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12-2508
Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff CitiFinancial Services, Inc., a Pennsylvania Corporation PLAINTIFF, V. Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011, DEFENDANT t ;? i R ^ E t l Py i' "R ERE_." ND COUNTY `i NINS Y 1..VANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA` DOCKET N0: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND 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 1 ?? ? cos8 t? 1 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 of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 AVISO LE HAN DEMANDADO A LISTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands 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 objecciones 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 edades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. 2 SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOME AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 CitiFinancial Services, Inc., a Pennsylvania Corporation PLAINTIFF, V. Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, CitiFinancial Services, Inc., a Pennsylvania Corporation by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 4 1. Plaintiff, CitiFinancial Services, Inc., a Pennsylvania Corporation is a corporation, limited partnership, limited liability company, federal savings bank, federal credit union, or national banking association under and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 1000 Technology Drive, O'Fallon, MO 63368-2240. 2. Defendant, Jeannette M. Reisch, is the real owner, mortgagor, and grantee in the last Deed of record to the real property located at 1510 Carlisle Road Camp Hill, PA 17011 and, if applicable, riparian rights appertaining thereto (hereinafter referred to as "Premises") . 3. On April 18, 2007, Defendant made, executed, and delivered a Mortgage to CitiFinancial Services, Inc., a Pennsylvania Corporation (hereinafter referred to as "Originating Lender") as security for Defendant's payment and other obligations in consideration of a mortgage loan made to Defendant by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, and was recorded on April 20, 2007 in Mortgage Book 1989, Page 1876, and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The aforesaid Mortgage has not been re-recorded. 5. The aforesaid Mortgage has not been modified. 6. Plaintiff is the owner and holder of the aforesaid Mortgage. 7. The address of the Premises is 1510 Carlisle Road, Camp Hill, PA 17011. 8. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid Mortgage have not been made from December 7, 2010 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said 5 breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 9. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendant shall be liable for, inter alia, Plaintiff's costs, corporate advances, escrow advances, and attorneys' fees. 10. The following amounts are due as of January 31, 2012: Principal Accrued Interest through January 31, 2012 BPO 5% of Principal for Attorneys' Fees Total $ 111,446.85 $ 19,204.59 $ 87.00 $ 5572.34 $ 136,310.78 plus additional pre-judgment and post-judgment interest at the per diem rate of $34.05 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage. 11. If the Mortgage is reinstated prior to a sheriffs sale, the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5%) of the remaining principal balance in the event the Premises is sold to a third party 6 purchaser at sheriffs sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. 12. Plaintiff is not seeking a judgment on personal liability (or an in personam judgment) against Defendant in this action but reserves the right to bring a separate action to establish that right, if such right exists. If Defendant received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish the personal liability that was discharged in bankruptcy, but only to foreclosure the Mortgage and sell the Premises pursuant to Pennsylvania law. 13. Plaintiff has demanded the total amount due from Defendant, but Defendant has failed and/or refused to pay the same. 14. Notice of Intention to Foreclose pursuant to Act 6 and/or Act 91 was sent in accordance with Pennsylvania law more than 34 days ago. WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendant, Jeannette M. Reisch, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 10., namely $136,310.78, plus additional pre judgment and post judgment interest at the per diem rate of $34.05 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage, and such other relief as this Court deems just and proper. 7 RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richard M. Squire, Esq. (PA I.D.# 04267) L,,'*'M. Troy Freedman, Esq. (PA I.D.# 85165) Christina C. Viola, Esq. (PA I.D.# 308909) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791(fax) rsquire@squirelaw.com tfreedman@squirelaw.com cviola@squirelaw.com Attorneys for Plaintiff Date: UNLESS YOU NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS 8 COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire ID. Nos. 04267 / 85165 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 CitiFinancial Services, Inc., a Pennsylvania Corporation PLAINTIFF, V. Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION Stacey Rodgers hereby states that she is employed by CitiMortgage, Inc. as a Document Control Officer. Pursuant to an agreement, CitiMortgage, Inc. provides certain loan servicing activities to CitiFinancial Services, Inc., a Pennsylvania Corporation the servicer of the loan and Plaintiff in this matter and is authorized to make this Verification. 10 I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. U, 0 Name: Stacey Rodgers DATE: 14 / I C) / I D., Title: Document Control Officer File #: CMI-859F CFNA Name: Jeannette M. Reisch 11 EXHIBIT "A" ALL THAT CERTAIN PARCEL OF LAND IN LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, COMMONWEALTH OF PA, AS MORE FULLY DESCRIBED IN BOOK 19-P, PAGE 298, 10#13-23-0547-297, BEING KNOWN AND DESIGNETED AS LOT NO 35, BLOCK I ON THE REVISED PLAN OF HIGHLAND PARK, FILED IN PLAN BOOK 3 AT PAGE 96. BEING THE SAME FEE SIMPLE PROPERTY CONVEYED BY DEED FROM HAROLD E. RING AND MARY K. RING, HUSBAND AND WIFE TO JOHN E. REISCH AND JEANNETTE M. REISCH, HIS WIFE AS TENANTS BY THB ENTIRETIES, DATED 01/14/1960 RECORDED ON 01/15/1960 IN BOOK 19-P, PAGE 298 IN CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF PA. THE SAID JOHN E. REISCH HAVING DEPARTED THIS LIFE, THEREBY VESTING FEE SIMPLE TITLE IN JEANNETTE M. REISCH. 12 F,na/i (,'41 Serc), (,6. Tn c., a Plaintiff(s) n vs. Defendant(s) FORM Y z.. -art IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYL? - ; , ; --, ?a-a5o? Civil +y 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 that 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 it 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 attsched 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. Oat Respectfully sub ' e [Signa a of Counsel for Plaintiff) FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: State: Zip: Yes El No F1 Listing date: Price: $_ _ . Realtor Phone:_ Borrower Occupied? Yes ? No ? Mailing Address (if different): City: State Zip: Phone Numbers: Home: Cell: Email: # of people in household: Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: How long? Date You Closed Your Loan: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Office: Other: How long? Is the loan in Bankruptcy? Yes ? No ? 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 transportation (automobiles. boats. motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: I . 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mort a e Utilities Car Payment(s) Condo/Neigh, Fees Auto Insurance Med. not covered Auto fueMT airs Other prop. payment Install. Loan Payment Cable TV Child Supp2rt/Alim, Spending Money Da /Child Care/Tuit. Other Expenses 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: Year: Year: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: 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. /'We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements V+ Proof of any expected income for the last 45 days Y Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation r (hardship letter) Y Listing agreement (if property is currently on the market) 3 FORM 3 C J4 F?(1Gnc,-Cr J lerJ, (e J, T /-7 ( ,) g IN THE COURT OF COMMON PLEAS OF Gr P??? 17 Un : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. e 0n e ?4 e et, s c.. i Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date C +; FkA(//7Ct L)i'(eS, To C. ct penNy 1 v0/1",? Call Plaintiff(s) vs. ?)ecme-?fe Defendant(s) FORM a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO, CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the ,plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY `I ifJ (.....^ ry Ronny R Anderson F1jj Sheriff r' T ??i err Jody S Smith Chief Deputy Richard W Stewart Solicitor w k'' `lnurrl>0a - PE.?',iSYL\'AutiliA Citifinancial Services Inc. vs. Jeannette M. Reisch SHERIFF'S RETURN OF SERVICE Case Number 2012-2508 05/04/2012 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: Jeannette M. Reisch, 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 Jeannette M. Reisch. Request for service at 1510 Carlisle Road, Camp Hill, Pennsylvania 17011 is vacant. The Camp Hill Postmaster has confirmed, Jeannette M. Reisch has moved and left no forwarding address. SHERIFF COST: $48.00 SO ANSWERS, May 04, 2012 RON R ANDERSON, SHERIFF Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig A. Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-879 Attorneys for Plaintiff r-JP {MOD -Ir T1 " r iT N e? ? : : f} , . OneMain Financial, Inc., a Delaware Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011 NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANT. PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly mark the Plaintiff's Complaint in the above matter as reinstated pursuant to Rule 401 (b) and Rule 1141 Pa. R. C. P. RICHARD M. SQUIRE & ASSOCIATES By: M. Tr reedman, Esquire Att eys for Plaintiff s Date: May 23, 2012 C *(:9s638 9#a7s4o&a CMI-859F CFNA/LC SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith M Chief Deputy 77, Richard W Stewart co Solicitor Citifinancial Services Inc vs. Jeannette M. Reisch Case Number 2012-2508 SHERIFF'S RETURN OF SERVICE 05/31/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 31, 2012, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Jeannette M. Reisch. Jeannette M. Reisch is currently in a nursing home and not able to accept service. 06/11/2012 07:05 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2012 at 1905 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeannette M. Reisch by making known unto David Reisch, Power of Attorney for Defendant at 721 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true an orr t copy of the same. WN SHALL, SHERIFF COST: $75.00 June 12, 2012 SO ANSWERS, RON Y R ANDERSON, SHERIFF Acceptance of Service I accept the service of the e- , I (t 1 16 ce- ?e Lcvic+(ler? (-7o I (on behalf of ICI nrm q'1 resc h and certify that I am authorized to do so.) (-,:, -- I/ -l`z Date -7 2-1 W a Mailing Address Sovz nczA?,A n e.`sc1, P06 Authorized Ag?ent? S Z- -t 0 yk7P , ?° I70? Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attornevs for Plaintiff Attorneys for Plaintiff ?a 3 MW N c- m c= Cn ?C 7f:' rn ' cCD - MC -I '- C) s, c.a r ; _ - , N) c.,a a OneMain Financial, Inc., a Delaware Corporation 1000 Technology Drive O'Fallon, MO 63368-2240 PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil CIVIL ACTION DEFENDANT. PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Jeannette M. Reisch, Defendant, for his/her/its/their failure to file an Answer to Plaintiffs Complaint w 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiffs damages as follows: Judgment payoff request Payoff Good Through 8/2/2012 Principal Balance Interest Due $111,446.85 41(a, so Pd Cf'as718 & an of NO41&" Ind, a""l BPO $87.00 $25,401.82 led Taxes $5,582.31 F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\default judgment. wpdLC Total Due 142,517.98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2 that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Rich. Squire, Esq. (PA I.D.# 04267) ?M. T y Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264; 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquirensquirelaw.com tfreedmangsauirelaw.com coppenheimer&sauirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED 1 DATE: PROTHONOTARY F:\Clients\Citi Mortgage\Reisch, Jeannette -859Rdefault judgment.wpdLC Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, DOCKET NO: 12-2508 civil CIVIL ACTION DEFENDANT. VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) an address 1510 Carlisle Road, Camp Hill, PA 17011 and/or 721 Walton Street, Lemoyne, PA 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FAChents\Citi Mortgage\Reisch, Jeannette -859Rdefau1t judgment.wpdL.C RICHARD M. SQUIRE & ASSOCIATES, By: Richar . Squire, Esq. (PA I.D.# 04267) ?M. Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA LD.# 313264 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquireksauirelaw.com tfreedmanksquirelaw.com col2penheimerksquirelaw.com Attorneys for Plaintiff F:\C1ients\Citi Mortgage\Reisch, Jeannette -859F\defau1t judgment.wpdL Department of Defense Manpower Data Center 40 Statue Repwt P'wmuant to Slervicemembers Civil. Relief Act Last Name: REISCH First Name: JEANNETTE Active Duty Status As Of: Jul-05-2012 Results as of : Jul-05-20V 07:09:13 dCRA 2.2.1 Active Duly Start Dab Adlve Duty End Dab status service component On Acgve Duty On Active Duty Status Data NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty SWA n Dab AW" Duty Start Della Actlve Duty End Date status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unfl Was NodW of a Fub" Call-Up to A:cdvo MAY W Ad" M4 Status Oats Order NotMptlon Start Dab Order Notification End Date stolue Sam= Component NA NA 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 tatus of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Healt , and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. YJWJ A. LAA.J_ 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 at seq, as amended) (SCRA) (formerly kno n 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 fa ily member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled o 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 active duty st tus date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual le Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for duty on the Active Duty Status Date. 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 period 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 servic 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 R serve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the i 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 of 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 p riods. 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 ha a 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 th 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 are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: N9NE000JLR PACER Case Locator - View Bank'U a" Ju5 08 088 4Y7 Search Case Locator No Records Found User: rs0431 P Client: Search: Bankruptcy Party Search Name reisch, jeannette (ssn 5145) All Courts Page: 1 No records found Receipt 07105/2012 08:08:48 9216073 User rs0431 P Client Description Bankruptcy Party Search Name reisch, jeannette (ssn 5145) All Courts Page: 1 Pages 1 ($0.10) Page l of 1 https://pcl.uscourts. gov/view?rid=MMugUDIuObvHe4GSBxRgcRHwqkk5OlRNtmj EZ4MA... 7/5/201.2 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 717-240-6195 Date OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANTS. NOTICE TO: Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given tl on 7AT/1a , a judgment(decree)(order) was entered against you in this office in the jprding as indicated above. • Prothonotary F:\Chents\Citi Mortgage\Reisch, Jeannette -859F\defau1t judgment.wpolj5 Deputy Prothonotary Date Mailed: F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\default judgment.wpdL6 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 717-240-6195 Date OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANTS. NOTICE TO: Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011 Pursuant to re uirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given t on /I& , a judgment(decree)(order) was entered against you in this office in the proceeding as indicated above. ?r Prothonotary Deputy Prothonotary Date Mailed: F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\default judgment.wpdLC7 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 717-240-6195 Date OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANTS. NOTICE TO: Jeannette M. Reisch c/o David Reisch 721 Walton Street Lemoyne, PA 17043 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given t on / , a judgment(decree)(order) was entered against you in this office in the proceeding as indicated above. Prothonotary Deputy Prothonotary Date Mailed: FAClients\Citi Mortgage\Reisch, Jeannette -859Rdefault judgment.wpdL8 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 717-240-6195 Date OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANTS. NOTICE, TO: Jeannette M. Reisch c/o David Reisch 1510 Carlisle Road Camp Hill, PA 17011 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given t on 1 a judgment(decree)(order) was entered against you in this office in the pr eding Indic Bove. Prothonotary Deputy Prothonotary Date Mailed: FAChents\Citi Mortgage\Reisch, Jeannette -8591Adefau1t judgtnent.wpdLV Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANT. TO: Jeannette M. Reisch 721 Walton Street Lemoyne PA 17043 NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DATE OF NOTICE: July 2, 2012 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH FAChentsUb Mortgage\Reisch, Jeannette -859FU0 day noticempd\LC 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 LEG SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAClientsTiti Mortgage\Reisch, Jeannette -859FU 0 day notice.wpd\LC Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANT. TO: Jeannette M. Reisch 1510 Carlisle Road Camp Hill, PA 17011 NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DATE OF NOTICE: July 2, 2012 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND FAChentsUti Mortgage\Reisch, Jeannette -859F\10 day noticempdU.C OUT WHERE YOU CAN GET LEGAL HELP. 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 LEC SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Chents\Citi Mortgage\Reisch, Jeannette -859F\10 day noticempd\LC Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANT. TO: Jeannette M. Reisch C/o David Reisch 721 Walton Street Lemoyne PA 17043 DATE OF NOTICE: July 2, 2012 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHbUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND FAChentsTiti Mortgage\Reisch, Jeannette -859M10 day noticempd\L..C OUT WHERE YOU CAN GET LEGAL HELP. 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 LEG SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAChentsUd Mortgage\Reisch, Jeannette -859MIO day notice.wpd\L.C Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, V. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANT. TO: Jeannette M. Reisch c/o David Reisch 1510 Carlisle Road Camp Hill, PA 17011 DATE OF NOTICE: July 2, 2012 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND FAChentsUd Mortgage\Reisch, Jeannette -859MI0 day noticempdU.C OUT WHERE YOU CAN GET LEGAL HELP. 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 LEC SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAC1ients\Citi Mortgage\Reisch, Jeannette -859F\10 day notice.wpd\LC WRIT OF EXECUTION and/or ATTACHMENT' COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 2012-2508 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs clue ONEMAIN FINANCIAL, INC. A DELAWARE CORPORATION Plaintiff (s) From JEANNETT'E M. REISCH, 721 WALTON STREET, LEMOYNE, PA 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $142,517.98 L.L.: $.50 Interest FROM 8/3/2012 to 12/5/2012 @ $34.05 PER DIEM - $4,256.25 Atty's Comm: °% Due Prothy: $2.25 Atty Paid: $286.00 Other Costs: Plaintiff Paid: Date: 7/31 /2012 "'~ ' ~. l~ --- David D. Buell, Prothonotary fSeal) --~'' Deputy REQU:ESTINC PARTY: Name: CR~~3[G OPPENHEIMER, ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 313264 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire IV1. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 1 15 West Avenue Jenkintown, PA 19046 Attorneys fir Plaintiff Telephone:215-886-8790 Fax:215-886-8791 za ~ z ~~~ ~ i aM s: 2 ~ CU~1~£RLANO CO_UW`C'~ OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANT I L17i~v s ~.•.-••••• IN THE COURT OF COMMON PLEAS ': CUMBERLAND COUNTY, PENNSYLVANIA •' NO. I2-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Kindly issue a Writ of Execution in the above matter. Amount Due $ 142,517.98 Interest From 8/3/2012 to 12/5/2012 @ $34.05 per diem ~ 4,256.25 Total: $ 146,774.23 ', plus fees and costs '', Date: July 27, 2012 l~ J ~ ~S.s~~'d a~ Q~` c~~. oo C6F ~f ~j. 00 ~~ u I o3.~5~~,~ 1 1, . Sv" ,~ o~ 5~ <=_ ~ a oo ~d a ~1 CMI-859F CFNA/DM1 --- - ../ By: ', Richard M. ire, Esq. (PA LD.# 04267) ~~ M. Troy Freedman, Esq. (PA LD.# 85165) Craig Oppenheimer, Esq. (PA LD.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA ] 9046 215-886-8790 215-886-879] (fax) rsauire(a~squirelaw com tfreedman(asauirelaw com conpenheimer ,sauirelaw com Attorneys for Plaintiff ~ a.}s ~~ ~ ~,sv~1- C ~= ~ as~l~~ ~ ~ U 0 N N_ 0 U 0 Q w ¢ ~° o¢ 0 Woo a ~~ a~ ~ W ~ aQ~. O Fem., `~ ~ U ~~~ H U .~ ~z ~ O W ~ ~ f-~ ~ O M ~ ~ ~ ~ ~ ~ o a -d ~ ~ ~3;~ ~~~Q ti ~ ~ z 0 U ~ W ~ ~,, O O ~ H ~ O w a~ o ~ 1 (.z.., OO a `'~"' 1~ W a b (i U ~ W W' W ~~ a~p~~ a~ o ~ ~ ~ ~ . ~~ a~Q•ro ¢ a r~ ,'~ ~ ~ '~ °° 00 _U O ~~ ~. v G .~ a ~. ~° v 0 Q ~¢ z w U w o, U LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northerly line of Carlisle Road, said point being the dividing li' e between Lots Nos. 34 and 35, Block "I" of the hereinafter mentioned Plan of Lots; thence in a Norther y direction along said dividing line one hundred fifty and eight tenths (150.8) feet to Lot No. 17, Block "I '; thence in an Easterly direction along said Lot No. 17, Block "I" fifty five (55) feet to Lot No. 33, Block "I"; thence in a Southerly direction along said Lot No. 35, Block "I" one hundred sixty one and nine tenths 161.9) feet to Carlisle Road; thence in a Westerly direction along said Carlisle Road fifty six and one tenth (56.1) feet to the place of BEGINNING.. HAVINCT THEREON ERECTED a single brick dwelling House No. 1510 Carlisle Road. BEING Lot No. 35, Block "I", on the revised Plan of Highland Park as recorded in the Cumberl~lnd County Recorder's Office in Plan Book 3, Page 96. TAX PARCEL NO. 13-23-0547-297 BEING the same premises which Harold E. Ring and Mary K. Ring granted and conveyed u to John E. Reisch and. Jeannette M. Reisch, his wife by Deed dated. January 14, 1960 and recorded Janua 15, 1960 in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania as Deed Book 19-P Page 298. AND THE SAID John E. Reisch having departed this life on March 7, 1991; title is thereby vetted solely to Jeannette M. Reisch, by operation of law, as surviving tenant of the entireties. F:\Clients\Citi Mortgage\Reisch, Jeannette -859E\writ packal;e 7-26-2012.wpd Richard M. Squire & Associates, LLC ~By: Richard M. Squire, Esquire M. "Troy Freeciman, Esquire Craig Oppenheimer, Esquire LD. Nos. 042.67 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-879 Attornevs for Plaintiff ZQI2.I~JL 3 ~ AM 8~ 27 ~~MB~~Lar~to eouN~Y PENNSYLVANIA, OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 12-2508 civil CIVIL AC"TION MORTGAGE FORECLOSURE AFFIDAVIT' PURSUANT TO RULE 3129.1 OneMain Financial, Inc., a Delaware Corporation, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the followi . g information concerning the real property located at 1510 Carlisle Road, Camp Hill, PA 17011, T x Parcel No:.13-23-0547-297. 1. Name and last known address of Owner(s) or Reputed Owner(s): Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 2. Name and last known address of Defendant(s) in the judgment: Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a ', record lien on the real property to be sold: Citifinancial Services, Inc. ', c/o CitiMortgage Inc ', 1000 Technology Drive O'Fallon, MO 63368-2240 Capital One Bank 1680 Capital One Drive McLean, VA 22102 F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd 4. Name and address of last recorded holder of every mortgage of record: OneMain Financial, Inc., a Delaware Corporation 3401 Hartzdale Drive, Ste 126 Camp Hill, PA 17011 Citifinancial Services, Inc. c/o CitiMortgage Inc 1000 Technology Drive O'Fallon, MO 63368-2'40 ', 5. Name and address of every other person who has any record lien on the propertyk None other. 6. Name and address of every other person who has any record interest in the prop~rty and whose interest may be affected by the sale: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square -Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn :Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd 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: Tenant/Occupant 1510 Carlisle Road Camp Hill, PA 17011 VERIFICATION 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. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC ,-- __ __ . Richard M. quire, Esquire M. Troy Freedman, Esquire _~Craig Oppenheimer, Esquire ', 115 West Avenue, Suite 104 Jenkintown, PA 19046 (21 S) 886-8790 ', Attorneys for Plaintiff ', Date: July 27, 2012 F:\Clients\Citi Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd Richard M. Squire &. Associates, LLC By: Richard M. Squire, Esquire N[. Troy Freedman, Esquire Craig Oppenheimer, Esquire LSD. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation PLAINTIFF, v. Jeannette M. Reisch ;• ,; ~~'i~l7F i0t~0 iA ~,~. ~~IZ Jl1~ 3 I AM 8.28 ~'~MBERLAND COUNTY PENNS Yl.VgNiA IN THE COURT OF COMMON PLF,AS CUMBERLAND, PENNSYLVANIA. NO. 12-2508 civil CIVIL ACTION 721 Walton Street :MORTGAGE FORECLOSURE Lemoyne, PA 17043 DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 cxnd/or 1510 Carlisle Road, Carnp Hill, PA 17011. Your house (real estate) at 1510 Carlisle Road, Camp Hill, PA 17011 is scheduled to ~e sold at Cumberland County Sheriff Sale, on 12/5/2012 at 10:00 a.m., at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 'to enforce the court judgment of $142,517.98 plus interest ~o the sale date obtained by OneMain Financial, Inc., a Delaware Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: ~' 1. The sale will be canceled if you pay back to OneMain Financial, Inc., a pelaware Corporation, the amount of the judgment plus costs or the back payments, late char~es, costs and reasonable attorneys' fees due. To find out how much you must pay, you ~' ay call: Richard M. Squire, Esquire, M. Troy Freedman, Esquire or Craig Oppenheimer, b?squire at (215) 886-8790. '~ 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. F:\Clients\Citi MortgagelReisch, ]rannette -859E\writ packs@,e 7-26-2012.wpd You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHEPk RIGHTS EVEN IF THE SHF,RIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidden You may find out the price bid bar calling the Cumberland Sheriffs Office at 717-240-610. 2. You may be able to petition the Court to set aside the sale if the bid ri p ce vas grossly inadec{uate compared te~ the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due inn the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the o~ner 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 ~heriff and the Sheriff gives a deed Ito the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A s~hedule of distribution of the money bid for your house will be filed by the Sheriff no later th~n 30 days after the Sheriffs Sale. This schedule will state who will be receiving the money. he money will be paid out in accordance with this schedule unless exceptions (reasons why th proposed distribution is wrong) are' filed with the Sheriff within ten (10) days after the date f filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, I~if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 7L7-249-3166 and 800-990-9108 F:\Clients\Citi Morteage\Reisch, Jeannette -A59F1writ package 7-26-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue x ' J I! ON0TA'. 2x17. SEP -6 A 10: 5- Jenkintown, PA 19046 1- CUMBERLAND COUNT' (215) 88678790 Fax (215) 886-8791 PENNSYLVANIA Attorneys4 for Plaintiff OneMaih Financial, Inc., a Delaware IN THE COURT OF COMMON PLEAS Corporation, CUMBERLAND, PENNSYLVANIA PLAINTIFF, DOCKET NO. 12-2508 civil V. Jeannette M. Reisch 721 Walton Street Lemoyno, PA 17043, DEFENDANT CIVIL ACTION MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 OneMairt- Financial,lnc., a Delaware Corporation, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following informatipn concerning the real property located at 1510 Carlisle Road, Camp Hill, PA 17011, Tax Parcel No%13-23-0547-297. Name and last known address of Owner(s) or Reputed Owner(s): Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 2, Name and last known address of Defendant(s) in the judgment: Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citifrnancial Services, Inc. c/o CitiMortgage Inc 1000 Technology Drive O'Fallon, MO 63368-2240 Capital One Bank 1680 Capital One Drive McLean, VA 22102 FAClients\Cidi Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd Capital One Bank 15000 Capital One Drive Richmond, VA 23238 4. Name and address of last recorded holder of every mortgage of record: OneMain Financial, Inc., a Delaware Corporation 3401 Hartzdale Drive, Ste 126 Camp Hill, PA 17011 Citifinancial Services, Inc. c/o CitiMortgage Inc 1000 Technology Drive O'Fallon, MO 63368-2240 5. Name and address of every other person who has any record lien on the property: None other. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square - Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn : Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 FAClients\Citi Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd 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: Tenant/Occupant 1510 Carlisle Road Camp Hill, PA 17011 VERIFICATION 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. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: Z4/1 har . Squire, Esquire 4Ri roy Freedman, Esquire Craig Oppenheimer, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: 9"5-12 FAChentsTiti Mortgage\Reisch, Jeannette -859F\writ package 7-26-2012.wpd Richard M. Squire & Associates, LL(' • By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire 1.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Attorneys for Plaintiff _.' I ~;' , . n . y. J ~,;!:1j~~,i ...~il "~ OneMain Financial, Inc., a Delaware Corporation, PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE PLAINTIFF'S MOTION FOR ALTERNATIVE SERVICE OF THE NOTICES OF SHERIFF'S SALE AND NOW, comes Plaintiff, OneMain Financial, Inc., a Delaware Corporation, by its undersigned attorney and moves this Honorable Court for an Order permitting alternative service of the Notices of Sheriff s Sale upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to 1510 Carlisle Road, Camp Hill, PA 17011, 721 Walton Street, Lemoyne, PA 17043 and 1100 Grando Way, Room, 555, Mechanicsburg, PA 17055; and (2) posting a true and correct copy thereof on the mortgaged premises at 1510 Carlisle Road, Camp Hill, PA 1701 l by any competent adult. In support thereof, Plaintiff avers the following: 1. In this mortgage foreclosure proceeding, Plaintiff properly caused a default judgment to be entered against Defendant as a result of her failure and/or refusal to make, tender, and deliver the monthly mortgage payments. 2. Plaintiff thereafter properly caused a Writ of Execution to be issued in order to list Defendant's property situated at 1510 Carlisle Road, Camp Hill, PA 17011 (hereinafter referred to as "mortgaged premises") for the 12/05/2012 Cumberland County sheriffs sale. That sale will need to be postponed to a later date due to difficulties encountered in serving Defendant with the Notice of Sheriffs Sale, pursuant to Pa. R.C.P. 3129.2(a), as explained herein. 3. The Defendant could not be served with the Notice of Sheriff's Sale at the mortgaged premises. True and correct copies of the Cumberland County Sheriff s service forms are attached hereto as Exhibit "A" and made a part hereof. Notably, the Cumberland County Sheriff's service form states the following: "1510 Carlisle Road, Camp Hill, PA 17011 is vacant." See Ex. "A." 4. The Defendant also could not be served with the Notice of Sheriffs Sale at as suspected alternate address of 721 Walton Street, Lemoyne, PA 17043. See Ex. "A."Notably, the Cumberland County Sheriff's service form states the following: "`Not found' at 721 Walton Street, Lemoyne, PA 17043, defendant is currently in a Nursing Home [sic] at 1100 Grando Way, Room 555, MECHANICSBURG, this facility does not grant access to patients..." [emphasis in original]. See id. 5. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to locate Defendant. An Affidavit of Good Faith Investigation, which sets forth the specific inquiries made and the results thereof, is attached hereto as Exhibit "B" and made a part hereof.' 6. Requests for Change of Address or Boxholder [hereinafter referred to as "Request"], pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Camp Hill, Pennsylvania and Lemoyne, Pennsylvania Postmaster indicate that `Social security numbers and dates of birth have been omitted in observance of federal privacy laws. Defendant received mail at the Lemoyne, Pennsylvania address as of the date thereof. True and correct copies thereof are collectively attached hereto as Exhibit "C" and made a part hereof. 7. As of the present date, Defendant has not contacted Plaintiff or the undersigned to bring her delinquent mortgage loan current through a reinstatement, enter into a forbearance plan, propose a Deed in Lieu of Foreclosure, or discuss the sale of the mortgaged premises. Defendant's inaction and utter failure to take any initiative whatsoever strongly suggests that she is/are avoiding and/or evading her mortgage company and outstanding indebtedness. 8. Despite Plaintiffs good faith efforts to locate Defendant, it appears more likely than not that she is avoiding and/or evading service of the Notice of Sheriff's Sale. Plaintiff requests an Order in the form attached so that Defendant can be properly served via alternate means with notice of the sheriffs sale thirty (30) days or more before such sale in accordance with Pa. R.C.P. 3129.2(c). 9. Pursuant to Cumberland County Local Rule 208.3(a)(9), Plaintiff sent a request for concurrence with copies of the herein Motion for Alternative Service of the Notice of Sheriff's Sale to Defendant on November 9, 2012 via simultaneous regular mail and certified mail, return receipt requested. True and correct copies of the cover letter and proof of the aforesaid mailings are collectively attached hereto as Exhibit "D" and made a part hereof. Defendant has not responded to Plaintiff's request for concurrence. 10. This matter has not previously been assigned to a Judge for disposition. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to 1510 Carlisle Road, Camp Hill, PA 17011, 721 Walton Street, Lemoyne, PA 17043 and 1100 Grando Way, Room, 555, Mechanicsburg, PA 17055; and (2) posting a true and correct copy thereof on the mortgaged premises at 1510 Carlisle Road, Camp Hill, PA 17011 by any competent adult. Respectfully submitted, Dated: November ~ ~ , 2012 RICHARD M. SQUIRE & ASSOCIATES, LLC By: ~,/ Richar .Squire, Esq. (PA LD.# 04267) ~/ M. roy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire ,s~uirelaw.com tfreedmanna.squirelaw.com c~ppenheimer~a.squirelaw com Attorneys for Plaintiff Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 OneMain Financial, Inc., a Delaware Corporation, PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE DEFENDANT. VERIFICATION I, M. Troy Freedman, Esquire, hereby state that I am one of the attorneys for Plaintiff, a corporation unless designated otherwise; that I am authorized to make this Verification; that I have personal knowledge of the facts averred in the foregoing Motion; and that the statements made in the foregoing Motion are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: November ~, 2012 RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richard M. quire, Esq. (PA I.D.# 04267) M. Tro reedman, Esq. (PA I.D.# 85165) Crai Oppenheimer, Esq. (PA I.D.# 313264) Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax:215-886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, M. Troy Freedman, Esquire, hereby certify that, on this date, I served or caused to be served a true and correct copy of the foregoing Plaintiff's Motion for Alternative Service of the Notice of Sheriff s Sale, Brief/Memorandum of Law, Verification, and proposed form of Order upon the following person via regular mail, postage prepaid: Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043 and 1510 Carlisle Road, Camp Hill, PA 17011 and 1100 Grando Way, Room 555 Mechanicsburg, PA 17055 Dated: November ~~ , 2012 RICHARD M. SQUIRE ASSOCIATES, LLC \` By: Richard quire, Esq. (PA LD.# 04267) ~/ M. T Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 1 I5 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsa uire(a~squirelaw.com tfreedmannae.squirelaw.com connenheimer(a~sq_uirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC • By: Richard M. Squire, Esquire M. Troy Freedman, Esquire • Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil CIVIL ACTION MORTGAGE FORECLOSURE BRIEF/MEMORANDUM OF LAW With respect to service of a Notice of Sheriff's Sale, Pa. R.C.P. 3129.2(c) provides, in pertinent part: (c) The [Notice of Sheriff s Sale] shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the [Notice of Sheriff s Sale] shall be made (i) upon a defendant in the judgment who has not entered an appearance and upon the owner of the property. (A) by the sheriff or by a competent adult who is not a party to the action in the manner prescribed by Rule 402(a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court; and [... ] Pa. R.C.P. 430(a) provides, in pertinent part: (a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of defendant and the reasons why service cannot be made. Official Note A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As reflected on the attached Sheriff's service form, Plaintiff's multiple attempts to have Defendant served with the Notice of Sheriff s Sale, in accordance with Pa. R.C.P. 3129.2(c)(1)(i)(A), have been unsuccessful. See Ex. "A." Requests for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Camp Hill, Pennsylvania and Lemoyne, Pennsylvania Postmasters indicate that Defendant received mail at the Lemoyne, Pennsylvania address as of the date thereof. See Ex. "C." Good faith efforts to discover the whereabouts of Defendant have been made, as evidenced by the numerous inquiries set forth in the attached Affidavit of Good Faith Investigation. See Ex. "B." In particular, inquiries have been made to the following persons and entities: Directory Assistance, White Pages, and On-Line Telephone Records; 2. County Tax Assessment; Federal Aviation Administration; 4. United States Drug Enforcement Administration; 5. Pennsylvania Department of State-Uniform Commercial Code filings; and 6. Pennsylvania Department of Corrections. See id. Also searched were United States Bankruptcy Court records, sexual offenders database, nationwide professional licenses, federal firearms and explosives licenses, and civil. proceedings filed in the Commonwealth of Pennsylvania. See id, As of the present date, Defendant has not contacted Plaintiff or the undersigned to bring her delinquent mortgage loan current through a reinstatement, enter into a forbearance plan, propose a Deed in Lieu of Foreclosure, or discuss the sale of the mortgaged premises. Defendant's inaction and utter failure to take any initiative whatsoever strongly suggests that Defendant is avoiding and/or evading her mortgage lender and outstanding indebtedness. Based on the foregoing, it is more likely than not that Defendant is avoiding andlor evading service of process. Pursuant to Cumberland County Local Rule 208.3(a)(9), Plaintiff sent a request for concurrence with copies of the herein Motion for Alternative Service of the Notice of Sheriff's Sale to Defendant on November 9, 2012 via simultaneous regular mail and certified mail, return receipt requested. See Ex. "D." Defendant has not responded to Plaintiff's request for concurrence. This matter has not previously been assigned to a Judge for disposition. For all of the foregoing reasons, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to 1510 Carlisle Road, Camp Hill, PA 17011, 721 Walton Street, Lemoyne, PA 17043 and 1100 Grando Way, Room, 555, Mechanicsburg, PA 1.7055; and (2} posting a true and correct copy thereof on the mortgaged premises at 1510 Carlisle Road, Camp Hill, PA 17011 by any competent adult. Dated: November~~ , 2012 Respectfully submitted, RICHARD M. SQUIRE & ASSOCIATES, LLC By: R' hard ~ quire, Esq. (PA I.D.# 04267) -i ~I. Tro Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire e,squirelaw.com tfreedman(~sauirelaw.com connenheimer(a,squirelaw. com Attorneys for Plaintiff Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor .~~ttitity, ~i 4aarat~rr~a~ Y !~ ~.~~Fr,~_= ~;~ ~ ~z~F~ Citifinancial Services Inc. vs. Case Number Jeannette M. Reisch 2012-2508 SHERIFF'S RETURN OF SERVICE 10/03/2012 01:46 PM -Deputy Noah Cline, 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 1510 Carlisle Road, Camp Hill, PA 17011, Cumberland County. 10/12/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jeannette M. Reisch, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 721 Walton Street, Lemoyne, PA 17043, defendant is currently in a Nursing Home at 1100 Grando Way ,Room 555 MECHANICSBURG, this facility does not grant access to patients, alternate address provided of: 1510 Carlisle Road, Camp Hill, PA 17011 is vacant. SHERIFF COST: $913.75 October 12, 2012 SO ANSWERS, RON ~ R ANDERSON, SHERIFF (~:~ c:c~i~=r~s;.~~te si,t SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson sheriff w~}5tit~` t~1. Gt~tlifarr(r~b Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~`"~~=~ "``` ~~ "' Citifinancial Services Inc. vs. Jeannette M. Reisch Case Number 2012-2508 SHERIFF'S RETURN OF SERVICE 05/04/2012 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: Jeannette M. Reisch, but was unable to locate her in his bailiwick. H2 therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Jeannette M. Reisch. Request for service at 1510 Carlisle Road, Camp Hill, Pennsylvania 17011 is vacant. The Camp Hill Postmaster has confirmed, Jeannette M. Reisch has moved and left no forwarding address. SHERIFF COST: $48.00 May 04, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF EXlllblt "B": Affidavit of Good Faith Investigation AFFIDAVIT OF GOOD FAITH INVESTIGATION Commonwealth of Pennsylvania County of Montgomery SS: I, Rosemary McCrory Sweet, an Owner of Rosemary McCrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSE THE FOLLOWING: 1) I HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: JEANNETTE M REISCH DOB:6/5/1927 2. THE PROPERTY ADDRESS IS 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPORT iS RFi IFVFn Tn• Most recently reported: Note: This is Manor Care Health Services (Possibly a Nursing Home) 1700 MARKET ST RM 164, CAMP HILL PA 17011-4817, CUMBERLAND COUNTY (May 2011- Mar 2012) or 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY (Jan 1960 -Apr 2012) Name Associated with Address: JEANNETTE M REISCH Current Residents at Address: JEANNETTE M REISCH 3. DIRECTORY ASSISTANCE wHITF aerGC enin nruro nni 1 I~IC TGI cnul~~ir nri^~nr~r Phones Plusls): Phones Plus 1 Name: REISCH, JEANNETTE Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503 Phone Number: 717-737-6809 -EDT Carrier: VERIZON PENNSYLVANIA - (HARRISBURG , PA ) Phones Plus 2 Name: REISCH, JEANNETTE Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503 Phone Number: 717-737-7454 -EDT Carrier: VERIZON PENNSYLVANIA - (HARRISBURG , PA ) Phones Plus 3 Name: REISCH, JEANNETTE Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503 Phone Number: 717-737-8395 -EDT Carrier: VERIZON PENNSYLVANIA - (HARRISBURG , PA ) 4. ADDRESS HISTORY SEARCH Address Summary: '/721 WALTON ST, LEMOYNE PA 17043-2035, CUMBERLAND COUNTY 1700 MARKET ST RM 164, CAMP HILL PA 17011-4817, CUMBERLAND COUNTY (May 2011- Mar 2012} 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY (Jan 1960 -Apr 2012) 1514 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY (Feb 1994) 210 SENATE AVE APT, CAMP HILL PA 17011-2312, CUMBERLAND COUNTY (Nov 1979 -Dec 1992) 1010 CARLISLE RD, CAMP HILL PA 17011-6210, CUMBERLAND COUNTY (Nov 1987) 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: Property: Parcel Number - 13-23-0547-297 Book-19P Page - 298 Name Owner :REISCH, JOHN E & JEANNETTE M Property Address: - 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY Owner Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY Land Usage -SINGLE FAMILY RESIDENTIAL Assessed Value - $182,900 Land Size - 8712 SF Year Built -1949 Data Source - B Property: Parcel Number - 23-0547-0297-0000000-13 Name Owner :REISCH JOHN E Name Owner 2: REISCH JEANNETTE M Property Address: - 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY Owner Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503, CUMBERLAND COUNTY Total Market Value - $182,900 Assessed Value - $182,900 Land Value - $37,700 Improvement Value - $145,200 Land Size - 8,712 Square Feet Year Built -1949 Data Source - A 6. UNIFORM COMMERCIAL CODE FILINGS NO RECORD FOUND 7. FEDERAL BANKRUPTCY COURT NO RECORD FOUND 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS Liens and Judgments: > Filing Number: 20042605 Filing Type: FEDERAL TAX LIEN Location: CUMBERLAND CNTY PROTHONOTARY State: PA Original Filing Date: 4/27/2009 Amount: $13,638 Debtor Name: REISCH, JEANETTE M Debtor Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503 Creditor: INTERNAL REVENUE SERVICE Filing Number: 200801089 Filing Type: CIVIL JUDGMENT Location: CUMBERLAND CNN PROTHONOTARY State: PA Original Filing Date: 4/14/2008 Amount: $3,289 Debtor Name: REISCH, JEANNETTE M Debtor Address: 1510 CARLISLE RD, CAMP HILL PA 17011-7503 Creditor: CAPITAL ONE BANK 13 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS -PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND PROFESSIONAL LICENSES (NATIONWIDE) NO RECORD FOUND 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATIONWIDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16. CORPORATIONS AND BUSINESS' AND POSSIBLE EMPLOYERS NO RECORD FOUND 1 17. OTHER INFORMATION NO RECORD FOUND 3) 1 DECLARE THAT THE FOREGOING IS TRUE AND CORRECT. May 22nd, 2012 SIGNATURE: ~-- SWORN TO AND SUBSCRIBED BEFORE ME THIS ,. 22nd Day of May, 2012 . ' COMirr0lI11N6N]N OF PEIr~IBYLYANW NOTARY PUBLIC T PAT~CIA TAf~tii, NOTIINY PUBLIC CITYOFPIHIADEI.PFNA, P~HP~COUNTY Mfr OO~IbN3910N EXPIRES,lUNE tS, 2012 EX~11Ult "C" RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LA W Richard M. 3quire* Montgomery County Office M. Troy Freedman Craig a. Oppenheimer One Jenkintown Station * Also admitted in MD 115 West Avenue, Suite 104 Jenkiintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www. sg u irelaw. com Chester Gounty Otflce 33 South Brlck Lane Elverson, PA 19520 Tel.: (810) 913-8442 Fax: (810)913-8381 Please reply to: Montgomery County Office Postmaster Lemoyne, PA 17043 Dear Madam or Sir: May 23, 2012 Request for Change of Addressor Boxholder information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Jeannette M. Reisch Address: 721 Walton Street. Camp Hili. PA 17011 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: OneMain Financial, Inc., a Delaware Corporation v. Jeannette M. Reisch CMI-859F CFNA/LC r 4. The court in which the case has been or will be heard: Cumberland County Court of Common Pleas Pennsylvania 5. The docket or other identifying number if one has been issued: 12-2058 civil 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC e By: Richard r , -FOR POST OFFICE USE ONLY V No change of address order on file. NEW ADDRESS or BOXHOLDER'S Not known at address given. NAME and STREET ADDRESS ~~ ~~, Moved, left no forwarding address. No such address. CMI-859F CFNA/LC e RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard M. Squire* A'Iontgomery Coun Office cheater county office M. Troy Freedman ~ 33 South Brick Lane '" Also admitted in MD One Jenkntown Station Elverson, PA 19824 115 West Avenue, Suite 104 7e1.: (810) 913.8442 Fax: (610) 913-8381 Jenkintown, PA 19046 Tei.: (215) 886-8790 Fax: (215) 886-8791 www.s uirelaw.com Ptease reply to: Montgomery County Office Postmaster Camp Hill, PA 17011 May 14, 2012 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Dear Madam or Sir: Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Jeannette M. Reisch Address: 1510 Car{isle Road. Camp Hiil. PA 17011 Note: The name .and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The fallowing information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.444 and b. 1. Capacity of requester (e.g., process server,. attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: OneMain Financial. Inc., a Delaware Corporation v. Jeannette M. R~isch 4. The court in which the case has been or will be heard: Cumberland County Court of Common Pleas Pennsylvania 5. The docket or other identifying number if one has been issued: 12-2508 civil 6. The capacity in which this individual is to be served {e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC r By: Richard M. Squire, Esqu' FOR POST OFFICE USE ONLY No change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK Not known at address given. NAME and STREET ADDRESS Moved, left no forwarding address. No such address. Exhibit "D" f ~ ~ S O N N ' ~ t0 OD J Of N A W N --~ ~ CD "' n `n n a ~ ~' ~ ~°' Z o `~~ : ~ nzo-oc~ OO~m nzo-oc~ 00~m nzo~n 00~n °~°- ~ ~ ~ Q ~ D ~ ~~ D am (n ~ ~ cn~~~ cnD~,e ~ - m o c ~ ~ ~ o -r1~cn ~ ~~N ~0 o -r-1~cn ~0 D ~ o . D~ ~ -• J ~ ~ ~ v, ~ v, ~ T ~ ~ c ~ (D N O ~ Z O ~ Z O ~ ~ O N '~ O fn ~ N m o m o ~ o~ ~, rn S. D ~ ~ ~ ~ ~ m ~' m ~o o ~?. A N (p O (D j O N (r (D ~ s N CD N (D ~ 0 ~ ~ C O D ~ N C O ~ ( 300 3 +(7 CD y ~ (D ~ ~ ' ~ O CD _ ~ =QN Q~ N ~O ~ `~ D cn ~ D m ~ ~ o ~ -~, rp O O _ '~ ZI N ~ ` ,-. D Q ~Q O~ (D V ° ~ ~ O N oaf ~ fD D~ - ~N ~; O ~ W 0' ~ ~ ~ ~ 3 W N COD COIi V ~ ~ N G N CT N G N ~ ~ 1 N N O1 7 Q ~ Q ~ ^ ~ ^ ~ ^ ~ ~ CD N v ITI (~ C7 j Z7 X (D ~ O D ~ ~~c~ ~ N y ~ CD N d. ~ C ~ O /~ Q ~ m ~ ~~ a' ~ ~' ~ m ~ ~~ ~ m ~. --- CD ~ 3 ~ S ~ I N Q ~ 3 Cp I ~~ ~ I ~ N N 03 3 N ~ .C. O d . O ~ -. ~ . ~ N ~ cpn n m x. ~ x. ~ ~ ~. 1 N . ~ m>> ~^ ~_ N ~ C 0 - y ~ w ~ `~ 3. n 3 2 n ~ CD ~ G f~/1 p7 1 o idao ad C 0 p ~ m m N p < fD , ' ., (7 N `~ N `G d O N m m - ~ 0 0' vi p' C 7 O LS C " ~g~.~~~ off c O ~ ~ 0 ~ C-„ / m ~ X ~ O C m`y'~2ma ~1~ 0 D m a O O X i ~d d t o n ~ 3-~Dmn O C O ~' =' N cap 'fl f/1 O' 2 m ~~~cN N ~ n'O 7 ~ 0 a 0 j 01 .p \'~ m ~~ m n ~ 11 ~ ~38343Z02 ~ ~ m O S 3~ 3 Om y 4 o n° m 3 ~ ~ ~ ~ ° m ov ~~ ~~ ~ ~ ~ U1 n m Ny ooym _ O(flOai OUI - 'U ~ ~O~ 1 ~ N v ~Omdy CP j ~ ~ 7 N ~Zyi~om r ~N .~ n 1O' ;;.~ oonD g p ?'n rnrnv m ~3 33 3 lo i . o ~3a ~ to ~ ~ 3 ' fD N ~ m ~ 7 (O Gi jr TO: Jeannette M. Reisch 721 Walton Street Lemonye, P.A 17043 SENDER: REFERENCE: co PS Forht~BfJb ,latt oo~ 0 4 0 131r 0 7 4 21 RETURN Postage ', RECEIPT SERVICE Certified Fee 1.70 Return Receipt Fee 2.9$ ' Restricted Delivery 1.1$ Total Postage 8 Fees USPS• POSTMARK OR DATE Receipt for Certified Mail'" i No Insurance Coverage Provided ' Do Not Use for international Mail ", ,,,, y TO: Jeannette M. Reisch 1$10 Carlisle Road Camp Hill, PA 1701 l TO: Jeannette M. reisch 1100 Grando Way, Rm $$5 Mechanicsburg, PA 170$$ SENDER: REFERENCE: co 040 ],310 7346 RETURN Postage RECEIPT SER Certified Fee 1.70 VICE Retum Receipt Fee 2.9$ Restricted Delivery 1.1$ Total Postage & Fees 0 . 00 E USPS~ 55 R POSTMARK Of{SATE ~ Receipt for Certified Mail'" Nolnsurance Coverage Provided Do Not Use for International Mail SENDER: i REFERENCE: co PSFor~ Ja`~ 0040 1310 7391 RETURN FostaoF ' RECEIPT SERVICE Certified Fee 1.70 Return Receipt Fee 2.9$ Restricted Delivery 1.1$ Total Postage & Fees 0,. 0 0 i USPS~ nn g R POSTMARK OFi"DATE Receipt for Certified Mail'" f No Insurance Coverage f', vided ' Do Not Use for Inta1~~!~nonal Mail 1 RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LA W ~ Richard h1. S sire e Montgomery County Office Chester County Office M. Troy Freedman 33 South Brick Lane Craig a. Oppenheimer One Jenkintown Station Elverson, PA 19520 ' AIso.4dmittedinhlD 115 West Avenue, Suite 104 Tel.: (610) 913-8442 Fax: (610) 913-6381 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) $86-8791 www.sguirelaw.com Jeannette M. Reisch 1100 Grando Way, Rm 555 Mechanicsburg, PA 17055 Please reply to: Montgomery County Office November 13, 2012 RE: One Main Financial, Inc. v. Jeannette M. Reisch Docket No. 12-2508 Our File No. CMI-859 Dear Sir/Madam: The enclosed Motion for Alternative Service of Notice of Sheriff's Sale, Verification, BrieflMemorandum of Law, Certificate of Service, and proposed Order are being provided to you pursuant to the local rules of procedure. Please advise the undersigned in writing on or before November 20, 2012 via mail, facsimile, or electronic mail whether you concur to the relief sought in the enclosed Motion for Alternative Service of the Notice of Sheriff's Sale. If I do not receive any correspondence from you, we will forward a substantially similar version of the enclosed Motion/Petitionpaekage to the Court for filing on November 21, 2012. Thank you for your courtesies. Enclosures, as stated Very truly A+1 Troy Freedman, Esquire Ext. 12 tfreedmanna,squirelaw. com ~ RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW ~ Richard M. Squire * Chester Countv Office M. Troy Freedman Montgomery County Office 33 Soukh Brick k.ane Craig A. Oppenheimer One Jenkintown Station Elverson, PA 19520 ` Also .Ad[ni[ted in IKD 115 West Avenue, Suite 104 Tel.: (610) 913-8442 Fax: (610)913-6381 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com Please reply to: Montgomery County Office November 13, 2012 Jeannette M. Reisch 1510 Carlisle Road, Camp Hill, PA 17011 RE: One Main Financial, Inc. v. Jeannette M. Reisch Docket No. 12-2508 Our File No. CMI-859 Dear Sir/Madam: The enclosed Motion for Alternative Service of Notice of Sheriff s Sale, Verification, Brief/Memorandum of Law, Certificate of Service, and proposed Order are being provided to you pursuant to the local rules of procedure. Please advise the undersigned in writing on or before November 20, 2012 via mail, facsimile, or electronic mail whether you concur to the relief sought in the enclosed Motion for Alternative Service of the Notice of Sheriff s Sale. If I do not receive any correspondence from you, we will forward a substantially similar version of the enclosed Motion/Petition package to the Court for filing on November 21, 2012. Thank you for your courtesies. Very ~I. Troy Freedman, Esquire ,.-~ Ext. 12 tfreedman crsquirelaw.com Enclosures, as stated ~ RICHARD M. SQUIRE & ASSOCIATES, LLC • ATTORNEYSAT LAW Richard M. Squire * 1Vlontgomery County Office Chester County Office M. Troy Freedman 33 South Brick Lane Craig A. Oppenheimer One Jenkintown Station Elverson, PA 19520 ' Also Admitted in b~ 115 West Avenue, Suite 104 Tel.: (610) 913-8442 Fax: (810}913-6381 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791. www.squirelaw.com Please reply to: Montgomery County Office November 13, 2012 Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 RE: One Main Financial, Inc. v. Jeannette M. Reisch Docket No. 12-2508 Our File No. CMI-859 Dear Sir/Madam: The enclosed Motion for Alternative Service of Notice of Sheriff s Sale, Verification, Brief/Memorandum of Law, Certificate of Service, and proposed Order are being provided to you pursuant to the local rules of procedure. Please advise the undersigned in writing on or before November 20, 2012 via mail, facsimile, or electronic mail whether you concur to the relief sought in the enclosed Motion for Alternative Service of the Notice of Sheriff's Sale. If I do not receive any correspondence from you, we will forward a substantially similar version of the enclosed MotionlPetition package to the Court for filing on November 21, 2012. Thank you for your courtesies. Very trul o ~-Ni. "hroy Freedman, Esquire `~~ Ext. 12 tfreedman cr,squirelaw.com Enclosures, as stated ' Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware Corporation, PLAINTIFF, v. Jeannette M. Reisch 721 Walton Street Lemoyne, PA 17043, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 12-2508 civil I CIVIL ACTION ~ MORTGAGE FORECLOSURE ORDER GRANTING ALTERNATIVE SERVICE OF THE NOTICE OF SHERIFF'S SALE AND NOW, this .? 9 ~ day of /~~"~~`~` , 20 ~ Z, upon consideration of Plaintiff s Motion for Alternative Service of the Notice of Sheriff s Sale, and upon consideration of any answer or response thereto, and good cause showing; it is hereby ORDERED that Plaintiff may serve the Notice of Sheriffs Sale pursuant to Pa. R.C.P. 3129.2(a) upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to 1 S 10 Carlisle Road, Camp Hill, PA 17011, 721 Walton Street, Lemoyne, PA 17043 and 1100 Grando Way, Room, 555, Mechanicsburg, PA 17055-5303; and (2) posting a true and correct copy thereof on the mortgaged premises at 1510 Carlisle Road, Camp Hill, PA 17011 by any competent adult. Service of the aforementioned mailings is effective upon the date of mailing and is to be effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a Certificate of Service as to such mailings. r BY THE COUR`T': chard M. Squire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA LD.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire(~squirelaw.com tfreedman~squirelaw.com coppenheimer~a.squirelaw.com ~eannette M. Reisch 721 Walton Street Lemoyne, PA 17043 and 510 Carlisle Road, Camp Hill, PA 17011 and 1100 Grando Way, Room 555 Mechanicsburg, PA 17055 Co'~~ c..-s rn~~ ~~ /'2 0 ~ ~ t t .~'~ ~ J o"..) r -~ 3 ~ ._; ~ ~ z `''' ~ ~ ~ ~.. = '~`~' , c~ ~ ~~' ~-a ~: ~ +:_i -r, C j te- - (""y ~.1 .a ~ ~.... t~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff of 4aairt i" Ti Jody S Smith � Grr/,rrr� Chief Deputy `ry � ` 3 i�{ " . : Richard W Stewart CUMBERLAND CC,U1����,i j , Solicitor ���°�� �� PENNSYLVANIA Citifinancial Services Inc. Case Number vs. Jeannette M. Reisch 2012-2508 SHERIFF'S RETURN OF SERVICE 10/03/2012 01:46 PM -Deputy Noah Cline, 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 1510 Carlisle Road, Camp Hill, PA 17011, Cumberland County. 10/12/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jeannette M. Reisch, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found"at 721 Walton Street, Lemoyne, PA 17043, defendant is currently in a Nursing Home at 1100 Grando Way , Room 555 MECHANICSBURG, this facility does not grant access to patients, alternate address provided of: 1510 Carlisle Road, Camp Hill, PA 17011 is vacant. 12/03/2012 As directed by Richard M Squire,Attorney for the Plaintiff, Sheriff's Sale Continued to 1/9/2013 01/09/2013 As directed by Richard M Squire,Attorney for the Plaintiff, Sheriff's Sale Continued to 3/6/2013 03/07/2013 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, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Richard Squire, on behalf of Citifinancial Services, Inc., being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,093.80 SO ANSWERS,, April 30, 2013 RONIV R ANDERSON, SHERIFF 7Z$ AdIl, all Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D.Nos. 04267/ 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware IN THE COURT OF COMMON PLEAS Corporation CUMBERLAND, PENNSYLVANIA PLAINTIFF, NO. 12-2508 civil V. CIVIL ACTION Jeannette M. Reisch 721 Walton Street MORTGAGE FORECLOSURE Lemoyne, PA 17043 DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129.1 OneMain Financial,Inc.,a Delaware Corporation,Plaintiff in the above action,being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 1510 Carlisle Road, Camp Hill, PA 17011,Tax Parcel No:.13-23-0547-297. 1. Name and last known address of Owner(s) or Reputed Owner(s): Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 2. Name and last known address of Defendant(s) in the judgment: Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citifinancial Services, Inc. c/o CitiMortgage Inc 1000 Technology Drive O'Fallon, MO 63368-2240 Capital One Bank 1680 Capital One Drive McLean, VA 22102 F:\Clients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd 4. Name and address of last recorded holder of every mortgage of record: OneMain Financial, Inc., a Delaware Corporation 3401 Hartzdale Drive, Ste 126 Camp Hill, PA 17011 Citifinancial Services, Inc. c/o CitiMortgage Inc 1000 Technology Drive O'Fallon, MO 63368-2240 5. Name and address of every other person who has any record lien on the property: None other. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Domestic Relations Family Services Bldg. 13 North Hanover Street PO Box 320 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square - Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn : Legal Department Health& Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health& Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 FAClients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd 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: Tenant/Occupant 1510 Carlisle Road Camp Hill, PA 17011 VERIFICATION 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. §4904 relating to unswom falsification to authorities. Richard M. Squire & Associates,LLC By: Richard M. quire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: July 27, 2012 FAClients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267/ 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff OneMain Financial, Inc., a Delaware IN THE COURT OF COMMON PLEAS Corporation CUMBERLAND, PENNSYLVANIA PLAINTIFF, NO. 12-2508 civil V. CIVIL ACTION Jeannette M. Reisch 721 Walton Street MORTGAGE FORECLOSURE Lemoyne, PA 17043 DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeannette M. Reisch 721 Walton Street, Lemoyne, PA 17043 and/or 1510 Carlisle Road, Camp Hill, PA 17011 Your house (real estate) at 1510 Carlisle Road, Camp Hill, PA 17011 is scheduled to be sold at Cumberland County Sheriff Sale, on 12/5/2012 at 10:00 a.m., at the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,PA 17013 to enforce the court judgment of$142,517.98 plus interest to the sale date obtained by OneMain Financial, Inc., a Delaware Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay back to OneMain Financial, Inc., a Delaware Corporation,the amount of the judgment plus costs or the back payments,late charges,costs and reasonable attorneys' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, M. Troy Freedman, Esquire or Craig Oppenheimer, Esquire at (215) 886-8790. 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. FAClients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd 3: You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland Sheriff s Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 FAClients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northerly line of Carlisle Road, said point being the dividing line between Lots Nos. 34 and 35, Block "I" of the hereinafter mentioned Plan of Lots; thence in a Northerly direction along said dividing line one hundred fifty and eight tenths (150.8) feet to Lot No. 17, Block"I"; thence in an Easterly direction along said Lot No. 17, Block "I" fifty five (55) feet to Lot No. 33, Block "I"; thence in a Southerly direction along said Lot No. 35, Block"I"one hundred sixty one and nine tenths (161.9) feet to Carlisle Road; thence in a Westerly direction along said Carlisle Road fifty six and one tenth (56.1) feet to the place of BEGINNING.. HAVING THEREON ERECTED a single brick dwelling House No. 1510 Carlisle Road. BEING Lot No. 35, Block"I", on the revised Plan of Highland Park as recorded in the Cumberland County Recorder's Office in Plan Book 3, Page 96. TAX PARCEL NO. 13-23-0547-297 BEING the same premises which Harold E. Ring and Mary K. Ring granted and conveyed unto John E. Reisch and Jeannette M. Reisch, his wife by Deed dated January 14, 1960 and recorded January 15, 1960 in the Office of the Recorder of Deeds for Cumberland County,Pennsylvania as Deed Book 19-P,Page 298. AND THE SAID John E. Reisch having departed this life on March 7, 1991; title is thereby vested solely to Jeannette M. Reisch, by operation of law, as surviving tenant of the entireties. FAClients\Citi Mortgage\Reisch,Jeannette-859F\writ package 7-26-2012.wpd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2012-2508 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ONEMAIN FINANCIAL,INC. A DELAWARE CORPORATION Plaintiff(s) From JEANNETTE M. REISCH,721 WALTON STREET, LEMOYNE,PA 17043 (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $142,517.98 L.L.: $.50 Interest FROM 8/3/2012 to 12/5/2012 @$34.05 PER DIEM-$4,256.25 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $286.00 Other Costs: Plaintiff Paid: Date: 7/31/2012 David D. Buell,Prothonot (Seal) Deputy REQUESTING PARTY: Name: CRAIG OPPENHEIMER,ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES,LLC ONE JENKINTOWN STATION,SUITE 104 115 WEST AVENUE TRUE COPY FROM RECORD Whereof:t here unto set my hand JENKINTOWN,PA 19046 In Testimony ° and the seal of said Court at Carlisle,0 1� Attorney for: PLAINTIFF This day of—""� I pr onotary 1 Telephone: 215-886-8790 LJA�(0 Q. Supreme Court ID No.313264 On August 16, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 1510 Carlisle Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 16, 2012 By: (/,k i�aj-L-CL Real Estate Coordinator 8I :Z d I l'itl ZIOl CUMBERLAND LAW JOURNAL Writ No.2012-2508 Civil Term Cumberland County, Pennsylvania as Deed Book 1 9-P,Page 298. CITIFINANCIAL SERVICES INC. AND THE SAID John E. Reisch vs. having departed this life on March JEANNETTE M. REISCH 7, 1991;title is thereby vested solely Atty.: Richard M.Squire to Jeannette M.Reisch,by operation ALL THAT CERTAIN lot of land of law, as surviving tenant of the entireties. situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows,to wit: BEGINNING at a point on the Northerly line of Carlisle Road, said point being the dividing line between Lots Nos. 34 abd 35, Block "I" of the hereinafter mentioned Plan of Lots;thence in a Northerly direction along said dividing line one hundred fifty and eight tenths (150.8) feet to Lot No. 17, Block "I"; thence in an Easterly direction along said Lot No. 17,Block"I"fifty five(55)feet to Lot No.33,Block"I";thence in a South- erly direction along said Lot No. 35, Block"I"one hundred sixty one and nine tenths (161.9) feet to Carlisle Road;thence in a Westerly direction along said Carlisle Road fifty six and one tenth (56.1) feet to the place of BEGINNING.. HAVING THEREON ERECTED a single brick dwelling House No. 1510 Carlisle Road. BEING Lot No. 35, Block "I", on the revised Plan of Highland Park as recorded in the Cumberland County Recorder's Office in Plan Book 3, Page 96. TAX PARCEL NO. 13-23-0547- 297. BEING the same premises which Harold E. Ring and Mary K. Ring granted and conveyed unto John E. Reisch and Jeaimette M.Reisch,his wife by Deed dated January 14, 1960 and recorded January 15, 1960 in the Office of the Recorder of Deeds for 77 r PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r r s Coyne, itor SWORN TO AND SUBSCRIBED before me this 9 dgy of November, 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2414 i n 1N* c JUN AZZ 0iNC,"T Agen 10 toflftd Ntuate live of atagpoiatas to •1»o f�tw ."Zots being fLo te�nafter �d3S b dmrs/.,,, , to Lot YAnd e s�leOne Arky�adur,�n ,and feet h nditd - ��, Oe�n, fe atle'And Qde P-Osd;tl Aga 61. • �AIly Stty uA0. h�435 e of ap ice �Co r,ka,.ss_ C, 13g'"�'�+ers la• ZZ andandw1 Jea����unfoJo���tedX�O�f MIt._,� 8 . January Y14~19 60 We by and 4r , 5y�*adz County l$ for Of the AND s8 I1ae�`ft19. ise!�rted U&,of�E.Reiss P vog � *aw �M mv�' The Patriot-News Co. M e a rlo ews 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 Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. UBLICATION COPY This ad ran on the date(s)shown below: 10/26/12 11/02/12 11/09/12 Sworn a d s bscribed be re a s 1 da f November, 2012 A.D. i r' otary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L.Owens,Notary Public Lower Paxton Twp.,Dauphin County My Commission Expires Nov.26,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citifinancial Services Inc. is the grantee the same having been sold to said grantee on the 6th day of March A.D.,2013,under and by virtue of a writ Execution issued on the 31 st day of Jam, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2508, at the suit of OneMain Financial Inc. against Jeannette M. Reisch is duly recorded as Instrument Number 201314825. IN TESTIMONY WHEREOF, I have ereunto set my hand and seal of said office this day of A.D. c� © U �zj corder of Deeds t corder of D Cur+�berland County,Carlisle,PA q corrin,ission Expires the First Monday of Jan,2014