HomeMy WebLinkAbout12-0567
Leon P. Haller, Esquire r` J e N 4 P;
Purcell, Krug & Haller
1719 North Front Street v u L rt Ml f,
Harrisburg, PA 17102 GGiN
717.234.4178 PENNSYLVA.NlI,t,
mtg@pkh.com
MIDFIRST BANK IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
JILL RICHARDSON ACTION OF MORTGAGE FORECLOSURE
Defendant
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THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
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 the 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
claim in the Complaint of 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 OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA
Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU
PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE
USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED
PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE
ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
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5 f k -4 173733
MIDFIRST BANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JILL RICHARDSON,
Defendant
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT
COLLECTION PRACTICES ACT, 15 U.S.C. 1601
The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any
information obtained will be used for that purpose. The amount of the debt is stated in this
Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty
(30) days after your receipt of this notice disputes the validity of the aforesaid debt or any
portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is
valid. If the. Debtor notifies the undersigned attorney in writing with the said thirty (30) day
period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall
obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon
written request by Debtor to the undersigned attorney within said thirty (30) day period, the
undersigned attorney will provide debtor with the name and address of the original creditor if
different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorney I.D.# 15700
Attorney for Plaintiff
MIDFIRST BANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
JILL RICHARDSON, ACTION OF MORTGAGE FORECLOSURE
Defendant
7 ..'
COMPLAINT IN MORTGAGE FORECLOSURE
The Plaintiff is MIDFIRST BANK, a corporation, whose address is 999 N.W. GRAND BOULEVARD
OKLAHOMA CITY, OK 73118.
2. The Defendant, JILL RICHARDSON, is an adult individual whose last known address is 31 MARKET
STREET, WORMLEYSBURG, PA 17043.
3. On or about, October 19, 2000, the Defendant executed and delivered a Mortgage Note in the sum of
$61,660.00 payable to EQUITY ONE, INCORPORATED, which Note is attached hereto and marked
Exhibit "A".
4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to
secure payment of the same, the Defendant made, executed, and delivered to original Mortgagee, a
certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and
Commonwealth on October 23, 2000 in Mortgage Book 1646, Page 804 conveying to original
Mortgagee the subject premises. The Mortgage was subsequently assigned to HOMESIDE LENDING,
INC. and was recorded on October 23, 2000 in the aforesaid County in Book 657, Page 1109. The
Mortgage was subsequently assigned to MIDFIRST BANK and was recorded in the aforesaid County on
January 22, 2003 in Book 693, Page 3266. On March 18, 2008, the Plaintiff and the Defendant executed
a Loan Modification Agreement changing the amount of the Unpaid Principal Balance to $63,300.68,
changing the monthly payment amount and changing the Maturity Date. The Loan Modification
Agreement was recorded April 30, 2008 as Instrument Number 200813922. On March 9, 2010, the
Plaintiff and the Defendant executed a Loan Modification Agreement changing the amount of the
Unpaid Principal Balance to $73,778.62, changing the monthly payment amount, changing the Maturity
Date and changing the Interest Rate to 5.375%. The Loan Modification Agreement was recorded May
5, 2010 as Instrument Number 201011466. The said Mortgage, Assignments and Loan Modification
Agreements are incorporated herein by reference.
5. The land subject to the Mortgage is: 31 MARKET STREET, WORMLEYSBURG, PA 17043 and is
more particularly described in Exhibit "B" attached hereto.
6. The Defendant is the real owner of the property.
7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on
July 01, 2011 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $10.70 per day
From 06/01/2011 To 02/01/2012
( based on contract rate of 5.3750%)
$71,680.50
$2,568.56
Accumulated Late Charges
Good through 01/12/2012
Escrow Deficit
Corporate Advance
Attorney's Fee at 5% of Principal Balance
TOTAL
$133.71
$716.49
$1,152.44
$3,584.03
$79,835.73
"Together with interest at the per diem rate noted above after February 01, 2012 and other charges and
costs to date of Sheriff's Sale.
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the
Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter
dated September 26, 2011 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the
September 26, 2011 Act 6 Notice is attached hereto and marked Exhibit "C".
9. The within Mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in
any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. A copy
of the website report from the Department of Defense Manpower Data Center, confirming non-active
military duty is attached as Exhibit "D".
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 5.3750% ($10.70 per diem), together with other charges
and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale
of the property within described.
By: It,
P CELL, KRI & HALLER
L 66n P. Haller, Esquire
I.D. # 15700
Jill M. Wineka
I.D. #58802
Attorneys for Plaintiff
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
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Multistate ORIGNALNOTE Fse NW 00240407 October 19, 2000
inA01
31 Market Street,Wormleysburg,PA 17043
I OP-y Add-)
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
Equity One, Incorporated, a Pennsylvania Corporation
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender. Borrower promises to pay the principal sum of
'Sixty One Thousand Six Hundred Sixty and no/100
Dollars 61,660. 00 plus interest, to the order of Lender. Interest will be charged on unpaid principal.
from the date of disbursement of the loan proceeds by Lender, at the rate of Eight
percent( , 8-D000 96) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instalment that is dated the same date
as this Note and called the 'Semrity Instrument.' The Security Instrument: protects the Lender from losses which might result if
Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
December 1 2000 . Any principal and interest remaining on the first day of November
2030 will be due on that dare, which is called the "Maturity Date."
B) Mace
Paymentshallbemadeat 400 Lippincott Drive, Marlton. NJ 08053
or at such place as Lender may designate in writing
by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $452.44 This amount
will be part of a larger monthly payment required by the Security Instnrment, that shall be applied to principal, interest and
other items in the order described in the Security Instrument.
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of
the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of
this Note. [Check applicable box]
?Graduated Payment Allonge OGrowing Equity Allonge ?Other [specify]
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first
day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes it
partial prepayment, them will be no changes in the dire date or in the amount of the monthly payment unless Lender agrees in
writing to those changes.
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6. BORROWER'S FAII.URE TO PAY
(A) Late Charge for Overdue Payments
If tender has not received the full monthly payment required by the Security Instrument, as described in Paragraph
4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a We charge in the amount
of Fou r percent ( 4.0000 %) of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and
all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Leader's rights to require immediate
payment is
full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used
in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Casts and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable
law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "presentment' means the tart to requite Lender to demand payment of amounts due. "Notice of dishonor" means the
right to require Lender to give notice to other persons that amounts due have not been paid.
S. GIVING OF NOTTCES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given
by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if
Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in
Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER TIUS NOTE
If more than one person signs this Notq. each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note. Ls also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this
Note against each person individually or against all signatories together. Any one person signing this Note may be required to
pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
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WrMOUr RECOURSE PAY TO THE ORDER OF:
HOMESIDE LENDING, INC.
Page 2 or 2
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-Borrower
ALL THAT CERTAIN TRACT, OF LAND SITUATE IN THE BOROUGH OF WORMLEYSBURG,
COUNTY OF CUMBER+AND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY
BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY OF MICHAEL C. 9 ANGELO, R.S.
DATED APRIL 27. 1991 , AS FOLLOWS, TO WIT;
BEGINNING AT A POINT ON THE SOUTHERN LINT OF MARKET STREET, SAID POINT BEING
MEASURED BY SAME IN A SOUTHWESTERLY DIRECTION A DISTANCE OF 71.50 FEET FROM
SECOND STREET, THENCE SOUTH 41 DEGREES 36 MINUTES 00 SECONDS EAST BEING ALONG
AND THROUGH A PARTITION WALL AND BEYOND A DISTANCE OF 57.99 FEET TO A POINT,
THENCE SOUTH 48 DEGREES 24 MINUTES 00 SECONDS WEST A DISTANCE OF 14.66 FEET TO A
POINT, THENCE NORTH 45 DEGRES 25 MINUTES 00 SECONDS WEST ALONG THE
NORTHEASTERN LINE OF AN UNOPONED ALLEY A DISTANCE OF 58.12 FEET TO A POINT ON
THE SOUTHERN LINE OF MARKET STREET AFORESAID; THENCE ALONG SAID SOUTHERN LINE
OF MARKET STREET, NORTH 48 DEGREES 24 MINUTES 00 SECONDS EAST, A DISTANCE OF 18.53
FEET TO A POINT AND PLACE OF BEGINNING.
BEING KNOWN AND NUMBERED AS 31 MARKET STREET.
UNDER AND SUBJECT. NEVERTHELESS, TO ALL OTHER CONDITIONS AND RESTRICTIONS OF
RECORD, IF ANY, AS THEY MAY APPEAR.
Midland Mortgage A Division of MidFirst Bank
P.O. Box 268806 * Oklahoma City, OK 73126
Tel: 800.552.3000 * Fax: 405.767.5815 * MyMidlandMortgage.com
09/26/11
***REV**4.41 ***
JILL RICHARDSON
31 MARKET ST
WORMLEYSBURG PA 17043-1673
RE: 31 MARKET ST
WORMLEYSBURG PA 17043-1673
Loan Number 0046967134
Dear Mortgagor:
MidFirst Bank is the holder of a Mortgage and a Note on the above premises, or is the mortgage-servicing
agent for such holder. As of the date of this notice, THE MORTGAGE IS IN DEFAULT STATUS because
of non-payment of the following:
payments, late charges, and advances from 07/01/11 through 09/01/11
The total amount now required to cure the default (or in other words, to get caught up on your payments)
is $2825.00.
All payments referred to in this notice must be in the form of Cashier's or Certified Check made payable to
Midland Mortgage at P.O. Box 268888, Oklahoma City, OK 73126-8888, not later than the dates and
times specified herein.
In the event that payment (as specified in the proceeding paragraph) is not made WITHIN THIRTY (30)
DAYS from the date of this letter, it is the intention of the holder of the mortgage, through this company, to
accelerate (declare due and payable immediately the entire loan) the mortgage obligation and all other
lawful charges and instruct our attorney to institute MORTGAGE FORECLOSURE PROCEEDINGS.
(A) If you wish to CURE THE DEFAULT within thirty (30) days from the date of this letter, you must pay
the TOTAL AMOUNT DUE stated above, plus an additional monthly installment if payment is made
after the 1" day of the next month, plus an additional late charge if due at time of payment and not
included above. A LATE CHARGE is due with each mortgage payment that is paid more than fifteen
(15) days after the due date. Your current monthly installment is $553.39.
(B) If payment is made AFTER THIRTY (30) DAYS from the date of this letter, but BEFORE
FORECLOSURE PROCEEDINGS have been started, the amount you will have to pay will also
include the regular monthly installments and late charges then due, plus, if incurred, any
ATTORNEY'S FEES OF NOT MORE THAN $50.00 and any title report costs, which amount can be
obtained by contacting Midland Mortgage at 1-800-552-3000, extension 1799.
*If you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently in bankruptcy
under the protection of the automatic stay, this letter is not an attempt to collect the debt, but any default will need to be cured to
avoid foreclosure. If your loan was in default at the time MidFirst Bank acquired the servicing of your loan and you have not filed
bankruptcy or received a discharge of the debt secured by the Mortgage/Deed of Trust, we are required to advise you that this
communication is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that
purpose.
Midland Mortgage A Division of MidFirst Bank
P.O. Box 268806 • Oklahoma City, OK 73126
Tel: 800.552.3000 • Fax: 405.767.5815 • MyMidlandMortgage.com
AFTER FORECLOSURE PROCEEDINGS HAVE STARTED, you have the right to STOP the foreclosure
action at any time up to ONE (1) HOUR BEFORE the commencement of the SHERIFF'S SALE by paying
the entire amount due at the time (which shall include all delinquent installments and unpaid late charges,
together with REASONABLE LEGAL FEES ACTUALLY INCURRED, costs and other sums related
to the foreclosure action, and which amount can be obtained by contacting Midland Mortgage at
1-800-552-3000).
Should you FAIL to reinstate the loan as outlined above, the mortgage premises will be SOLD AT A
SHERIFF'S SALE, which will take place approximately seven (7) to eleven (11) weeks following
SERVICE of the Complaint in Mortgage Foreclosure, at which time your OWNERSHIP interest in the
mortgaged premises will be TERMINATED, and thereafter, if occupied, proceedings will be taken to
OBTAIN POSSESSION of the real estate.
You have the right to REFINANCE THE LOAN with another lending institution or TRANSFER THE
PROPERTY to another person, under and subject to the existing mortgage. That person will have the
SAME RIGHT TO CURE THE DEFAULT as you have, subject to the same limitations and requirements.
You may CURE DEFAULTS up to three (3) times in any calendar year. Upon cure of a default you will be
in the same position as if there had been NO DEFAULT. A default may be cured by ANYONE on your
behalf.
It is important that you call our office as soon as possible to discuss the options available to you. Our
Loan Counselors may be reached toll-free at 1-800-552-3000, Monday through Friday, 8:00 a.m. to
9:00 p.m. (Central Time).
Sincerely..
Delinquency Assistance Center
Midland Mortgage
Loan Number 0046967134
'If you have received a bankruptcy discharge of the debt secured by the Mortgage/Deed of Trust or you are currently in bankruptcy
under the protection of the automatic stay, this letter is not an attempt to collect the debt, but any default will need to be cured to
avoid foreclosure. If your loan was in default at the time MidFirst Bank acquired the servicing of your loan and you have not filed
bankruptcy or received a discharge of the debt secured by the Mortgage/Deed of Trust, we are required to advise you that this
communication is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that
purpose.
a .
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Pagel of 2
Dec-29-2011 13:23:52
Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
RICHARDSON JILL Based on the information you have furnished, the DMDC does not
possess any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Amtt A. ka+fu?
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 hft://www.defenselink.mil/faa/vis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www dmdo.osd.mil/appj/scra/poprepo?rt.do 12/29/2011
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 RDAs. 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:SHPDPBES9G
https://www,dmdc.osd.mil/appj/scra/popreport.do 12/29/2011
COMPANY NAME: MIDFIRST BANK
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct upon my
personal knowledge and upon 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.
Dated ? 2 ?Z
sY
Title ?or 1'- ?3ezn 5%c??`oS ""
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Midfirst Bank
vs.
Jill Richardson
V ol', of clatiGrl'4?f6
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F'E NN "iY€..VA I
Case Number
2012-567
SHERIFF'S RETURN OF SERVICE
02/02/2012 08:09 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
2, 2012 at 2009 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Jill Richardson, by making known unto herself personally, at 31 Market
Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time
handing to her personally the said true and correct copy of the same.
TIM 1A K, DEPUTY
02/03/2012 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 31 Market Street, Wormleysburg,
Pennsylvania 17043, but was unable to locate them in his bailiwick. He therefore returns the within
Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. Request for service at 31
Market Street, Wormleysburg, Pennsylvania 17043 is owner occupied only.
SHERIFF COST: $65.00
February 03, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
fq Gourt;Suite Shenif_ IeieosctY. inc
MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
JILL RICHARDSON,
VS.
DEFENDANT(S)
CIVIL ACTION LAW
NO. I2-567-CIVIL
MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
77
v
Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s)
JILL RICHARDSON for failure to plead to the above action within twenty (20) days from date of
service of the Complaint, and assess Plaintiff's damages as follows:
Unpaid Principal Balance
Interest
Per diem of $10.70
From 06/01/2011
To 02/01/2012
Accumulated Late Charges
Late Charges
( per month to 02/01/2012)
Escrow Deficit
5% Attorney's Commission
TOTAL
$71,680.50
$2,568.56
$133.71
$1,152.44
$716.49
$3,584.03
$79,835.73
"Together with additional interest at the per diem rate indicated above from the date herein, based on
the contract rate, and other charges and costs to the date of Sheriff's Sale.
PURCELL, KRUG &
By
Leon Y. er PA I.D. # 15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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C4 196988
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Il)o?jce Wi)e_c(
L
MIDFIRST BANK,
PLAINTIFF
Vs.
JILL RICHARDSON,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL r'
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE _
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on February 29, 2012 I served the Ten Day Notice required by Pa. R.C.P.
on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the
attached Notice.
By
Leon P. ZHaller I.D. # 15700
Attorney Purcell,
er
1719 North Front Street
Harrisburg, PA 17102
NPIDFIRST BANK,
Plaintiff
VS.
JILL RICHARDSON
Defendant
DATE OF THIS NOTICE: February 29, 2012
TO:
JILL RICHARDSON
31 MARKET STREET
WORMLEYISBURG, PA 17043
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 12-567-CIVIL
CIVIL ACTION LAW
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALITY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PURCELL, KRUG & HALLER
Bv
LEON P. HALLER, Attorney for Plaintiff
I.D. # 15700
1719 N. Front St., Harrisburg, PA 17102
(717) 234-4178
MIDFIRST BANK,
VS.
JILL RICHARDSON,
PLAINTIFF
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL
IN MORTGAGE FORECLOSURE'
NON-MILITARY AFFIDAVIT
1--7
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said Commonwealth and County,
LEON P. HAILER, ESQUIRE who being duly sworn according to law deposes and states that the
Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way
which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended.
Sworn to and subscribed
P. HALLER, ESQUIRE
CO ONWgd 6 NN51' NIA
NOTARIAL SEAL
MAOYLAND K. FERRETTi, Notary Public
L wer Paxton Twp., Dauphin County
M Commission Expires Aug. 8, 2014
before me this day :
of
20?.?-
i--Al-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO. 12-567-CIVIL
MIDFIRST BANK, Total Judgment Amount $79,680.50
PLAINTIFF Interest $2,290.30
Per diem of $10.70 to sale
vs. date 9/5/2012
Additional Late Charges $46.12
JILL RICHARDSON, Escrow Deficit $1,657.65
DEFENDANT(S)
TOTAL WRIT $83,674.57
*Plus additional interest, late ch arges and other costs
to date of sheriffs sale.
SALE DATE: Wednesday, September 05, 2012
(PROTHONOTARY'S USE)
Pltf. Paid
Deft. Paid
Due Proth/Clerk
Other Costs
PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE
TO THE PROTHONOTARY/CLERK OF SAID COURT: -
C- r.,
Issue Writ of Execution in the above captioned case. -' r-,
M"'
?-
Date: May 29, 2012
Attorney for Plaintiff
1719 North Front Street Leo . aller "c
c
"7
Harrisburg, PA 1,7102 .D. #15700 _
(717) 234-4178
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
TO THE SHERIFF OF CUMBERLAND COUNTY:
WRIT OF EXECUTION - MORTGAGE FORECLOSURE
SS
To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and
sell the property described in the attached description known as 31 MARKET STREET WORMLEYSBURG,
PA 17043 Q
Date: $ 018. S0
(05. bo
110.5. 75
Ito-50
ATTN
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PO ATT-,Y
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PROTHONOTARY/CLERK CIVIL DIVISION
BY
DEPUTY
*a.a5 f-stwoo
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All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey
of Michael C. D'Angelo, R.S. dated April 27, 1991, as follows, to wit;
Beginning at a point on the southern line of Market Street, said point being measured by same in a
southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes
00 seconds East' being along and through a partition wall and beyond a distance of 57.99 feet to a point;
thence South 4& degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45
degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance of
58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of
Market Street, Forth 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and
place of beginning.
Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they may
appear.
HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET
WORMLEYSBURG, PA 17043
BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00
and recorded 10'23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill
Richardson.
TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 12-567-CIVIL.
AS SESSMENT NO. 47-20-1858-157
MIDFIRST BANK,
vs.
JILL RICHARDSON,
IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENN SYLVANIA
CIVIL ACTION LAW cs
NO. 12-567-CIVIL r i --
DEFENDANT(S) u7 C-3
IN MORTGAGE FORECLOSURE
P }
AFFIDAVIT PURSUANT TO RULE 3129.1 ==
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of`fhe date
the praecipe for the writ of execution was filed, the following information concerning the real property
located at 31 MARKET STREET WORMLEYSBURG, PA 17043:
1. Flame and address of the Owner(s) or Reputed Owner(s):
JILL RICHARDSON
31 MARKET STREET
WORMLEYSgURG, PA 17043
2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1)
above: SAME
3. Name and address of every judgment creditor whose judgment is a record lien on the
real property tobe sold: UNKNOWN
Borough of Wormleysburg
20 Market Street
Wormleysburg,', PA 17043-1396
Asset Acceptance LLC
15 East Centre Street
Deptford Township, NJ 08096
Asset Acceptance LLC c/o
Edwin Abrahanlsen & Associates
1729 Pittston Alvenue
Scranton, PA 18505
4. Name and address of last recorded holder of every mortgage of record:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
Citifinancial, Inc.
P. O. Box 17170
Baltimore, MD 21203
Citifinancial, Inc.
3401 Hartzdale Drive - Suite 126
Camp Hill, PA 17011
One Main Financial
NTBS - 2320
6801 Colwell Boulevard
Irving, TX 75039
5. Name and address of every other person who has any record lien on the property:
UNKNOWN
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: UNKNOWN
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:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 171013
TENANT/OCCUPANT
31 MARKET STREET
WORMLEYSBURG, PA 17043
(In the preceding information, where addresses could not be reasonably ascertained, the same is
indicated.)
I verify that the statements made in this Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made, sect the
penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. /
Leon P.
I.D. #15700
Purcell, INr g & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: May 29, 2012
MIDFIRST BAND,
PLAINTIFF
VS.
JILL RICHARDSON,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, September 05, 2012
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
:-j
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THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property, together with a brief mention of the buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
31 MARKET STREET
WORMLEYSBURG, PA 17043
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County to:
No. 12-567-CIVIL JUDGMENT AMOUNT $79,680.50
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
JILL RICHARDSON
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of
Common Pleas of the within County at the Courthouse address specified herein.
THIS gAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
IT HA$ BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU
MAX CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO P
You may have legal rights to prevent your property from being taken away. A lawyer can advise
you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE' THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
S Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You, may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set' aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FI61) BEFORE. THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey
of Michael C. D'Angelo, R.S. dated April 27, 1991, as follows, to wit;
Beginning at a 'point on the southern line of Market Street, said point being measured by same in a
southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes
00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a point;
thence South 4$ degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45
degrees 25 minjutes 00 seconds West along the Northeastern line of an unopened alley a distance of
58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of
Market Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and
place of beginning.
Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they may
appear.
HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET
WORMLEYS8URG, PA 17043
BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00
and recorded 10'/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill
Richardson.
TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 12-567-CIVIL.
ASSESSMENT' NO. 47-20-1858-157
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-567 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s)
From JILL RICHARDSON
(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: $79,680.50
L. L.: $.50
Interest per diem of $10.70 to sale date 9/5/12 -- $2,290.30
Atty's Comm: % Due Prothy: $2.25
Atty Paid: d1(v.a25 Other Costs:
Additional Late Charges: $46.12
Escrow Deficit: $1,657.65
Plaintiff Paid:
Date: 5/31/12
David D. &Bell, Prothonotary(Seal)
Deputy
REQUESTING PARTY:
Name: LEON P. HALLER, ESQUIRE
Address: PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PA 17102
Attorney for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ID No. 15700
_ _ _ ____T __ T.
MIDFIRST BANK,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLXAN~
C ~'
CIVIL ACTION LAW
~ ~
rn
:~=~ ~
N0. 12-567-CIVIL ~~ ~
~~ ~
IN MORTGAGE FORECLOSURE 2
0
- ~
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~*t
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VS.
JILL RICHARDSON,
DEFENDANT(S)
RETURN OF SERVICE ~'' ~
~i. N
I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on
(D ~~~) I'ol , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA
R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail
(Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evide
and also to the Defendants by Certified Mail, which mailing receipts are attached. Service address.
as follows:
JILL RICHARDSON
31 MARKET STREET
WORMLEYSBURG, PA 17043
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
TENANT/OCCUPANT
31 MARKET STREET
WORMLEYSBURG, PA 17043
Citifinancial, Inc.
P. O. Box 17170
Baltimore, MD 21203
Citifinancial, Inc.
3401 Hartzdale Drive -Suite 126
Camp Hill, PA 17011
One Main Financial
NTBS - 2320
6801 Colwell Boulevard
Irving, TX 75039
e),
are
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043-1396
Asset Acceptance LLC
15 East Centre Street
Deptford Township, NJ 08096
Asset Acceptance LLC c/o
Edwin Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
By
~JG & HALLER
Plaintiff
orth Front Street
urn. PA 17102
(717) 234-4178
LAW OFFICES
HOWARD B. KRUG
LEON P. HALLER
JOHN W. PURCELL JR.
JILL M. WINEKA
LISA RYNARD
JILL RICHARDSON
31 MARKET STREET
WORMLEYSBURG, PA 17043
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Cazlisle, PA 17013
TENANT/OCCUPANT
31 MARKET STREET
WORMLEYSBURG, PA 17043
Citifinancial, Inc.
P. O. Box 17170
Baltimore, MD 21203
Citifinancial, Inc.
3401 Hartzdale Drive -Suite 126
Camp Hill, PA 17011
One Main Financial
NTBS - 2320
6801 Colwell Boulevazd
Irving, TX 75039
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043-1396
Asset Acceptance LLC
15 East Centre Street
Deptford Township, NJ 08096
Asset Acceptance LLC c/o
Edwin Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
~fG~~til°rGG, i/~~~ ~ [~f~~~2~~
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
TELEPHONE (717) 234-4178
FAX (717) 234-1206
HERSHEY
(717)533-3836
NOTICE IS HEREBY GIVEN to the Defendants in the within action and those partie who
hold one or more mortgages, judgments or tax liens against the real estate which is the subject f the
Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the
of Common Pieas of the within county on the judgment of the Plaintiff named herein the said real
will be exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate ill be
divested by the sale and that you have an opportunity to protect your interest, if any, by being d of
said Sheriffs Sale.
By:
Leon P. er PA ID.15700
ev for Plaintiff
r
MIDFIRST BANK,
PLAINTIFF
VS.
JILL RICHARDSON,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSU~4NT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1
TAKE NOTICE:
That the Sheriffs Sale of Real Property (real estate) will be held:
DATE: Wednesday, September O5, 2012
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly
of a statement of the measured boundaries of the property, together with a brief mention of the
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property ~to be sold is:
31 MARKET STREET
WORMLEYSBURG, PA 17043
THE JUDGMENT under or pursuant to which your property is being sold is docketed in
within Commonwealth and County to:
No. 12-567-CIVIL JUDGMENT AMOUNT $79,680.$0
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
JILL RICHARDSON
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmen 1 or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities th t are
owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale aid distribut on of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone obje is by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Co~rt of
Common Pleas of the within County at the Courthouse address specified herein.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
THE JUDGMENT
You may have legal rights to prevent your property from being taken away. A lawyer can
you more specifically of these rights. If you wish to exercise your rights, YOU MUST
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GQ TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YUU CAN G]
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Cazlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
717-243-9400
ACT
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to op n the
judgment if you have a meritorious defense against the person or company that has entered jud ment
against you. You may also file an petition with the same Court if you are aware of a legal defect n the
obligation or the procedure used against you.
2. After the Sherii~s Sale you may file a petition with the Court of Common Pleas of the ithin
County to set aside the sale for a grossly inadequate price or for other proper cause. This tition
MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding para aphs
must be presented to the Court of Common Pleas of the within County. The petition must be se don
the attorney for the creditor or on the creditor before presentation to the court and a proposed or er or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administ ator's
Office -Civil Division, of the within County Courthouse, before a presentation of the petition o the
Court.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
All that certain tract, of land situate in the Borough of Wormleysbwg, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a s~
of Michael C. D'Angelo, R.S. dated Apri127, 1991, as follows, to wit;
Beginning at a point on the southern line of Market Street, said point being measwed by same in a
southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 m' utes
00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a p int;
thence South 48 degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence No 45
degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance o
58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line f
Mazket Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and
place of beginning.
Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they
appeaz.
HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET
WORMLEYSBURG, PA 17043
BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10 10/00
and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto J 11
Richardson.
TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 12-567
ASSESSMENT NO. 47-20-1858-157
7196 9008 9111 4950 067'5
~'p; JILL RICHARDSON
31 MARKET STREET
WORMLEYSBURG, PA 17043
SENDER: MIDFIRST v. RICHARDS
REFERENCE: NOS 09/05/12
RETURN Postage
RECEIPT Certified Fee
i SERVICE Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Servios® P~
Receipt for ti
Certified Maim"
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MIDLAND MORTGAGE v. JILL RICHARDSON
Cumberland County Sale 9/5/2012
U. S. POSTAL SERVICE
CERTIFICAT~,Q~' MAILING
(In camnliance with Poai$~rvice Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
JILL RICHARDSON
31 MARKET STREET
WORMLEYSBURG, PA 17043
U. S. POSTAL SERVICE
CERTIFICATE OF ILING
(In comaliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Citifinancial, Inc.
P. O. Box 17170
Baltimore, MD 21203
U. S. POSTAL SERVICE
CERTIFICATE OF 1V~AI_,,,LING
(In comoliaoce with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Citifinancial, Inc.
3401 Hartzdale Drive -Suite 126
Camp Hill, PA 17011
_~~~ ~ ~ _
~ .~.% ~ -:
J
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`,' g~SP~~ P~4.,
~ ~iiis
., ~ ~~ PITNEY BOWES
02 1M $ 01.1
i 0004284324 JUN 21 20
MAILED FROM ZIP CODE 1 71
U. S. POSTAL S),~~tVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to;
One Main Financial
NTBS - 2320
6801 Colwell Boulevard
Irving, TX 75039
Postage:
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAI~NG
(Ip compliance with Postal Service Form 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Borough of Wormleysburg
20 Mazket Street
Wormleysburg, PA 17043-1396
Postage:
Postmark:
U. S. POSTAL SE~tVICE
CERTIFICATE OF MAILING
(Ia compliance with Postal Service Form 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to:
Asset Acceptance LLC
15 East Centre Street
Deptford Township, NJ 08096
Postage:
Postmark:
~~~ ~ ~~'~
l ~ ~ ~ ~ Per
~~1~/ ~e r~nrev
02 1M ~ 01.1 °
0004284324 „IUN 21 2 1 2
MAILED FROM ZIP CODE 1 10 2
U. S. POSTAL SERVICE
CERTIFICATE OF ~VIAILING
(In comaliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Asset Acceptance LLC c/o
Edwin Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
Postmark:
U. S. P,~1ST~A 1.~, SE VICE
CERTIFICATE OF MAILING
(ln comaliaace with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
,Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS
Cumberland County Courthouse
13 North Hanover Street
Carlisle, PA 17013
Postmark:
U. S. POSTAL. SE .VICE
CERTIFICATE OF MAI iWG
(In comaliance with Postal Service Form 3877)
Received from:
Pwcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
TENANT/OCCUPANT
31 MARKET STREET
WORMLEYSBURG, PA 17043
Postmark:
w
~ ~~
'®~ pTNEY
02 ,M $0115°
0004284324 JUN 2 201 2
MAILED PROM ZIP CODE 1 710 2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson, ~ ~-~_ .~ ~r ,~~~ ~_
Sheriff ~ ~ ~ ~ ~ v r~.yn- r ~~~-I~ ,-, ~r
5~~ ` ~~"~~ ~~,/ 7~1U!'YV 1171 {,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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Ctl~B~~Latill Cu~lt~TY
~~r~~~sY~vara~a
Midfirst Bank
Case Number
vs.
Jill Richardson 2012-567
SHERIFF'S RETURN OF SERVICE
06/18/2012 01:47 PM -Deputy Amanda Cobaugh, 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 31 Market Street, Wormleysburg Borough, Wormleysburg, PA 17043,
Cumberland County.
06/18/2012 01:47 PN1 -Deputy Amanda Cobaugh, 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: Jill Richardson at 31 Market Street, Wormleysburg Borough, Wormleysburg, PA 17043, Cumberland
County.
09/06/2012 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, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for
the sum of $1.00 to Attorney Leon Haller, on behalf of MidFirst Bank, being the buyer in this execution,
paid to the Sheriff the sum of $
SHERIFF COST: $865.25
October 29, 2012
SO ANSWERS,
~7
. Y
RONN R ANDERSON, SHERIFF
.SZ' l~ ~d
~~~ ~~y~
~ ~~~~43
COPY
MIDFIRST BANK,
`~'S.
PLAINTIFF
JILL RICHARDSON,
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date
the praecipe for the writ of execution was filed, the following information concerning the real property
located at 31 MARKET STREET WORMLEYSBURG, PA 17043:
1. Name and address of the Owner(s) or Reputed Owner(s):.
JILL RICHARDSON
31 MARKET STREET
WORMLF.YSBURG, PA 17043
2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1)
above: SAME
3. Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold: UNKNOWN
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043-1396
Asset Acceptance LLC
15 East Centre Street
Deptford Township, NJ 08096
Asset Acceptance LLC c/o
Edwin Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 1805
4. Name and address of last recorded holder of every mortgage of record:
PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW):
MIDFIRST BANK,
VS.
PLAINTIFF
IN THE COURT OF COMMON PI_,EAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
NO. 12-567-CIVIL
JILL RICHARDSON,
DEFENDANT(S)
TAKE NOTICE:
IN MOKTGAGE FORECLOSi1RE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA :RULE OF CIVIL PROCEDURE 3129.1
That the Sheriffs Sale of Real Property (real estate;) will be held:
DATE: Wednesday, September O5, 2012
TIME: 10:00 O'clock A.M.
LOCATION: Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLI) is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property, together with a brief mention of the buildings
and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
31 MARKET STREET
WORMLEYSBLiRG, PA 17043
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the
within Commonwealth and County fo:
No. 12-567-CIVIL JUDGMENT AMOUNT $79,680.50
THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is:
JILL RICHARDSON
A SCHEDULE OF DISTRIBUTION, being a list: of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are
owed taxes;) will be filed by the Sheriff of this County thirty {30) days after the sale and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by
filing exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of
Common Pleas of the within County at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PRnPF.RTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT itiIAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY
THE JUDGMENT
You may have legal rights to prevent your property from being taken away. A lawyer can advise
you more specifically of these rights. If you wish to exercise your rights, YOi1 ':MUST ACT
PROMPTLY.
YOL SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc
8 Irvine Row
Carlisle, Pennsylvania 17013
71 "7-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the
judgment if you have a meritorious defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if you are aware of a legal defect in the
obligation or the procedure used against you.
2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within
County to set aside the sale for a grossly inadequate price or for other proper cause. This petition
MUST BE FILED BEFORE. THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs
must be presented to the Court of Common Pleas of the within County. The petition must be served on
the attorney for the creditor or on the creditor before presentation to the court and a proposed order or
rule must be attached to the petition.
If a specific return date is desired, such date must be obtained from the Court Administrator's
Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the
Court.
PURCELL, KRUU & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and
Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey
of Michael C. D'Angelo, R.S. dated April 27, 1991, as follows, to wit;
Beginning at a point on the southern line of Market Street, said point being measured by same in a
southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes
00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a point;
thence South 48 degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45
degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance of
58.12. feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of
Market Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and
place of beginning.
Under and subject, nevertheless, t:o all other conditions and restrictions of record, if any, as they may
appear.
HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STKI?E`T
WORMLEYSBLIRG, PA 17043
BEING THF, SAME PREMISES WHICH Guy A. Berry, Jr.. and Virginia A. Berry, by deed dated 10/10!00
and recorded I0/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill
Richardson.
TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 12-567-CIVIL.
ASSESSMENT 110. 47-20-1858-157
'~ WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-567 Civi9
CO[JNTY OF CUMBERLAND) CIVIL, ACTION - I,AW
LO I'IfE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s)
From JILL RICHARDSON
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LECAL
DESCRIPTION .
(? i You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISFIEE(S) as follows:
and to notify the garnishee(s) ghat: (a) an attachment has been issued; (b) the garnishee(sl is enioined from
pa~~ing an.~~ debt to or for the account of the defendant (s) and from delivering any property of the detendant
(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 I~ue: 579,680.50 1,.L.: 5.50
Interest pc:r diem of 5(0.70 1o sale date 9/5/12 -- 52,290.30
A~ty's Comm: °/, Due Prothy: 52.25
Atty Paid: $al(o.a5 Other Costs:
Additional Late Charges: 546.12
Escrow Deficit: $1,657.65
Plaintiff Paid:
Date: 5/31!12
(Seal)
REQUi~ST1NG PAR"['Y:
Name: LEON P. HALLER, ESQUIRE;
Address: F'URCELL, KRUG &HALLER
1?19 NORTH FRONT STREET
HARRISBURG, PA 17102
Attorne~~ for: PLAINTIFF
Telephone: 717-234-4178
Supreme Court ID No. 15700
7
I ~
David D. Eau IL Prothon/ot~ar~
Deputy
TRUE COPY FROM fZECORD
In Testimony whereof, I bare unto set my hand
end the seal of said Co rt at Carlisle, Pa.
This ~ st da of ~ 20 ~c~.
~-Prothonotary
On June 1, 2012 the Sheriff ierrie~ open the defendar~:`~~
interest in the real property situates in Wormieysi~ur
Borough, Cumberland County, i~A& l~newn and r~urr~~ere
31 Market Street, Wormfeysl~urg, IAA 1043 mare uliy
described on Exhibit "~A" filet) with this wht anq ~ ~:~~~is
reference incorporated hereir~_
Date: June 1, 2012
v~ u
Claudia Brewbaker, Real Estate Cor~rdinatc~r
CUMBERLAND LAW JOURNAL
Writ No. 2012-567 Civil Term
Midfirst Bank
vs.
Jill Richardson
Atty.: Leon P. Haller
All that certain tract, of land situ-
ate in the Borough of VVormleysburg,
County of Cumberland and Com-
monwealth of Pennsylvania, more
particularly bounded and described
in accordance with a survey of Mi-
chael C. D' Angelo, R.S. dated April
27, 1991, as follows, to wit;
Beginning at a point on the south-
ern line of Market Street, said point
being measured by sanie in a south-
westerly direction a distance of 71.50
feet from Second Street; thence South
41 degrees 36 minutes 00 seconds
East being along and through a par-
tition wall and beyond a distance of
57.99 feet to a point; thence South
48 degrees 24 minutes 00 seconds
West a distance of 14.66 feet to a
point; thence North 45 degrees 25
minutes 00 seconds West along the
Northeastern line of an unopened
alley a distance of 58.12 feet to a
point on the Southern line Market
Street aforesaid; thence along said
Southern line of Market Street, North
48 degrees 24 minutes 00 seconds
East, a distance of 18.53 feet to a
point and place of beginning.
Under and subject, nevertheless,
to all other conditions and restric-
tions of record, if any, as they may
appear.
HAVING THEREON ERECTED A
DWELLING KNOWN AS 31 MARKET
STREET WORMLEYSBURG, PA
17043.
BEING THE SAME PREMISES
WHICH Guy A. Berry, Jr. and Virginia
A. Berry, by deed dated 10/10/00
and recorded 10/23/00 in Cumber-
land County Record Book 232, Page
7, granted and conveyed unto Jill
Richardson.
TO BE SOLD AS THE PROPERTY
OF .JILL RICHARDSON ON JUDG-
MENT NC). 12-567-CIVIL. ASSESS-
MEPtT NO. 47-20-1858-157.
85
'L
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 t:he following dates,
viz:
July 27, August 3, and August 10, 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.
~--
visa Marie Coyne, Ed' or
SWORN TO AND SUBSCRIBED before me this
10 daY of August 2012
;' ~ ~' /
~- Not --~~T~L~
~' ,~ ;
- --___.
NCTAR~AL SEAL
DEBCHAN A CCLLi~`J5
Natarv }'ublic
GARLESLE BOfCJGH. CilMBE~iLANU (;(~;~; ~,~
«Y~,nmission expires Apr 25, ~°~;1 i
COMMONWEALTH OF PENNSYLVANIA
COUN"I'Y OF CUMBERLAND
~' SS:
I. Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriffs Deed in which MidFirst Bank is the grantee the same having been sold to said grantee on
the 5th day of September A.D., 2012, under and by virtue of a writ Execution issued on the 31st day of
May, A.D., 201 ~ ,out of the Court of Common Pleas of said County as of Civil Term, 2012 Number
567, at the suit of MidFirst Bank against Jill Richardson is duly recorded as Instrument Number
20123332.
IN TESTIMONY WHEREOF, I have hereunto set my hand
r ~._.
and seal of said office this day of
. ~, A.D. ~~/~-
7~ -~ ~ ~:
e ecorder of Deeds
Recorder of Deeds, G .a1~ ~:c~arny, Ca+l+sle, PA
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