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HomeMy WebLinkAbout12-1803McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 .a The Bank Of New York Mellon f/k/a The I CUMBERLAND COUNTY Bank Of New York as Trustee for The Certificate Holders Cwabs, Inc., I COURT OF COMMON PLEAS Asset-Backed Certificates, Series 2005-13 Number: v 1 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants ?c © ,?-, COMPLAINT IN EJECTMENT 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 Attorneys for Plaintiff AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 S ar?? io3.7s? ??a-?aco g? McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff The Bank Of New York Mellon f/k/a The Bank Of New York as Trustee for The Certificate Holders Cwabs, Inc., Asset-Backed Certificates, Series 2005-13 1800 Tapo Canyon Road Mail Stop 4SV-103 Simi Valley, California 93063 VS. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants 210 Regal View Drive Carlisle, Pennsylvania 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: COMPLAINT IN EJECTMENT Plaintiff is the owner of the premises known as 210 Regal View Drive, Carlisle, Pennsylvania 17013, the legal description of which is set forth in the Sheriffs Deed which is attached hereto as Exhibit "A." 2. Plaintiff acquired title by reason of a Sheriffs Sale conducted by the Sheriff of Cumberland County on February 1, 2012, by reason of Writ of Execution issued out of Cumberland County Court of Common Pleas, Number: 2011-5209 Civil Term at the suit of The Bank Of New York Mellon f/k/a The Bank Of New York Not In Its Individual Capacity But Solely As Trustee For The Benefit Of The Certificateholders Of The CWABS Inc., Asset-Backed Certificates, Series 2005-13 vs. Leslie A Blessing a/k/a Leslie Blessing and James Blessing. 3. Defendants Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants are in possession of the foregoing described premises without title, color of title, or benefit of a lease from Plaintiff. 4. Defendants are wrongfully and unlawfully in possession of the premises. Defendants have no rights of possession to said premises. 6. By reason of the aforesaid Sheriff's sale, Plaintiff holds paramount title to the premises but Defendants continue to unlawfully and willfully retain possession and keep Plaintiff out of possession thereof and refuse to vacate and deliver up the said premises to Plaintiff. 7. No landlord tenant relationship exists between Plaintiff and Defendants, either written or oral, express or implied, and no such relationship was created as a result of the mortgage foreclosure. 8. Because there is no landlord tenant relationship - this is an action in ejectment, not eviction - there is no requirement to give Defendants a notice to quit or vacate the premises. Further, the commencement of an action in foreclosure culminating in a sheriffs sale, followed by the filing of a complaint in ejectment should have put Defendants on notice that Plaintiff intends to recover full interest, title, and possession of the premises. 9. Notwithstanding the aforesaid, Defendants have willfully remained in possession of Plaintiffs property and refuse, and still refuse to vacate the premises and continue to occupy the same. WHEREFORE, Plaintiff demands a judgment be entered in its favor for possession of the property. McCABE, WEISBERG, AND CONWAY, P.C. BY. Z-?k-O-A- f - ) ? Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE VERIFICATION I, the undersigned, hereby verify that I am the attorney for the Plaintiff in this action, and that I am familiar with the matters set forth in the within action, that I am authorized to make this verification, and that the forgoing facts are true and correct to the best of my knowledge, information and belief, and further state that false statements herein are made subject to the penalties of 18 PA.C.S. § 4904 relating to unsworn falsifications to authorities. McCABE, WEISBERG, D YO WAY, P.C. BY: " Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE The Bank Of New York Mellon f/k/ a The Bank Of New York as Trustee for The Certificate Holders Cwabs, Inc., Asset-Backed Certificates, Series 2005-13 v. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201205573 Recorded On 2/24/2012 At 1:33:2 1 PM * Instrument Type - DEED-SHERIFF'S Invoice Number - 102710 User ID - KW * Grantor - BLESSING, JAMES * Grantee - CWABS INC * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CARLISLE AREA SCHOOL $0.00 DISTRICT NORTH MIDDLETON TOWNSHIP $0.00 TOTAL PAID $63.00 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER OF " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. miiNiTui?i? ?? 1111111111 Tax Parcel No. 29-15-1251-125 Know all Men by these Presents That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to The Bank of New York Mellon f/k/a The Bank of New York As Trustee for The Certificate Holders Cwabs, Inc., Asset-Backed Certificates, Series 2005-13 2011-5209 Civil Term. The Bank of New York Mellon Vs James Blessing Leslie A. Blessing, a/k/a Leslie Blessing Atty: Terrance McCabe All that certain tract or parcel of land and premises situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania more particularly bounded and described as follows: BEGINNING at a point on the western right of way line of Cottonwood Court, at the terminus of a curve connecting said right of way with the southern right of way line of Regal View, thence from said point of beginning, by said western right of way line of Cottonwood Court South seven degrees, twenty nine minutes, eighteen seconds West (S 070 29' 18" W), a distance of one hundred fourteen feet (114.00') to a point; hence by Lot No. 82 North eighty two degrees, thirty minutes, forty two seconds West (N 82 ? 30' 42" W), a distance of one hundred five feet (105.00) to a point; thence by Lot No. 44 North seven degrees, twentynine minutes, eighteen seconds East (N 070 29' 18" E), a distance of one hundred twenty five feet (125.00'), to a point; thence by said southern right of way line of Regal View South eighty two degrees, thirty minutes, forty two seconds East (S 820 30'42" E), a distanc. of ninety four feet (94.00'), to a point; thence by a curve to the right, having a radius of eleven feet (R= 11.00'), an arc distance of seventeen and twentyeight hundredth feet (A/L = 17.28'), to a point, the place of BEGINNING. CONTAINING 13,099.03 square feet, more or less. BEING Lot No. 45 on the plan entitled "Final Subdivision Plan for North Ridge Phase 3 dated January 10, 2002, last revised May 6, 2002, prepared by Hartman and Associates Exhi i? bit A and recorded in the Office of the Recorder of Deeds of and for Cumberland County in Plan Book 85, Page 106. RB5678 210 Regal View Drive, Carlisle, Pennsylvania 17013. BEING the same premises which MICHAEL P. GARDNER AND CYNTHIA L. GARDNER, HUSBAND & WIFE by deed dated October 25, 2005 and recorded November 9, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 271, Page 4462, granted and conveyed to Leslie A Blessing a/k/a Leslie Blessing and James Blessing, husband and wife, in fee. TAX MAP PARCEL NUMBER: 29 15 1251 125 The same having been sold by me to the said grantee on the 1st day of February, Anno Domini Two Thousand and Twelve (2012) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 30th of August Anno Domini 2011 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eleven (2011) Number 5209 at the suit of The Bank of New York Mellon Vk/a The Bank of New York not in its individual capacity but solely as Trustee for the Benefit of the Certificateholders of the CWABS Inc., Asset- Backed Certificates, Series 2005-13 vs Leslie A. Blessing a/k/a Leslie Blessing and James Blessing. In Witness Whereof, I have hereunto affixed my signature this 16th day of February Anno Domini Two Thousand and Twelve (2012) o . Anderson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 16th day of February Anno Domini Two Thousand and Twelve (2012) ) ) i" ?occIif .>, ( Q..A A'6 -A Aft^ , nfr? thonotaryDgVzO 'IiU L . hotFiOrsotary, Cumberland County,- Car6k, PA ;6 T f My CanjWuj n Eeplres the" Monday of *L 7M4 • I hereby certify that the residence = ?'' ?= ' ;? 1 And Post Office address of the `?; ,'< • • • • = 1? ??` • Within Grantee is ?' 4' 00` ? /?fr?= if r 1800 Tapo Canyon Road ,t t r Mail Stop #SV-103 Simi Valley, CA 93063 f Solicitor REV-183 EX (04-10) RECORDER'S USE ONLY pennsylvania REALTY TRANSFER TAX State Tax Paid DEPARTAENTOFMANUE STATEMENT OF VALUE Book Number Bureau of Individual Taxes Page Number PO Box 280603 See reverse for instructions. Rec"ded Harrisburg. PA 17128-0603 date .7- Complete each section and file in duplicate with Recorder of Deeds when (1) the full value/consideration is not set forth in the deed, (2) the deed Is without consideration or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from tax based on family relationship or public utility easement. If more space is needed, attach additional sheets. A. CORRESPONDENT - AU inquires may be directed to the following person: Name Telephone Number McCabe, Weisberg and -Conway, P.C. ---- 215-790-1010 - _ Mailing Address C State --? Zip Code 123 S. Broad Street, Suite 2080 _ f Philadelphia - PA 19109 B. TRANSFER DATA C. Date of Acceptance of Document Grantor(s)/Lessor(s) Grantee(s)/Lessee(s) The Bank Of New York Mellon Fka The Bank Of New Sheriff of Cumberland York As Trustee For The Certlfloateholders Cwabs, Inc., Asset-Backed Certificates, Series 2005-13 Mailing Address Mailing Address 1 Courthouse Square, Third Floor 1800 Tapo Canyon Road, Mail Stop #SV-103 Stale c;ty Mate Zip Code City Zip Code Carlisle PA 17013 Simi Valley CA 3063 D. REAL ESTATE LOCATION _wns_ - - -" - , Tohip, Borough Street Address ' 210 Regal View Drive _ Carlisle (city) County School District Tax Parcel Number Cumberland - --- - 29-15-1251-125 - E. VALUATION DATA - WAS TRANSACTION PART OF AN ASSIGNMENT OR RELOCATION? ? Y N _- -.- --- _-- . _ 1. Actual Cash Consideration ?2. Other consideration 3. Total Consideration = $1,073.91 $1,073.91 I +0.00 ?- -_ _ - 4. County Assessed Value 5-Common Level Ratio Factor 6. Fair Market Value $210,765.00 x 1.00 __L= $2102765.00 _ F. EXEMPTION DATA 1a. Amount of Exemption Claimed 1b. Percentage of Grantor's Interest in Real Estate 1c. Percentage of Grantors Interest Conveyed 100 100% 100% Check Appropriate Box Below for Exemption Claimed. F-1 Will or intestate succession. (Name of Decedent) (Estate File Number) 0 Transfer to a trust. (Attach complete copy of trust agreement identifying all beneficiaries.) 0 Transfer from a trust. Date of transfer into the trust if trust was amended attach a copy of original amended trust. f-1 Transfer between principal and agent/straw party. (Attach complete copy of agency/straw party agreement.) Transfers to the commonwealth, the U.S. and instrumentalities by gift, dedication, condemnation or in lieu of con- demnation. (If condemnation or in lieu of condemnation, attach a copy of resolution.) Transfer from mortgage to a holder of a mortgage in default. (Attach copy of mortgage and note/assignment.) r7 Corrective or confirmatory deed. (Attach complete copy of the deed to be corrected or confirmed.) p Statutory corporate consolidation, merger, or division. (Attach copy of article.) Mellon Fka The Bank Of New York As Trustee For The Certificateholders Cwabs Inc Asset-Backed Certificates Series 2005-13 as holler of a mortcaae in defaultand thus. tax exempt. Under penalties of law, I declare that I have examined this statement, including accompanying information, and to the heat of my knowledge and belief, It is true, correct and complete. Signal Co spondent or R nsible arty /(IDate FAILU TO COMPLETE THIS F RM PROPERLY OR ATTACH REQUESTED DOCUMENTATION MAY RESULT IN THE RECORDER'S REFUSAL TO CORD THE D. 9 Other (Please explain exemption claimed.) Property was sold at Sheriff sale on December 1 2012 to The Bank Of New York SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff >01ov, ;rf ?of;r'r, Jody S Smith Chief Deputy Richard W Stewart Solicitor !? h= 29 A EEPAHS` L.11A,111;1' The Bank of New York Mellon Case Number vs. Leslie A. Blessing (et al.) 2012-1803 SHERIFF'S RETURN OF SERVICE 03/23/2012 04:10 PM - 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 210 Regal View Drive, Carlisle, Pennsylvania 17013, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 210 Regal View Drive, Carlisle, Pennsylvania 17013 is only occupied by James and Leslie Blessing, Husband and Wife. ///Z.& Z/ VAL RIE WEARY, DEPUTY 03/23/2012 04:06 PM - Valerie Weary, who being duly sworn according to law, states that on March 23, 2012 at 1606 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: James Blessing, by making known unto himself personally, at 210 Regal View Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. C 1' VALERIE WEARY, DEPUTY 03/23/2012 04:06 PM - Valerie Weary, who being duly sworn according to law, states that on March 23, 2012 at 1606 hours, she served a true copy of the within Complaint in Ejectment, upon the within named defendant, to wit: Leslie A. Blessing, by making known unto James Blessing, Husband of Defendant at 210 Regal View Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. l v VALERIE WEARY, ]AEPUTY SHERIFF COST: $71.00 March 27, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants CUMBERLAND COUNTY.' 1 COURT OF COMMON PLEAS:! z' Number: 2012-1803- Civil P R A E C I P E TO THE PROTHONOTARY: a -ri Kindly enter judgment for possession against the Defendants Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants in the above-captioned matter for failure to answer Complaint in twenty days as required by Pennsylvania Rules of Civil Procedure. Premises: 210 Regal View Drive Carlisle Pennsylvania 17013 McCABE, WEISBERG, AND CONWAY, P.C. BY:' Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Cic.# 11?4?33 (L+k ???4A3??3?,? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Curt Long Prothonotary Leslie A Blessing a/k/a Leslie Blessing 210 Regal View Drive Carlisle, Pennsylvania 17013 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in e above proceeding as indicated below. Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call Christine L Graham Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Curt Long Prothonotary James Blessing 210 Regal View Drive Carlisle, Pennsylvania 17013 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants NOTICE Pursuant to Rule 236, you are hereby notified th t a JUDGME 'has been e ed in the above proceeding as indicated below. w Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call Christine L. Graham, Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Curt Long Prothonotary Occupants 210 Regal View Drive Carlisle, Pennsylvania 17013 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been en ed in the above proceeding as indicated below. Prothonotary Judgment by Default Money Judgment Judgment in Replevin X Judgment for Possession If you have any questions concerning this Judgment, please call Christine L. Graham, Esquire at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants , are over eighteen (18) years of age, and reside at 210 Regal View Drive, Carlisle, Pennsylvania 17013. SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF pw 2012 NOTARY PUBLIC TERRENCE J. McCABE, ES U RE MARC S. WEISBERG, ESQUkUW EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA FNE3TAF1AL. isEA?._ CCHIAN KANE-NCTPf','Y PUBLIC Cit,, of Philadelphia, Philadephia County ?av QcICN F`:ITES A''R. i 8 K! 5 Department of Defense Manpower Data Center Results as of: Apr-24-2012 07:47:36 40 Status Rep ort Pursuant to theSerzicemenibersCivil Rehef Act Last Name: Blessing First Name: Leslie A Date Of Interest: Apr-24-2012 Active Duty End Date Status Service Component On Active Duty On Date of Interest No NA This response reflects the individual's active duty status based on the Date of Interest. Left Active Duty Within 367 Days of Date Of Interest No NA This response reflects whether the individual left active duty status within 367 days preceding the Date of Interest. The Member or Hls/Her Unit Was Notified of a Future. Call-Up to Active Duty on Date of Interest I No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the date of interest as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the date of interest, 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: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the date of interest 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., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Date of Interest (2) Whether the individual left Active Duty status within 367 days preceding the Date of Interest (3) Whether the individual or his/her unit received early notification to report for active duty on the Date of Interest. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and date of interest provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: null Last Name: Blessing First Name: James Date Of Interest: Apr-24-2012 Active Duty End Date status service Component On Active Duty On Date of Interest No NA This response reflects the individual's active duty status based on the Date of Interest. Left Active Duty Within 367 Days of Date Of Interest No NA This response reflects whether the individual left active duty status within 367 days preceding the Date of Interest. The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Date of Interest No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the date of interest as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 14. 4 04fol4t 4W? oral Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the date of interest, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the date of interest and you fail to obtain this additional Service verification, punitive provisions of the SCRA maybe invoked against you. See 50 USC App. § 521(c). If you obtain additional information about the person (e.g., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Date of Interest (2) Whether the individual left Active Duty status within 367 days preceding the Date of Interest (3) Whether the individual or his/her unit received early notification to report for active duty on the Date of Interest. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and date of interest provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: null McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ED # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for "The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil CERTIFICATION The undersigned attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail letters notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letters in accordance with Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS )LA DAY OF pSpy,\ , 2012 NOTARY PUBLIC TERRENCE J. McCABE, MARC S. WEISBERG, ES I EDWARD D. CONWAY, ESQ IRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff COMMONWEALTH 017 PENNSYLVANIA Fc rl TA r I,-:, t f ^. "- RIAN KANE-N.--?RR, Flu LDLiC o' Philadelphia, -'hI.de uhia County Z' L :A"Z _Q°15 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary Leslie A Blessing a/k/a Leslie Blessing 210 Regal View Drive Carlisle, Pennsylvania 17013 April 13, 2012 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, lne.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2012-1803- Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH ]TIE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TI IIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W ITEIOUT A IJIARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGI ITS. YOU SEIOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO -I'D OR TELEPHONE T'EIE OFFICE Sl F FORTH BELOW. TI-IIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TI-Its OFFICE MAY 13E ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FFE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE US'rrn SF. E:NCUENTRA EN ESTADO DC REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SJS DFPF.NSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. Al. NO TOMAR LA ACCION DEBIDA DENTRO DE DIE.Z (10) DIAS DE LA FECHA DF ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SEN'1'ENCIA EN SU CONTRA Y USTED PODRIA PERDFR BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR EST'E PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELF.FONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACK)N ACFRCA DE FMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPA7. DE PROPORCIONARLO CON INFORNIAC16N ACERCA DE LAS AGENCIAS QUE PUEDFN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORAR10, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CCON(,`W,?AY, P.C. BY:?r?t ? ci 1` Attorneys for Plaintiff TERRENCE J. McCABE, ESQU MARC S. WEISBERG, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary James Blessing 210 Regal View Drive Carlisle, Pennsylvania 17013 April 13, 2012 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2012-1803- Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 DFFENSES OR OBJFCTIONS TO THE CLAIMS SET FORTI I AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM T111' 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 TI Its PAPER TO YOUR LAWYER AT ONCE. IF YOu DO NOT FIAVF. A LAWYER, GO'I'O OR'rELEPI-IONS TIIE OFFICE SEC FORTH BELOW. TIIIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 1BRING A LAWYER. IF You CANNOT AFFORD TO HIRE A LAWYER, TI-IIS OFFICE MAY 13E ABLE TO PROVIDE YOU W I'I'I I INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENrRA EN ESTADO DE REBELDIA POR NO HABE:R PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO 1 [ABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DBFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL, NO TOMAR LA ACCION DEBIDA DENI'RO DE D117Z (10) DIAS DE LA FECI IA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA AL.GUNA, DICTAR SENTENCIA EN SU CONTRA Y UST ED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTF. PAPEL, A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABA.10. F.,STA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACF.RCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, FSTA OFICINA PUEDE SER CAPAZ. DE PROPORCIONARLO CON INFORMACION ACERC'A DE LAS AGENCIAS QUE. PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELIGIBLES EN UN HONORARIO REDIICIDO NI NINGUN IIONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIR MARC S. WEISBERG, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary April 13, 2012 Occupants 210 Regal View Drive Carlisle, Pennsylvania 17013 The Bank Ol'New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, lne.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2012-1803- Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W TTI LOUT A HEARING AND YOU MAY LOSEYOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TEAS PAPER TO YOUR LAWYER AT ONCE. 1F YoU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE "1'I IE OFFICE SIT FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT AIRING A LAWYER. IF YOLJ CANNOT AFFORD'1'01 ]IRE A LAWYER, THIS OFI'ICr MAYBE ABLE TO PROVIDE YOU W rrH INFORNIA"I'ION ABOUT AGENCIES'I'HATMAY OFFlilt LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO IIABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENI'E O POR ABOGADO Y POR NO HABER RADICADO POR F,SCRITO CON ESTE TRIBUNAL. SUS DEFENSES U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIET. (10) DIAS DE LA Fr:C11A DE ESTA NOTIFICACION, EL TRIBUNAL. PODRA, SIN NF.CESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA,DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER HIENFS U OTROS DERECHOSIMPORTANTES. USTED LE: DEBE TOMAR ESTE PAPEI. A SU ABOGADO INMEDIATAMENTE. SI USTED NO "rIF.NE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABA10. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DE EMPL.EAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER C APAZ DE PROPORCIONARLO CON INFORMAC16N ACERCA DE LAS AGENCI AS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO M NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE WEISBERG AND C WAY, P.C. BY: Attorneys for Plaintiff TERRENCE J. MCCABE, ESQUI MARC S. WEISBERG, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE KEVIN T. MCQUAIL, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number: 2012-1803- Civil AFFIDAVIT OF LAST-KNOWN ADDRESS OF DEFENDANTs I, the undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that to the best of my information, knowledge and belief, the last-known address of the Defendants are as follows: Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants 210 Regal View Drive, Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFORE ME THIS a01 DAY OF (3943 (A , 2012 NOTARY PUBLIC TERRENCE J. MCCABE, E Q RE MARC S. WEISBERG, ES I EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA CO,?IAN KANE-N01A, J City of Philadelpn,a Philadeiphia County MY C ". MISSIONY.=' E:S ,4'R. 08, 20131 VERIFICATION The undersigned, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. McCABE, WEISBERG, AND CONWAY, P.C. r 2 ')?) - BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE I of 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-13 VS. No. 12-1803 Civil Term LESLIE A. BLESSING A/K/A LESLIE BLESSING, JAMES BLESSING AND OCCUPANTS 210 Regal View Drive Carlisle, PA 17013 Costs Attorney's $ 219.75 Plaintiff's $ Prothonotary $ 2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-13 being: (Premises as follows): 210 Regal View Drive, Carlisle, PA 17013 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. Buell, Prothonotary, Common Pleas Court of Cumberland Cou PA Date 4.!27/12 (Sea!) 2 of 2 No 12-1803 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-13 vs. LESLIE A. BLESSING A/K/A LESLIE BLESSING, JAMES BLESSING AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 219.75 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: CHRISTINE L. GRAHAM, ESQUIRE - ID#309480 MCCABE WEISBERG, AND CONWAY, P.C. 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 215-790-1010 Attorney for Plaintiff (s) By virtue of this writ, on the named _ appurtenances, and Where papers may be served day of . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of So Answers, Sheriff By McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE ID# 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 , The Bank Of New York Mellon f/k/a The Bank OF New York as Trustee for The Certificate Holders Cwabs, Inc.,Asset-Backed Certificates, Series 2005-13 V. Leslie A Blessing a/k/a Leslie Blessing, James Blessing and Occupants CUMBERLAND COUNTY ;== COURT OF COMMON PLEAS,.-; 7) Number: 2012-1803- Civil PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the above-captioned matter. 210 Regal View Drive, Carlisle, Pennsylvania 17013 l? cak %?)$. ' I0• iU Sb o21S??da 1 McCABE, WEISBERG, AND CONWAY, P.C. BY: C__ C.2 'z ??_ Attorneys for Plaintiff TERRENCE J. McCABE, ESQUII?_ MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE 'S a.as J?) us q X33 9-7g373 W?l? a ~r1 ss.led ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201205573 Recorded On 2/2412012 At 1:33:2 1 PM * Instrument Type - DEED-SHERIFF'S Invoice Number -102710 User ID - KW * Grantor - BLESSING, JAMES * Grantee - CWABS INC * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $12.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 CARLISLE AREA SCHOOL $0.00 DISTRICT NORTH MIDDLETON TOWNSHI P $0.00 TOTAL PAID $63.00 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA i RECORDER O D EDS trao + - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. III IBIIIIIIIY111IM 111illill i?Tax Parcel No. 29-15-1251-125 Know all Men by these Presents That 1, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00 (One Dollar), to me in hand paid, do hereby grant and convey to The Bank of New York Mellon f/k/a The Bank of New York As Trustee for The Certificate Holders Cwabs, Inc., Asset-Backed Certificates, Series 2005-13 2011-5209 Civil Term The Bank of New York Mellon Vs James Blessing Leslie A. Blessing, a/k/a Leslie Blessing Atty: Terrance McCabe All that certain tract or parcel of land and premises situate, lying and being in North Middleton Township, Cumberland County, Pennsylvania more particularly bounded and described as follows: BEGINNING at a point on the western right of way line of Cottonwood Court, at the terminus of a curve connecting said right of way with the southern right of way line of Regal View, thence from said point of beginning, by said western right of way line of Cottonwood Court South seven degrees, twenty nine minutes, eighteen seconds West (S 070 29' 18" W), a distance of one hundred fourteen feet (114.00') to a point; hence by Lot No. 82 North eighty two degrees, thirty minutes, forty two seconds West (N 820 30' 42" W), a distance of one hundred five feet (105.00) to a point; thence by Lot No. 44 North seven degrees, twentynine minutes, eighteen seconds East (N 070 29' 18" E), a distance of one hundred twenty five feet (125.00'), to a point; thence by said southern right of way line of Regal View South eighty two degrees, thirty minutes, forty two seconds East (S 820 30'42" r), a distanc. of ninety four feet (94.00'), to a point; thence by a curve to the right, having a radius of eleven feet (R= 11.00), an are distance of seventeen and twentyeight hundredth feet (A/L = 17.28), to a point, the place of BEGINNING. CONTAINING 13,099.03 square feet, more or less. BEING Lot No. 45 on the plan entitled "Final Subdivision Plan for North Ridge Phase 3 dated January 10, 2002, last revised May 6, 2002, prepared by Hartman and Associates Exhibit A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor The Bank of New York Mellon vs. Leslie A. Blessing (et al.) ?4?rttr ?f ??tutbrr?rz?b T4 OFFICE OF THE ?$wERIFF F11...L{1 DHICS: i'I PROTHONOT1=#I 2012 MAY -8 PM 1: 29 CU PENNSYLVAM AST Case Number 2012-1803 SHERIFF'S RETURN OF SERVICE 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on May 3, 2012 at 154, hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be an Occupant, to wit: Matt Blessing at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Occupant of contents of same. Occupant was also advised they had 14 days to vacate the premises. 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on May 3, 2012 at 154 hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be Adult in Charge for James Blessing, to wit: Leslie A. Blessing, wife of defendant James, at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Defendant of contents of same. Defendant was also advised they had 14 days to vacate the premises. 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on May 3, 2012 at 1541 hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Leslie A. Blessing at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Defendant of contents of same. Defendant was also advised they had 14 days to vacate the premises. May 08, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF c'; CountySUIle Sheriff, Teleo=_oft Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson l J 3,0 uody S Smith Chief Deputy ` ?2 , - (? c Richard W Stewart Solicitor CUMB dLMD I PEN SYLYA I The Bank of New York Mellon Case Number vs. 2012-1803 Leslie A. Blessing (et al.) SHERIFF'S RETURN OF SERVICE 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on May 3, 2012 at 154, hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be an Occupant, to wit: Matt Blessing at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Occupant of contents of same. Occupant was also advised they had 14 days to vacate the premises. 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn'according to law, states that on May 3, 2012 at 154 hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be Adult in Charge for James Blessing, to wit: Leslie A. Blessing, wife of defendant James, at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Defendant of contents of same. Defendant was also advised they had 14 days to vacate the premises. 05/03/2012 03:47 PM - Deputy Shawn Gutshall, being duly sworn according to law, states that on May 3, 2012 at 154 hours, he served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Leslie A. Blessing at 210 Regal View Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County, and informed Defendant of contents of same. Defendant was also advised they had 14 days to vacate the premises. 05/31/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED per request of plaintiffs attorney. SHERIFF COST: $57.83 SO ANSWERS, May 31, 2012 RON R ANDERSON, SHERIFF ,;? .mss- rd .Co- a.74Poyy ,1i (-,cu I"y'SU'..C@ Shy;, ff IC300:iCil. I!1C