HomeMy WebLinkAbout12-0382SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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Ct.9?9BBLAND COUNTY
PENNSYLVANIA
Ocwen Loan Servicing, LLC Case Number
vs. 2012-382
Janet I. Musser
SHERIFF'S RETURN OF SERVICE
01/30/2012 05:15 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January
30, 2012 at 1715 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Janet I. Musser, by making known unto Chris Reisinger, adult in charge at
416 Dogwood Court, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $34.00
February 02, 2012
TIM LA K, DEPUTY
SO ANSWERS,
RON e R ANDERSON, SHERIFF
%,ourySuita Shenff. Teleosoft. Inr..
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
I11 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingF@udren.com
Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
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V. MORTGAGE FORECLOSURE
JANET I. MUSSER
416 DOGWOOD COURT
CARLISLE, PA 17013 NO. 2012-382
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
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Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), JANET I. MUSSER; for
failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of
the mortgaged premises, and assess Plaintiffs damages as follows:
Unpaid Principal Balance
Interest Per Complaint
Additional Interest
Late Charges Per Complaint
Additional Late Charges
Escrow Per Complaint
Title Report
Attorney Fees- Estimated
Property Inspections
Grand Total
FROM TO
$122,563.32
$2,605.50
12/28/2011 03/29/2012 $1,355.01
$130.24
12/28/2011 03/29/2012 $97.68
$865.80
$300.00
$1,300.00
$67.00
$129,284.55
I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has
been given in accordance with Rule 237.1, a copy of which is attached hereto.
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: YAM?
MJU#: 11110626 CASE#: 11110626-1
P.C.
Alan M. Minato, Esquire
PA ID 75860
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PRO PROTHY
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UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
PAIGE M. BELLINO, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
AMY GLASS, ESQUIRE - ID#308367
KASSIA FIALKOFF, ESQUIRE - ID#310530
DONNA L. SKILTON, ESQUIRE - ID#206551
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings(4),u.dren.com
Ocwen Loan Servicing, LLC
CIO Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
V.
JANET 1. MUSSER
416 DOGWOOD COURT
CARLISLE, PA 17013
Defendant(s)
ATTORNEY FOR PLAINTIFF
c.
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
NO. aQta-a{V? t
COMPLAINT IN MORTGAGE FORECLOSURE
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YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further. notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff of Cam
Jody S Smith
Chief Deputy'
Richard W Stewart
Solicitor OFF ICE OF THE "iPAPP
Ocwen Loan Servicing, LLC Case Number
vs, 2012-382
Janet 1. Musser
SHERIFF'S RETURN OF SERVICE
01130/2012 05:15 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January
30, 2012 at 1715 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Janet I. Musser, by making known unto Chris Reisinger, adult in charge at
416 Dogwood Court, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $34.00
February 02, 2012
66 ff.,/ (/ ?i. ?{ 7
TIM LA K, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
JANET I. MUSSER
MORTGAGE FORECLOSURE
Defendant(s)
NO. 2012-382
TO: JANET I. MUSSER
416 DOGWOOD COURT
CARLISLE, PA 17013
Date of Notice: February 22, 2012
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS
DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DIN"ERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
UDREN LAW OFFICES, PC.
BYE --
Attorney for Plaintiff
,Adan M. Minato, Esquire
PA ID 75860
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, New Jersey 08003-3620
MJU#: 11110626 CASE#: 11110626-1
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
lP eadings a*udren.com _
Ocwen Loan Servicing, LLC
Plaintiff
V.
Janet I. Musser
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE,
NO. 2012-382
AFFIDAVIT OF NON-MILITARY SERVICE
UNDER Pa.R.C.P 76
THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data
Center for the Defendant(s), that the Defendant(s), JANET I. MUSSER, who/each of whom is over 18
years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The
Military Status Report(s) is/are attached hereto as Exhibit "A".
The Affiant lacks sufficient information to be able to determine whether any other Defendants in
this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social
Security number(s) for said Defendant(s) to enable a search.
This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Attorney for Plaintiff
Alan M. Minato, Esquire
PA ID 758,60
MJU#: 11110626 CASE#: 11110626-1
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Mar-29-2012 08:42:50
Last
First/Middle
Begin Date
Active Duty Status
Active Duty End Date Service
S Agency
Name
Based on the information you have furnished, the DMDC does not possess
MUSSER JANET any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
00
y6t In 414
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://ww":.defenselink.mil/fag/vis/P('09SLE)R.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/29/2012
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:MDJP254EOJ
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/29/2012
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadiny,sa@udren.com
Ocwen Loan Servicing, LLC
Plaintiff
V.
JANET I. MUSSER
Defendant(s)
TO : Janet I. Musser
416 Dogwood Court,
Carlisle, PA 17013
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
11 MORTGAGE FORECLOSURE
NO. 2012-382
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
? Judgment by Default
? Money Judgment
? Judgment in Replevin
? Judgment for Possession
? Judgment on Award of Arbitration
? Judgment on Verdict
? Judgment on Court Findings
Prothonotary
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CONTACT:
Attorney for Plaintiff
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003-3620
Phone: (856) 669-5400
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 r-
pleadines(a)udren.com
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS '
Plaintiff CIVIL DIVISION'
V. Cumberland County
Janet I. Musser MORTGAGE FORECLOSURE
Defendant(s) "?-
NO. 2012-382
PRAECIPE TO ISSUE WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount due
Interest From 3/30/2012
to Date of Sale September 5, 2012
Ongoing Per Diem of $14.57
to actual date of sale including if sale is
held at a later date
(Costs to be added)
$ 129,284.55
$ 2,331.20 0
$ d8 .-P fn AMY
31.00 C-Ew
/03,75
$ A,-50 01.50 $185. Q5 -. Pp A'rM
UDREN LAW OFFICES, P.C.
MJU#: 11110626 CASE#: 11110626-1
Alan M. Minato, Esquire
PA ID 7SF360
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P'E (,)rif Awact
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings gudren.com
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION -
Cumberland County
Janet I. Musser MORTGAGE FORECLOSURE,?__
s .,
Defendant(s) , - . `-
..
NO. 2012-382 - c
CERTIFICATE OF ACT 91
I hereby state that as the attorney for the Plaintiff in the above-captioned matter:
M Act 91 procedures have been fulfilled
n Premises is not subject to the provisions of Act 91
as this is an FHA insured mortgage
This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
UDREN LAW_OFFICES,P.C.
Attorney for Plaintiff
Alan M. Minato«? Esquire
PA ID 75860
t UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadino(d?,udren.com
Ocwen Loan Servicing, LLC
Plaintiff
V.
Janet I. Musser
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
y?7
Defendant(s)
NO. 2012-382
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
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Ocwen Loan Servicing, LLC, Plaintiff in the above action, by its undersigned attorney, upon information and
belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the
following information concerning the real property located at:
416 Dogwood Court, Carlisle, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Janet I. Musser
416 Dogwood Court
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Janet I. Musser
416 Dogwood Court
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders - None
4. Name and address of the last recorded holder of every mortgage of record:
Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Sr Mortgage Holders - None
Jr Mortgage Holders - None
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders - None
6. Name and address of every other person who has any record interest in the property and whose interest may
be affected by the sale:
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
416 Dogwood Court
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale:
Federal Tax Lien Holders - None
Willow Crossing Condominium Association
Address to Follow
I verify that the statements made in this affidavit are true and correct to the best of my information and
belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904
relating to unsworn falsification to authorities.
DATED: l 2 UDRE OFFICES, P.C.
Attorney for Plaintiff
MJU#: 11110626 CASE#: 11110626-1 Alan M. Minato, Esquire
PA ID 75860
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadinasAudren.com
Ocwen Loan Servicing, LLC
Plaintiff
V.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Janet I. Musser MORTGAGE FORECLOSURE
Defendant(s)
NO. 2012-382 w `=
AFFIDAVIT OF LAST KNOWN ADDRESS
UNDER RULE 76
r
The Defendant(s) last known address is as follows:
JANET I. MUSSER
416 DOGWOOD COURT
CARLISLE, PA 17013
This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
UDREN LAW OFFICES P.C.
Attorney for Plais??
AIM K Mmat o, Esquim
PA Eli ?SM
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings(&udren.com
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION -
V. Cumberland County 3 q -
JANET I. MUSSER MORTGAGE FORECLOSURE N r
Defendant(s) NO. 2012-382
SHORT DESCRIPTION FOR ADVERTISING
ALL THAT CERTAIN LOT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA:
BEING KNOWN AS 416 Dogwood Court, Carlisle, PA 17013
PARCEL NUMBER: 40-22-0485-070-U1
IMPROVEMENTS: Residential Property
UDREN LAW OFFICES, P.C.
Attorney Ior am i
Alan M. Minato, Esquire
PA ID 75860
ALL THAT CERTAIN UNIT, BEING UNIT NO. 1 (THE UNIT"), OF WILLOW
CROSSING, A CONDOMINIUM, LOCATED IN SOUTH MIDDLETON TOWNSHIP,
CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN
THE DECLARATION OF CONDOMINIUM OF WILLOW CROSSING, A
CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION
PLATS AND PLANS AS RECORDED IN THE OFFICE OF THE RECORDER OF
DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN MISCELLANEOUS BOOK
388, PAGE 869 AND PLAN BOOK 61, PAGE 62 AND FIRST AMENDMENT TO
DECLARATION OF CONDOMINIUM FOR WILLOW CROSSING, A CONDOMINIUM
(THE "FIRST AMENDMENT TO DECLARATION OF CONDOMINIUM") AND
DECLARATION PLATS AND PLAN AS RECORDED IN THE OFFICE OF THE
RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN
MISCELLANEOUS BOOK 388, PAGE 412 AND PLAN BOOK 61, PAGE 97.
TOGETHER WITH THE UNDIVIDED 2.50% INTEREST IN COMMON ELEMENTS
AS MORE PARTICULARLY SET FORTH IN THE AFORESAID DECLARATION OF
CONDOMINIUM AND DECLARATION OF PLATS AND PLANS.
TOGETHER WITH THE RIGHT TO USE THE LIMITED COMMON ELEMENTS
APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE
DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS,
AND AMENDMENTS THERETO.
BEING KNOWN AS 416 DOGWOOD COURT.
PARCEL NUMBER 40-22-485-070-U1
AS DESCRIBED IN MORTGAGE INSTRUMENT NUMBER 200817764
BEING KNOWN AS: 416 DOGWOOD COURT, CARLISLE, PA 17013
PROPERTY ID NO.: 40-22-0485-070-U1
TITLE TO SAID PREMISES IS VESTED IN JANET I. MUSSER, WIDOW BY DEED
FROM DAVID L. DESFOR AND CHRISTINE M. DESFOR, HIS WIFE DATED
05/03/1996 RECORDED 05/09/1996 IN DEED BOOK 138 PAGE 1083.
Fax:
Apr 2 2012 10:23am P002/003
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
lea ' s udren.com
Oewen Loan Ser?-icing, LLC 'COURT OF COMMON PLEAS -? _
Plaintiff CIVIL DIVISION
,--^-7-
v Cumberland County c
JANET I. MUSSER MORTGAGE FORECLOSURE ? .
Defendaut(s) >
NO. 2012-382
NO'T'ICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Janet I. Musser
416 Dogwood Court
Carlisle. PA 17013
Your house (real estate) at 416 Dogwood Court, Carlisle, PA 17013 is scheduled to be sold at
the Sheriffs Sale on September 5, 2012 at 10:00am, at the Cumberland County Courthouse,
Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment
of $129.284.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is
postponed, the property will be relisted for the Next Available Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable
attorney's fees, To ;fund out how much you must pay, you may call: (856) 669-5400.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the
judt-went was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the We. (See notice on page two on how to obtain an attorney.)
Fax: Apr 2 2012 10:23am P003/003
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU RAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
I . If the SherifTs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling 856-669-5400.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call 856-669-5400.
4. If the amount due from the Buyer is not paid to the Sheriff, you unit remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be fined by the Sheriff within 30 days after the sale. This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after
Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale-
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
ASSOCLMON DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-382 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OCWEN LOAN SERVICING, LLP, Plaintiff (s)
From JANET I. MUSSER
(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: $129,284.55
L. L.: $.50
Interest from 3/30/12 to Date of Sale 9/5/12 Ongoing Per Diem of $14.57 to actual date of sale
including if sale is held at a later date -- $2,331.20
Atty's Comm: %
Atty Paid: $185.25
Plaintiff Paid:
Date: 4/2/12
Due Prothy: $2.25
Other Costs:
(Seal.)
REQUESTING PARTY:
Name: ALAN i14. MINATO, ESQUIRE
Address: UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
11 I WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No. 75860
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadinas(d?udren.com
Ocwen Loan Servicing, LLC
Plaintiff
~~.
JANET I. MUSSER,
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT' OF COMMON PLEAS ~ ~ -
CIVIL DIVISION -_
Cumberland County
MORTGAGE FORECLOSURE
NO. 2012-382 .~ - ~ `~' :
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as
Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date
of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified maul on the date
appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on
the said Return Receipt. Copies of the'said Notice and Return Receipt are attached hereto a~, Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal service on the date
specified on the attached Return of Service, attached hereto as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as
Exhibit "B''.
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification
to authorities.
~,
Dated:~~' ' ~ ~ ~~ UDRE LAW FICES, P.C.
Att f Iai iff r
HARRY B. F;EESE, ESt~',J':Fi.,;.
MJU#: 111.10626 CASE#: 11110626-1
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 VVOODCREST ROAD, SUITE 200
CHERRY- HILL, NJ 08003-3620
856-669-5400
pleadings(d~udren.com
ATTORNEY FOR PLAINTIFF
__
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. 'Cumberland C'ount~~
Janet I. Musser ~' MORTGAGE FORECLOSURE
Defendant(s)
NO. 2012-382
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
AND RULE 76
Ocwen Loan Servicing, LLC, Plaintiff in the above action, by its undersigned attorney, upon
information and belief; Udren Law Offices, P.C., sets forth, as of the date the Praecipe for t:he
Writ of Execution was filed, the following information concerning the real property located at:
416 Dogwood Court, Carlisle, PA 17013
1. Name and address of Owner(s) or reputed Owner(s):
Janet I. Musser
416 Dogwood Court
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Janet I. Musser
416 Dogwood Court
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Jr Lien Holders -None
4. Name and address of the last recorded holder of every mortgage of record:
Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FI~ 33409
Sr Mortgage Holders -None
Jr Mortgage Holders -None
5. Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
6. Name and address of every other person who has any record interest. in the property and whose
interest maybe affected by the sale:
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
416 Dogwood Court
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge whc> has any
interest in the property which maybe affected by the sale:
Federal Tax Lien Holders -None
Willow Crossing Condominium Association
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA17013
Willow Crossing Condominium Association
722 Limekiln Road
New Cumberland, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my
information and belief: I understand ghat false statements herein are made subject to the
penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
^~%
DATED: ,~ ' ~ ~ C) ~ ~ ~~ ~~ UDREN LAW OFFICES, P.C.
J
BY. ..._.- --.
At ain 'ff
HARRY B. REESE, ESQUIRE
MJU#: 11110626 CASE#: 11110626-1
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
_8.56-669-400
----
Ocwen Loan Servicing, LLB
Plaintiff
~.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland Count~~
JANET I. MUSSER; ~~
Defendant(s) MORTGAGE FORECLOSURE
NO. 2012-382
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
OWNER(S): JANET L MUSSER;
FROPERTI': 416 Dogwood Court, Carlisle, PA 17013
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale
on 09/05/2012 at 10:00 AM, at the Cumberland County Courthouse, Commissioners
Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you ma~~ hold a
mortgage or judgment on the property, which will be extinguished by the sale. Y'ou may wish to
attend the sale to protect your interests.
The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30
days after sale. Distribution will be made in accordance with the schedule unless exceptions are
filed thereto within 1 G days after the filing of the schedule.
MJU#: 11110626 CASE#: 11110626-1
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UDREN LA W OFFICES, P. C.
WOODCREST CORPORATE CENTER
11.1 WOODCREST ROAD
SUITE 200
CHERRYHILL, NEW JERSEY 08003-3620
856. 669. 5400
FAX: 856. 669. 5399
MARK J. UDREN, ESQUIRE
ADMITTED NJ, PA, FL
TINA MARIE RICH
Director of Operations
PLEASE RESPOND TO NEW JERSEY OFFICE
October 24, 2012
Prothonotary of Cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Ocwen Loan Servicing, LLC'
vs.
JANET I. MLJSSER; et al
Cumberland(:ounty C.C.P. No. 2012-382
Dear Prothonotary:
In connection with the: above file, enclosed please find Praecipe to File; Proof of Service for
filing.
Also enclosed is an extra copy of the Praecipe to be time stamped and returned in the enclosed
self-addressed stamped envelope.
Thank you. for your assistance with this matter.
Sincerely yours,
Danielle Devlin
Legal assistant
/dad
Enclosure
cc: Sheriff of Cumberland Country
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY' HILL, NJ 08003-3620
856-669-5400
Ocwen Loan Servicing, LLC COURT OF COMMON PLF,AS
CIVIL DIVISION
Plaintiff Cumberland County
v.
JANET L MUSSER; et al NO. 2012-382
Defendant(s)
PRAECIPE TO FILE PROOF OF SERVICE
TO TH E PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter,
.~ ,
Date " ~, '~ ~'i~ ~ `~
~_ ~, ` ~
UDREN LAW OFFICES, P.C.
r .,
/ 1 ~~ ~,
BY _____
Attorne or laintiff -
...,~5~~,4i;,R
~A :~ 310501
Oc,-•en Loan Scrvicin.g, LLC, et. aL, Plaintiff(s)
vs.
Janet 1. 14fusser, et. al., Defendant(s)
UDREN LAV1' OFFICES
Ms. Danielle Devlin
1 I I Woodcrest Rd., Ste. 200
C6errv Hill, NJ 08003-3620
Service of Process by
~~ APS International, Ltd.
~' ~~
~_ - ~ 1-800-328-7171
' A['S IN7ExNATiO~~AL l APS lntcrnational PIa2a
\ 7800 Glenroy Rd.
\ Nlinncapolis, A1N SSa39-3122
APS File k: t 19117.0001
___ AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
-~-Janet I. Musser, by posting
Court Case No. Cumberland Co 2Q12-382
- -- -- -- -
State oP - s . - ._ - - - - - - - - -- - - - - - - -- - --
County of:
Name of Server: ~ ~rr5~-tarn I~oeS e.( ,undersigned, being duly sworn, deposes and says
that at the time of service, sllte vas of legal age and was not a party to this action;
Date/Time of Service: that on the ~_day of ~efl~ertber , 20 i2 , at _ ! ~!s o'clock ~~ M
Place of Service:
Documents Served:
Service of Process nn
Person Served, and
Method of Service:
at 41G Dogwood Court > In Carlisle, PA 17013
the undersigned served the documents described as:
Notice of Sheriff s Sale of Real Property w/Order
A true and correct copy of the aforesaid document(s) was served on:
Janet I. Musser, by posting
~ ^~By personally delivering them into the hands of the person to be served.
'~~ By dcaivering them into the hands of , a person
of suitable age, who verified, or who upon questioning stated. that he/she resides with
Janes: 1. Musser, by posting
at the: place of service, and whose relationship to the person is: _
Description of Person The person receiviltg documents is described as follows:
Receiving Documents: Sex __; Skin Color ;Hair Color _ ;Facial Hair
Approx. Age ;Approx. Height ;Approx. Weight
^ To the best of lny knowledge and belief, said person was not engaged in the US Military at
the time of service.
Signature of Server: Undersigned declares under penalty of perjury
that the foregoing is true and correct.
Signature of Server
APS International, Ltd.
. roMMONWEALTFf pp PENNSYLVANiq
M, MitheNe rtal ~~ ry
Carll~e eoro, Kota PubNc
Cumberland County
~ ~ ExDlres July 9, 2016
MEMBER, r'ENMSYLVAWA ASSOCIATION OF t+IOTARIES
UDREN LA W OFFICES, P. C.
WOODCREST CORPORATE CENTER
ll I WOODCREST ROAD
SUITE 200
CHERRYHILL, NEW JERSEY 08003-3620
856. 669. 5400
.FAX: 856. 669. 5399
MARK J. UDREN, ESQUIRE
ADMITTED NJ, PA, FL
TINA MARIE RICH
Director of Operations
PLEASE RESPOND TO NEW JERSEY OFFICE
October 24, 2012
Prothonotary of Cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Ocwen Loan Servicing, LLC
vs.
JANET I. MUSSER; et al
Cumberland(:ounty C.C.P. No. 2012-382
Dear Prothonotary
In connection with the above captioned matter, enclosed please
find Verification of Service by Certified Mail and Regular Mail
Pursuant to Court Order. I have enclosed a copy of the i=first .
page to be time stamped a:nd returned in the enclosed sell=-
addressed stamped envelope.
Thank. you for your assistance with this matter
Sincerely yours,
Danielle Devlin
Legal assistant
/dad
Enclosure
cc: Sheriff of Cumberland County
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
lll WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Ocwen Loan Servicing, LLC
Plaintiff
v.
JANET L MUSSER; et al
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURTT OF COMMON PLEAS
CIVIL DNISION
Cumberland County
NO. 2012-382
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that he is counsel for I?laintiff
in the above case and that pursuant to the Court order issued in
this matter a true and correct copy of the Notice of sale was
mailed to Defendant(s), by certified mail and regular fi~.~st class
mail, to the last known address of Defendant(s) as follows:
DATE MAILED: 9/25/2012
Janet I. Musser
416 Dogwood Court
Carlisle, PA 17013
I verify that the statements made herein are true and correct and
I understand that false statements made herein are subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date // ~, ~~ ~ ~;~ ti 2-~ ~
UDREN LAW OFFICES, P.C.
B / a
At or aintiff
~r~RRY 8. REESE, ESQUIRE
~, ~ ~ ; ~,~ r (l 1
IN THE COLiRT OF COMMON PLEAS OF CUMBERLAND COUNTY
______ _ __________ CIVIL TRLAL DIVISION
Ocwen Loan Servicing, LLC !, COURT OF COMMON PLEAS
Plaintiff '~ CNIL DIVISION
CUMBERLAND County
v.
3A'VET 1. MUSSER: ET AL ~ :. y.
NO. 2012-382 ~~ ,
Defendant(s)
ORDER PERMITTING SPECIAL SERVICE
~~
AND NOdV, this /~ day of c;_~~/~ ° , 2012 ,upon consideration. of Plaintiff's Motion
and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that
sen~ice of the Notice of Sale and all subsequent pleadings on Defendant(sj, JANET I.
MUSSER, shall be complete when Plaintiff or its counsel or agent has mailed true and correct
copies of the Notice of Sale and all subsequent pleadings by posting the mortgage premises at:
41b Dogwood Court
Carlisle, I'A 17(113
And b_y mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
JANET L. MUSSER
41.6 DOGWOOD COURT
CARLISLE, PA 17013
BY THE COURT:
Est: c~~ - ,~ f .
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u °~` _ Carlisle, PA 17013 ~
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SHERIFF'S OFFICE OF CUMBERLAND COUNTX
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Ocwen Loan Servicing, LLC
vs.
Janet I. Musser
~.~~:,titit5, nt 4+uri#E~fy7i,~
Cease Number
2012-382
SHERIFF'S RETURN OF SERVICE
06/22/2012 05:39 PM -Deputy Michael Garrick, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 41E Dogwood Court, South Middleton Township; Carlisle.. PA 17013.
C:',umberland County,
SHERIFF COST: $905.20 SO ANSWERS,
,luiy 17, 2012 RON ~ R ANDERSON, SHERIFF
a~s,~~ ~~~-, ~ c~ .nu ~„_