- --------------- Balance Due 106,347.88 Mortgage Payment 906.54 By 4/30/12 If paid after this date please add: If applicable, a Monthly Late Charge of 35.57 Per Diem Interest of 19.75 ---------------------------------------------------------------------------------- Estimated Disbursements: Amount Income Tax Information HAZARD INS 640.00 TOWNSHIP TAX 377.70 Interest Paid YTD .00 SCHOOL 1,405.48 Hazard Ins Policy# 38-CE-3083-1 Coverage Amount 148,500 -------------- ---------------------------------------------------------------- We reserve the right to correct any portion of this statement at any time. Ail balances may change if a payment becomes due, a payment is made, or a payment is reversed- We will also continue to pay escrow disbursements as they become due, unless we -+-^ notified otherwise. Affidavit Exhibit "A" MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION-LAW-MORTGAGE FORECLOSURE AFFIDAVIT I, Laura Zerbst , DOPR for Midwest Loan Services, Inc., ("Midwest"), being duly sworn, do hereby depose and say as follows: 1. That I have been an employee of Midwest for 12 years and am the officer that is responsible for maintaining and reviewing the receipt and disbursement records of Midwest as the servicing agent for Members 1 S` Federal Credit Union ("Members 1 S`") in connection with the loan (the "Loan") evidenced by the Mortgage (the "Mortgage") and the Note (the "Note") as set forth in the Complaint in Mortgage Foreclosure filed on January 24, 2012, in the above captioned matter (the "Complaint"). 2. That my responsibilities as such officer include reviewing the records of Midwest for the purpose of determining the amount due to Members 15` by a borrower. 3. That I have examined the records of Midwest in connection with the Loan and hereby certify that the complaint accurately sets forth the amounts due to Members 15L 4. That the amount currently due to Members 1 S` under the Mortgage and the Note as of April 30, 2012 exclusive of legal fees and costs is in the amount of $106,252.88, itemized as follows: a. Outstanding principal $97,722.95 b. Interest to April 30, 2012 7,179.11 c. Fees billed 2.50 EXHIBIT "C" d. Late Charge 0.00 e. Defer Late Charges 675.83 f. Corporate Advance 1,094.44 g. NSF Check Fees 180.00 h. Less forbearance suspense 601.95 i. Total due to Members 1St $106,252.88 5. That a true and correct copy of Midwest's records evidencing the amount due under the Loan by Defendants as of April 30, 2012 exclusive of legal fees and costs is attached hereto as Exhibit "A" and made part hereof. 6. That the debt due to Members 1 St under the Mortgage and the Note continues to accrue interest at the rate of $19.75 per day through the date of payment and including on and after the entry of judgment on the Complaint and continues to accrue late charges, attorney's fees and other charges collectible under the Mortgage and the Note. 7. That, as of the date of the filing of the Complaint, Defendants were in default of their obligations under the Note and the Mortgage for, among other reasons, failure to deliver to Members 1St, through its servicing agent, Midwest, the monthly payments of principal, interest and escrow due thereon in the amount of $906.54 each for June, 2011 through January, 2012, as set forth in paragraph 7 of the Complaint. 8. That the last payment received by Midwest in connection with the Mortgage and the Note as on 7-11-2011 in the amount of 1,792.11 9. That Midwest Loan Services, Inc., gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. SeMc ., and in particular section 403 thereof, and of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. seq., by letter dated August 5, 2011, addressed to Defendants at the Defendants' last known address set forth in paragraph 2 of the Complaint via certified mail, return receipt requested. 10. That a true and correct copy of the said notices is attached to the Complaint as Exhibit "D" and made part thereof and hereof by reference. 2 11. That a true and correct copy of the US Postal Service confirmations evidencing the mailing of said Notices is attached to the Complaint as Exhibit "B" and made part thereof and hereof by reference. 12. That on August 5, 2011, Midwest, forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 9 above by United States mail, first class, postage prepaid, bearing the return address of Midwest Loan Services, Inc. The Notices forwarded in said manner have not been returned to the offices of Midwest Loan Services, Inc., as undeliverable or otherwise. Signed and sworn this 24 day of April, 2012. Midwest Loan Services, Inc., } By: Laura Zerbs Sworn to and subscribed before me, the day and year aforesaid. otar ubli Kelly M Dubois My Commission Expires: 7-1 -1 ARIXY 0 MOSOIS a jMWy AUgUC-WCK4GAN 4tpW,HTDtj-CQUNTY *.Y' M {%WWWi F:' JUL'Y•;19, 2043 3 MEMBERS IST F-'U Midwest Lo,,n Services, Inc. 616 `;he-der Avenue, Su:te jJ PC Box 144 Houghton M. 4-'931-0144 1800) .,62-6J/4 April 24, 2°i12 Payoff Statement >enc to: MEMBERS IST DAN SUMMERS GARDNERS, PA 1'324 Loan Number-i0/06 Stat -e - PA LoarType--CONV UNIS ii vestor-599 Poo_# i P-ease refer to our?oan number on a_! correspondence. Phis statement- reflects the amount needed to prepay this mortgage n fu- ONLY CASHIERS CHECK OR WIRED FUNDS ARE ACCEPTABLE FOR FINAL PAYMENT. The monthly mortgage payments should be made in the normai manner as the fact that the roan :s in the process of being paid in ful? does not affect the -espcnsibiiity of mak_ng scheduled payments. WARNING: This loan is presently in for ec_osure proceedings o- Name: TAUNYA L M * = -- GEORGE ---------------------------- Next Payment Due -- Date : 6/01/11 q cr _q ROBERT W GEORGE Interest Paid To Date : 5/01/11 Property Add-: 298 FROST 3D Ma--ing Addr: 298 FROST RD GARDNERS, -A 1/324 GARDNERS, PA 1/324 Statement of Account -m Brest is collected to the date of the rece'-pt of the payoff funds. Please allow for mailing time. Any funds over the payoff amount writ. be he appl'ed to your escrow account, and be ret,.rrned when we rece-ve tr:e canoe-led documents from the investor. Unpaid Pr-nc;pa_ 97 722.95 -nterest Due 1,179.11 (From -:%01'11 at 375x) Fees B` lieu if 2 t Forebearance S,isper,se E 01 °, Defer- Late Ct:afges 6 /5.83 ?orc)orate Advance 1,C94.44 - - - - --- - - - - - - - - - - - - - - - - - - - - - - - - - NSF ;heck Fees of 180.00 Prin and Int -11.40 Mth-y Escrow )ep 95.14 Recording/Recon Fee '05.00 Quote Fee 30.00 ------ --------- --------------- Ba_ance Due 106,347.88 Mortgage Payment 906.59 By 4130 12 If pa'_d afte_ this date please add: If applicable, a Monthly Late -ha-ge of 35.5-1 Per Diem Interest of 19.15 ---------- ----------------- Estimated Disbursements: Amount Cncome Tax __:itormation HAZARD INS 640.00 TOWNSHIP TAX 37%./0 Interest Paid YTD 00 SCHOOL 1,405.48 0 Hazard Ins P-,-i-y# 38-CE-3083-1 Coverage Amount 48,?0 We ese? e the -fight to correct any portion. cf t[-is statement. at ans tirre. b?L - ai,ces may chance -f a paIme ii ± be<,omes due, a paymen- >> ma 1 a p ,vment _ , -e,%ersed. Je nt _. r - pa - _ n d_sb _sement as t h e v become due, un ess we a-, e notif ed other r Affidavit Exhibit "A" MEMBERS IST FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE VERIFICATION I, Dan Summers, Collections Manager for Members 1St Federal Credit Union, being authorized to do so on behalf of Members 1St Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Members 1St Federal Credit Union By: Dan Summers, Collections Manager 10 Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1" FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 12-301 Civil Term CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 2"d day of May, 2012, I served a true and correct copy of Plaintiff's Motion for Summary Judgment as to Defendant Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and for Judgment by Default as to Robert William George a/k/a Robert W. George in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Gardners, PA 17324 Date: May 2, 2012 Charles J. Hartwell, Esquire Attorney for Taunya Lynn George 2132 Market Street Camp Hill, PA 17011 Resp?c ly sub ` j arl M. Le ebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 C,?/AL PENNSYLVANIA Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1'3' FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term CIVIL ACTION - LAW : MORTGAGE FORECLOSURE PRAECIPE TO REMOVE CASE FROM ARGUMENT LIST To the Prothonotary of Cumberland County: Please remove the above captioned matter from the argument list for June 1, 2012. Defendant filed an Amended Answer rendering the Preliminary Objections filed by Plaintiff and scheduled for argument moot. Date: May 7, 2012 Respect ly sub arl M. Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I" FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term CIVIL ACTION -- LAW MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 8t' day of May, 2012, I served a true and correct copy of foregoing Praecipe to Remove Case from Argument List upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Gardners, PA 17324 Charles J. Hartwell, Esquire Attorney for Taunya Lynn George 2132 Market Street Camp Hill, PA 17011 Date: May 8, 2012 ,Karl A Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 ? r _q Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PRAECIPE FOR LISTING CASE FOR ARGUMENT To the Prothonotary of Cumberland County: List the within matter for the next Argument Court: MEMBERS IST FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term : CIVIL ACTION - LAW MORTGAGE FORECLOSURE 1. Matter to be argued: Plaintiff's Motion for Summary Judgment as to Defendant, Taunya Lynn George, and for Judgment by Default as to Defendant, Robert William George. 2. Identify all counsel who will argue cases: (a) Karl M. Ledebohm, Attorney for Plaintiff, P.O. Box 173, New Cumberland, PA 17070-0173. (b) Charles J. Hartwell, Attorney for Taunya Lynn George, 2132 Market Street, Camp Hill, PA 17011. IUoI ?? a-) y3a 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: July 13, 2012. Date: June 4, 2012 `tt- ( ? - Karl M. edebohm, Esq. 1 Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Karl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1" FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I. Karl M. Ledebohm, Esquire, hereby certify that on the 5th day of June, 2012,1 served a true and correct copy of Praecipe for Listing Case for Argument on Plaintiff s Motion for Summary Judgment as to Defendant Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and for Judgment by Default as to Robert William George a/k/a Robert W. George in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Gardners, PA 17324 Charles J. Hartwell, Esquire Attorney for Taunya Lynn George 2132 Market Street Camp Hill, P* 17011 Date: June 5, 2012 karl M. Ledebohm, Esq. - Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff V. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N ? rT1 ? NO. 2012 - 0301 CIVIL TERM Z? N ca r? co • c.?a IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT BEFORE GUIDO, PLACEY, JJ. ORDER OF COURT AND NOW, this 27TH day of JULY, 2012, upon consideration of Members 1St Federal Credit Union's Motion for Summary Judgment and argument held thereon, it is hereby ORDERED THAT judgment, IN REM, is hereby entered against Defendants Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter, and Robert William George a/k/a Robert W. George in the amount of one hundred eight thousand six hundred dollars and sixty two cents ($108,600.62) plus interest at the rate of $19.75 per day from April 30, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. B Court, -- C-7-1 ?- Edward E. Guido, J. ? Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, Pa. 17070 ? Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, Pa. 17011 ? Robert W. George 298 Frost Road Gardners, Pa. 17324 Court Administrator sld Cpl ;ei ma-led glah? 4 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 J' FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS ~''~ ~N£ F'R€~T#1IIN~TE~ii` 212 SEP -4 PM i ~ i 5 ~i1MB~.Rl.ANO G4UNTY PENi~SY~.V,~NlA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendants, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and Robert William George a/k/a Robert W. George, in the amount of ONE HUNDRED EIGHT THOUSAND SIX HUNDRED AND 62/ 100 DOLLARS ($108,600.62) plus interest at the rate of $19.75 per day from Apri130, 2012 through the date of judgment as well as on and after entry of judgment until the date of payment, additional attorney's fees and costs of suit and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to the Order of Court ate} ~1lQ.Sv C.k ~ (l~(,o q ~~ ago~t~3 Notice ~~~~ dated July 27, 2012 and filed in the above captioned matter by the Court on August 2, 2012, a copy of which is attached hereto as Exhibit "A" and made part hereof. Date: September 3, 2012 Karl M. l,edebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff MEMBERS 1 ST FEDERAL CREDIT UNION, Plaintiff V . TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE, Defendant IN THE COURT OF COMMON PLEAS QF CUMBERLAND COUNTY, PENNSYL IPr°' _~ "~~. . `~ ~ t - --= i r NO. 2012 - 0301 C'1V11. ~f1:RM IN RE: PLAINTIFF' S MOTION FOR SUMMARY JUDGMENT BEFORE GUIDO. PLACEY. JJ. ORDER OF COURT AND NOW, this 27TH day of JULY, 2012, upon consideration of Members 1 S` Federal Credit Union's Motion for Summary Judgment and argument held thereon. it is hereby ORDERED THAT judgment, IN RF,M, is hereby entered against Defendants Taunya Lynn George aJk/a Taunya L. George t71:/a "l~aunya 1.. Motter, and Kuhert William George a/k/a Robert W. George in the amount of one hundred eight thousand six hundred dollars and sixty two cents ($108,600.62) plus interest at the rate of $19.75 per day from April 30, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. By Court, l d~~ard 1~;. (~uii3c;..l Exhibit "A" Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, Pa. 17070 Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, Pa. 17011 Robert VV. George 298 Frost Road Gardners, Pa. 17324 Court Administrator sld t~~= TE~~ ~R~~NO~~iT~n~~~;; Karl M. I,edebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 7~~2 SEP -4 PM I. 15 ~~'~*r~va-~anTv MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MII,ITARY SERVICE The undersigned hereby swears and affirms on behalf of Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiffs knowledge, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter and Robert William George a/k/a Robert W. George are not currently on active military service. Date: September 3, 2012 ,`~2~ azl M: Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff (4) and against N/A Garnishee (s); (5) and index this writ against Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter, 298 Frost Road, Gardners, PA 17324, Defendant; and Robert William George a/k/a Robert W. George, 298 Frost Road, Gardners, PA 17324, Defendant; (6) and against N/A Garnishee (s), and levy upon and seize the following real property of Defendants and index this writ against the following real property of Defendants as a lis pendens: All that certain real estate and improvements erected thereon situate in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 298 Frost Road, Gardners, PA 17324 and as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof by reference. Dated: August 29, 2012 ~ Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN pazcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: On the north by the road, No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particulazly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwazdly 181 feet to a point; thence northwazdly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwazdly 135.5 feet to a point where said road bears southeast; thence southeastwazdly 96 feet to a point; thence southwazdly 41 feet to a point in the center of the Frost Road; thence west 16 '/2 feet to a post, the place of BEGINNING. HAVING thereon erected a 1 '/2 story frame dwelling house known and numbered as 298 Frost Road, Gazdners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Molter, husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George, husband and wife, as joint tenants with right of survivorship. TAX PARCEL N0.40-39-2214-005 EXHIBIT "A" Kazl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717~I38-6929 cis Y~E ~~t~THt3i~~~t-~~~' Zs~2 SEP -4 PM ~ ~ 19 MEMBERS 1" FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS ~~ RT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1st Federal Credit Union, plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 298 Frost Road, Gardners, PA 17324. 1. Name and address of owner(s) or reputed owner(s): Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 2. Name and address of defendant(s) in the judgment: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gazdners, PA 17324 Taunya Lynn George c/o Chazles J. Hartwell, Esquire 2132 Mazket Street Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1St Federal Credit Union Attn.: Lynn Unger, Bankruptcy Specialist 5000 Louise Drive Mechanicsburg, PA 17055 Cumberland County Adult Probation 1 Courthouse Square Cazlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Members 1St Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 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: Cumberland County Tax Claim Bureau One Courthouse Square Cazlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 298 Frost Road Gardners, PA 17324 U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: August 29, 2012 // i arl M. L,edebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PRQTf~Qh~~~'~~`t ~~ ~ ~~12 SEP -4 PM i ~ 19 CUM Y ~ ~ ~~~ ~ Y 1~~ MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF V s. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 298 Frost Road, Gardners, PA 17324, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sherii~s Sale on December 5, 2012 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $108,600.02 plus interest at the rate of $19.75 per day from Apri130, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back payments, late charges, costs and reasonable attorney's fees, if any, due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929. 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 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 fmd out if this has happened, you may call the Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) 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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before January 4, 2013 (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 The Sheriff's phone number is: (717)240-6390. f /, ~ / /~-. Karl M. ~L,edebohm, Esquire ~' Supreme Court ID #59012 P.O. Box 173 %~ New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania, more particulazly described as follows: On the north by the road, No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particulazly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwazdly 181 feet to a point; thence northwazdly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwazdly 135.5 feet to a point where said road bears southeast; thence southeastwazdly 96 feet to a point; thence southwazdly 41 feet to a point in the center of the Frost Road; thence west 16 '/2 feet to a post, the place of BEGINNING. HAVING thereon erected a 1 '/2 story frame dwelling house known and numbered as 298 Frost Road, Gazdners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Molter, husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George, husband and wife, as joint tenants with right of survivorship. TAX PARCEL N0.40-39-2214-005 EX~IIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~ C ~~~' Ronny R Anderson C.n r- iv ~,. ~:7 Sheriff ~tihtr ©t ~ua~berl~ '...{-.2%~ ~ .~ -~ ~=- ¢ Jody S Smith ~' ~ ~ ~$ ~ ~ ~ r> ~ Chief Deputy ~ ~ ~ `r ~~~ ~ c,~ ~ ,~ c Richard W Stewart ~ c_~ SOIICItO! pFF~CEPTFF a"dRIFF _r; {/'..,~ Members 1st Federal Credit Union Case Number vs. 2012-301 Taunya Lynn George (et al.) SHERIFF'S RETURN OF SERVICE 09/27/2012 07:12 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 298 Frost Road, South Middleton Township, Gardners, PA 17324, Cumberland County. 09/27/2012 07:12 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Notice and Description, in the above titled action, by making known its contents and at the same Writ , time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Taunya Lynn George at 298 Frost Road, South Middleton Township, Gardners, PA 17324, Cumberland County. 09/27/2012 07:12 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contenfs and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Robert William George at 298 Frost Road, South Middleton Township, Gardners, P14 17324, Cumberland County. 10/26/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $637.91 SO ANSWERS, November 20, 2012 RON R ANDERSON, SHERIFF ~~.5 ~G'/ g ~~ P`~ ~L cl~~ ~` ~ ~ (c ~ountyS;iite Sheriff, Teleosoft, in:. On September 5, 2012 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberl-and County, PA, known and numbered 298 Frost Road, Gardners, PA 17324 fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2012 By: CQ.u,.c Claudia Brewbaker, Real Estate Coordinator b Z ~ZI c~ S ° d3S 1101 vd t.~°i: ~ ~~1 a30 . WRIT OF EXECUTION andJor ATTACHMENT Cd1~MONWEALTH OF PENNSYLVANIA) NO. 12-302 Civil COUNTY OF CUMBERLAND) CIWIL ANION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEIVIBERS 1sT FEDERAL CREDIT UNION Plaintiff (s} From TAUNYA LYNN GEORGE A/K1A TAUNYA L. GE41~GE F/I~JA TAUNYA L. MATTER AND ROBERT WILLIAM GEORGE A/IUA ROBERT W. GEORGE (1} You are directed to levy upon the property of the defendan# (s)and to sell SEE LIaGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEES} as follows: and to notify the garnishee(s) that: (a} an attachment has beemissued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the deferrelant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendants}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: $108,600.62 L.L.; $.50 Interest FROM 4/30/2012 AT THE RATE OF $19.75 PER DAY TO BE A-DED Atty's Comm: % Due. Prothy: $2.25 Atty Paid: $~ (,~-~. yt~ Other Casts: Plaintiff Paid: Date: 9/4/2012 (Seal) REQUESTING PARTY: Name: KARL M. LEDEH~UIIM, ESQUIRE Address: P.O. BQX 59412 NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-93&6929 Supreme Court ID No. 59012 Deputy Tt2~t~` r`'e-`.~~'r . ~~. ~,ry~ hand ~ TP ' v .: ~ a. ~rrd ~h >~'. t ~ ~~ ~_. This __ ~r,,,, ~~, ~.,ry -~~ ~. G ~ `~°~'° `1 D~'. The Patriot-News Co. 2020 Technology Rtcwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ~e~atriot News NOw you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday! Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s- shown below: 10!26/12 ,. D. ~+wEU~ ~.ww>ra MEM ~ ~~•+ Di COYflty BER, ~V°v. Z6 aOiS CUMBERLAND LAW JOURNAL Wrlt Ifo. 9012-301 Civil Term Members 1st Federal Credit Union vs. Taunya Lynn George a/k/a/ Taunya L. George f/k/a Taunya L. Molter, Robert William George a/k/a Robert W. George Atty.: Karl M. Ledebohm ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumber- landand Commonwealth of Pennsyl- vania, more particularly described as follows: On the north by the road, No. 21005, lmown as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or for- merly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particularly bounded and described as follows: BEGINNING at a post along the west aide of the Frost Road, at the southeast comer of the herein conveyed tract of land; thence west- wardly 181 feet to a point; thence northwardly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point; thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16 1 / 2 feet to a post, the place of BEGINNING. HAVING thereon erected a 1 '/2 story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Molter, hus- band and wife, by their deed dated 2 J 11 / 02 and recorded in Cumber- land County Deed Book 250, Page 4599 granted arid conveyed unto Robert William George and Taunya Lynn George, husband and wife, as joint tenants with right of survivor- ship. TAX PARCEL NO. 40-39-2214- 005. 42 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (71738-6929 MEMBERS 1' ` FEDERAL CREDIT UNION PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L.. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1 ~` Federal Credit Union, plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 298 Frost Road, Gardners, PA 17324. 1. Name and address of owner(s) or reputed owner(s): Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 2. Name and address of defendant(s) in the judgment: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 C~Oo G°'~l Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Chazles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on ' the real property to be sold: Members 1 S` Federal Credit Union Attn.: Lynn Unger, Bankruptcy Specialist 5000 Louise Drive Mechanicsburg, PA 17055 Cumberland County Adult Probation 1 Courthouse Square Cazlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Members 1st Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 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: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare 1PL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 hiheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 298 Frost Road Gardners, PA 17324 ~':.S.A U.S. Dept. of Justice i;~.S. Attorney, Federal Building 22$ Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-174 I verify that the statements made in this affidavit are true and correct to the best ~f my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification. to authorities. Date: August 29, 2012 /.- ~ ~__ ~ /_., ~ ' Ems' __ ~ _- ___ arl M. Ledebohm, F_.sq_ Supreme Court ID #: 59U 1 P.O. Box l 73 New Cumberland, PA 17(17(1-~t 7 (717)938-6929 Attorney for Plaintiff Karl M. L,edebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF V s. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-301 Civil Term CIVIL ACTION -LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Raad Gazdners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Mazket Street Camp Hill, PA 17011 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 298 Frost Road, Gardners, PA 17324, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sheriff s Sale on December S, 2412 at 10s~t1 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $108,600.02 plus interest at the rate of $19.75 per day from Apri130, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER' S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back payments, late charges, costs and reasonable attorney's fees, if any, due. To fmd out how much you must pay, you may call> Karl M. Ledebohm, Esquire, at (717)938-6929. 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 be able to stop the sale thr+th other legal prac~. You may need an attorney to assert your rights. "Ffie soot~r' you contest o~e> the more°chance you will have of stopping the sale. (See notice~lclo~v-td foht'Iv~v ~ obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 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 Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) 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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before January 4, 2013 (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLANA COUNTY Bit A~IA1"ION 32 SO~J'T'ilI O S . ET CARLI~,1P'A 1713 (717)24-31~i1i E `(t1~9i9~-8 The Sheriff's phone number is: (717}240-6390. /- ~v ~ -., /' ; r r i ti. __- _ - ... ~° Karl M. edebohm, Esquire Supreme Court ID #59012 ~ P.O. Box 173 i New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: On the north by the road, No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particulazly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwardly 181 feet to a point; thence northwazdly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwazdly 135.5 feet to a point where said road bears southeast; thence southeastwazdly 96 feet to a point; thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16'/z feet to a post, the place of BEGINNING. HAVING thereon erected a 1 1/z story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises v~hich Robert W. George and Taunya L. George f/k/a Taunya L. Molter, husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George, husband and wife, as joint tenants with right of survivorship. TAX PARCEL N0.40-39-2214-005 EXHIBIT "A" ZO'1~'~Ot tILW MNnbws ~ftlilirral't~rdk Unfan vs '~~~ 11oll~r tAobi ~ tttitlliia Kitr!'M. ~t ALLTHAT4'EATAW paiRor#o!'hmd and prem~a, i~uate, ~apd being in the 1b~vnrLip alf8oui in the Cou~jof~bettand and ~~+mtxe partiadazly dstrt~ad is 1ioNvwec On the notes by themed, No. 21085,. known ss the te'a lea Road; as the eatbg the ~ tl~~outh by propcrt~ now or ~a'af NtM6 Vtince and on ~,reatbrlxooaatY now or 1•~d; ffieoen p~ai~g tif'l~t to a Point; thc~de~arittlt+~rdly231iect~apramtin the Huddle aL irad PIo. ZitIDS ktawa a's the Hurraer's Rata Y 135.5 ~ b apoitd wherearid road Mars southeast; tlbaee ~ 96 to a point; the6Ex southtoa[dllr4l fed to a point is tlse`oe. of the Frost Road; thence west 16 `/2 feet to a poet the plane of BEGII+~tIG. ;~ `~ HAVII~IG thesran sneered a i "12 ~Y frame dweUmg horse kagwn add membered as 29817raet Rtlid Giar~iten, l!~ ff324: BEING tlrtaaN~aisl Robert W. Georgo aod'aunya L. tiomge fhJa 1ku~a L Hotter; huabamd aa~dwitie, by their dxd daiect2l11/0tl aadteoarsietttin Cumberland t'ouety TJ~sed Bann 2Stl, Page 4599 granted atidcaaeeyed u~o RoM:rt Witliam Geotgt aa~'19wega Lymt George, husband ardwiFe, ~)~ whh ~~• TAX PARCFI. NO.4439-2214005 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No..587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. `~,~ Lisa Marie Co ne, Editor SWORN TO AND SUBSCRIBED before me this 26 day of October, 2012 . ~, C - ~ f~ ~! Notary ~,,. NOTARIAL SEAL DEBORAH A COLLii`JS Notary Public CARLISLE 80ROUGH, CUMBERLAND COUNi"~' My Commission Expires Apr 28, 2014 =4 . HLEO`OF HCE Cf- THE PROTHONOTARY 2013 OCT -9 PM 1 02 CUMBERLAND COUNTY PENNSYLVANIA Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND.CO.UNTY; PLAINTIFF : PENNSYLVANI-A. Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION(MORTGAGE FORECLOSURE) TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, Amount Due: $108,600.62 Interest from: 4/30/12 at the rate of$19.75 per day to be added Attorney's fees $to be added Costs $to be added Directed to the Sheriff of Cumberland County, Pennsylvania; To satisfy the judgment, interest and costs in the above captioned case,you are directed to levy upon and sell the following real property: All that certain real estate and improvements erected thereon situate in South Middleton Township, Cumberland County, Pennsylvania,known and numbered as 298 Frost Road, Gardners,PA 17324 and as more particularly set forth and described on Exhibit"A" goo attached hereto and made part hereof by reference. a \4) 6' •SCE` -l(o.‘IS CBS ��.°11 931. lo_.i S fa \\?cl u '1 � cI clot 1986 It t( Ilo•So gyrc)q ldiss Uj ' Oc �L Std d ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania,more particularly described as follows: On the north by the road,No. 21005,known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particularly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwardly 181 feet to a point; thence northwardly 231 feet to a point in the middle of road No. 21005,known as the Hunter's Run Road;thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point;thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16 %2 feet to a post,the place of BEGINNING. HAVING thereon erected a 1 1/2 story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Motter, husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250,Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George,husband and wife, as joint tenants with right of survivorship. TAX PARCEL NO. 40-39-2214-005 EXHIBIT "A" 'L '"D-EiT ICE THE PROTHONOTARY 2013 OCT -9 FM 1: 02 Karl M.Ledebohm,Esquire P.O.Box 173 CUMBERLAND COUNTY New Cumberland,PA 17070-0173 • PENNSYLVANIA (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : MORTGAGE.FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1st Federal Credit Union,plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in South Middleton Township, Cumberland County, Pennsylvania,known and numbered as 298 Frost Road, Gardners,PA 17324. 1. Name and address of owner(s)or reputed owner(s): Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Molter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners,PA 17324 Taunya L. George and Robert W. George c/o Charles J. Hartwell,Esquire 2132 Market Street Camp Hill,PA 17011 2. Name and address of defendant(s) in the judgment: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya L. George and Robert W. George c/o Charles J. Hartwell,Esquire 2132 Market Street Camp Hill,PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1st Federal Credit Union Attn.: Lynn Unger, Bankruptcy Specialist 5000 Louise Drive Mechanicsburg,PA 17055 Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Members Pt Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg,PA 17055 Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 Susquehanna Bank P.O. Box 639 Maugansville, MD 21767 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 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: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 298 Frost Road Gardners, PA 17324 U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October 4,2013 Respect lly bmitted, r � arl M. Ledebohm, Esq. Supreme Court ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 'lLEO--OFF CE F THE PROTHONOTARY 2083 BCT --9 PM 1: 03 CUMBERLAND COUNTY PENNSYLVANIA Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE WAIVER OF WATCHMAN Plaintiff, Members 1st Federal Credit Union,through its legal counsel, Karl M. Ledebohm, Esquire,hereby waives the necessity of providing a watchman upon service of the Writ of Execution in the above captioned matter. Reslie• fully submitted Date: October 7,2013 Al K. 11M. Ledebohm, Esquire Supreme Court ID#59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff E °Orr IN h'�?0THOfNGTAh 201300 ' -9 P1 is 03 Karl M.Ledebohm,Esquire CUMBERLAND 00U fiTv P.O.Box 173 PENNSYLVANIA New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya L. George &Robert W. George do Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER,IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 298 Frost Road, Gardners,PA 17324, as more particularly set forth and described on Exhibit"A" attached hereto and made part hereof, is scheduled to be sold at Sheriffs Sale on March 5,2014 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $108,600.02 plus interest at the rate of$19.75 per day from April 30, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back payments, late charges, costs and reasonable attorney's fees, if any, due. To find out how much you must pay, you may call.Karl M. Ledebohm, Esquire, at (717)938-6929. 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped,your house(real estate)will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 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 Sheriff at the County Courthouse,which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate)as if the sale never happened. 5. You have a right to remain in the house(real estate)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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before April 4, 2014 (within thirty(30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10) days after the schedule of distribution is filed by the Sheriff. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 OR(800)990-9108 The Sheriff's phone number is: (717)240-6390. "Pe, —1� arl M. Ledebohm, Esquire Supreme Court ID#59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania,more particularly described as follows: On the north by the road,No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe,more particularly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land;thence westwardly 181 feet to a point;thence northwardly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road;thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point;thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16 1/2 feet to a post,the place of BEGINNING. HAVING thereon erected a 1 1/2 story frame dwelling house known and numbered as 298 Frost Road, Gardners,PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Molter,husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George,husband and wife, as joint tenants with right of survivorship. TAX PARCEL NO. 40-39-2214-005 EXHIBIT "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-301 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION Plaintiff(s) From TAUNYA LYNN GEORGE a/k/a TAUNYA L.GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE (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: $108,600.62 L.L.: Interest FROM 4/30/12 AT THE RATE OF$19.75 PER DAY TO BE ADDED Atty's Comm: Due Prothy: $2.25 Atty Paid: $931.11 Other Costs: Plaintiff Paid: Date: 10/9/13 Da '• D :uell,Prot onotary (Seal) By: Deputy REQUESTING PARTY: Name: KARL M.LEDEBOHM,ESQUIRE Address:P.O. BOX 173 NEW CUMBERLAND,PA 17070 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term �= TAUNYA LYNN GEORGE a/k/a : 7"' TAUNYA L. GEORGE f/k/a • tJ TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a =' ROBERT W. GEORGE `=' ) f, DEFENDANTS : MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1St Federal Credit Union,plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in South Middleton Township, Cumberland County, Pennsylvania, known and numbered as 298 Frost Road, Gardners, PA 17324. 1. Name and address of owner(s) or reputed owner(s): Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners,PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya L. George and Robert W. George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 2. Name and address of defendant(s) in the judgment: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners,PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners,PA 17324 Taunya L. George and Robert W. George c/o Charles J. Hartwell,Esquire 2132 Market Street Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1St Federal Credit Union Attn.: Lynn Unger, Bankruptcy Specialist 5000 Louise Drive Mechanicsburg,PA 17055 Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Members 1St Federal Credit Union Attn.: Lynn Unger, Bankruptcy Specialist 5000 Louise Drive Mechanicsburg, PA 17055 Susquehanna Bank 1570 Manheim Pike P.O. Box 3300 Lancaster, PA 17604-3300 Susquehanna Bank P.O. Box 639 Maugansville, MD 21767 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 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: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 298 Frost Road Gardners, PA 17324 U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 Philadelphia Indemnity Insurance Co. a/s/o Human Achievement Program One Bala Plaza, Suite 100 Bala Cynwd, PA 19004 Philadelphia Indemnity Insurance Co. a/s/o Human Achievement Program do Edward T. Rostick, Esquire 104 Lakeside Drive Southampton, PA 18966 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October 24, 2013 Re e 11 ubmitted, Karl 1VI r edebohm, Esq. Supreme Court ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff �p .!3 o r-/ ak iI 0I �: 114\lit COUNTY Karl M.Ledebohm,Esquire P E N N S YL VA NIA P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE • DEFENDANTS : MORTGAGE FORECLOSURE AMENDED NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya L. George&Robert W. George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER,IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 298 Frost Road, Gardners, PA 17324, as more particularly set forth and described on Exhibit"A" attached hereto and made part hereof, is scheduled to be sold at Sheriff's Sale on March 12,2014 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $108,600.02 plus interest at the rate of$19.75 per day from April 30, 2012 through the date of judgment as well as on and after judgment until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back payments, late charges, costs and reasonable attorney's fees, if any, due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929. 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped,your house (real estate)will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 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 Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate)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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before (within thirty(30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10) days after the schedule of distribution is filed by the Sheriff. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 OR(800)990-9108 The Sheriff's phone number is: (717)240-6390. 7 40 r ....Wea,____ Karl . Ledebo ,Esquire Supre e Court ID#59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania,more particularly described as follows: On the north by the road,No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particularly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwardly 181 feet to a point;thence northwardly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point;thence southwardly 41 feet to a point in the center of the Frost Road;thence west 16 1/2 feet to a post,the place of BEGINNING. HAVING thereon erected a 1 1/2 story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/a Taunya L. Motter, husband and wife,by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George,husband and wife, as joint tenants with right of survivorship. TAX PARCEL NO. 40-39-2214-005 EXHIBIT "A" Karl M.Ledebohm,Esquire P.O.Box 173 'w' ° 1 3 PH j New Cumberland,PA 17070-0173 (717)938-6929 '1.2M E( L A i i j COUNTY PENNSYLVANIA MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF • Vs. : NO.: 12-301 Civil Term • TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO Pa. R.C.P.3129.2 (c) I, Karl M. Ledebohm, Esquire,hereby swear and affirm that on the 5th day of November, 2013, I served the attached AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY pursuant to Pa. R.C.P. 3129.2(c) in the above captioned matter upon the individuals/entities by first class mail,postage prepaid as set forth on the PS Form 3817,copies of which are attached as Exhibit"1"and made part hereof. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:November 12, 2013 Re ct /10 Karl M. Ledebohm,Esq. Supreme Court ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE TO: ALL PARTIES IN INTEREST AND CLAIMANTS AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Owner(s): Robert William George and Taunya Lynn George Property: 298 Frost Road Gardners, PA 17324 (Legal description attached) Judgment Amount: $108,600.62 The above-captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on March 12,2014 at 10:00 a.m in the Office of the Sheriff, Cumberland County Courthouse, One Courthouse Square, South Hanover Street, Carlisle, PA 17013. Our records indicate that you may hold a mortgage,judgment, or other interest with respect to the property which may 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 30 days after the sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriff Sale upon your lien, I urge you to CONTACT YOUR OWN ATTORNEY as I am not permitted to give you legal advice. Date: November 4, 2013 Resp-/1 fitted, `.0111 l Kar M YLe.ebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff • ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: On the north by the road,No. 21005, known as the Hunter's Run Road; on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particularly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land; thence westwardly 181 feet to a point; thence northwardly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run Road; thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point; thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16 1/2 feet to a post,the place of BEGINNING. HAVING thereon erected a 1 1/2 story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises wiich Robert W. George and Taunya L. George f/k/a Taunya L. Molter, husband and wife, by their deed dated 2/11/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George, husband and wife, as joint tenants with right of survivorship. TAX PARCEL NO. 40-39-2214-005 EXHIBIT "A" o I I I I 3 " cn- 3 v 0 Z "Zj yyy m°o^ "0 c• o I I ' CO O �1 c E O I a_i �, a � - 3 cINNn Z 'b � av rj co o iv m � � O • up N D = K N a cu ri � = m _• Q a ryj ^�' m 1 j o D ,..t CU ��i w CAD ° r Cl rr l'+ C . 3 ri, b °3 x'11 cn O to __ Q,• `1�� 0 0 m < = > Ct z t-+ �� N _ c n'v o o n' o O c J ID Ni , f o , M O o O fD 0 o fD co O of J l o t 3 O W uc �' O- -_^. �t C' �p �n L n CD Ni,,;‘ • Q tv b0-b009TL000 1 13 ,„,,,.. ,y .. 1Nf10WH ✓' 1-?'7n1rNn b0-b009L0l�Q ._ El `SO AON — 07 I 1!1!0!0!0 OLOLI 1N ` Hd'ONHla38Wf13 M3N 0I Hd 371Aa357V1S0J 39H1SOd •S•fl 1•SOWH 5317150311N1 E1.'3 113 OLOLI Hd•ONHla38Wf1� M3N 0IHd 391;11S0d •S•fl s -- ---- _ UNITED STATES Certificate Of POSTAL SERVICET, Mai ' = r7�.� -'”'"°`°°`" This Certificate of Mailing provides evidence that mail has been presented to USPS° rna ng. This form may be used for domestic and international Mall / (:f. From .7%, )4 f.-- c k H. Karl M. Ledebohm, Esq. /., "if _ P.O. Box 173 New Cumberland, PA 17070-0173 . , z To: -- --- _ m U.S.A E U.S.Dept.of Justice - D< C • p co Oo,1WI' cutom.-.-a U.S.Attorney,Federal Building - TN -. o70m 228 Walnut Street,P.O.Box 11754 _ 00 W Z Harrisburg,PA 17108-1754 • m n PS Form 3817.April 2007 PSN 7530-02-000-9065 Exhibit "1" U.S. POSTAGE a PAID u,S. POSTAGE Ailar NEW CUMBERLAND,PA E PAID 17070 � ; NEW CUMBERLRND.PA NOV 05,'13 K 17070 VNIrensrer -_:,� AMOUNT ' 1 NOV 05, 13 POSTAL a, es AMOUNT X1 .20 tiv, oa ru #g�� X00076004-04 - E �'• 1000 ;,. ,,- , ,.*.0 , 00076004-04 Or: = o t, E r I C = Mtsl C o M o Cr) J CI v p d a)6 i p 1 co °s ,. ; ° Z O ° CV & ••• CV t ,1-1-1 E 6 W Q' co o W Q' cu S o Ln L1U ' a ` i 14 Eo 0-I j x p 2, f � yv N z 111V _ ^d aia > c co " ' l� � 'b n a .I O m o a>i o co n 111 W'0 �� v-I . L„v m C ,� L 1 . .-+ a 1/1 o h v 0 0 M i4+ ±+ Q ? Q Q ..1 °E 'dam t. CO Q N V1 ' = Ot� � N4' C o0 l� L.y 0 v 0 .-i CC a = Q .. o f F„1 CU > C .... a N 1"' l_ a a . C ,_ a Lu o o . 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'O N (n I1 I ,,,:...0 > Z L1,I -% a) M i•, o D a, tc 5 Q l o c VI Cr c a l/l ^d l� .. > 00 m a o 1/l 41 w 'p p D © J v v 0 - .fl aa) CO 0 0000 m G.. ° "y 0 M i-+ (0 U 7 °o cv 1` e a O it m a, o -0 a 144 a) ,-i o: c r < = F+ moalU ammo a I� � ma `'� iC CO � � a �� Q �� � Q y � H w d 3 S •r ' Q � O U N F U � Q rid' d° �' a.a Z M 'SIC �a ~ 0 E c •� w (1,.., _ I I LLL I If r E ' i a 'z i I U I UI I o U.S. POSTAGE U.S. POSTAGE �j- NEW CUMBERLAND,PA PAID 17070 NEW CUM NOV= J NOV 05. 13 (75. NOV 05, 13 AMOUNT :i 00076009-09 K4� •0 �. .i-.•„,1 } ? 1000 00076004-04 ✓ x ,CP •° 14,. I 1 1' ffJJ� • a L U N CD v C `) N U E a) o on C O V L o tJ v "C T O c) c OL. d L o O = Q lf1 °o 1�, C E W■11 LO o ` • g$ [� U C N o 14,�' .y v P. c > U ,,1 I Lu E w m d FDIC '� v z p > Q 111 V yv Q+ j a z i^1Ww� cQ � � a• a ��IC 'O�+ iy a C 0 � N N O 1L < �° ,-ti �' 7. ro d C N tJ N n m "d L �` N '3 'u CV Vi '" a0,76 >. § G) Z 1g co a lL < o 8 N y J J a z0 �; � U Oat r O E C Pi, p L r• I e, -" a m u v)i w -` 3 G� v �E aZ �' : I� oa • 3 24v) In � o0 E yr E L LL I I i LL W Z 11;, E d a. ti t t o o Q f- U.S. POSTAGE PAI Aiilf NEW CUMBERLAND,PR 17070 U.S. POSTAGE NOV 05, 13 PAID POSTED STATES - AMOUNT NEW CUMBERLAND,PA °°sr°I.SERVJ 17070 NOV 05,'13 120 UNITED STATES AMOUNT • IOQO " 076004-09 POSTAL SE7t)/ICt W '- • /�� �� �" 110076009-04 45C ry ,,.- /te a: /// J ,p � CU= E i i tt — C o d 7-5 C 0) v m ;, N o L Q.) v e) - (O o w r-� CD o I a O m C a-, o I o S 0 O ° O - Cs -0 c: g Q q O 0 vl CV 0 w E ° Q d to Z ,r)1� m m l/1'v 'A� a ...14 _v 1 7 OO N ^ 0 11� a I �gtj \Q CD b 2 t a CVV i^IVVID O '"" m t ai Q ,J ''4^",?,"E -d = C M N H O O Q tL '� 09 r•a X § y 2 m ua i a ;�I O1� � l i � U :z v1 �" W U ff oh O c ti irill .ti ) , 1 I 11 u_ U.S. POSTAGE U.S. OS POSTAGE 177 jian NEW CU0 ND,PA NEW CUMBERLAND. PR 10 17070 NOV 05, 13 NOV 05, 13 UNITED STATES AMOUNT UNITED STATE'' .,, AMOUNT POSTAL SERVICF POST SFl+K�rl� LJ , 120 = ^ .20 MO '40076009-09 (4 1 fIJ000 ',00076009-09, . . . ,=1,,,, O E a °w ITS (1:5 o _. I T_ .% o V G ,, N N 41. a .t M as �+ o - 0 M o - N 2 h Q d O d) d ,--1 I CO o to Y� p O m I up o E o ci) CD CD 2I tD °a, ,-- U o r ~ N ° w..E o W o W e o W c o o W U 5 C ^a Cr z V A m �p n F� 3 v v? 0 c N m z tll � �� tj m z y M ( `1 Cl_ -'�t � �" O com ai h 0m chi � � h C 2; _., c m a 'I, W 'L, t-. O �-+ °o W O M C to r !1 N D- w ~ C = N v, 0 - .0 x c o �J ^� o f a k m . a - Q --I °E •--a O O cu `ti v o • O L = LU o�o 7 m d0 = i'� {•� rn o = U v O w Q I� coo • � J � o Q "' — • 3 L .� 0 �= x�,,110 „ Paz uoci M C -6 2,, r}4 a c, �E I I E rug E U o E I I I I II. d co F H LL d • • I pE 1i//s T'<, Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff/Movant Vs. : NO.: 2012-0301 CIVIL TERM TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and • ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE • Defendant/Respondent : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its attorney, Karl M. Ledebohm, Esquire, moves the Court to direct the Prothonotary to amend the judgment and the writ of execution in this matter, and in support thereof avers the following: 1. Plaintiff, Members 1st Federal Credit Union (sometimes hereinafter "Members 15t"), filed its complaint in mortgage foreclosure (the 1 "Complaint") in the above captioned matter against the above captioned defendants (collectively "Defendants") on January 24, 2012. 2. The concurrence of Charles Joseph Hartwell, Esq., Taunya Lynn George's attorney, has been sought and, as of the date hereof, Charles Joseph Hartwell, Esq., has not indicated whether he concurs in the relief requested on behalf of his clients. No attorney has entered an appearance on behalf of Robert W. George. 3. By order dated July 27, 2012, the Honorable Edward E. Guido granted Members lst's motion for summary judgment and judgment was entered on September 4, 2013, in the original principal amount of $108,600.62 (the "Judgment"). 4. The property (the "Property") which is the subject of the Complaint was originally listed for Sheriffs Sale on December 5, 2012 (the "Sheriff's Sale"). 5. Defendants filed a petition under chapter 13 of the Federal Bankruptcy Code before the Federal Bankruptcy Court for the Middle District of Pennsylvania on October 8, 2012 to Docket No.: 12-05895 (the "Bankruptcy") which forced the Sheriffs Sale to be stayed. 6. Some ten (10) months later, the Bankruptcy was dismissed by order entered in the Bankruptcy on August 20, 2013. 7. On October 9, 2013, Plaintiff again issued a writ of execution (the "Writ of Execution") in the above captioned matter and the Property is again scheduled for Sheriffs Sale on March 12, 2014. 2 8. Additional sums have been incurred or expended on Defendants' behalf since the Complaint was filed and Defendants has been given credit for any payments that have been made since the Judgment. The amount of damages to which Plaintiff is entitled is now in the amount of $125,538.90, itemized as follows: a. Outstanding principal $96,583.68 b. Interest to November 1, 2013 11,875.29 c. Fees billed 2.50 d. Defer Late Charges 1,742.93 e. Corporate Advance 3,738.79 f. NSF Check Fees 180.00 g. Less forbearance suspense (682.76) h. Attorney's fees 11,749.62 i. Title searches 103.90 j. Filing and Sheriffs costs 244.95 k. Total due to Members 1st $125,538.90 9. Interest continues to accrue on the above obligation at the rate of$19.52 per day and legal fees and costs also continue to accrue. 10. The Judgment formerly entered is insufficient to satisfy the amounts due on the mortgage which is the subject of the Complaint (the "Mortgage"). 11. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of the Judgment against the Defendants. 12. Plaintiffs foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiffs attached brief. 3 13. Unless the Judgment and the Writ are amended to include the above additional costs of collection, interest and other amounts, in the event a third party bidder successfully purchases the Property at the Sheriff's Sale, Plaintiff will be deprived of its contractual right to collect out of the proceeds of the Sheriff's Sale all of its costs of collection and other amounts to which it is entitled under the obligations evidenced by the Judgment. WHEREFORE, Plaintiff, Members 1st Federal Credit Union, respectfully requests this Honorable Court amend the Judgment and the Writ to reflect damages due to Plaintiff in the amount of$125,538.90 plus interest at the rate of $19.52 per day from November 1, 2013, until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage. Respectfully submitted, Date: November , 2013 arl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff 4 ' 03/06/2006 03:00 7179320317 KARLLEDEBOHM PAGE 06/06 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 2012-0301 CIVIL TERM • TAUNYA LYNN GEORGE a/lc/a TAUNYA L. GEORGE flit/a • TAUNYA L. MO' TER and ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE VERIFICATION I, Dan Summers, Collections Manager for Members 1"Federal. Credit Union, being authorized to do so on behalf of Members 1"Federal Credit Union,hereby verify that the statements made in the foregoing motion are true and correct to the best of my information knowledge and belief.I understand that false statements are made subject to the penalties of 18 Pa. C.S,A. Section 4904,relating to uusworn falsification to authorities. Members 1"Federal Credit Union October 2if, 2013 By: ',v✓v 53-41/1714/1-916 Dan Summers, Collections Manager 5 • Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm,Esquire,hereby certify that on the 14th day of November, 2013, I served a true and correct copy of Plaintiffs Motion to Reassess Damages in the above captioned matter upon the following by first class mail,postage prepaid, addressed as follows: Robert William George Charles Joseph Hartwell, Esquire 298 Frost Road Dethlefs-Pykosh Law Group, LLC Gardners, PA 17324 2132 Market Street Camp Hill, PA 17011 Respect►o ly submitt / Date: November 14, 2013 Ad ' V e (arl M. I edebohm, Esq. Attorney for Plaintiff Supreme Court ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 e t [ ILED-OFTIC:E 3 OF THE PROTHONOTARY 2t113 NOV 19 PH 3: 25 CUMBERLAND COUNTY PENNSYLVANIA Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 (7170 938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA • Plaintiff/Movant Vs. : NO.: 2012-0301 CIVIL TERM • TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and • ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE Defendant/Respondent : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE ORDER AND NOW, this /1 M day of A/D Y1121 c/G. , 2013, upon consideration of the foregoing motion, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Movant/Petitioner is not entitled to the relief requested; (2) the Respondent shall file an answer to the petition within twenty (20) days of service upon the Respondent; tap /1 .0 a #4.4 A•,• ee.. • -- - _, _ -te; en -- ; 494 , ' of -�.• SI - (: 6 • : i.. n . 0 4 ,fits 00-9-74-4411- eald, Gee`14..A° By the Court: 445— J. Legal Counsel for Defendant/Respondent, Taunya Lynn George: f/ Charles Joseph Hartwell, Esq. Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 obert William George 298 Frost Road Gardners, PA 17324 Legal Counsel for Members 1st Federal Credit Union: arl M.Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 6.4.) /1 14/12 z UA Karl M.Ledebohm,Esquire OF THE PROTHONOTARy P.O.Box 173 New Cumberland,PA 17070-0173 2*1 DEC —6 PM 3: 13 (717)938-6929 CE ERLAND COUNTY MEMBERS 1sT FEDERAL IN TH9 tMkqWrP6mmoN PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 22nd day of November, 2013, I served a true and correct copy of the Order dated November 18, 2013 in the above captioned matter upon the following by first class mail,postage prepaid, addressed as follows: Robert William George Charles Joseph Hartwell, Esquire 298 Frost Road Dethlefs-Pykosh Law Group, LLC Gardners, PA 17324 2132 Market Street Camp Hill, PA 17011 PAttomey sub itted, Date: November 22, 2013 - bohm, sq. Plaintiff Supreme Co urt ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 P R)OT H 0), X313 NOV 19 PPS 3* 2 PENN YLVAN ANT Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 (7170 938-6929 MEMBERS 1 IT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Movant Vs. NO.: 2012-0301 CIVIL TERM TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE : Defendant/Respondent : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE ORDER AND NOW, this /i, M day of Ald Y�/l'1.l�SlL , 2013, upon consideration of the foregoing motion, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Movant/Petitioner is not entitled to the relief requested; (2) the Respondent shall file an answer to the petition within twenty (20) days of service upon the Respondent; a err An— A te; of ( e an . .� By the Court: J. Legal Counsel for Defendant/Respondent,Taunya Lynn George: Charles Joseph Hartwell, Esq. Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Robert William. George 298 Frost Road Gardners, PA 17324 Legal Counsel for Members 15t Federal Credit Union: Karl M.Ledebohm, Esq, P.Q. Box 173 New Cumberland, PA 17070-0173 FILED-OFFiC E OF THE PROTHONOTArt: 2013 DEC 18 PM 1: 27 CUMBERLAND COUNTY PENNSYLVANIA Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA • Plaintiff/Movant Vs. : NO.: 2012-0301 CIVIL TERM • TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and • ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE Defendant/Respondent : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE PLAINTIFF'S MOTION TO MAKE ABSOLUTE THE ORDER TO SHOW CAUSE DATED NOVEMBER 18,2013, IN CONNECTION WITH PLAINTIFF'S MOTION TO REASSESS DAMAGES 1 AND NOW, comes Plaintiff/Movant, Members 1st Federal Credit Union ("Plaintiff'), in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and requests that the Order To Show Cause issued by this Court dated November 18, 2013, upon Defendant(s)/Respondent(s), in the above captioned matter be made absolute and avers in support thereof as follows: 1. This court issued a order upon Respondents, Taunya Lynn George and Robert W. George (collectively "Respondents") dated November 18, 2013 in the above captioned matter (the "Order"), a copy of which is attached hereto as Exhibit"A" and made part hereof by reference. 2. On November 22,2013, Plaintiff served the Order upon Respondents as set forth in the Certificate of Service filed in the above captioned matter on December 6, 2013. (See Exhibit"A" attached and made part hereof) 3. On November 14, 2013, Plaintiff served upon Respondents the Motion which is the subject of the Order(the "Motion") as set forth in the certificate of service attached to the Motion and filed to the above captioned matter on November 15, 2013. 4. Neither the Order nor the Motion have been returned to the law office of Karl M. Ledebohm, Esq., as undeliverable or otherwise. 5. The Order specifically required Respondents to file an answer to the Motion on or before twenty (20) days of service upon Respondents or on or before December 12,2013. 6. As of the date hereof, Respondents have not filed a response to the Motion. 2 WHEREFORE, Plaintiff respectfully requests this Court to enter an order: a. Making the Order issued in this matter absolute; b. Reassessing damages and amending the Judgment entered on September 4, 2013 in the original principal amount of$108,600.62 and corresponding writ of execution filed on October 9, 2013 to the above captioned matter to reflect an amount due and judgment in favor of Plaintiff and against Defendants/Respondents, in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND FIVE HUNDRED THIRTY-EIGHT AND 90/100 ($125,538.90) DOLLARS plus interest at the rate of$19.52 per day from November 1, 2013, until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage; and, c. Directing the Prothonotary for Cumberland County to amend upon the docket,the Judgment and the Writ of Execution as set forth herein. Respect ly . emitted, , Q919 Date: December 16, 2013 ✓' arl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff 3 Karl M. Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF • Vs. : NO.: 12-301 Civil Term • TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 22nd day of November, 2013, I served a true and collect copy of the Order dated November 18, 2013 in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George Charles Joseph Hartwell, Esquire 298 Frost Road Dethlefs-Pykosh Law Group, LLC Gardners, PA 17324 2132 Market Street Camp Hill, PA 17011 Res 'et sub itted, Date: November 22, 2013 l.r�,� arl . Ledebohm, sq. Attorney for Plaintiff mu)rn r r Supreme Court ID #: 59012 n P.O. Box 173 "., New Cumberland, PA 17070-01755(.1c" -o 3 (717)938-6929 zc .nz yor -C C..3 cnrY Exhibit "A" � HE PRO f HOND 2313 NOV 19 PM 3: 25 COUt PENNSYLVAN AN r ti Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 (7170 938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff/Movant • Vs. • : NO.: 2012-0301 CIVIL TERM TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and • ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE • Defendant/Respondent : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE ORDER AND NOW, this /S' tA day of AM Y£/Yl I'r/ , 2013, upon consideration of the foregoing motion, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Movant/Petitioner is not entitled to the relief requested; (2) the Respondent shall file an answer to the petition within twenty (20) days of service upon the Respondent; Aet . • --te; • • en mu ,, ,, , , • • r • of eat/ G•re (Air"' p� By the Court. ,, J. Legal Counsel for Defendant/Respondent, Taunya Lynn George: Charles Joseph Hartwell, Esq. Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill,PA 17011 Robert William George 298 Frost Road Gardners, PA 17324 Legal Counsel for Members 1St Federal Credit Union: Karl M.Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE • DEFENDANTS : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 17th day of December, 2013, I served a true and correct copy of the foregoing Plaintiff's Motion to Make Absolute the Order to Show Cause dated 11/18/13 and the proposed Order in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George Charles Joseph Hartwell, Esquire 298 Frost Road Dethlefs-Pykosh Law Group, LLC Gardners, PA 17324 2132 Market Street Camp Hill, PA 17011 Res p lore ed, , Date: December 17, 2013 h.‘i arl M Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 4,; L A'�i t t ? f Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : Vs. NO.: 2012-0301 CIVIL TERM TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a : TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE ORDER AND NOW,this day of -,� fci!J , 2013, upon consideration of Plaintiff's Motion to Reassess Damages and no response having been filed to the Order to show cause entered on November 18, 2013 (the"Order")to the above captioned matter, it is hereby ORDERED AND DECREED that: a. The Order is hereby made absolute; w b. The Judgment and the Writ of Execution entered to the above captioned matter in favor of Plaintiff and against Defendants are hereby amended to reflect an amount due and judgment in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND FIVE HUNDRED THIRTY-EIGHT AND 90/100 ($125,538.90) DOLLARS plus interest at the rate of$19.52 per day from November 1, 2013, until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage; and, c. The Prothonotary for Cumberland County is hereby directed to amend upon the docket the Judgment and the Writ of Execution as set forth herein. By the Court: Edward E. Guido, J. Service list: Attorney for Defendant/Respondent Taunya L. George: harles Joseph Hartwell, Esq. Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 efendant/Respondent: Robert W. George 298 Frost Road Gardners, PA 17324 aintiff/Movant: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 jj} Js *bP?,I Ctit13wCSt r, PENN y UWIT'' Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE : DEFENDANTS : MORTGAGE FORECLOSURE PRAECIPE TO AMEND JUDGMENT PURSUANT TO COURT ORDER DATED DECEMBER 20,2013 TO THE PROTHONOTARY: Please amend the judgment entered in the above captioned matter on September 4, 2012 as set forth in the Order of Court dated December 20, 2013, a copy of which is attached hereto and incorporated herein by reference to reflect judgment in favor of Members 1st Federal Credit Union, Plaintiff, and against the Defendants, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and Robert William George a/k/a Robert W. George, in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND FIVE HUNDRED THIRTY-EIGHT AND 90/100 DOLLARS ($125,538.90)plus interest at the rate of$19.52 per day from November 1, 2013 until the 004- � � soPda e Lik aogo 1\)0i1ie [e(I 3616Z date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. Respectfull ubmitted, j,// Date: January 27, 2014 ti arl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 3 :"r(3 NC 23 t-, I ' �f'I{UL i Lf"ite / i 1 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS l s r FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA • PLAINTIFF Vs. : NO.: 2012-0301 CIVIL TERM • TAUNYA LYNN GEORGE a/k/a • TAUNYA L. GEORGE f/k/a • TAUNYA L. MOTTER and • ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANT : CIVIL ACTION-LAW-MORTGAGE : FORECLOSURE ORDER AND NOW, this 4441 day of Acgind Y C , 2013, upon consideration of Plaintiff's Motion to Reassess Damages and no response having been filed to the Order to show cause entered on November 18, 2013 (the "Order") to the above captioned matter, it is hereby ORDERED AND DECREED that: a. The Order is hereby made absolute; b. The Judgment and the Writ of Execution entered to the above captioned matter in favor of Plaintiff and against Defendants are hereby amended to reflect an amount due and judgment in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND FIVE HUNDRED THIRTY-EIGHT AND 90/100 ($125,538.90) DOLLARS plus interest at the rate of$19.52 per day from November 1, 2013, until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage; and, c. The Prothonotary for Cumberland County is hereby directed to amend upon the docket the Judgment and the Writ of Execution as set forth herein. By the Court: Edward E. Guido, J. Service list: Attorney for Defendant/Respondent Taunya L. George: Charles Joseph Hartwell, Esq. Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Defendant/Respondent: Robert W. George 298 Frost Road Gardners, PA 17324 Plaintiff/Movant: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. : NO.: 12-301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and : CIVIL ACTION—LAW ROBERT WILLIAM GEORGE a/k/a • ROBERT W. GEORGE DEFENDANTS : MORTGAGE FORECLOSURE NOTICE OF AMENDED JUDGMENT PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE TO: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 You are hereby notified that on /Y the following amended judgment has been entered against you in the above captioned case: The judgment entered in the above captioned matter on September 4, 2012 is amended as set forth in the Order of Court dated December 20, 2013, a copy of which is attached hereto and incorporated herein by reference to reflect judgment in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendants, Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and Robert William George a/k/a Robert W. George, in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND FIVE HUNDRED THIRTY-EIGHT AND 90/100 DOLLARS ($125,538.90)plus interest at the rate of$19.52 per day from November 1, 2013 until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. c--.„e 07) als41) Dated: \I O 1 k Prothonotary I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 A: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter Robert William George a/k/a Robert W. George Por este medio se le esta notificando que el de 2014 el/la siguiente (Orden), (Decreto), (Fa11o), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Taunya Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter 298 Frost Road Gardners, PA 17324 Robert William George a/k/a Robert W. George 298 Frost Road Gardners, PA 17324 Taunya Lynn George c/o Charles J. Hartwell, Esquire 2132 Market Street Camp Hill, PA 17011 Respe ly submitted, Date: January 27, 2014 1!)-C2 ar M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 "r1LED-OFFICE ;:ir THE PROTHONOTARY 2014 APR 22 PM PJ CUMBERLAND COUNTY PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-301 Civil Term : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE NOTICE OF THE DATE OF CONTINUED SHERIFF SALE The Sheriff Sale scheduled for March 12, 2014 at 10:00 a.m. in the above-captioned matter has been continued until May 7, 2014 at 10 a.m. Date: April 21, 2014 Resp c y submitted, Karl M. Ledebolun, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff 1 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 12 -301 Civil Term TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 22nd day of April, 2014, I served a true and correct copy of the foregoing Notice of the Date of Continued Sheriff Sale in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Gardners, PA 17324 Date: April 22, 2014 Attorney for Taunya Lynn George: Charles Joseph Hartwell, Esquire Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 y submitt Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 F'=LEO -OFF?C = THE PROTHONOTARY 201 APR 22 PH :f:. 96 CUMBERLAND COUNTY PENNSYLVANIA Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA Vs. TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : NO.: 12 -301 Civil Term : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE CERTIFICATE OF FILI ' G On this date, I filed with the Prothonotary of Cumberland County a copy of the Notice of the Date of Continued Sheriff Sale in the above - captione • matter. Date: April 22, 2014 Resp ; ply submitted, Karl . Ledebohm, sq. Supr me Court ID #59012 P.O.: ox 173 New Cumberland, PA 17070 -0173 (717 938 -6929 Atto ey for Plaintiff 1 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 12 -301 Civil Term : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA TAUNYA LYNN GEORGE a/k/a TAUNYA L. GEORGE f/k/a TAUNYA L. MOTTER and ROBERT WILLIAM GEORGE a/k/a ROBERT W. GEORGE DEFENDANTS : CIVIL ACTION — LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 22" day of April, 2014, I served a true and correct copy of the foregoing Certificate of Filing in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robert William George 298 Frost Road Gardners, PA 17324 Date: April 22, 2014 Attorney for Taunya Lynn George: Charles Joseph Hartwell, Esquire Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Respect y s fitted, / ('P P Karl M. Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 S SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Members 1st Federal Credit Union Case Number vs. 2012-301 Taunya Lynn George a/k/a/Taunya L. George f/k/a Taunya L. Motter(et al.) SHERIFF'S RETURN OF SERVICE 01/06/2014 01:37 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 298 Frost Road, South Middleton Twp, Gardners, PA 17324, Cumberland County. 01/06/2014 01:37 PM - Deputy Shawn Gutshall, 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: Robert William George a/k/a Robert W. George at 298 Frost Road, South Middleton Township, Gardners, PA 17324, Cumberland County. 01/13/2014 06:36 PM - Deputy Dawn Kell, 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: Taunya Lynn George a/k/a/Taunya L. George f/k/a Taunya L. Motter at 298 Frost Road, South Middleton Township, Gardners, PA 17324, Cumberland County. 03/07/2014 As directed by Karl M. Ledebohm,Attorney for the Plaintiff, Sheriffs Sale Continued to 5/7/2014 04/22/2014 Cert of filing rcvd 4/22/14 05/07/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on May 07, 2014 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Karl Ledebohm on behalf of Members 1st Federal Credit Union, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,065.46 SO ANSWERS, May 13, 2014 RbNW R ANDERSON, SHERIFF ` �U .':x" Cd- 4 302? On November 20, 2013 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 298 Frost Road, Gardners, as Exhibit "A" filed with this writ and by this Reference incorporated herein. o Date: November 20, 2013 By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2012-301 Civil Term joint tenants with right of survivor- ship. Members 1st Federal Credit Union TAX PARCEL NO. 40-39-2214- 005. vs. Taunya Lynn George a/k/a/ Taunya L. George f/k/a Taunya L. Motter Robert William George a/k/a Robert W. George Atty.: Karl M. Ledebohm ALL THAT CERTAIN parcel of land and premises, situate, lying and being in the Township of South Middleton in the County of Cumber- land and Commonwealth of Pennsyl- vania, more particularly described as follows: On the north by the road, No. 21005, known as the Hunter's Run Road;on the east by the Frost Road; on the south by property now or for- merly of Noah Vance and on the west by property now or formerly of W.F. Howe, more particularly bounded and described as follows: BEGINNING at a post along the west side of the Frost Road, at the southeast corner of the herein conveyed tract of land;thence west- wardly 181 feet to a point; thence northwardly 231 feet to a point in the middle of road No.21005,known as the Hunter's Run Road; thence eastwardly 135.5 feet to a point where said road bears southeast; thence southeastwardly 96 feet to a point;thence southwardly 41 feet to a point in the center of the Frost Road; thence west 16 1/2,feet to a post,the place of BEGINNING. HAVING thereon erected a 1 & 1/2, story frame dwelling house known and numbered as 298 Frost Road, Gardners, PA 17324. BEING the same premises which Robert W. George and Taunya L. George f/k/aTaunya L.Motter,hus- band and wife, by their deed dated 2/11/02 and recorded in Cumber- land County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Taunya Lynn George, husband and wife, as 36 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 Notary r, r,,R 1;'�L S F AL DEPC;'i�.H. A.GOLLIC;S s Notary Pu !�o g CARL ISLE 60ri()UGK,%:, QEftLANO COUNT'S riy conn nission Exolras Apr 23,2C14, s ' The Patriot-News Co. 2020 Technology Pkwy thePatr1*ot*oXtws Suite 300 �, Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 01/19/14 01/26/14 02/02/14 W . . . . . . . . . . . . . . . Swo n and subscribedbefore thi 18 day of February, 2014 A.D. c Public ..- :moi , !•. y nl..lF- .. MEM iiE$ 2043401 CN#Twm Mks let lseders! Croats nion T Tanya Lynn George alWal Ta nyyLa Gm"- f�a Robert VANk rn Gorge aids Rout W.urge A* Katt M.Ledebohm ALL THAT CERTAIN parcel of land and premises,situate,lying and being in the Township of South Middleton in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: On the north by the road,No.21005, known as the Hunter's Run Road;on the east by the Frost Road; on the south by property now or formerly of Noah Vance and on the west by Property now or formerly of W.F. Howe,more particularly bounded and described as follows:., • BEGINNING at a post along the west side of the Frost Road,at the southeast corner of the herein conveyed tract of land; thence westwardly 181 feet to a point; thence northwardly 231 feet to a point in the middle of road No. 21005, known as the Hunter's Run.Road; thence eastwardly 135.5 feet to a point where said road bears southeast;thence southeastwardly 96 feet to a point; thence southwardly 41 feet to.a point in the center of the Frost Road;thence west 16 1/2,'feet to a post,the place of BEGINNING.- HAVING thereon erected a 1 &.Y, story frame dwelling house known and numbered as 298 Frost Road, Gardners,PA 17324. BEING the same premises which Robert W. George and Thunya L. George ,f/k/aThunya L. Motter, husband and wife,by their deed dated 241/02 and recorded in Cumberland County Deed Book 250, Page 4599 granted and conveyed unto Robert William George and Thunya Lynn George, husband and wife, as joint tenants v*h*M of suvivorship. TAX PARM.NO.40-39-2214-M COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Taminy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Members 1 st Federal Credit Union is the grantee the same having been sold to said grantee on the 7th day of May A.D., 2014, under and by virtue of a writ Execution issued on the 9th day of Ocrtober, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 301, at the suit of Members Ist Federal Credit Union against Tauyna Lynn George a/k/a Taunya L. George f/k/a Taunya L. Motter and Robert William George a/k/a Robert W. George is duly recorded as Instrument Number 201413646. IN TESTIMONY WHEREOF, I have hereunto set my hand an seal of said office this day of A.D. � — C Recorder of Deeds CAmberiand county,Car",as My Expires the first Wnfty of Jan.2018