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HomeMy WebLinkAbout12-20707!,J , 110 IN 0 TA ` R? Wa L/ ?. iS vl.? 33J? ?I: G'..J 1"TERLAND COUNTY -ININSYLVANIA 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Federal National Mortgage Association 14523 SW Millikan Way, Suite 200 Beaverton, Oregon 97005 V. Warren W. Morrison 211 Lincoln Street Enola, Pennsylvania 17025 and Shanna L. Morrison 211 Lincoln Street Enola, Pennsylvania 17025 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number O? t a " a0?a Ci Vii COMPLAINT IN MORTGAGE FORECLOSURE OD w1 U Nb3; 7 S t' Q N? Clc tt 11036-740 '4? A73a3 ? 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, 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 OFFERLEGAL 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 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) digs 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 cone 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 torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la torte 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. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. 1?STA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDI PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA Dl LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is Federal National Mortgage Association, duly organized and cluing business at the above-captioned address. 2. The Defendant is Warren W. Morrison, who is the mortgagor and real O\t ner of the mortgaged property hereinafter described, and his/her last-known address is 211 Lincoln Street, Enola, Pennsylvania 17025. 3. The Defendant is Sharma L. Morrison, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 211 Lincoln Street, Enola, Pennsylvania 17025. 4. On July 6, 2007, Warren W. Morrison and Sharma L. Morrison made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic 1egistration Systems, Inc., as nominee for ERA Home Loans which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1999, Page 1460, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 5. On February 28, 2011, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for ERA Home Loans to Federal National Mortgage Association, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument # 201106670, such Assignment of Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 211 Lincoln Street, Enola, Pennsylvania 17025. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due September 1, 2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $ 160,766.58 Interest through March 16, 2012 $ 4,140.98 (Plus $18.17 per diem thereafter) Late Charges $ 19.13 Attorney's Fee $ 1,450.00 Property Inspections $ 120.00 Escrow Overdraft $ 2,159.36 Mortgage Insurance Premiums (MIP) $ 149.63 Valuations $ 5.00 GRAND TOTAL $ 168,810.68 9. Notice of Intention to Foreclose under Act 6 of 1974 (41 P.S. §403) was sent to Defendants by certified mail, return receipt requested as required by that Act. Notice under the Homeowner's Emergency Mortgage Assistance Act (Act 91) was not provided as the provisions of such Act were not applicable at that time and no notice under such Act was required. WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $168,810.68, together with interest at the rate of $18.17 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P.C. BY: [ ] T RRE E J. cCABE, ESQtJ IRE. [ ] MARC SVWEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE, [./f MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQUIRE [ ] BRIAN T. LAMANNA, ESQUIRE' Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY,P.C. BY: hAt [ ] T RRE E J. McCABE, ESQUIRE, [ ] MARC . WEISBERG, ESQUIRE [ ] EDWARD D. CONWAY, ESQUIRE; [r] MARGARET GAIRO, ESQUIRE [ ] ANDREW L. MARKOWITZ, ESQtJIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ] MARISA J. COHEN, ESQUIRE [ ] KEVIN T. MCQUAIL, ESQUIRE [ ] CHRISTINE L. GRAHAM, ESQURRI; [ ] BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff Federal National Mortgage Association v. Warren W. Morrison and Shanna L. Morrison 1 ALL THAT CERTAIN had of lend situate in the Borough of t t penrlaboro Township, Cumberland County, Pennsylvania, being more partcuiarty bout and d foNows: BEGINNING at a point on the soutlWn One of Abolition Street at the western We of o 16 fM alley, thence akhrhg said alley, South 21 degrem 30 minute gait 138.32 feet to s point on If a side of Lincoln Street; thence along sold Lincoln Street, South 68 degrees 30 minutes West, 59 feet other lands now or We of Herbert Fanner. et ux, of which this tract was formerly a part; thence along Bald nd now or late of Father, North 21 degrises 30 mkhutes QO soomx% West, 127.38 feet to a point on The line of AboNtion Sheet thence along Abolition Street, North 58 degrees 00 minutes 00 seconwfa: do feet to e point, the pleas of BEGINNING. 8F1NG Late on the Phan of Martin's Addition to West Fairview, which plan is reoorded in ths bertmd !;aunty Recordme's 0111oe in Deed Book 6-U, Page *601. BEING Lot No. 1, CONTAINING 7,836 square feet. more or less. ewwdhg W RewAKRvielsn I 'ten by William 13. Whitlock, ProWaknal Engines. doled September 5. IM, for Hwbm M. and gar, i J. Famedr, recorded in the Cumberterhd County Reorhndees Wca in Plan Book 27, Page 130, nacorde . 197$. HAVING THEREON ERECTED a one amy dwelling kmmn as and numbered 211 Lincoln . , Ewa, Pennsylvania. UNDER AND SUBJECT to covenanfe. conditions. reservations. mstrictions. easements and 1 of Waye of record Erroneously sod IbM as (1) In previous deed. BEING THE SAME PREMISES which 0outiie Diamond 6rvestmenta. LLC:, a Pannwfivania-l IWbNlty company, by their dead to be rooorded arnutt neously herewith in the Ofka of the Rarawnd?r Deeds of Cumberland, granted and conveyed unto Warren W. Morrison rand Shenne L Morrison. C Ccrti fir Mis k,) be recorded in Cut',,*CT'jand County 'PA if `• `r{' ?. ,-'-"-r0cr n C Deed s 9K1999PG 1476 FORM 1 C? IN THE COURT OF COMMON PLEAS OF };a) CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) "?? e VS. 7 c.a WarJer? W, .AA*,r+so.1 ar\? 4>11 ShAY1ha L. 1" vrDefendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 7oI•D-- ?& Date Signature of Counsel for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY n Ronny R Anderson Moo ,-3 = rn `? Sheriff M 3- Jody S Smith o o Chief Deputy C ?; Richard W Stewart " 3a q -r :x- -, Solicitor r;. Federal National Mortgage Association Case Number vs. Warren W. Morrison (et al.) 2012-2070 SHERIFF'S RETURN OF SERVICE 04/03/2012 05:00 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: Warren W. Morrison, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Warren W. Morrison. Request for service at 4 Elm Drive, Enola, Pennsylvania 17025 is the Defendant's Father in Law's residence. C RONALD HOOVE , DEPUTY 04/03/2012 05:01 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: Shanna L. Morrison, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Shanna L. Morrison. Request for service at 4 Elm Drive, Enola, Pennsylvania 17025 is the Defendant's Fathers residence. L RONALD HOOVER, DEPUTY 04/17/2012 03:30 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 17, 2012 at 1530 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shanna L. Morrison, by making known unto herself personally, at 23 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. c RYAN BURGETT, DEPUTY 04/17/2012 03:30 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 17, 2012 at 1530 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Warren W. Morrison, by making known unto Shanna Morrison, Wife of Defendant at 23 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPUT 04/19/2012 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: Shanna L. Morrison, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Shanna L. Morrison. Request for service at 211 Lincoln Street, Enola, Pennsylvania 17025 is vacant. The Enola Postmaster has confirmed, Shanna L. Morrison's new address is 23 S. Enola Drive, Enola, Pennsylvania 17025. icj Cou!?r/.?:zlt? , She... 04/19/2012 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: Warren W. Morrison, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Warren W. Morrison. Request for service at 211 Lincoln Street, Enola, Pennsylvania 17025 is vacant. The Enola Postmaster has confirmed, Warren W. Morrison's new address is 23 S. Enola Drive, Enola, Pennsylvania 17025. SHERIFF COST: $173.00 April 19, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 1t C ,. ,. McCABE, WEISBERG & CONWAY, P.C. ' `~- - ' { ~ ~~~ ~,a i~ ; `` BY: BRIAN T. LAMANNA, ES UIRE - ID#310321 ~ ; ~ ~, ~ ~;-~ , ; - Q ,,~, __~ ~ ~ ~~~ !G~ ~! 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 ~'wf~~`~~ i; ` f; -, i„ r; ~~ ~.~U~T T 21s X90-1010 ' ~~~~lSYLY,~N-A Federal National Mortgage Association Cumberland County Court of Common Pleas Plaintiff v. Warren W. Morrison and Sharma L. Morrison Defendant No. 2012-2070 MOTION TO LIFT STAY OF PROCEEDINGS Plaintiff, Federal National Mortgage Association, hereby motions this Court to remove the captioned mortgage foreclosure action from the Cumberland County Residential Mortgage Foreclosure Program ("~he Program"), and in support thereof avers as follows: 1. This is an action in mortgage foreclosure brought by Federal National Mortgage Association against Warren W. Morrison and Shanna L. Morrison. 2. This case is currently under a stay pursuant to paragraph (b) of the Cumberland Cou~ty Administrative Order dated February 28, 2012, which establishes the Mortgage Foreclosure Diversion Program. Warren W. Morrison and Sharma L. Morrison were served a true and correct copy of original complaint in mortgage foreclosure, filed on April 2, 2012 tohis/her last known address of23 Enola Drive, Enola, Pennsylvania 17025. the A true and correct copy of the Sheriff's return of servic~ is attached hereto as Exhibit "A". Warren W. Morrison and Sharma L. Morrison were served with the Notice of Mortgage Foreclosure Diversion Program and Financial Worksheet on May 22, 2012 by certified mail, to his/her last-known address of211 Lincoln Street, Enola, Pennsylvania 17025. A true and correct copy of the Not of Residential Mortgage Foreclosure Diversion Program is attached hereto as Exhibit "B". S. It has been more than sixty days since Defendant(s) was served with the Notice 'of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet and Defendant(s) has not elected to participate in the Program by taking the affirmative steps identified in the Notice of Res Mortgage Foreclosure Diversion Program, and has not filed a Request for Conciliation Conference. 6. For the reasons set forth herein, the aforementioned stay of proceedings should be lifted~to allow Plaintiff to proceed with the instant mortgage foreclosure action. WHEREFORE, it is respectfully requested that the Court enter an Order lifting the stay proceedings, and for such further relief as the Court deems appropriate. MCCABE, WEISBERG & CONWAY, P.C. B~= %'' ian Manna ,Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: Heidi R. Spivak, Esquire, Atty I.D. #74770 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-101.0 Federal National Mortgage Association Plaintiff v. Warren W. Morrison and Shanna L. Morrison Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas No. 2012-2070 CERTIFICATE OF SERVICE 1, Heidi R. Spivak, Esquire, hereby certify that a true and correct copy of Plaintiff's Motion to Lift the Stay of Proceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012, was served on the below named person(s) by regular first class mail, postage prepaid, on August 14, 2012. Warren W. Morrison 23 South Enola Drive Enola, Pennsylvania 17025 Shanna L. Morrison 23 South Enola Drive Enola, Pennsylvania 17025 '^'/'/ .r Dated: _ anna, Esquire ~ /.~ f.1~. ~~~ ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY '1't ~ ~ Ronny R Anderson Sheriff Jady S Smith Chief Deputy Richard W Stewart Solicitor ~4~trtitp at t~aur~GrrrAk~t¢ 4F~ICEvF7H6;k~~tIPF Federal National Mortgage Association Case Number vs. Warren W. Morrison (et al.) 2012-2070 ~ SHERIFF'S RETURN OF SERVICE 04/03/2012 05:00 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: Warren W. Morrison, but was unable locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Warren W. Morrison. Request for service at 4 Elm Drive, Enola, Pennsylvan 17025 is the Defendant's Father in Law's residence. ~'~2 ~ RONALD HOOVE ,DEPUTY 04/03/2012 05:01 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: Shanna L. Morrison, but was dhable locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not fo nc as to the defendant Shanna L. Morrison. Request for service at 4 Elm Drive, Enola, Pennsylvania 170 5 is the Defendant's Fathers residence. RONALD HOOVER, DEPUTY 04/17/2012 03:30 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 1~i, 2012 at 1530 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the I within named defendant, to wit: Shanna L. Morrison, by making known unto herself personally, at 23 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handin to her personally the said true and correct copy of the same. , AN BURGETT, D 04/17/2012 03:30 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 1' 2012 at 1530 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Warren W. Morrison, by making known unto Shanna Morrison, Wife of Defendant at 23 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at th same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEP 04/19/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent sear h and inquiry for the within named defendant to wit: Shanna L. Morrison, but was unable to locate her in is bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Shanna L. Morrison. Request for service at 211 Lincoln Street, Enola, Pennsylvania 17025 i~ vacant. The Enola Postmaster has confirmed, Shanna L. Morrison's new address is 23 S. Enola Drive, Enola, Pennsylvania 17025. , (c oi~fy$y/l~P,p(t~~ln~ /` 04/19/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent seal'ch and inquiry for the within named defendant to wit: Warren W. Morrison, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the; defendant Warren W. Morrison. Request for service at 211 Lincoln Street, Enola, Pennsylvania 17025';.is vacant. The Enola Postmaster has confirmed, Warren W. Morrison's new address is 23 S. Enola Drive, Enola, Pennsylvania 17025. SHERIFF COST: $173.00 April 19, 2012 SO ANSWERS, RANDERSON, SHERIFF [-erliral ;~~3tii~nal l~lnrts.<~~;L F~scsciatian 1'ltiiruifl' lti .l~lll~: Cf.3i.~lt.~l~ (.)4~ C{.~IVIMO~ l'1 F:.1S f.)1~ (;L`~'11:3Iltl_.,~ti[) CC}t~ti"['Y, 1'1::?~NSYI.\~:Atit~"~. t-s. ~haruta 1.... 1~1c~rri:~m :zncl Warren tip'. R-lcyrrison tiumbe-° 2U1~-2070 C'ir~il Defendants NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action you maybe able to participate in acourt-supervised conciliation conference in an effort to resolve this matter ith your lender. If you do not have a lawyer, you must take the following steps to be eligible for a concili conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointor a legal representative at no charge to you. Once you have been appointed a legal representative, you promptly meet with that legal representative within twenty (20) days of the appointment date. Dunn meeting, you must provide the legal representative with all requested financial information so that a resolution proposal can be prepared on your behalf. If you and your legal representative complete a fin warksheet in the format attached hereto, the legal representative will prepare and file a Reyue Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days service upon you of the foreclosure complaint. If you do so and a conciliation conference is schedule will have an opportunity to meet with a representative of your lender in an attempt to work out reasc arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service i appointment of a legal representative. However, you must provide your lawyer with all requested fin information so that a loan resolution proposal can be prepared on your behalf. If you and your l complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Reyu~ Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days service upon you of the foreclosure complaint. If you do so and a conciliation conference is schedule will have an opportunity to meet with a representative of your lender in an attempt to work out reasc arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKF. STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. r._ 11-,t~rr Respectfully submitted: of that for 'the you be the ;ial t for the you able ibs` ~ Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas llocket # BORROWER REQiJEST FOR HARDSHIP ASSISTANCE I To complete your request for hazdship assistance, your lender must consider your circumstances to determine po ssible options while working with your III Please provide the following information to the best of your knowledge: Borrower name(s): _. _ Property Address: _ City: State: Zip: ___ _ Is the property for sale? Yes ^ No ^ Listing date: Price $ I Realtor Name: Realtor Phone: I Borrower Occupied? Yes ^ No ^ Mailing Address (if different): ; - City: State: Zip: ~ _ Phone Numbers: Home: Office: I _ Cell: _ Other: _ I _ Email: ~ # of people on household: How long? Mailing Address (if different): _ _ City: State: Zip: j ~ - Phone Numbers: Home: _ Office: _ i _ Cell: _ Other: Email: # of people on household; How long? First Mortgage Lender: ~ Type of Loan: _..._. _ . Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: -....._. Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment; i Primary Reason for Default: -- ~ - Isthe loan in Bankruptcy? Yes ^ No ^ I If yes, provide names, location of court, case number & attorney: _._ _._,_ Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount owed: Value: Automobile #2: Model: Amount owed: Value: _ Other transvortation (automobiles boats, motorcycles): Model Year: Amount owed: Monthiv Income Name of Employers: 1. Value: 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: - Year: Year: Co-Borrower Pay Days: Monthiv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food ~"d Mort age Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child SupportJAlim. Spending Money Da /Child Care/Tuit. Other Ex erases Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ if yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ~ No D If yes, please indicate the status of the application: Nave you had any prior negotiations with your lender or lender's loan servicing company to resolve your Yes ^ No O If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your Lender or lender's loan servicing company: Lender s Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We, _ ,authorize the above named _ to use/refer this information. to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obli~ to use the services provided by the above named _ Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: f Proof of income f Past 2 bank statements f Proof of any expected income for the last 45 days f Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 TERRENCE 1. McCABF. MARC S. WEISBERG EDWARD D. CONWAY MARGARET GAIRO LISA L. W ALLACE LAURA H.G. O'SULLI\'AN IANF.T L. CHARLTON GAYLC SPIVAK JASON E:. BROOKS ANDREW L. MARKOIV II': A7I CIIAEL T. CA NTRELL JOSEPH I~ RIGA ('AROL ROGERS CORE CATHERINE E- WELKER HEIDI R. SPIVAK DIANA C. THE•OLOGOU MARISA 1. COVEN MARK GOLAB JO-ANN T LAMBERT-0'NEILL MELISSA A. $POSATO BRIAN T. LaMANNA CORRIN M. DEMENT ANN E. SWARTZ PHILLIP MAHONY LEDEANNA D. ADAMS MATTHEW E. RUSSELL ERIN M. BRADY RICHARD O'BRIEN LAURA T. CURRY ANTOINETTE N. MOORE KEVIN T. McQUA1L ALEXANDRA T. GARCIA CHARLES A. HIGGS MICHAEL T. ROZEA lON.4THAN ELEFAN'f LAURA L. LATTA ABBY K. MOYNIHAN CHRISTINE L GRAHAM SHEERA G. ENGRISSEI JOSE O. HASBUN 10NATIIAN POLLACK IvIAKENNA E. PORCH RICHARD J 6GZOR. JR. IIE.4'fHl~.li ,tit WEINERT Ll!CAS ~.\1 ANDERSON D:\NIEI. F.4NASELLE K'ILLIAM D. JENNINCiS s,...uw,~~:,..-i~w.n~~, r:,. i~..~~.i~¢ E,AW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 1400 123 SOUTH BROAD STREE:'I' PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, Pennyslvania 17013 SUITE 7113 21G 11ADDON AVENUE W'ESTMONT, N1081118 (85C,) %58-70811 FA.K LN56) 85%-71120 SUITE 210 {45 HUGUENOT STREET NEW ROCHELLE, NY 10%d~l (`>14}636-%'NIIJ GENERAL FAX (914) G7G-BP01 SUITE %00 712 MARSHALL AVENUI[ I.AURF.L, MD 207(17 (HJ I) 4911-7361 ~, FAX (701) 49f1-I5G% Also scniciog the District of Co mbia SUITE 202 41121 UNI VERBITY DRI V ', FAIRFAX, VA 2211}II iN6G)GSfi~1379 Sl11TE 1110 ;0 BUXTON FARMS RO STA MFORD, CT !K 905 2113) Y92-%211U F.4X- I%5 Sj 425-1979 I SUITE U0 ~I" DELAWARE CORPORATE CER+TER ONE RICHTER PARK W W ILMING't'ON. DELAWARE 19%03 i,i112) 4f1935211 FAX %55-;25-I98f1 Re: Federal National Mortgage Association vs. Warren W. Morrison and Shanna L. Morrison Case Number 2012-2070 Dear Sir or Madam, Enclosed please find an original and one copy of Plaintiff s Motion to Lifr the Automatic Stay of Proceec Pursuant to Cumberland County Administrative Order dated February 28, 2012. Kindly file the original of record the court and return to my attention atime-stamped copy in the stamped, self-addressed envelope which is provic Thank you for your cooperation in this matter. Very truly yours, ~'- Steven ravascio, Legal Assistant for Mc be, Weisberg, & Conway, P.C. 'st enclosures This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. McCABE, WEISBERG & CONWAY, P.C. BY: HEIDI SPIVAK, ESQUIRE - ID#74770 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Federal National Mortgage Association Plaintiff V. Warren W. Morrison and Shanna L. Morrison Defendant Jt"'ERL,? e1- r PENNSYLV f ? ; Cumberland County Court of Common Pleas No. 2012-2070 ORDER AND NOW, this SO" day of Aajwsb" 20 a'f-' , upon consideration of Plaintiff's Motion to Lift the Stay of Proceed ings Pursuant to Cumberland County Administrative Order dated February 28, 2012, and any opposition thereto, it is hereby ORDERED and DECREED that: The stay of proceedings is hereby lifted, and Plaintiff may proceed with it's action in mortgage foreclosure in accordance with the applicable rules of civil procedure. BY THE COURT: J. SP-UQ? R OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Sharma L. Morrison 23 South Enola Drive Enola, Pennsylvania 17025 Federal National Mortgage Association Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY v. Sharma L. Morrison and Warren W. Morrison Defendants No. 2012-2070CIVIL NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary t~ X Judgment by Default _ Money Judgment Judgment in Replevin _ Judgment for Possession If you have any questions concerning this Judgment, please call McCabe. Weisberg and Conway. P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Warren. W. Morrison 23 South Enola Drive Enola, Pennsylvania 17025 Federal National Mortgage Association Plaintiff v. Shanna L. Morrison and Warren W. Morrison Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 2012-2070CIVIL NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default _ Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - lD # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 Federal National Mortgage Association Plaintiff v. Shanna L. Morrison and Warren W. Morrison Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2012-2070CIVIL ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: c`-~ ~ ~=, ~ ~n © ~i° r ~ ~ C "C7 r7''. -'~~ ~ ~ z. Z~ ~ ~'C`z ~ ~ '~ Q ~*'a ~. , -K: ~-~ , Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 168,810.68 Interest from 03/17/12 to 11/08/12 $ 4,306.29 Total 173,11 .97 _ ~ i 3"~RRENCE J. McCABE, ESQUIRE MARC 5. WEISBERG, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE JOSEPH FOLEY, ESQUIRE Attorney for Plaintiff AND NOW, this ~ day of , 2012, Judgment is entered in favor of Plaintiff, Federal National Mortgage Association, and against Defendants, Shanna L. Morrison and Warren W. Morrison, and damages are assessed in the amount of $173,116.97, plus interest and costs. B HE TH ARY: ~ X4.50 PA ATT/ ~ ~~~3~9 - ~ . ~#aa~98~ 1 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 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (21.5)790-1010 Federal National Mortgage Association Plaintiff v. Shanna L. Morrison and Warren W. Morrison Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 2012-2070CIVIL AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendants are: Shanna L. Morrison Warren W. Morrison 23 South Enola Drive 23 South Enola Drive Enola, Pennsylvania 17025 Enola~isylvania 17025 SWORN AND SUB~RIBED ~ NCE J. McCABE, ESQUIRE BEF MET IS ~ DAY ARC S. WEISBERG, ESQUIRE OF , 2012 MARGARET GAIRO, ESQUIRE ` ~ ~ _ ^ ~ CHRISTINE L. GRAHAM, ESQUIRE L~ JOSEPH FOLEY, ESQUIRE NO RY PUBLIC Attorney for Plaintiff COMNIONWEALTN QF PENNSYLVANIA 180TAR1AL SEAT. ZEI~BIA S. MARRERO, Notary Public MYC~ Ph~a ~~ ~, zols Y McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 Federal National Mortgage Association Plaintiff v. Sharma L. Morrison and Warren W. Morrison Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2012-2070CIVIL CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached to and marked as Exhibit "A". ~~ ~- r'` ~~ SWORN AND SUBSCRIBED BEF E ME HIS (+ DAY OF ~ ~ , 2012 NO'1"~RY PUBLIC COMMONWEALTH OF ~'ENNSYLVANtA ENCE J. McCABE, ESQUIRE ARC S. WEISBERG, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE JOSEPH FOLEY, ESQUIRE Attorney for Plaintiff NOTARIAL SEAL ZEN081A S. MARRERO, Notary Public C' of Ph' ' , PhNa. Countyy MY 1,2016 VERIFICATION The undersigned attorney 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 based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, 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. §4904 relating to unsworn falsification to authorities. T NCE J. McCABE, ESQUIRE ARC S. WEISBERG, ESQUIRE MARGARET GAIRO, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE JOSEPH FOLEY, ESQUIRE Attorney for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary September 17, 2012 ~~~~1~ To: Shanna L. Morrison 23 South Enola Drive Enola, Pemisylvania 17025 federal National Mortgage Association Cumberland County ~'s Court of Common Pleas Warren W, Morrison Shanna L. Morrison Number 2012-2070 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 WRIT°CBN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITFI TI•IE COURT YOUR DEFENSES OR OBJECTIONS TO TFIE CLAIMS SET FORTH AGAINST YOU. UNLGSS YOU ACT WITHIN TEN (10) DAYS FROM TFIE DATG OF'i'Ii1S NOTICE, A JUDGMENT MAY BE ENTERED \GaINS'I' 1'OU WITIiOUI'A FiF,AR(N<i AND YOU MAY LOSEYOl1R PROPERTY OR O'll-lER IMPORTANT' RIGHTS. YOU SHOULD TAKE, THIS PAPER TO YOl1R LAWYER AT ONCE. IF YOU DU NO"C HA VE A LAWYF_R, GO'CO OR TELEPHONE TI1E OFFICE SET FORTIi BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT FIIRING A LAWYER. 1F' YOU CANNOT APFORD'I'O HIRE A [,A WYER, THIS OFFICE MAY BE ABLE 'CO PROVIDE YOU W ITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED PEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE LISTED SL" ENCUENTRA GN ESTADO DL' REBELDIA PUR NO FABER PRESEN'CADO UNA COMPARECENCIA ESCRITA, YA SEA PERSUNALMENTE O POR ABOGADO Y POR NO HABER RAU[CADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBiDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PUDRA, SIN NECESIDAD DG COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR S1:NTENCIA EN SU CONTRA Y l1STED PODRIA PERDBRBIENES U OTROS DERECHOS IMPORTAN'rES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDiATAMIiNTE. S! LISTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXI'USO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DG EMPLEAR A UN ABOGADO. S I LISTED NO PUEDE PROPORC[ONAR PARR EMPLGAR UN ABOGADO, ESTA OPICINA PUEDE SER CAPAL DE PROPORCIONARLO CON INFORMACION ACERCA DE I,AS AGENCIAS QUE 1'UEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO RBDUCIDO NI NINGUN FIONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 .. BY: /// Attorfieys for Plaintiff TERRENCE J. McCABE, ESQUIRF, MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE st OFl ICE OF THE PROTHONOTARY COURT Or COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary September 17, 2012 7'0: Warren W. Morrison 23 South Enola Drive Enola, Pennsylvania 17025 Federal National Mortgage Association Cumberland County vs. Court of Common Pleas Warren W. Morrison Shanna I,. Morrison Number 2012-2070 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 F[LE IN WRITING W[TH THE COURT YOUR DEFENSES OR OBIECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN {lO) DAYS FROM THE DATE OF 1'1IlS NOTICE, A JUDGMENT MAY DE ENTERED AGAINS"C YOU W l1'HOUT A HEARING AND YOU MAY LOSE YOURI'ROPERTY OR OTHCR IMPORTANT 1t1G1~1'CS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO'f0 OR TELEPHONE THE OFFICE SET FORTIi pELOW. THiS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYC-R. IF YUU CANNOT AFFORD TO HIRE A LA W YER, THIS OFFICE MAY RB ABLE TO PRO V I DE YOU W ITH INFORMATIUN ABOUT AGENCIES THAT MAY OFfiER LF_GAL 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 LISTED SE ENCUENTRA EN ESTAllO DE REBELDIA I'OR NO HA13ER PRESENTADO UNA COMPARECENCIA F,SCRITA, YA SBA PERSONALMENTE O POR ABOGADO Y POR NO IIABER RADICADO POR ESCRITO CON ESTG TRIBUNAL SUS DEFENSAS U ODIECIONC•.5 A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ { l O) UTAS DG LA FECHA DE ESTA NOT[FICACION, EL TRIBUNAL PODRA, SIN NECES-DAD DG COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, D/CTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPOR'CANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMED[ATAMENTE. S[ USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OF[CINA LO PUEDE PROPORCIONAR CON INFORMAC16N ACERCA D6 EMALEAR A UN ABOGADO. S! USTED NO PUEDEPROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SCR CAI'AZ DE PROPORCIONARLO CON INFORMAC[ON ACERCA DE LAS AGENCIAS QUE PUEDCN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIIILES EN UN HONORARIO REDUCIDO NI N[NGUN HONORARIO. CLmbet•land County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 -~""~'~"-'? (800) 99 -9108 ,: BY: .-- Attor>6eys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE st McCABE, WEISBERG & CONWAY, P.C. TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorney for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE-ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 C MARISA J.COHEN,ESQUIRE-ID#87830 0z w `� KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 Z rrri BRIAN T.LaMANNA,ESQUIRE-ID#310321 Z::;7 ANN E.SWARTZ,ESQUIRE-ID#201926 C'' JOSEPH F.RIGA,ESQUIRE-ID#57716 { JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DerKRIKORIAN,ESQUIRE—ID#313673 G 123 South Broad Street,Suite 1400 r . Philadelphia,Pennsylvania 19109 a .-r'`i (215)790-1010 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 2012-2070CIVIL Shanna L. Morrison and Warren W. Morrison Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 25th day of March, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSC BED BEFO ME THIS DAY OF ,2013 9LOU /a. wz-'� McCABE,WEISBERG& CONWAY,P.C. NOTA Y PUBLIC Attorneys for Plaintiff B N fVOT1�i11►(, � TERR NCE J.McCABE,ESQUIW�-ID 164 "M P• IOMARC S.WEISBERG,ESQUIRE-I #17616 l� EDWARD D.CONWAY,ESQUIRE-ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DerIMKORIAN,ESQUIRE—ID#313673 McCABE, WEISBERG & CONWAY,P.C. TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorney for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE-ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ED#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DerKRIKORIAN,ESQUIRE—ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 2012-2070CIVIL Shanna L.Morrison and Warren W.Morrison Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 211 Lincoln Street,Enola,Pennsylvania 17025,as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Warren W. Morrison 23 South Enola Drive Enola,Pennsylvania 17025 Shanna L.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 2. Name and address of Defendants in the judgment: Name Address Shanna L. Morrison 23 South Enola Drive Enola,Pennsylvania 17025 Warren W.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address The Township of East Pennsboro 98 South Enola Drive Enola,Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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: Name Address Tenants/Occupants 211 Lincoln Street Enola,Pennsylvania 17025 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 81h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept. of Justice,Rm.5111 Atty General of the United States 950 Pennsylvania Avenue,N.W. Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm.4400 Atty General of the United States 950 Pennsylvania Avenue,N.W. Washington,DC 20530 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. MCCABE,WEISBERG& CONWAY,P.C. March 25,2013 DATE Attorneys for Plaintiff By: TERR NCE J.McCABE,ESQU -ID#164 6 �MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE-ID#346 7 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELtNE P.DerKRIKORIAN,ESQUIRE—ID#313673 McCABE,WEISBERG AND CONWAY,P.C. BY: Attorney for Plaintiff TERRENCE J.McCABE,ESQUIRE-ID#16496 MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE-ID#34687 MARGARET CAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQIJAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DerKRIKORIAN,ESQUIRE—ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Federal National Mortgage Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Shanna L. Morrison and Warren W. Morrison Defendants Number 2012-2070CIVIL DATE: March 25, 2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Shanna L.Morrison and Warren W.Morrison PROPERTY: 211 Lincoln Street,Enola,Pennsylvania 17025 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $173,116.97 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on June 5,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten(10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. r ,>SN A 00 W:4 IV Mel eD toe: O .S An6 a a y 0 Yxnon t-0-0 xvwv yym' fao o m'Q�gX'•e e'fl m= e°° G 'do�' n fn my en Qe� o 8 -•n o B Yyxm y �n o 9 m o - �11 o�oa n Y ►d �o A6 0f -i, ;-Map ,�, S, "'ac v c en B y " VICAAR C �NOC' pn4pm Co� Q.� yB oB ° ooe "CO•�0 "J' tJC YIOB 'J' �n � _,pia e�nv� e° Cd� NO""� � N"" na0Om �dm Qqo� A �� �AS � � m� N""'p � o °.O en O , m-1 m b0 p a �pnA 00 O b?�i ogCL•= � S�].m. ►�rd�rr m e! 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C7� Imo eIr- oe°,°, Y4Cc, ►-�t 0 QA m ��°-, o ro^° cam wft A a Nye A a -4rr a o°a ag w a 01 n CD 3. ep N fD °.77 A m CZ'.� A m JNGm <� �! m 0• =b tA VI 5 ° -• a ro o y y t n °° C C V1 A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -I.—# i Iv _ Sheriff r `.'- ,o R 0' '''l •� ' t Arirrbet,,��t r���i!S t, f i s"i T Jody S Smith - 4 211,13 JUL 23 AM 13= 10 Chief Deputy w Richard W Stewart * - Mi BERLQNrrD COMTY Solicitor OFFICE OF THE$AERIFF P Eta N S YLVA M A Federal National Mortgage Association Case Number vs. Warren W. Morrison (et al.) 2012-2070 SHERIFF'S RETURN OF SERVICE 04/03/2013 10:59 AM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 211 Lincoln Street, East Pennsboro-Township, Enola, PA 17025, Cumberland County. 06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,257.88 SO ANSWERS, July 02, 2013 RbNW R ANDERSON, SHERIFF sv (C)CountySuite Sheriff,Telecsoft,Inc. MCCAB]t,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 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 123 South Broad Street,Suite 2080 Philadelphia,Pennsylvania 19109 215 790-1010 Federal National Mortgage Association CUMBERLAND COUNTY ,COURT OF COMMON PLEAS Plaintiff V. NO: 2012-2070CIVIL Shanna L.Morrison and Warren W.Morrison Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at:211 Lincoln Street,Enola,Pennsylvania 17025,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Shanna L.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 Warren W.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 2. Name and address of Defendants in the judgment: Name Address Shanna L.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 Warren W.Morrison 23 South Enola Drive Enola,Pennsylvania 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: • Name Address • • Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address The Township of East Pennsboro 98 South Enola Drive Enola,Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Address Tenants/Occupants 211 Lincoln Street Enola,Pennsylvania 17025 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales • United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW . Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. YOt [ ]Terrence ..McCabe,Esquire DATE [ ]Edward Conway,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R.Spivak,Esquire [ ]Brian T.LaManna,Esquire [ ]Kevin T.McQuail,Esquire [ ]Marc S.Weisberg,Esquire 4-rMargaret Gairo,Esquire [ ]Joseph F.Riga,Esquire [ ]Marisa J.Cohen,Esquire ( ]Ann E.Swartz,Esquire [ ]Christine L.Graham,Esquire Attorneys for Plaintiff McCARE,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 ANDREW L.MARKOWITZ,ESQUIRE-ED# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ED#87830 KEVIN T.MeQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ED#310321 123 South Broad Street,Suite 2080 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Federal-National Mortgage Association COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Shanna L.Morrison and Warren W.Morrison Number 2012-2070CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Shanna L.Morrison Warren W.Morrison 23 South Enola Drive 23 South Enola Drive Enola,Pennsylvania 17025 Enola,Pennsylvania 17025 Your house(real estate)at 211 Lincoln Street,Enola,Pennsylvania 17025 is scheduled to be sold at Sheriffs Sale on June 5,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$173,116.97 obtained by Federal National Mortgage Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale you must take immediate action: I The sale will be canceled if you pay to Federal National Mortgage Association the back payments, late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFFS SALE DOES TAKE PLACE I if the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE,OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Redford Street, Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION RB5618 211 Lincoln Street,Enola,Pennsylvania 17025. ALL THAT CERTAIN tract of land situate in the Borough of West Fairview,now known as East Pennsboro Township,Cumberland County,Pennsylvania,being more particularly bounded and described as follows: BEGINNING at a point on the southern line of Abolition Street at the western line of a 16 feet wide alley;thence along said alley,South 21 degrees 30 minutes East, 138.92 feet to a point on the northern side of Lincoln Street, South 68 degrees 30 minutes West,59 feet to other lands now or late of Herbert Farner,et ux,of which this tract was formerly a part;thence along said land now or late of Farner,North 21 degrees 30 minutes 00 seconds West, 127.38 feet to a point on the southern line of Abolition Street;thence along Abolition Street,North 58 degrees 00 minutes 00 seconds East,60 feet to a point,the place of BEGINNING. BEING lots on the Plan of Martin's Addition to West Fairview,which plan is recorded in the Cumberland County Recorder's Office in Deed Book 6-U,page 601. BEING Lot.No. 1,CONTAINING 7, 838 Square feet,more or less,according to Resubdivision Plan by William B. Whittock,Professional Engineer,dated September 5, 1973,for Herbert M.and Sara J.Farmer,recorded in the Cumberland county Recorder's Office in Plan book 27,page 139,recorded April, 1976. HAVING THEREON ERECTED a one-story dwelling known as and numbered 211 Lincoln Street,Enola, Pennsylvania. UNDER AND SUBJECT to covenants,reservations,restrictions,easements and rights of ways of record. BEING the same premises which DOUBLE DIAMOND INVESTMENTS,LLC,A PENNSYLVANIA LIMITED LIABILITY COMPANY by deed dated July 6,2007 and recorded July 11,2007 in the office of the Recorder in and for Cumberland County in Deed Book 280,Page 4575,granted and conveyed to Sharma L.Morrison and Warren W. Morrison in fee. TAX MAP PARCEL NUMBER: 45-17-1044-108 CUMBERLAND LAW JOURNAL Writ No. 2012-2070 Civil numbered 211 Lincoln Street,Enola, Pennsylvania. FEDERAL NATIONAL UNDER AND SUBJECT to cov- MORTGAGE ASSOCIATION enants, reservations, restrictions, vs. easements and rights of ways of WARREN W. MORRISON, record. Sharma L. Morrison BEING the same premises which Atty.:Terrance McCabe DOUBLE DIAMOND INVESTMENTS, LLC, A PENNSYLVANIA LIMITED 211 Lincoln Street, Enola, Penn- LIABILITY COMPANY by deed dated sylvania 17025. July 6, 2007 and recorded July 11, RB5678 211 Lincoln Street,Eno- 2007 in the office of the Recorder in la,Pennsylvania 17025. and for Cumberland County in Deed ALL THAT CERTAIN tract of land gook 280, Page 4575, granted and situate in the Borough of West Fair- view,now known as East Pennsboro conveyed to Sharma L.Morrison and Township, Cumberland County, Warren W. Morrison in fee. Pennsylvania,being more particular- TAX MAP PARCEL NUMBER:45- ly bounded and described as follows: 17-1044-108. BEGINNING at a point on the southern line of Abolition Street at the western line of a 16 feet wide alley;thence along said alley, South 21 degrees 30 minutes East, 138.92 feet to a point on the northern side of Lincoln Street, South 68 degrees 30 minutes West,59 feet to other lands now or late of Herbert Farrier,et ux, of which this tract was formerly a part; thence along said land now or late of Farner, North 21 degrees 30 minutes 00 seconds West, 127.38 feet to a point on the southern line of Abolition Street; thence along Abolition Street, North 58 degrees 00 minutes 00 seconds East,60 feet to a point,the place of BEGINNING. BEING lots on the Plan of Martin's Addition to West Fairview, which plan is recorded in the Cumberland County Recorder's Office in Deed Book 6-U,page 601. BEING Lot.No. 1,CONTAINING 7, 838 Square feet,more or less,accord- ing to Resubdivision Plan by William B. Whittock, Professional Engineer, dated September 5,1973,for Herbert M. and Sara J. Farmer, recorded in the Cumberland county Recorder's Office in Plan book 27, page 139, recorded April, 1976. HAVING THEREON ERECTED a one-story dwelling known as and 57 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 12, April 19 and April 26, 2013 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. isa Ma tie-Coyne, ditor SWORN TO AND SUBSCRIBED before me this 26 da y of April, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. r �� the a " 2020 Technology Pkwy Suite 300 Mechanicsburg,*PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16; 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. T r�. This ad ran on the date(s)shown below: 2012-2070 Civil NE FEDERAL NATIONAL D 04/16113 ORTGAGE ASSOCIATION VS. it 04/23/13 WARREN W.MORRISON _ '<:� 04/30/13 Shanna L.Morrison n Aft Torrance Mccabe : - rn 211 Lincoln Street, Enola, Pennsylvania 11025 RB5678 211 Lincoln Street, Enola, I Pennsylvania 17025. � Sworn to and subscribed before me this 13 day of May, 2013 A.D. ALL THAT CERTAIN tract of land situate in the Borough of West Fairview, now(mown as East Pennsboro Township, Cumberland County, Pennsylvania, being more particularly bounded and described I N mmlic as follows: BEGINNING at a point on the souther line of Abolition Street at the western he i of a 16 feet wide alley;thence along said alley, South 21 degrees 30 minutes East, 138.92 feet to a point on the northern side of Lincoln Street, South 68 degrees 30! COMMONWEALTH OF PENNSYLVANIA minutes West,59 feet to other lands now or late of Herbert Famer,et ux,of which this' Notarial Seal tract was formerly a part;thence along said Holly Lynn Warfel,Notary Public land now or late of Farm w. dees Washington Twp.,Dauphin County 30 minutes 00 seconds West,27.38 feet to My Commission Expires Dec.12,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES a point on the southern line of Abolition Street;thence along Abolition Street,North COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND f SS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mtg Assoc is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013,under and by virtue of a writ Execution issued on the 13th day of December, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term,2012 Number 2070, at the suit of Federal National Mtg Assoc against Shanna L &Warren W Morrison is duly recorded as Instrument Number 201324175. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 13'-12-1 day of A.D. -f-./Recorder of Deeds erof 8,Cumberland County,Carlisle,PA My Commission Expires the First h4onday of Jan.2014