Loading...
HomeMy WebLinkAbout12-2933UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE- ID#308367 KASSIA FIALKOFF, ESQUIRE - #310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadinas(&udren.com PNC Bank, National Association C/O PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff V. DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF ' o . a COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. toy- a`? 3 COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 3.?1S?x1 a ?u aQUI 5ooy +a-7 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com PNC Bank, National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County DANA M. MALLORY MORTGAGE FORECLOSURE Defendant(s) I r°� NO. 12-2933-CIVIL PRAECIPE TO ISSUE WRIT OF EXECUTION vi'- =rT. crt - "O• .. y F, TO THE PROTHONOTARY: W- ■ • CD - d Issue Writ of Execution in the above matter: AC , Amount due $ 134,112.13 Interest From 8/29/2012 $ 10,476.14 to Date of Sale March 5,2014 Ongoing Per Diem of$18.91 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN L• : - ' ' BY: • - • -r for Plaintiff David Neeren, Esquire &MJU#: 12040077 CASE#: 12040077-1 PA nt if 204252 Lig ov C4P . DO << Lt (< « So ai8.gs Pi a - 9610(4S7 ,�� J75QJ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin's udren.com PNC Bank,National Association COURT OF COMMON PLEAS rar`p n Plaintiff CIVIL DIVISION 2 ca , V. Cumberland County ..cy C"C3 yr DANA M. MALLORY MORTGAGE FORECLOSURE `' ° © CQ Defendant(s) NO. 12-2933-CIVIL CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: f l Act 91 procedures have been fulfilled Premises is not subject to the provisions of Act 91 This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UD' - • - , P.C. BY• ey for Plain ' f n Esquire David Ne r , PAID 104252 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 gleadings(a udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County c o r DANA M. MALLORY " z. Defendant(s) MORTGAGE FORECLOSURE NO 12-2933-CIVIL 7 c f5) AFFIDAVIT PURSUANT TO RULE 3129.1 m AND RULE 76 PNC Bank,National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance Dept. 280946 Harrisburg, PA 17128 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue Mechanicsburg, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Mortgage Holders - None A 5. Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders -None Condo/Homeowners Association -None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: I V MI I t J UD W • - ' •.C. BY: At :: for Plaintif' Davi . Neeren, Esc 1 -- MJU#: 12040077 CASE#: 12040077-1 PA ID 204252 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. Cumberland County DANA M. MALLORY MORTGAGE FORECLOSURE " Defendant(s) rn° ° Tr NO. 12-2933-CIVIL {-- �. c.n NOTICE OF SHERIFF'S SALE OF REAL PROPERTY <© - c ° TO: DANA M. MALLORY 221 S MARKET ST — MECHANICSBURG, PA 17055 Your house (real estate) at 221 South Market Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on March 5,2014 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$134,112.13, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) t 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 Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2933 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION Plaintiff(s) From DANA M. MALLORY (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: $134,112.13 L.L.: Interest FROM 8/29/2012 TO DATE OF SALE MARCH 5,2014-ONGOING PER DIEM OF$18.91 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$10,476.14 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,218.45 Other Costs: Plaintiff Paid: Date: 10/16/13 , . • David D.B -II, Prothonota - (Seal) g Deputy REQUESTING PARTY: Name: DAVID NEEREN, ESQUIRE Address: UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 586-669-5400 Supreme Court ID No. 204252 LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted 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 demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is PNC Bank, National Association. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments oil' Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiffs favor: Assignor: N/A Assignee: N/A Date of Assignment: N/A Recorded Date: N/A Book/Instrument #: N/A Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Dana M. Mallory (hereinafter "Defendants"), are the owners of property located at 221 South Market Street, Mechanicsburg, PA 17055, by virtue of Deed dated 06/20/2003 and recorded 06/24/2003 in Official Records Book 257 at Page 3681 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property") 3. On 06/20/2003, Defendant(s) and/or their predecessor: DANA M. MALLORY promised to pay to the order of National City Mortgage Co., the principal sum of $144,500.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/20/2003, Defendant(s) and/or their predecessor: DANA M. MALLORY to secure the Note, mortgaged to National City Mortgage Co., the Property which is the subject of this action. The Mortgage was recorded on 06/24/2003 in Official Records Book 1818 at Page 3825. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. Said mortgage is in default in that the payment due 08/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $125,480.18 Accumulated Interest $5,213.90 Accumulated Late Charges $369.18 NSF Charges $64.00 Grand Total $131,127.26 The above figures are calculated as of 04/03/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 5.50000 %. The per diem interest accruing on this debt is $18.91 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $41.02. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. .Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $131,1.27.26 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. SS, ESQ. # 308369 # 13862010 VERIFICATION Jacqueline Sapitro I, - as an Authorized Signer _ of the Plaintiff, PNC Bank, National Association, do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: (r \a U ?E ZUI Z ?f Jacqueline Sapitro Nam Title: Authorized Signer Company: PNC Bank, National Association MJU #: 12040077 CASE #: 12040077-1 04-04-'12 16:14 FROM-Premier Abstracts "Exhibit All 8005456/63 T-67 P0011/0015 F-883 ALL THAT CERTAIN lot of ground with the buildings thereon erected, situate on the northeast corner of Market and Keller streets in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a post on the corner of said Market and Keller Streets; thence northward by Market Street 35 feet to a corner of lot now or formerly of Samuel Mumma; thence by said lot eastward 130 feet, more or less, to Brandt Alley; thence by said Alley southward 43 feet to corner of said Alley and Keller Street; thence westward by said Keller Street 130 feet more or less, to the place of BEGINNING. HAVING THEREON ERECTED a brick dwelling house known and numbered 221 south Market Street, Mechanicsburg, Pennsylvania. UNDER AND SUBJECT to all easements, reservations, restrictions and rights-of-way of record, including a right-of-way to Mechanicsburg Water Company. BSING THS SAME PREMISES which Richard D. Adams, widower, by his deed dated June 20, 2003 and recorded in the office of the Recorder of Deeds in and for Cumberland County granted and conveyed unto Dana M. Mallory, single person. I Certify this to be recollic"ci In Cumberland /y( ;ou lltYr(,y?_A i g Corder of Dee&- 8K 18 1 BPG3839 REPRESENTATION OF PRINTED DOCUMENT PNC Attention: Collection Department Q (B6-YM07-01-5) 3232 MORTGAGEW M iami sb g aOHD45342 9-749-72241-000043"01-01.000-0004)00-000 DANA M MALLORY 221 S MARKET ST MECHANICSBURG PA 17055-6327 7107 8381 6540 2128 3837 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE EXHIBIT A PA001 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT February 23, 2012 Re: Loan No. 0002400162 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 221 S Market St Mechanicsburg PA 17055, IS IN SERIOUS DEFAULT because you have not made the monthlypayments of $8,288.04 for the months of August 1, 2011 and February 1, 2012. Late charges and other charges have also accrued to this date in the amount of $446.16. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $8,734.20. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $8,734.20, plus any additional monthly payments and late charge which may fall due during this period Such payment must be made either by cash, cashier's check, certified check or money order, and made at PNC Mortgage/Collections Center, Mail Code B6-YM09-01-01, 3232 Newmark Drive, Miamisburg, OH 45342. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed vour mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have. begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may, do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately nine - ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-523-8654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. We do encourage you to contact a HUD-approved counseling agency for financial counseling. To locate an agency near you, please visit www.hud.gov or call 1-800-569-4287. This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. INTERNET REPRINT 9 p?L hinli,l ?y?vnc\\ P15Sc?L?afiOn Plaintiff(s) VS. ` Defendant(s) FORM I nWt r IN THE. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLtiAf$A > rc ty -aI33Civil r_, , CD -71 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 opportunivy to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an opportunity to meet with a representative of your lender in all attempt to work out reasonable air angernents 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. q11 I ) I 2.. Date re of Cdlunsel for Plaintiff) AMY-GLASS, ESQ. PA BAR # 30836"r NA BAR P 1386201i' 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: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email.: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: Type of Loan: State:_ Zip: Yes ? No ? Listing date: Price: $_ Realtor Phone:_ Yes ? No ? Home: Cell: How long? State: Zip: Office: _ Other: Home: Cell: Office: Other: State: Zip: How- long? Loan Number: _ Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: _ Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: 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: S $ Retirement Funds: $ $ Investments: $ $ Checking: S Savings: $ $ Other.: $ $ Automobile #1: Model: Amount owed: _ Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Year: Year: Monthly Income Name of Employers: 1. Additional Income Description (not wages): I monthly amount: 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" Mortgage Utilities Car Payment(s) Cundo/Nei h. Fees Auto Insurance Med. (not covered) Auto fuel/re airs Other prop. payment Install. Loan Pa ment Cable TV Child Su ort/Alim. Spending Money Da /Child Care/Tuft. 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.- I? 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 F-1 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): Servicing Company (Name): Contact: Phone: Phone: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no 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: of Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 1( Copy of a current utility bill 11 Letter explaining reason for delinquency and any supporting documentation J (hardship letter) ?1 Listing agreement (if property is currently on the market) FORM 3 PNC. dean k ? I?k;,h G nc+ ? ?sac;c??-a ?n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY.. PENNSYLVANIA Plaintiff(s) vs. ?GI?10. M • ma????? Defendant(s) civil, REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland Countv 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 Mort gage 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 Legal Representative Signature of Defendant Signature of Defendant Date Date Date 1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIIl`? f 10, A 10, 1 BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 M DR L D C 0 U14 >( LORRAINE DOYLE, ESQUIRE - ID #34576 E N N S YVAN I A ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE- ID#308367 KASSIA FIALKOFF, ESQUIRE - #310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings a udren.com PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 1 a-?Q 33 ??? I ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire on behalf of the Plaintiff, in the above-captioned matter. W PFFICES, P.C. BY MY G ASS, ESQ. B # 308367 NJ BAR 0 13862010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 'z", 00 r12A 30 A 52 4 pj 'YLVAM A PNC Bank, NA Case Number vs. 2012-2933 Dana Michelle Mallory SHERIFF'S RETURN OF SERVICE 05/23/2012 07:04 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 23, 2012 at 1904 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Dana Michelle Mallory, by making known unto herself personally, at 221 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.00 May 25, 2012 - - - - -,- --- v-, -; Z'? DE IS FRY, DEP SO ANSWERS, RON R ANDERSON, SHERIFF Ccu ; ?.kr Sh E Te:!?a??4t lnc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-2933 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s) From DANA M. MALLORY (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: $134,112.13 L. L.: $.50 Interest FROM 8/29/2012 TO DATE OF SALE DECEMBER 5, 2012 - ONGOING PER DIEM OF $18.91 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $1,872.09 Atty's Comm: % Due Prothy: $2.25 Atty }paid: $199.25 Other Costs: Plaintiff Paid: Date: 8/30/2012 r'ti , -"\ n David D. Buell, Prothonotary, (Seal) B : Deputy REQUESTING PARTY: Name: KATHERINE E. KNOWLTON, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 311713 UDREN LAW OFFICES, P.C. WOODCREST' CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association 3232 Newmark Drive Miamisburg, I OH 45342 Plaintiff DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF a COURT OF COMMON PLEAS CIVIL DIVISION = ` Cumberland County MORTGAGE FORECLOSURE !Zo x• zo c NO. 12-2933-CIVIL p 2 C-r 03 f' PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROT140NOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), DANA M. MALLORY; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $125,480.18 Interest Per Complaint $5,213.90 Additional Interest 04/04/2012 08/28/2012 $2,779.77 Late Charges Per Complaint $369.18 Additional Late Charges 04/04/2012 08/28/2012 $205.10 NSF Charges $64.00 Grand!Total $134,112.13 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW_QFFICES, P.C. ft ` _ BY: Attorney for Plainti Esq DAMAGES ARE rRfBY ASSESSED AS INDICATED P i DATE: P ROTHY MJU#: 120400717 CASE#: 12040077-1 A.A 1,14.* 4? CL4 35o? ? g)ka800 13 c,hce' (110M_ UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART? WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M MINATO, ESQUIRE - ID #75860 SHERRI',J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY . REESE, ESQUIRE - ID#310501 AMY GW , ESQUIRE- ID#308367 KASSIA FIALKOFF, ESQUIRE - #310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODC ST CORPORATE CENTER IIt WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-660400 pleadinaskudren.com PNC Bank, National Association C/O PNC Bank, N.A. 3232 Newmark Drive Miamisourg, OH 45342 Plaintiff V. DANA MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF 4g, f COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County ta-??33 O'V(? NO. COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20). days after this Complaint and Notice are served, by entering, a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Cojurt without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE All LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYE IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAYO R LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.' 7*t (?fju6)077 -' l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriffs at L"?caabt?l?? crtti? Jody S Smith -s Chief Deputy =? Richard W Stewart Solicitor O"ICE OF THE SKEF(IFF PNC Bank, NA vs. Dana Michelle Mallory Case Number 2012-2933 SHERIFF'S RETURN OF SERVICE 05/2312012 07:04 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 23, 2012 !,at 1904 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Resioentiai Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Dana Michelle Mallory, by making known unto herself personally, at 221 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. DE IS FRY, DEP SHERIFF COST: $48.00 SO ANSWERS, May 25, 2012 RON R ANDERSON, SHERIFF ci GountyStAte Shen t. reieosott hr. 1 -) n I I& h -1 -1 1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association P1abitiff V. DANA M. MALLORY Defendant(s) TO: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Date of Notice: August 14, 2012 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12-2933-CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN'TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IFI YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRMA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERM,[NO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD PE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SEN ENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIAT NTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL S RVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION E ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PU SUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT Al DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. BY: Attorney for Plaintiff Katherine E. Knowlton, E" PA ID 311713 Wooderest Corporate Center I I I Wooderest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 12040077 CASE#: 1.2040077-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOOD CREST ROAD, SUITE 200 CHERRY', HILL, NJ 08003-3620 PNC Bank, National Association Plaintiff V. Dana M. Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12-2933-CIVEL AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), DANA M. MALLORY, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Attorney for Plaintiff Katherlne E. Knowlton, Esq PA ID 311713 MJU#: 12040077 CASE#: 12040077-1 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: MALLORY First Name: D6NA Middle Name: Active Duty Status As Of: Aug-28-2012 Results as of : Aug-28-2012 11:13:31 SCRA 2.3 On Aclil" Duty On Active Duty Shun Date Active Duty tart Dale AGive Duty End OEM status Ser Acs Cornponent NA'. NA No NA This response reflects the individuals' active duly status based on the Active Duty Status Date I Lett Active Duty Within 387 Drys of Active Duty Status Date Active Duty tart Data Active Duty End Date status Service Cornponent NA'. NA No NA This response reflects where the individual left active duty status wtftn 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a Futum C"p to Active Duty on Active Duty StAs Date Order No n Start Date Order Notification End Date status service component NA'. NA No NA This response reflects whether the Individual or Maher unit has received early nofification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Y)bj )4. LA AIJ. 7-W - Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drlive, 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 known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status 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 left Active 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 active 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 periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun activel duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: UABQGCIRS8 UDREN AW OFFICES, P.C. WOODC ST CORPORATE CENTER 111 WO DCREST ROAD, SUITE 200 CHERR HILL, NJ 08003-3620 PNC Bank, National Association Plaintiff V. Dana M? Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS `. CIVIL DIVISION = -- -- Cumberland County r z= c7 MORTGAGE FORECLOSURE c"> o ? cy NO. 12-2933-CIVIL E5 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 8/29/2012 to Date of Sale December 5. 2012 Ongoing Per Diem of $18.91 to actual date of sale including if sale is held at a later date (Costs to be added) $134,112.13 $ 1,872.09 UDREN LAW OFFICES, P.C. B _ Attorney for Plaintiff Katherine E. Knowlton, Esa PA ID 311713 ?MJ'U#: 12040077 CASE#: 12040077-1 10 Kc . So ' „ 'g.-Soya ? ? a/ S jje `?' ?,a ,j, So t-L- Co P?o?g bbj f Wdj ()? I2? ,sAjed UDREN LAW OFFICES, P.C. ' C T ; N'0 TATIrORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTEI? 12 AUG 30 AM I I. 01 111 WOCIDCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 CUMBERLAND COUNTY 856-669-51400 PEPLANSYLVANIA, pleadings@udren.com PNC Bank, National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Dana M Mallory MORTGAGE FORECLOSURE Defendant(s) ' NO. 12-2933-CIVIL CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: M Act 91 procedures have been fulfilled n Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 UbREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff V. Dana M. Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS 4-, CIVIL DIVISION zFer r-Zi 7-- Fz° -K- Cumberland County = 0 ? -?? r` c.a MORTGAGE FORECLOSURE © , L, =C) NO. 12-2933-CIVIL o AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren' Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance Dept. 280946 Harrisburg, PA' 17128 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Dwight Foster; r'oster's Automotive Inc. 117 East Strawberry Avenue Mechanicsburg; PA 17055 4.'Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr Hen Holders -'None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland Colanty Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17113 Commonwealth] of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA' 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburgti PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unswom falsification to authorities. DATED: MJU#: 12040077 CASE#: 12040077-1 UDREN LAW OFFICES, P.C. BY: ----- - Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF PNC Bank, National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V, Cumberland County DANA M. MALLORY MORTGAGE FORECLOSURE Defendant(s) NO. 12-2933-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dana M. Mallory 2?1 South Market Street Mechanicsburg, PA 17055 .? ca P, C) za c ?? zm w CD C? Your house (real estate) at 221 South Market Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on December 5, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $134.112.13, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE --a ct-r O? r x? To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) Y( RI Y 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property aslif the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state Who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF PNC Bank, National Association Plaintiff V. DANA M. MALLORY; ET AL Defendant(s) COURT OF COMMON PLEAS '' CIVIL DIVISION ~I CUMBERLAND County N0. 12-2933-CIVIL ~.~ -g., .: ('~l rl ,~ ~ ~.t ), °.~ Mr,1 ~.,.,,,7 -~ ~-; ~n:~ ;..F= :~~ C_.~, i;C:;:3 4~ w ,`'`'M ~~ ~~~,5 ~°~ ~ __,. ~~~ ~Tyl i E... ~} . ,. ~:_> - w c:J ~~ , MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant(s): DANA M. MALLORY, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: DANA M. MALLORY 221 SOUTH MARKET STREET, MECHANICSBURG, PA 17055 A copy of the Return of Service is attached hereto as Exhibit "A". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "B". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. Plaintiff conducted a postal search which did not reveal any new addresses or information. A copy of the postal search is attached as Exhibit "C". 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. 6. No other issue has been ruled upon in this same or related matter. 7. Defendants are not represented by counsel and concurrence is not needed. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C.1 _.~ ` ) ~ ~,' BY:~~ Attorneys PA.> . ,,, ESQUIRc rH lu .,15091 PNC Baak National Association. et. al„ Plaintiff(s) ' vs. Dana M. Mallory, et. al„ Defendant(s) -~ .-- I UDREN LAW OFFICES Ms. Danielle Devlin i 111 Woodcrest Rd„ Ste. 200 Cherry Hill. NJ 08003-3620 Service of Process by /--~~~~ APS International, Ltd. AFFIDAVIT OF DUE AND DILIGENT ATTEMPT -^ I Servi« of Process on: -Dana M. Mallory Court Case No. Cumberland Co 12-2933-Civil i i C Comer File: N12040077-1 - _ I •- - - - -• - - - - - - - State of: ~ L ~( ~I ~ . ~ ~ - - - - - •- - - - - •- - - - County of• 1 Name of Server: (~ hrr~~-i~M 1~„~y~( .undersigned, being duly sworn, deposes and says that at all times mentioned herein, s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice oiSberiffs Sale of Real Propert}' Service of Process an: The undersigned attempted to serve the documents on Dana M. Mallory and after due and diligent efforts, was unable to effect service. Attempts: The following is a list of the attempts made to effect service: Dates/l'ime/Address Attempted: n~ t South Market S,rtr~cet, hlechanicsburg, PA 17055 Rcason for NonSenice: `t ~' ~ °~ 1 ~',~v ~ K ~ .~ n t t.JE r DoteslrimdAddress Attempted: Al all '~ G'dS ~t1 Reason for Non-Senicr. ~/IV / .'~+' ~'-~~-~'~r Dates rime/Address Attempted: q/i~.l ^ 4''^i ~ N Reason for Von•Servier. .110 ~FY7Si,r6r - -- [- Based upon the above stated facts, Affiant believes the defendan~is avoidin~aer~ice. Signature otServer: Undersigned declares under penalty of perjury S d that the foregoing is true nd cornea. ~ y of Signature of Server APS Intemationai, Ltd. coMMOnivuFU~l~ vawu tiobrlal seal M. MititeNe C,tryton, Notary HtbBc Carlisle Ooro, C:anberland tAUnty MY Cort:rrYSSlon ExpNes 9, 2016 rsErteEa, vertasvtvnrtta AssoCU7[oa of tttn•Aatts _ 1-800-328-7171 APS International Plaza - '~ 7800 Glenroy Rtud Minneapolis. MN 55439-3122 APS Fik q: 118999-0081 this ires) EXHIBIT A T,N THE ' COiJRT OF COA3ARON PLEAS OF CUMBERLAND CO . , PENNSYLVA~TF PNC BANK, N . A. -- - ,Plaintiff{s} DANA N~,LLORY, ET AL ,Defendant{s) - agrainst - AFFIDAVIT OF DUE DILIGENT INQUIRY Docket No. I, THE UIv'DERSIGNED AM AA'D WAS OA? THE DATES IIEREIi~Y MENTIONED, OVER THE AGE OF EIGHTEEN YEARS AND NCT A PARTY TO THE ACTION, ATTEMPTED TC LOCATE TIE FOLLOI~~ING rr^OR SERVICE OF PROCESS: CERT. OF DILIGEN" INQUIRY FOR CURRENT ADDRESS. AND THP.T AFTER DUE AND DILIGENT SEARCH AND INQUIRY AT THE RESIDENCE: 221 SOUTH MA_R.KET STREET A2ECHANICSBURG PA 17C55 ALTERNATE ADDRESS: UNKNOWZI? I HAVE ATTEMPTED TO LOCATE THE FOLLOWING NAMED: DANA M. MALLORY THE FOLLOWING INFORMATION IS CURRENTLY AVAILABLY PER PERMISSIBLE INQUIRY: 20116j12 CERT. OF DILIGENT INQUIRY BEING PRGCESSED. 1p116j12 DILIGENT INQUIRY INDICATES AS FOLLOWS:-- S5#: ~XX-XX-Y>986 NAME : DAIV~A M . MALLORY ADD: 2Zi SOUTH MARKET STREET MECHANICSBURG, PA 17Q55-6327 DOB: 04jC9/1969 TELE #: NU LISTING FOUND UNDER THE LAST NAME MALLORY AT 221 SOUTH MARKET STREET, MECHANICSBURG, PA 10,f26j12 PA VOTER REGISTRATION INQUIRY IIvTDICATES THAT DANA M. MALLORY hTITH DOB 441`09/1969 IS A REGISTERED VOTER IN CUMBERLAND COUNTY, PA. 10,f16112 THE ABOVE IS T?iE MOST CURRENT INFORMATION ON FILE FOR. THIS SUBJECT AT THIS TIME. .~f,` •. , ., SEARCHER: LOUIS CIFELLI Continued on next~~gq ~T ~ T~ DGR - The Source Por Legal Support X ~ 1 1 "~?59 Littleton Road, Morris Plains, NJ C7950-30CC File ~ 120HC07?-1 (973; 4C3-17CC Far (0731 40?~-9222 Work Order ~ 90'_924 IN THE' CCURT OF CO.!U1MOI3 PLEAS OF CCTMBERLPND CO. , PEIdNSYLVP.DIIA Docket No . ANC B.ziNK, aT.E~. ,Plaintiff{s} - against - DP,NA Nf.ZLLLORY , ET AF, ,Defendant ts) SWORN A7VTD SUBSCRIBED TO BEFORr, ME THIS -y;~- ~ _. `' DAB OF / ~ ' ? !r ,(~ ~~- '~~.~ 2 4 ' Cy:._ ~': .._ - .- ~ -_ _ r ~- __w ~. ~.--K ,, o ~` ,~...~. A t~ W 4 ;4cSG~.i.A ~. R{CHARDSGN NQTAf~Y PUSI.lC OF N£W JERSEY ^~y Cammi~sion Expires April 15, 2013 DGR - The Source for Legal. Support 1359 Littleton Road, bTcrris Plains, I3u 0?950-3004 File ~ 120440?^-~',9?3] 403-1704 Fay: i9?3',• 443-9222. Wort: Order # 901.824 '~Ou~77'J I •Gl:t~, ,lw:, _. , ..~ '~!T~ ~ ~...c:a. ~TiDMd^ ~.__,~_.. ~,~ '°_.iul~.._ ,.," ~il...'~:C= ~? _....~°~.. „ ,iii u~i.. -,~ ,~ i~. ii ~:i, 1'N' = i.. .,,.....~ ,_O JJI. ....J^'.C.. _.. ~ ~ J11 ..... ".. ...v n~l'~:ry~ .. ..... 1.....+. •, ~.~ -_ai alli , 11 ,.. , _,~~. ._ ^~_4 .._,. i;' _~_..~ua,,..o Jvu, .,., .. . _~ .J! ,I ~.ii} ..,.._ .. :L^. ".._ "D'Jlri:' .~i .~.. n, ~..V_-.-. !~, ~~~I:i _,.,., .,.. __~ v' 'DVEC'i.G .,. ~nP.~~ .., nG~..~.-.~.... 1„•v~~liGl:Jr'. !~ tIY=I~. =.r. ~,~ - (" ~^Q ..., _~Gv(;:1!i r ..:i1Lr1J4.. ci!;%_ '~D:''" iA%i^'Yi+? _ .r:./~ Ti ~! ^~nI~~C:._. _~.I ~.r... ~...: .. ~:,'_ .:.~iT.: GII JG ~:ll _ :: IUi, _~ .., f ~..._~~~=V ~_~~.__ .. "_,2.,., .,i,~ °'-;: C7Vtrc^- T._ .... o i'd° ..,1'.,___„ .w[ ,-wllii ~.. Y~i!°~. 1"=~U~:..a =: ...,, '-, ;15 .. 1 ..,. PIP,i~~ ., ~ ~25? '.-_ _c_,..., Vsr!.. C° ":°_~i"----~ ~S.d.._~' ~_ .~ .., .,.J.._. U :i'.-, :C',F.^,ll-'~J,i. il',.i~~,.. S` :ail= .s.^-._ 7__.. !ggtig _ rtrt~~ WA~N1TMi ^syl::..J IV ..... I7~, .. ~ -I I - 1.r' - 1{~~ ns t/~ F .- ~ J ~ 'lti, ~^ ` h. ... ~ I `l ~ ^ ~ t Y~ i f'.. I v~ h1 _.. , . _ i ~ ~ ~ I f+.l l `f H t~ '... ._. _.. ..+: t r., f'k .... -. sJ:' KL':.... _-.:.4~,. ~i~i'.iili'ih.~I-a~` :~ ~'...~r:-?~___--.'~v-.:y,r-,,iV'If.YY~''i~°~ -:..-~1rF~,,r'a.~~`` =".~~~...~_ -a _~nit .- .. .:: `~Vt. ,..= .. ~~.hN.... ~;l.J ~. _:... ~1'1 ~+~I~l ~~~v IJt\ ~~~ ~, K-~'i Ur.~ .r. . .. .... -... i t _., I.r r.. IJiV .,J -, .~ .. 1+.,1. ...,,. iti ~. M~~t ...- .._ _- -~~. v;"Kln:'_.:~ `.- :,~.~_.._:._ !'~i=G?Pr'1r'-.-~~iv ~~U~.J -~~.I'_- lF.' ., ~fllilidA! =iV,'-._-._:,'";~~.~'~lha~.. =~±'~i= - ., .~ ,. i ~,uu~: ^,' If111=a:~~i`[iVi='~~' .:1= tiG"' ~'IG== T~-ir.lti ~ `.'~%:..P.~, ,.,=; 3'~ i -, - _~ _ ,_ .'a..._ ~~...___ .. ,W , ,_.._ .. ._____ _.,.. vr, -~i~=r~r - _- _---- ~ yJ::"''~^ ~ ~u _. ,. ~ _ ~7 ~1~r d ~~,~«~ 4r ~c'_ . EXHIBIT C UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County N0.12-2933-CIVIL MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (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 the defendant and the reasons why service cannot be made. NOTE: A sheriff s return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. 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 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries 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 set forth in the Return of Service marked Exhibit "A", the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B". Plaintiff conducted a postal search which did not reveal any new addresses or information. A copy of the postal search is attached as Exhibit "C". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN-LAW OFFICES, A:C. 1 BY: Attc u1Kt h':^.. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County N0.12-2933-CIVIL CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 13th day of November, 2012. Udren Law Offices, P.C. Attorney for Plaintiff By: PAIGE M. BELLING, ESQUIRE PA ID 309091 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP. No. Docket Number 12-2933-CIVIL NAME: DANA M. MALLORY MAILING ADDRESS: 221-SOUTH MARKET STREET MECHANICSBURG, PA 17055 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F!) ED-�r r Sheriff - TiTfj �$01r at cam6Pr�h Jody S Smith � ������� �� Chief Deputy wr AM to. Richard W Stewart � .� ( � T ' Solicitor �' E `� �"� "rr PENNSYLVANIA PNC Bank, National Association VS. Case Number Dana Michelle Mallory 2012-2933 SHERIFF'S RETURN OF SERVICE 10/03/2012 09:58 AM-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 221 S Market Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 11/27/2012 As directed by Katherine E. Knowlton,Attorney for the Plaintiff, Sheriffs Sale Continued to 2/6/2013 02/01/2013 As directed by Katherine E. Knowlton,Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 03128/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $993.20 SO ANSWERS, r. March 28,2013 RONW R ANDERSON, SHERIFF S la' (c)OountySuite Sheriff,Teleosoft,Inc. 1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s dren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Dana M. Mallory Defendant(s) MORTGAGE FORECLOSURE NO. 12-2933-CIVIL AFFIDAVIT PURSUANT TO RM 3129.1 AND RULE 76 PNC Bank,National Association,Plaintiff in the above action,by its undersigned attorney, upon information and belief,Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed., the following information concerning the real property located at: 221 South Market Street,Mechanicsburg, PA 17055 1.Name and address of Owner(s)or reputed Owner(s): Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 2.Name and address of Defendants) in the judgment: Dana M.Mallory 221 South Market Street Mechanicsburg,PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance Dept.280946 Harrisburg,PA 17128 Borough of Mechanicsburg 36 Nest Allen Street Mechanicsburg,PA 17055 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue Mechanicsburg,FA 17055 I' 4.Name and address of the last.recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg,OH 45342 Sr Mortgage Holders-None Jr Mortgage Holders-None 5.Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6.Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburg,PA 17055 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unworn falsification to authorities. DATED: UDREN LAW OFFICES,P.C. BY: Attorney for Plaintiff MJU#: 12040077 CASE#: 12040077-1 KAhwim E. Knowlton,EsQ PA I0 311713 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s dren.com PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Dana M. Mallory Defendant(s) MORTGAGE FORECLOSURE NO. 12-2933-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank,National Association,Plaintiff in the above action,by its undersigned attorney, upon information and beliefs Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street,Mechanicsburg, PA 17055 1.Name and address of Owner(s)or reputed Owner(s): Dana M.Mallory 221 South Market Street Mechanicsburg,PA 17055 2.Name and address of Defendant(s) in the judgment: Dana M. Mallory 221 South Market Street Mechanicsburg,PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance Dept.280946 Harrisburg,PA 17128. Borough of Mechanicsburg 36 West Allen Street Mechanicsburg,PA 17055 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue Mee taicti01bu PA 17055 4.Name and address of the last.recorded holder of every mortgage of record: PNC Bank,National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders-None Jr Mortgage Holders-None 5.Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6.Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17413 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburg, PA 17055 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa-C.S. sec. 4904 relating to unworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. Attorney for Plaintiff MJU#: 12040077 CASE#: 12040077-1 Kedwine E. Knowlton, Esq PA ID 311713 M UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-6b9-5400 Weadwokwiren4m PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County DANA M. MALLORY MORTGAGE FORECLOSURE Defendant(s) NO. 12-2933-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dana M.Mallory 221 South Market Street Mechanicsburg,PA 17055 Your house(real estate) at 221 South Market Street,Mechanicsburg,PA 170$5 is scheduled to be sold at the Sheriff's Sale on December 5,2012 at 10:00am at the Cumberland County Courthouse,Commissioners Hearing Room,2nd Floor,Carlisle,PA 17013,to enforce the court judgment of$134.112.13, obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF QH�' IS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIF'F'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) .+r Y Y TO SAVE YOUR PR-OP AND YOU HAVE OTHER RIGM EVEN IP THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out m accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17413 (800)994-9148 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17413 (800)990-9148 ALL THAT CERTAIN lot of ground with the buildings thereon erected, situate on the northeast corner of Market and Keller Streets in the .Borough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a post on the corner of said Market and Keller Str*ets; thence northward by Market Street 35 feet to a' corner of lot now or formerly of Samuel Mumma; thence by said lot eastward 130 feet, more or less, to Brandt Alley; thence by said Allay southward 43 feet to corner of said Alley and Keller Street; thence westward by said Keller Street 130 feet more or less, to the place of BEGINNING, HAVING THERE ERECTED a brick dwelling house known and numbered 221 South Market Street, Mechanicsburg, Pennsylvania, UNDER AND SUWECT to all easements, reservations, restrictions and rights-of-way of record, including a right-of-way to Mechanicsburg Water Company. BEING THE SAME PREMISES which Richard D. Adams, widower, by his deed dated June 20, 2003 and recorded in the office: of the Recorder of Deeds in and for Cumberland County granted and conveyed unto Dana M. Mallory, single person. BEING KNOWN AS: 221 SOUTH MARKET STREET,MECHANICSBURG, PA 17055 PROPERTY ID NO.: 17-23-0565-077 TITLE TO SAID PREMISES IS VESTED IN DANA M.MALLORY BY DEED FROM RICHARD D.ADAMS,WIDOWER DATED 06/20/2003 RECORDED 06/24/2003 IN DEED BOOK 257 PAGE 3651. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 12-2933 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PNC BANK,NATIONAL ASSOCIATION Plaintiff(s) From DANA M.MALLORY (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: $134,112.13 L.L.: $.50 Interest FROM 8/29/2012 TO DATE OF SALE DECEMBERS,2012-ONGOING PER DIEM OF $18.91 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE- $1,872.09 Atty's Comm: % Due Prothy:$2.25 Arty Paid:$199.25 Other Costs: Plaintiff Paid: Date:8/30/2012 =- .4uAtt, IB vid D.Buell,Prothono (Seal} : Deputy REQUESTING PARTY: Name: KATHERINE E.KNOWLTON,ESQUIRE Address: UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER,111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for:PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No'.311713 TRUE COPY FMM RECORD In Testism Y 1 here unto set MY hand and the of add Court at Carlisle,Pa This of >20 tot On September 4., 201 _ s � 'C C. and ru 2 1, UAdlso k PA {� ♦ b M wit 1 h� lopes", Chat . SWember 4., ;j : 1 r � CUMBERLAND LAW JOURNAL Writ No. 2012-3933 Civil Term PNC BANK,NATIONAL ASSOCIATION vs. DANA MICHELLE MALLORY Atty.:Katherine E.Knowlton ALL THAT CERTAIN lot of ground with the buildings thereon erected, situate on the northeast comer of Market and Keller Streets in the Bor- ough of Mechanicsburg,Cumberland County, Pennsyhania bounded and described as follows,to wit: Beginning at a post on the comer of said Market and Keller Streets; thence northward by Market Street 35 feet to a comer of lot now or for- merly of Samuel Mumma thence by said lot eastward 130 feet, more or less,to Brandt Alley;thence by said Alley southward 43 feet to corner of said Alley and Keller Street; thence westward by said Keller Street 130 feet more or less, to the place of beginning. HAVING THEREON ERECTED a brick dwelling house known and numbered 221 South Market Street, Mechanicsburg,Pennsylvania UNDER and SUBJECT to all ease- ments,reservations,restrictions and rights-of-way of record,including a right-of-way to Mechanicsburg Water Company. BEING THE SAME PREMISES which Richard D. Adams, widower, by his deed dated June 20,2603 and recorded in the office of the Recorder of Deeds in and for Cumberland County granted and conveyed unto Dana M.Mallory,single person. BEING KNOWN AS: 221 SOUTH MARKET STREET, MECHANICS- BURG,PA 17055. PROPERTY ID NO.: 17-23-0565- 077. TITLE TO SAID PREMISES IS VESTED IN DANA M. MALLORY BY DEED FROM RICHARD D.ADAMS, WIDOWER DATED 06/20/2003 RECORDED 06/24/2003 IN DEED. 59 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 Liss 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, 2412 i Affiant ftu Cher deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Coyne,rAtor SWORN TO AND SUBSCRIBED before me this 9 day of November, 2Q12 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 �'-- � m 2020 Technology �7 {�u —= � —'^ ���NNN- Pair, N �N��uite 300 ����-� �~rM�/chaqicsburg, PA17050 Now you knov 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, 1 6'29 Commonwealth of Pennsylvania, County ofDouohin) ss Holly Blain, being duly sworn according to |aw, deposes and says: That she iaaStaff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsy|vania, with its principal office and place of business at 2020 Technology Phvvy, Suite 300. in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and pu:)Iisher of The Patriot-.News and The Sundel) 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 Ma'ch 4th, 1854. and September 18th. 1949. respectively, s ' -`'- been continuously published ever since; |h t oabonwhiohinseoure|ya�aohedharehoiaexaot|yosprinte6andpub|iuhedintheirregu|a/ daily U/ / '-~ jidonu which appeared on the dota(a) indicated below. That neither she nor said 'Company is .r of said printed notice or advertising, and that all of the allegations of this statement a 3 ,t the time, - Uon are true� and |h �of the haut aforesaid and isdu�outhor�ed and ernpowenadhzvehfv this sbtenmento1 behalf f | -^ by virtue and pursuant to a resolution unanimously passed and adopted severally by the Sin o kk |d '~ e said Com pany and subsequently duly reco rded in the office for the Recording of Deed!; Uto .oeUaneoue800k ^K4^. Vn|uma 14. Page 317. r` �� This ad ran mn the datm(s) shown bmlom/: 1�/�GV1� ^ �Uel '11/02/12— 11/09/13 et Strft4 411d b*k � bvvonn 10 ang subscribed Deko sl �oyoY November, 2O12XD. re*ER WS eck rots-of r / / ~��- to -- Not,�ry Public Of 4ad e�ti. deed 100 a8doon for COMMONWCAU'K OF PENNSYLVANIA PA Sherrie I..Oviens,Notary Public My Commission Expires Nov.26,2015 IS UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. DANA M. MALLORY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIV1T, DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12- 2933 -CIVIL AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its /his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A ", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B ". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B ". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B ". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Dated: .3 • 6. 1 `-■ UDREN LA S FFICES P MJU #: 12040077 CASE #: 12040077 -1 BY: Attorneys for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin s ' udren.com PNC Bank, National Association Plaintiff v. DANA M. MALLORY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12- 2933 -CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Commonwealth of Pennsylvania Department of Revenue Lien Section, Department 280948 Harrisburg, PA 17128 -0948 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Dwight Foster; Fosters Automotive Inc. 117 East Strawberry Avenue Mechanicsburg, PA 17055 American Express Brank, FSB 4315 South 2700 West Salt Lake city, UT 84148 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders — None Mechanicsburg Water Company 317 North Market Street Mechanicsburg, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128 -1230 Tenants /Occupants 221 South Market Street Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo /Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: 3 - 6. t' MJU #: 12040077 CASE #: 12040077 -1 UDREN LAW OFFICES, P.C. BY: A ey for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 LTDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 21)0 CHERRY HILL, NJ 08003-3620 856-669-5400 PN atEIt;WaTional ssociat.on Plaintiff v. DANA M. MALLORY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12-2933 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): DANA M. MALLORY PROPERTY: 221 South Market Street, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 12, 2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2"d Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 08080322 CASE#: 08080322-1 Name and Address of Sender Article !Amber Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered Insured COD 0 Certified Name of Addressee, Street and Post Office Address 0 Return Receipt for Merchandise 0 Intl Recorded Del. EExpress Mail Postage Check appropriate block for Registered Mail: 0 With Postal Insurance ri Without postal Insurance Handling Charge Act. Value If Re is. Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Recei t Insured Value Due Sender If COD R.R. Fee S.D. Fee Remarks Cumberland County Real Estate Tax Department 1 Courthouse Square, Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street, Carlisle, PA 17013 Commonwealth of Penna, Department of Revenue Bureau of Compliance, P.O. Box 281230 Harrisbur., PA 17128-1230 12-2933 Tenants/Occupants 221 South Market Street, MechaflicSburf, PA 17055 Commonwealth of PA, Department of Revenue Lien Section, P.O. Box 280948, HarrisbUr., PA 17128-0948 03/12/2014 Borough of Mechanicsburg [ 36 West Allen Street, Mechanicsburg, PA 17055 Dwight Foster — Foster's Automotive Inc. 117 E. Strawberry Avenue, Mechanicsburg, PA 17055 Total number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) PS Form 877, Feb u 994 Dana M. Maltory MJU #12040077-1 Cumberland Coun Form Must be Com The full declaration of value is required on ell domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50000 per piece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is 5500. The maximum indemnity payable is 525,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only 10 third and forth class parcels. e riter, Ink or Ball Point Pen Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ Insured Ell COD n Certified Return Receipt for Merchandise lnt'I Recorded Del. 0 Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance n Without postal Insurance Affix stamp here if issued as rtificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value D °e Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 12 -2933 American Express Bank, FSB 4315 South 2700 West Salt Lake City, UT 84184 2 Mechanicsburg Water Company 317 North Market Street Mechanicsburg, PA 17055 3 03112/2014 _ U.Sr „POSTAGE CHERRY 003LL'NJ FEB 18. ' 14 00 �; 1 .30 09 4 5 -mac Mili _____ Srdr65 poSra- .1000 a ^aItip . Mb, � ■ •.M `'�srt'LL.N 10 r C aU�'RE'-- - 11 uN�rEasrert s posre F LSD B : �l is yS 1000 12 13 0$1.30 0095931 -13 14 15 Total number of Pieces Listed by Sender 2 Total Nu r ..-r if Pieces Receiv =.. t P • st Office / F.. master, ' -r (Name of Receiving Employee] - lire full declaration of value is required on all domestic and intcmatiooat registered mail Th e maxunum indemnity payable forthe reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S9I3, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling char, es a..1 oal to third and forth class ,arcels. O/ �! PS Form 3877, Feb l uar 1994 Farm Must be Co m r feted b T r ewriter, Ink or Ball Point Pen DANA M. MALLORY - MJU# 12040077 -1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s udren.co PNC Bank, National Association Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County DANA M. MALLORY, MORTGAGE FORECLOSURE Defendant(s) NO. 12-2933-CIVIL VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: DANA M. MALLORY 221 S MARKET ST, MECHANICSBURG, PA 17055 DATE MAILED: February 4, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: tJit 6 , 2014 MJU#: 12040077 CASE#: 12040077-1 UDREN LA • FICES, P.C. BY:/ At mey for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Association Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) NO. 12-2933-CIVIL ORDER PERMITTING SPECIAL SERVICE AND NOW, this 1 a� day of 064 , 2012 , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), DANA M. MALLORY, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 221 South Market Street Mechanicsburg, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: DANA M. MALLORY 221 SOUTH MARKET STREET • MECHANICSBURG, PA 17055 ✓ Wren (at.) D7ers f'j /NR ;Ia /l //G�.Z CERTIFIED MAIL UDREN LAW OPNCES, Re. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD CHERRY HILL NJ 08003 111 11 1 11 itt 11 1 91 7199 9991 7033 2444 4214 Div IL.r..--‘314-5111EICIUFF'S-SALE-OF-Iti, TO: DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 0..914,;;;: „:11, U.S. POSTAGE >> PITNEY BOWES i=twarirwiew NamairiwArmior ZIP 08003 $ 005.i 30 02 1W 0001387090 FEB 04 2014 • • ,Z,19334g?.gg,-;V:Irrocr0;,0 • * role disreu. ito4trit4icor tle ina.Up :SO S OlatAkie !Ito tO tte pevos. palliatIVO 61. ressed to*. p,dd Oftthe ito0 22A South thatttet Street \7714t. WIaltory Isftectootetao,gb _ \ lte■e %umber :_ice (arisfer fro 20 m apeli3 PS Foro'.$81'1 , 301 COMPLETE THIS SECTION ON DELIVERY Mortt Nidtessee ' of Ooll‘lotY p. skg ad by Voted Name)- &Noy addros ircStOeto tiles, enter &Weil address belolig t4,:o VEAPressr p thii—ettrt fteeeltle tietsboi0e ■ caect on DePo ll\ l Foo) 91 "1199 9991 CI33 VA 44 Return fk ■ SENDER: COMPLETE THIS SECTION II Complete items 1, 2, and 3. Also complete item 4 ff Restricted Delivery is desired. Print your name and address on the reverse so that we can return the card to you. „.„.. • Attach this card to the back of the rnallpie.;e, , or on the front if space permits. 1. Mcle Addressed to: Dana M. Mallory 221 South Market Street _Mechanicsburg, PA 17055 COMPLETE THIS SECTION ON DELIVERY D. Is delivey address clifferent from Item 1? 0 Yes if YES, enter delivery addr 0 No 9' ‘CSBU N/055 FEB24 2. Article Number (Taunter from service labe# Service Type Registered 0 Insured Mall 0 °lie y Mail &obit andise 4. ResblctedDeliveiy? Etia Fe ) 91 7199 9991 7033 2444 4214 0 Yes PS Form 3811, July 2013 Domestic Return Receipt 7MM Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 LJ Registered Insured 0 COD 0 Certified Return Receipt for Merchandise 0 Intl Recorded Del. Express Mail Check appropriate block for Registered Mail: . With Postal Insurance Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handlin g Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Remarks 1 Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 , 2 3 4 12-2933 5 'OSTN • )8003 13&7C MN =mil 1111111111111iro..4 ............aur....4mil im..........ctim.- .,,--- w„-- Illikrur:: 6 03/12/2014 7 10 INIMIN1111111111111111111111117113111 11 12 IIIIIIIIMIIIIIIIIIII 11=1..11111111111/.11111111111 1 14 ' 15 Total n mber of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per N me of Receiving Employee) The full declaration of value is required on all domestic and intemational registered mail The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $500,003 per occurrence. The maximum indemnity payable an Express Mail merchandise is 5500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal inSurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on intemational mail. Special handling charges apply only to third and forth class parcels. 1 PS Form 3877, February 1994 Form Must be Completed by Typewriter, nk or Ball Point Pen Dana M. Mello — MJU #12040077-1 (Cumberland County) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY vc■ 01 II;t14 Ibte 0,,FcEoF SHEPJFF PNC Bank, National Association vs. Dana Michelle Mallory Case Number 2012-2933 SHERIFF'S RETURN OF SERVICE 01/09/2014 11:36 AM - Deputy Ronald Hoover, 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 221 South Market Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $953.71 SO ANSWERS, January 29, 2014 RON R ANDERSON, SHERIFF (c) County Suite Sheriff, Teleosoft, UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin ' s ' udren.com PNC Bank, National Association Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County DANA M. MALLORY, MORTGAGE FORECLOSURE Defendant(s) NO. 12- 2933 -CIVIL VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: DANA M. MALLORY 221 S MARKET ST, MECHANICSBURG, PA 17055 DATE MAILED: February 4, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: NA) 6 , 2014 MJU #: 12040077 CASE #: 12040077 -1 UDREN LAF'FICES, P.C. BY: Attfrney for Plaintiff SALVATORE CAROLLO, ESQUIRE PA ID 311050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Association Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) NO. 12-2933-CIVIL ORDER PERMITTING SPECIAL SERVICE AND NOW, this I S day of N404 , 2012 , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), DANA M. MALLORY, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 221 South Market Street Mechanicsburg, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 ✓ UIre' Lao D e-e.s tek- • BY THE COURT: CERTIFIED MAIL UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD CHERRY HILL, NJ 08003 11 I� 11 1 11 1 91 7199 9991 7033 2444 4214 - n I7UI RTI SALt OF Rt TO: DANA M. MALLORY 221 S MARKET ST MECHANICSBURG, PA 17055 U.S. POSTAGE» PITNEY BOWES (4171.== ZIP 08003 $ 005.13 re 02 1114' 0001387090 FEB. 04. 2014 0 TE THIS SECTION COMPLE 3 Also °omP1ete SENDER items A , 2, and. is desired verse Complete rInt it Pest ceeand address card to Y °rever ece, r Print your wecan returns back of the m 1 , s�othat h i fron tit to a Pemuts l or °n the to: A. Article N ddr O Dana �. r _ 22A South et Street Me ch purg,_-� 5 5 g, prte Number •� (Transfer at s ervice tabu PForn' i , July 203 PLETE THIS SECTION ON DELIVERY coM Signature tinted Name) t3 R elved by �' dress t item A4 fl No d>��nt hoot � D. �s defer as detyer aware tf YES, enter © moot ,0 Pdd�es�e C Date of Deliver Tess g• Service Mai® C7 p storm Receipt tot Me�t'a'd1 C Delivery Registered all D Collect on © Yes Insured Fee) Restricted Detverl ? ©33 2t`�4 t}2yu 991'11 ca 7199 meStc 'Return 1pt 'SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed tor Dana M: Mallon/ 221 South Market Street Mechanicsburg, PA 17055 COMPLETE THIS SECTION ON DELl VERY . r Received by (Prfn Cl Agent 0 Addressee C. Date of Delivery D. Is delivery address different from Item 1? 0 Yes If YES, enter delivery add 0 No C Lth fro 055 A 4 3. Servlco Type C dined Mario 0 Registered 0 Insured Mail Priority Mall Expre mj,,cf 0 Col e • ive erchandlse 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service labe01 91 7199 9991 7033 2444 4214 : PS Form 3811 , Julr2013 Domestic Retum Receipt Name and Address Sender Henrietta Crommarty UDREN LAW OFFICES, P..CC. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered Insured ❑ COD ❑ Certified Return Receipt for p Merchandise 0 Intl Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Line 1 Article Number Name of Addressee, Street, and Post Office Address Pane M. Mallory Postage Fee Handling Charge Value (If Regis.) Insured Value Receipt Due Sender COD R.R. Fee S.D. Fee S.H. Fee Remarks 221 South Market Street Mechanicsburg, PA 17055 ..e If 2 ,l! 3 o 4 12 -2933' ,u iA o 6 03/12/2014 U n' 4 t�M r-i3 7 OO- ? g-NO o NOO 8 9 ..,••221 m' 'r'� 10 �� — ``�' 11 r �� 121 ''r 13 14 15 —jI Total number of Pieces Total Number Pieces Listed by Sender 1 of Received at Post Office 1 Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and for the reconstruction of nonnegotiable documen s $50,000 per piece subject to a limit of $500,000 per occurrence. merchandise is $500. The maximum indemnity payab e intemational registered under Express The maximum is $25,000 for registered Mail document indemnity mail, mail. The reconstruction payable sent maximum insurance on Express indemnity is Mail tiMA:arb with optional postal insurance. See Domestic Mail Manua R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. / PS Form 3877, Februa 1994 ry Form Must be Completed by Typewriter, Ink or Ball Point Pen Dana M. Mallory - MJU #12040077 -1 (Cumberland County) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF T E $MEFIFFF n _3 F..t. rut`fi3ERLP,o PENN SYL\Wil PNC Bank, National Association vs. Dana Michelle Mallory Case Number 2012-2933 SHERIFF'S RETURN OF SERVICE 01/09/2014 11:36 AM - Deputy Ronald Hoover, 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 221 South Market Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 02/28/2014 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/04/2014 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 06/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $992.96 SO ANSWERS, July 01, 2014 RONNY RANDERSON, SHERIFF /L 30-d6 J V (c) (sount}Su: e S eriff,'ieleosoft. Enc. On October 31, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 221 South Market Street, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: October 31, 2013 By: Real Estate Coordinator I I :01 V LI 130 EIdZ Vd 'A1Nn00 ONV PI3L ►,l00 3.dI3HS 3141 20 3:313J0 LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2012-2933 Civil Term PNC Bank, National Association vs. Dana Michelle Mallory Atty.: Mark J. Udren ALL THAT CERTAIN lot of ground with the buildings thereon erected, situate on the northeast corner of Market and Keller Streets in the Bor- ough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a post on the cor- ner of said Market and Keller Streets; thence northward by Market Street 35 feet to a corner of lot now or for- merly of Samuel Mumma; thence by said Lot eastward 130 feet, more or less, to Brandt Alley; thence by said Alley southward 43 feet to corner of said Alley and Keller Streets; thence westward by said Keller Street 130 feet more or less, to the place of BEGINNING. HAVING thereon erected a brick dwelling house known and numbered 221 South Market Street, Mechanics- burg, Pennsylvania. UNDER AND SUBJECT to all easements, reservations, restrictions and rights-ofway of record, includ- ing aright -of-way to Mechanicsburg Water Company. BEING THE SAME PREMISES which Richard D. Adams, Widower, by his deed dated June 20, 2003 and recorded in the Office of the Recorder of Deeds in and for Cumberland County granted and conveyed unto Dana M. Mallory, single person. BEING KNOWN AS: 221 South Market Street, Mechanicsburg, PA 17055. Property ID No.: 17-23-0565-077. TITLE TO SAID PREMISES IS VESTED IN Dana M. Mallory by deed from Richard D. Adams, wid- ower dated 06/20/2003 recorded 06/24/2003 in Deed Book 257 Page 3681. 58 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: January 24, January 31, and February 7, 2014 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. Lisa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 7 da of Februar 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 riot -News Co. echnology Pkwy Suite 300 anj sOurg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Iie patriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller 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. PUBLICATION COPY 2012-2933 Civil Term PNC Bank, National Association Vs Dana Michelle Mallory Atty: Mark J Udren ALL THAT CERTAIN LOT OF GROUND WITH THE BUILDINGS THEREON ERECTED, SITUATE ON THE NORTHEAST CORNER OF MARKET AND KELLER STREETS IN THE BOROUGH OF MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POST ON THE CORNER OF SAID MARKET AND KELLER STREETS; THENCE N( TLIWART1 PV TA ADTTtT This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Swor to an subscribed before me this 18 day of j bruary, 2014 A.D. IL,, otary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County M C.omminionExpi! Dec. 12, 2016 MEMBER, PEN SYLVANIA ASSOCIATION OF NOTARIES UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Dana M. Mallory ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL PRAECIPE TO ISSUE WRIT OF EXECUTION Defendant(s) TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 08/29/2012 to Date of Sale 03/04/2015 Ongoing Per Diem of $18.91 to actual date of sale including if sale is held at a later date (Costs to be added) OJAI' Zts° ttv 9a3. ao 1-1 t• MJU#: 12040077 CASE#: 12040077-1 4 P, a'-9,9 I # 4-3/Lioat LI 73(16/ wf drla $ 134,1.1.2.13 $ 17,359.38 C. :re Crl Gfk C) Sherri 3. Braunstein, Esquire PA ID 90675 (QS -Idtk a. J UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com PNC Bank, National Association Plaintiff v. Dana M. Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 This statement is made subject to the penalties of 18 Pa.C.S. authorities. lating to unsworn falsification to laintiff Sherri J. Braunstein, Esquire PA ID 90675 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s ' udren.com PNC Bank, National Association Plaintiff v. Dana M. Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance Dept. 280946 Harrisburg, PA 17128 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue Mechanicsburg, PA 17055 American Express Centurion Bank 4315 South 2700 West Salt Lake City, UT 84184 American Express Bank FSB 4315 South 2700 West Salt Lake City, UT 84184 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders — None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject . - . - • ies of 18 Pa.C.S. sec. 4904 relating to unswrn fa ific tion to authorities. _ DATED: tt % it `( UD' `'nom:—�e,,.vt� i' -mMllMillIllBY:11111.1. MJU#: 12040077 CASE#: 12040077-1 Attorney for P aintiff Sherri J. Braunstein, Esquire PA ID 90675 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin l s ' udren.com PNC Bank, National Association Plaintiff v. DANA M. MALLORY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 Your house (real estate) at 221 South Market Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $134,112.13, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net PNC BANK, NATIONAL ASSOCIATION Vs. DANA M. MALLORY WRIT OF EXECUTION NO 12-2933 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $134,112.13 L.L.: Interest FROM 08/29/2012 TO DATE OF SALE 3/4/2015 - ON GOING PER DIEM OF $18.91 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $17,359.38 Atty's Comm: Due Prothy: $2.25 Atty Paid: $2,239.91 Other Costs: Plaintiff Paid: Date: 12/1/2014 L.Iee� David D. Buell, Prothonotary (Seal) REQUESTING PARTY: Name: SHERRI J. BRAUNSTEIN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. PLAINTIFF C 7cl?QdLt.r-- Deputy UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. DANA M. MALLORY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL co AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as' — Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements here' ' . re made subject to the penalties of 18 Pa.C. s , c. 4904 relating to unsworn falsification to a Dated: MJU#: 12040077 CASE#: 12040077-1 UD BY: Atto tiff AMANDA L. RAKER,, FSC PA. I.©, 4 3O71):L UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsna,udren.com PNC Bank, National Association Plaintiff v. Dana M. Mallory Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 221 South Market Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Commonwealth of PA, Bureau of Compliance Lien Section, P.O. Box. 280948 Harrisburg, PA 17128-0948 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue Mechanicsburg, PA 17055 American Express Centurion Bank 4315 South 2700 West Salt Lake City, UT 84184 American Express Bank FSB 4315 South 2700 West Salt Lake City, UT 84184 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 221 South Market Street Mechanicsburg, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: MJU#: 12040077 CASE#: 12040077-1 UD EN L p,l'�; ES, P.C. BY Att AMA RAVER. ESQUIRE I.U. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ank, ahona Association Plaintiff v. DANA M. MALLORY; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): DANA M. MALLORY; PROPERTY: 221 South Market Street, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 03/04/2015 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 12040077 CASE#: 12040077-1 EXHIBIT A Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑Registered ❑ Insured ❑ COD ❑ Certified ❑ Return Receipt for Merchandise ❑ Intl Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 x• 4 12-2933 Tenants/Occupants 221 South Market Street Mechanicsburg, PA 17055 m COo CO N 5 Commonwealth of Pa, Bureau of Compliance Lien Section, P.O. Box 280948 Harrisburg, PA 17128-0948EE .. /6 o 0 • `t V i O 5/ATIOA, 6 03/04/2015 Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 W 0 40 rn o o 0 p O >k 'l�` ,% eo a 7 Dwight Foster; Foster's Automotive Inc. 117 East Strawberry Avenue PA 17055 CL CO. t tt 0I}. o :,J i oMechanicsburg, 8 American Express Centurion Bank 4315 South 2700 West Salt Lake City, UT 84184 N 00 r .lt :. H 9 American Express Bank FSB 4315 South 2700 West Salt Lake City, UT 84184 114r; •� 4•" , • 7•:rr-. •.• ;t;; • { # r+T�, 'JC` W 10 r it ■ 11 12 13 14 15 Total number of Pieces Listed by Sender 9 Total Number of Pieces Received ost Office Post .. ter, Per (Name of Receiving Employee) �./' The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction ofnonnego fable documents under Express Mail document reconstruction insurance is $50,000 per p ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, 5913, and 5921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Dana M. Mallory - MJU# 12040077-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin • s ' udren.com PNC Bank, National Association Plaintiff v. DANA M. MALLORY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: DANA M. MALLORY 221 SOUTH MARKET STREET, MECHANICSBURG, PA 17055 DATE MAILED: December 8, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January , 2015 MJU#: 12040077 CASE#: 12040077-1 EXHIBIT B UD BY: Atto ES, P.C. ff AMANDA L. RAUER, ESQUIRE PA, # 307028 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Associalion Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) NO. 12 -2933 -CIVIL ORDER PERMITTING SPECIAL SERVICE AND NOW, this S day of 1064 , 2012 , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), DANA M. MALLORY, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 221 South Market Street Mechanicsburg, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 / Wren Lac) O7&.< lefy ,tis,/Cd /1/fd�a BY THE COURT: EXHIBIT B CO :8 HV 91 MN t 1 O 4 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) # 12040077-1 1 111 11 in 11 1 1 11 u 11 91 7199 9991 7034 1907 1950 DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 '' + U.S. POSTAGE* PITNEY BOWES tea: ( 4� �.. ter► z!P 08003 $ 005.130 02 1111 0001387090DEC 08 2014 Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ Insured ❑ COD ❑ Certified Return Receipt for ❑ p Merchandise ❑ Int'l Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 12-2933 Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 2 3 3/04/2015 4 &.e5.., .ey� �TATtp. %a 5 O 0 1Q' i� o 6 ., (es, z 7 U.S. POSTAGE 'rf.•' ,� ZIP 08003 $ ,Aiti�z ; • 02 111 00013870901 I r -' -HERO �\ CO 8 1 H 9 CO P....1 10 1 11 ,X w 12 13 14 15 Total number of Pieces Listed by Sender 1 Total Number of Pieces Received aj Post Office (/ Pos i• .F er, Per (Name of Receiving Employee) /// 4 The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Dana M. Mallory - MJU# 12040077-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. DANA M. MALLORY; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12 -2933 -CIVIL Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: BY: Atto' AMAIN A L. RAUER. ESQUIRE PA. I . U . # 307028 EXHIBIT B IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION • PNC Bank, National Association Plaintiff v. DANA M. MALLORY; ET AL Defendant(s) NO. 12 -2933 -CIVIL ORDER. PERMITTING SPECIAL SERVICE AND NOW, this b day of klaq , 2012 , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), DANA M. MALLORY, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 221 South Market Street Mechanicsburg, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: DANA M. MALLORY 221 SOUTH MARKET STREET MECHANICSBURG, PA 17055 / Laren tau) .0g7Ces. 4/ /hb BY THE COURT: EXHIBIT B c -0= rn co X "1 z(n ZcD r- < > c-) --4 c-= 9? UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings_@udren. CAM PNC Bank, National Association Plaintiff v. DANA M. MALLORY Defendant(s) ATTORNEY FOR PLAINTLU COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12 -2933 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dana M. Mallory 221 South Market Street Mechanicsburg, PA 17055 Your house (real estate) at 221 South Market Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $134,112.13, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late chArges, costs and reasonable attomey's fees. To find out bow much you xnust pay, you may call: 056) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open thejudgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) EXHIBIT B 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 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed_ 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 EXHIBIT E3 PNC Bank, National Association. et. al.. Plaintiff(s) vs. Dana M. Mallory, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty I11 Woodcrest Rd., Ste. 200 Cherry Hill. NJ 08003-3620 APS INTER' Tb0N,tL ? APS International Plaza 7800 Glenroy Rd. Minneapolis. MN 55439-3122 APS File #: 132452-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process by APS International, Ltd. 1-800-328-7171 Service of Process on: —Dana M. Mallory, by posting Court Case No. Cumberland Co 12 -2933 -Civil State o `er e.)\\I&nt cQ, ) SS. County ofC.A.AA *13 rtA )n'_`^Name of Server: �('C�l\Q (-'u. ko _ . undersigned, being duly sworn, deposes and says y that at the ti e of service. s/he was of legal ,age and was not a party to this action: that on the day of ^���-pV-'\ 20 1�1. at Vao'clock Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: at 221 South Market Street the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property w/ Order in Mechanicsburg, PA 17055 A true and correct copy of the aforesaid document(s) was served on: Dana M. Mallory, by posting L By personally delivering them into the hands of the person to be served. By delivering them into the hands of ���`11�j� a person o suitable age, who verified. or who upon questions( tated, that he/she resides with Dana M. Mallory, by posting at the place of service, and whose relationship to the person is: Description of Person Receiving Documents: Signature of Server: The person receiving documents is described as follows: Sex • Skin Color Approx. Age To to bes my of service. • Hair Color • Approx. Height owledge and b • Facial Hair : Approx. Weight said person was not engaged in the US Military at signed declare under penal egoin • 's true . nd c .s ibed . d sworn to before the this ,of of Server APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Tammle L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 9, 2015 MEMBER, PENNSYLY NIA ASSOCIATION OF NOTARIES /(Cornrnission Expires) EXHIBIT 0