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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
CIVIL DIVISION
NO. /a .3038 Vi
COMPLAINT IN MORTGAGE
FORECLOSURE
vs.
JASON W. MYERS and ALICIA THRUSH
Defendants.
TO DEFENDANT(S):
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT IN MORTGAGE FORECLOSURE
WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF
OR A DEFAULT JUDGMENT MAY BE ENTERED
AGAINST YOU.
By: /S/ oCoij V. Vim
Attorney for Plaintiff
MORTGAGE FORECLOSURE
Filed on behalf of Plaintiff
Counsel of record for this party:
Lois M. Vitti, Esquire
PA I.D. #209865
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
3
103-17,!5 PO AT7y
C? ?o7S?/85?o??'D6
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PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
VS.
JASON W. MYERS and ALICIA THRUSH
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No.
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION
WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE
SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE
ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND
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
SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-8:00-990-9108
(717) 249-3166
COMPLAINT IN MORTGAGE FORECLOSURE
NOW, comes the Plaintiff by its attorneys, Vitti & Vitti & Associates, P.C. and Lois M.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141
through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a national association having a principal place of business
located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is the holder of the
mortgage and is seeking enforcement of the mortgage through foreclosure.
2. The Defendant(s) is/are individuals with a last known mailing address of 119 S.
Fayette Street, Shippensburg PA 17257. The property address is 119 S. Fayette Street,
Shippensburg PA 17257 and is the subject of this action.
3. On the 23?d day of October, 2008, in consideration of a loan of One Hundred
Thirty Four Thousand Two Hundred Eight and 00/100 ($134,208.00) Dollars made by
National City Mortgage, a division of National City Bank to Defendant, the said Defendant
executed and delivered to National City Mortgage, a division of National City Bank a "Note"
secured by a Mortgage with the Defendant as mortgagor and National City Mortgage, a
division of National City Bank, as mortgagee, which mortgage was recorded on the 29th day
of October, 2008, in the Office of the Recorder of Deeds of Cumberland County, at
Instrument # 200835431. The said mortgage is incorporated herein by reference thereto
as though the same were set forth fully at length. The Plaintiff is successor by merger to
National City Mortgage, a division of National City Bank.
4. The premises secured by the mortgage are:
SEE EXHIBIT 'A"A 77ACHED HERETO.
5. Said mortgage provides, inter alia:
"that when as soon as the principal debt secured shall become due and payable,
or in case default shall be made in the payment of any installment of principal and
interest, or any monthly payment, keeping and performance by the mortgagor of any of
the terms, conditions or covenants of the mortgage or note, it shall be lawful for
mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the
mortgage, of principal debt, interest and all other recoverable sums, together with
attorney's fees."
6. Since October 1, 2011, the mortgage has been in default by reason, inter alia,
of the failure of the mortgagor(s) to make payments provided for in the said mortgage
(including principal and interest) and, under the terms of the mortgage, the entire principal
sum is due and payable.
7. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in
1998, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s) on the date set forth thereon, and the temporary stay as
provided the said notice has terminated because Defendant(s) has/have failed to meet with
the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied
assistance by the Pennsylvania Housing Finance Agency.
8. The amount due on said mortgage is itemized on the attached schedule.
9. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases
from liability for the debt secured by the mortgage any mortgagor, personal representative,
heir or devisee of the mortgagor who, is not a real owner of the property at the time of the
filing of this Complaint.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6),
Plaintiff demands judgment for the amount due of One Hundred Seventy Four Thousand
Eight Hundred Sixty Five and 39/100 ($174,865.39) with interest and costs.
Respectfully submitted,
VITfI & VVUWA5SOCIATES, P.C.
BY:
Lois "itti!E§gUre
Attorney for Plaintiff
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance 155,035.03
Interest @ 4.5000% from 09/01/11 through 5/31/2012 5,218.10
(Plus $19.1139 per day after 5/31/2012 )
Late charges through 5/8/2012
0 months @ 50.11
Accumulated beforehand 303.27
(Plus $50.11 on the 17th day of each month after 5/8/2012 )
Attorney's fee 7,751.75
Escrow deficit 6,557.24
(This figure includes projected additional charges that may be incurred by the Plaintiff
and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale)
BALANCE DUE 174,865.39
EXHIBIT "A"
LEGAL DESCRIPTION
ALL that certain lot of ground with dwelling house and other buildings erected thereon
situated on Soatk Fayette Street, is the Borough of Shippensburg, Cumberland Conmty,
Pennsylvania, bounded and described as follows:
BEGINNING at a point on the East side of Fayette Street in said Borough: thence by land
formerly of Dr. D. D. Hayes, now or formerly of Pblisdelphis and Reading Railroad
Company, North 62 degrees East 175 feet, more or fees, to a post; thence by line of
Dykeman Will race, North 17 degrees West 32 feet to a post; thence by land formerly of
Johns Bank, now or formerly of Paul Martin, Soatk 62 degrees West 175 feet, more or leas, to
the tine of Fayette Street aforresaid; thence by the said Street, South 28 % degrees East 32
feet to the place of BEGINNING.
VERIFICATION
AND NOW Lois M. vitti verifies that the statements made in this Complaint are true
and correct to the best of her knowledge and information. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the
pleading is submitted by counsel having sufficient information based upon the information
provided him by the Plaintiff.
i?
Lois M.
Dated: May 8, 2012
PNC Bank, National Association
Plaintiff(s)
vs.
Jason W. Myers and Alicia Thrush
Defendant(s)
FORM 1
IN THE COURT OF COMMON PLEAWF
CUMBERLAND COUNTY, PENNSA#AN
y-
l?. X038 Civil r erpt
27-
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. TIPS PROGRAM IS FREE.
Respectful
5/8/12
[Si
1 for Plaintiff]
Date
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: State: Zip:
Is the property for sale? Yes No F-1 Listing date: Price: $_
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ? No ?
Mailing Address (if different):
City:
Phone Numbers: Home:
Cell:
Email:
# of people in household:
State: Zip:
Office:
Other:
How long?
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender:
Type of Loan:
State: Zip:
Dome: Office:
Cell: Other:
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
Home:
Other Real Estate:
Retirement Funds:
Investments:
Checking:
Savings:
Other:
Amount Owed:
Value:
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.
2.
3.
Additional Income Description (not wages):
I . monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 Morta e Utilities
Car Payment(s) Condo/Nei . Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su rt/Alim. Spending Money
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
I/We, _ , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. 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:
V1 Proof of income
V Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Y Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
3
FORM 3
PQC 9?-_-,inw -`wal `
? ? ' ? /`F-6C7ci (.31i iY1
Plaintiff(s)
vs.
r
Hefendant(s)
CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Date
FORM 4
IN THE COURT OF COMMON PLEAS OF
PNC Bank, National Association CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
CIVIL ACTION
VS.
NO.
Jason W. Myers and Alicia Thrush
Defendant(s)
CASE MANAGEMENT ORDER
AND NOW, this day of
, 20 , the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on
at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed -Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available rc olution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter! offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
I
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
PNC Bank, NA
vs.
Jason W. Myers (et al.)
4
cuEitl.? 0 C0
Yi..`!
Case Number
2012-3038
SHERIFF'S RETURN OF SERVICE
05/21/2012 03:36 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 21
2012 at 1536 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Alicia Thrush now known as Alicia Myers, by making known unto Jason
Myers, Husband of Defendant at 119 S. Fayette Street, Shippensburg, Cumberland County, Pennsylvania
17257 its contents and at the same time handing to him personally the said true and correct copy of the
same.
4TTWNSHALL, DEPUTY
05/21/2012 03:36 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 21
2012 at 1536 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Jason W. Myers, by making known unto himself personally, at 119 S.
Fayette Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time
handing to him personally the said true and correct copy of the same.
S6 HALL, D
SHERIFF COST: $64.00 SO ANSWERS,
May 22, 2012
4RON R ANDERSON, SHERIFF
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
PNC MORTGAGE, NATIONAL
ASSOCIATION,
Plaintiff,
VS.
JASON W. MYERS and ALICIA
THRUSH,
Defendants.
CIVIL DIVISION
NQ-F1-3039 Civil Term
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7.,
PRAECIPE FOR DEFAULT
JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NO
MILITARY SERVICE
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412)281-1725
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C-# 01 (P 0 11 Lo
& 127790
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) No. 12-3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants.
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Enter judgment in Default of an Answer in the amount of $175,534.37, in favor
the PNC Mortgage, National Association, Plaintiff in the above-captioned action, against tl
Defendants, Jason W. Myers and Alicia Thrush and assess Plaintiffs damages as follows and/
as calculated in the Complaint:
Unpaid Principal Balance $155,035.03
Interest from 9/1/2011-7/5/12 5,887.08
(Plus 6% per day after 7/5/12)
Late charges (Plus $50.11 per
month from 5/8/12-12/05/2012 $350.77) 303.27
Attorney's fee 7,751.75
Escrow Deficit 6,557.24
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
Total Amount Due X175.534.37
The real estate, which is the subject matter of the Complaint, is situate in Boro
k/a 119 South Fayette Stre
Shippensburg, Cumberland County, Pennsylvania, HET a d71?
Shippensburg, PA 17257. Parcel# 34-34-2415-056. _
T ris P. Vitti, Esquire
O
Attorney for the Plaintiff
or
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV.
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) No. 12-3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was
Defendant(s), in the above-captioned case on June 13, 2012, giving ten (10) day notice that
would be entered should no action be taken.
VITTI & VITTI & ASSOCIATES, P.C.
BY: 4L
11. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 5th day
of July, 2012.
lakry Public
h+. VTAA
x
to the
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) No. 12-3038 Civil Term
Plaintiff, )
VS.
JASON W. MYERS and ALICIA THRUSH,
Defendants.
EMPORTANT NOTICE
TO: Jason W. Myers
Alicia Thrush
119 South Fayette Street
Shippensburg, PA 17257
Date of Notice: June 13, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAr
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES C
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHT;
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET 7
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
'717.249.3166
& 47i, & S O IATES, PC
BY: ? z-S Louis P. wire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL. BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOU LY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOUL
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEME T
OF A LIEN AGAINST PROPERTY.**
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or flie
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Service Members Civil Relief Act of 2004 and designated therein as military service,
and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act,
and that the averments herein set forth, insofar as they are within his knowledge, are correct, and
true; and insofar as they are based on information received from others, are true and correct as e
verily believes. In the alternative, should the defendant(s) be currently serving in the military t e
Service Members Relief Act does not apply as the mortgage in question did not originate before e
period of the Service Members military service and is secured by a mortgage pursuant to 50 U.S. .
App §533 formerly cited as 50 U.S.C. App §532 (a)(1)(2).
This Affidavit is made under the provisions of the Servi embers Civil Relief Act of
----------------- -------_`''"" l .
Louis P. Vitti, Esquire
SWORN to and subscribed
before me this 5th day
of Jul , 2012. a
otary Public
I
C I
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
PNC MORTGAGE, NATIONAL
ASSOCIATION,
Plaintiff,
VS.
JASON W. MYERS and ALICIA
THRUSH,
Defendants.
CIVIL DIVISION
NO. 12.3o3$ Civil Term
PRAECIPE FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
Filed on behalf of
Plaintiff
Code MORTGAGE FORECLOSURE
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) No: 11-,3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s)
above-captioned matter as follows:
Amount Due $175,534.37
Interestl6/2012-12/5/12 4,385.95
Total $179.920.32
The real estate, which is the subject matter of the Praecipe for Writ of Execution is
in:
Boro of Shippensburg, Cumberland County, Pennsylvania, HET a dwg k/a 119 South Fayette
Shippenssburg, PA 17257. Parcel# 34-34-2415-056.
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Louis P. Vitti, Esquire
Attorney for Plaintiff
in the
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV.
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION,
Plaintiff,
VS.
JASON W. MYERS and ALICIA THRUSH,
Defendants.
AFFIDAVIT
No. 12-3038 Civil Term
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute.
Defendants' last known address is 119 South Fayette, Shippensburg, PA 17257.
?r
AVitti, SWORN to and subscribed
before me this 5th day on,`a
of July, 2012.
otary Public
the
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) No. 12-3038 Civil Term
Plaintiff,
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
AFFIDAVIT
I, Louis P. Vitti, hereby certify that as representative of PNC Mortgage am familiar with the
captioned case and various servicing activities related thereto and that the provisions of the
Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the
captioned case.
SWORN to and subscribed
before me this 5th day
of July, 2012.
Notary Public
ouis P. Vitti, Esquire ?.
Attorney for Plaintiff c
of the
t:,:r C
C) -r i
i.. C"3
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Jason W. Myers r?
C
3
-
Alicia Thrush
„
ca ,-
.._
;.
119 South Fayette Street
Shippensburg, PA 17257 r^'
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on December 5, 2012 at 10:00 A. ., the
following described real estate, of which Jason W. Myers and Alicia Thrush are owners or reputed o ers:
Boro of Shippensburg, Cumberland County, Pennsylvania, HET a dwg k/a 119 South Fayette
Shippensburg, PA 17257. Parcel# 34-34-2415-056.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action o PNC
Mortgage, et al vs. Jason W. Myers, et al at 2010-5835 in the amount of $175,534.37
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30 days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your prop from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO OUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON , GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YO CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE I
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriff s Sale and the loss of your property. In o der to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help yo q.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale ours, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objecti n you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and otice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriff s Sale would ordinarily be delayed pending a trial of the issue of ether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twen (20)
days after service or in certain other events. To exercise this right, you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the S eriff s
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other 1 gal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold fora grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you shoul file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the prop . The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the Sheriff.
is P. Vitti, sq ire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCE ENT
OF A LIEN AGAINST PROPERTY.**
C .
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ri... T.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN
IN
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) No., I2--3038'''ivil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Mortgage, et al , Plaintiff in the above action, sets forth as of the date the Praecipe for the
Execution was filed the following information concerning the real property located at 119 South
Shippensburg, PA 17257.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Jason W. Myers 119 South Fayette
Alicia Thrush Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record
the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
None
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
rit of
on
None
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien
property and whose interest may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who
interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Shippensburg Boro
Shippenburg Borough
Pennsylvania Department of Revenue
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
Court of Common Pleas of
Cumberland County
Domestic Relations Division
c/o Grace Kiter
PO Box 282
Shippensburg, PA 17257
(water and sewage)
111 North Fayette Street
Po Box 129
Shippensburg, PA 17257
Office of Chief Counsel
PO Box 281061
Harrisburg, PA 17128
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
the
any
PA Dept. of Sheriff Sales
Bureau of Compliance
Tenant/Occupant
Dept. #281230
Harrisburg, PA 17128-1230
119 South Fayette Street
Shippensburg, PA 17257
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge or information and belief. I understand that false statements herein are made subj
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
July 5, 2011
Date
SWORN to and subscribed
before me this 5th day
of July, 2012.
Notary Public
?Juis tP.Vitti, Esquire
Attorney for Plaintiff
to the
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-3038 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC MORTGAGE, NATIONAL ASSOCIATION,
Plaintiff (s)
From JASON W. MYERS and ALICIA THRUSH
(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: $175,534.37 L.L.: $.50
Interest 7/6/12 - 12/5/12 -- $4,385.95
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $215.25
Other Costs:
Plaintiff Paid:
Date: 7/13/12
David D. Buell, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: LOUIS P VITTI, ESQUIRE
Address: VITTI & VITTI ASSOCIATES, PC
215 FOURTH AVENUE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 01072
!i
~, u~~'lrk~~ 1 ~t~~
IN THE COURT OF COMMON PLEAS OF COUNTS', PENNSYLVANIA
CIVIL DNISION
CIVIL DIVISION
PNC MORTGAGE, NATIONAL
ASSOCIATION No.12-303 8
Plaintiff, AFFIDAVIT OF SERVICE
VS. Code 140-MORTGAGE FORECLOSURE
JASON W. MYERS and ALICIA Filed on behalf of
THRUSH, Plaintiff
Defendants.
Counsel of record for this
P~Y~
Louis P. Vitti, Esquire
Supreme Court #01072 .
Vitti &Vitti & Assoc., P.C. -`~
215 Fourth Ave
Pittsburgh, PA 15222
-
_
.
•~...~
(412) 281-1725 _:"
_..
_~., _-
1N THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, ) N0.12-3038 Civil Term
PLAINTIFF, )
VS. )
JASON VV'. MYERS and ALICIA THRUSH, )
DEFENDANTS. )
AFFIDAVIT OF SERVICE
I, Louis P. Vitti, do hereby certify that the Notice of Sale has been served upon the
Defendants, Jason W. Myers and Alicia Thrush by the Sheriff of Cumberland County on October
8, 2012 and all Lien holders, by Certificate of Mailing, for service in the above-captioned case on
August 29, 2012 advising them of the Sheriff s sale of the property 119 South Fayette Street,
Shippensburg, PA 17257 on December 5, 2012.
VITTI & TI & ASSOCIATES, P.C.
r r"
Y
Louis P. Vi
SWORN to and subscribed
before me this 21st day
of November, 2012.
`~ ` ~
Notary Public
~ 4
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received f°rom.
Vitti 8r Vitti 8r Associates. P.C.
215 Fourth Avenue. Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Tax Collector of Shippensburg Boro
c/o Grace Kiter
PO Box 282
Shippensburg, PA 17257
ro rvnu ov r r, January cuu I
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Vitti 8 Vitti 8 Associates. P.C.
215 Fourth Avenue. Pittsburgh PA 15222
One piece of ordinary mail addressed [o:
Shippenburg Borough
(water and sewage)
111 North Fayette Street
P.O. Box 129
Shippensburg, PA. 1~-~8 1'12}
ra rolrn oat r, uanuary tuu-I
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAV BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Fom:
Vitti 8r Vitti 8 Associates. P.C.
215 Fourth Avenue. Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Pennsylvania Department of Revenue
Office of Chief Counsel
PO Box 281061
Harrisburg, PA 17128
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From.
Vitti 8r Vitti 8 Associates. P.C.
215 Fourth Avenue. Pittsburgh PA 15222
One piece of ordinary mail addressed to:
Commonwealth of PA-DPW
PO Box 8016
Harrisburg, PA 17105
.~ rvu a vv r r , .rar iuar y cuu I
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster forcurcent
fee.
$1.150
US POSTAGE
FIRST-CLASS
~ 062S0007065222
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for current
fee.
$1.150
US POSTAGE
FIRST-CLASS
062S0007061721
`~° 15222
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for curcent
fee.
$1.150
US POSTAGE
FIRST-CLASS
~ 062S0007065222
~ ~~
_T ~~
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for current
fee.
$1.150
US POSTAGE
FIRST-CLASS
$ 062S0007061721
15222
~ ~
y
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAV BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Vitti 8 Vitti & Associates. P.C.
215 Fourth Avenue. Pittsburgh. PA 15222
One piece of ordinary mail addressed to:
Clerks of Courts
Criminal/Division
One Courthouse Square
Carlisle, PA 17013
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER -
Received Fnm
Vitti Sr Vitti 8r Associates. P.C.
215 Fourth Avenue. Pittsburgh. PA 15222
One piece cf ordinary mail addressed to:
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
rs rorm :ssr~, sanuary zuut
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAY BE USED FOR DOMESTIC AND IMERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From.
Vitti 8r Vitti 8r Associates. P.C.
215 Fourth Avenue, Pittsburgh. PA 15222
Ona piece of ordinary mail addressed to:
Court of Common Pleas of
Cumberland County
Domestic Relations Division
P.O. Box 320
Carlisle. PA 17013
ra rorm soT r, sanuary zuu~
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Fmm
Vitti 8 Vitti 8~ Associates. P.C.
215 Fourth Avenue. Pittsburgh PA 15222
One piece of ordinary mail adtlressetl to:
PA Dept. of Sheriff Sales Bureau of
Compliance
Dept. ~` 281230
Harrisburg, PA 17128-1230
ra rorm saT r, uanuary zuu-I
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for current
fee.
$1.150
US POSTAGE
FIRST-CLASS
06250007061721
N 15222
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for current
fee.
$1.15a
US POSTAGE
FIRST-CLASS
06250007065222
~, ,.
Affix fee herein stamps
or meter postage and
post mark. Inquire of
Postmaster for current
fee.
$1.150
US POSTAGE
FIRST-CLASS
062S0007061721
° 15222
ti='w~
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster forcurcent
fee.
$1.150
US POSTAGE
FIRST-CLASS
w 062S0007061721
m 15222
~~ r ~.
,`~
U.S. POSTAL SERVICE CERTIFICATE OF MAILNG
MAY 8E USED FOR DOMESTIC ANO INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Fmm.
Vitti $ Vitti 8t Associates. P.C.
215 Fourth Avenue. Pittsburgh, PA 15222
One piece cd ordinary mail addressed to:
Tenant/Occupant
119 South Fayette Street
Shippensburg, PA 17257
PS Form 3817, January 2001
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster far current
fee.
$1.150
US POSTAGE
FIRST-CLASS
062S0007061721
~ 15222
ao
- ~. ~,
.:- c~ ,'
t.
L: PRO HoN0-(
rii',
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION,) No. 12-3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above -captioned matter as follows:
Amount Due
Interest 7/6/2012-09/03/2014 $22,766.57
Total
situate in:
$175,534.37
$198,300.94
The real estate, which is the subject matter of the Praecipe for Writ of Execution is
Boro of Shippensburg, Cumberland County, Pennsylvania, HET a dwg k/a 119 South Fayette Street,
Shippensburg, PA 17257. Parcel# 34-34-2415-056.
outit-PA aFSop21 atg,,,'
S`13.88 << „
/53.75(/
+
RD $6",
L.
Obi/ ggg?
«3S .t3
Jjc/2LAMJ
Louis P. Vitti, Esquire
Attorney for Plaintiff
aotion :
pi\
IN THE COURT OF COMMON . PLLEAS OF CUMBERLkW COUNTY, PENNSYLVANIA
ev
CIVIL DIVISION
PRAECIPE FOR WRIT OF EiOCUTION
or-I�ye, Noiio
vs.
01 A55Oc O. ion,
or, kkl: M,ye(s and Alicicichcush,
0 TIE P RO'lHON TARY OF THE SAID COURT :
( ) Confessed Judgment
(X)' Other
File "No. ) 2 -303E3 C iV(I 1enyn
Amount Due 53q. 3r7
Interest 4..1 22,7ito,57
Atty's Comm
. Costs
The undersigned hereby certifies that the below does not arise out of a _retail
nsta7lrrent sale, contract, or account based on a confession of judcar nt, but if it does,
:t is based on the appropriate or?:ginal proceeding filed pursuant to Act 7 of .1966 as
mended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above wetter to the- Sheriff of CumberloVi6
:ounty, for debt, interest and costs upon the following descibed property of the
iefendant (s )
My() 6nA hcm 1Thrush
PR kBCIFE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of
County, for debt,
n terest and costs, as above, directing attachment against the above-named garnishee (s) for
:he following property (if real estate, supply six copies of the description; supply four
n oies of lengthy personalty .list )
:nd F l 1 other property of the defendant (s) in the possession, custody or control of the
aid ca_rnishee(s)_
(Indicate) Index this writ against the garnishee(s) as a Lis pendens against
peal estate of the defendant(s) described in the attached.bit.
)ATE:
5-/q-Iq
Signator
Print
Names Leu 1 S ?. villi
address: 24 J fbur,1-, 1 Avenu-e
rl�-LC1 i1'�'rw.
{1-1EPROTHONGIA i
y °iii Y 21 P! 2: 16
CUMBERLAND GOVT '
PENNSYLVI\\NIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION,) No. 12-3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and
belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to
execute . That the Defendants' last known address is 119 South Fayette, Shippensburg, PA 17257.
Louis P. Vitti, Esquire
SWORN to and subscribed
before me this 19t day
of May, 2014.
Notarial Seal
Sherry L House, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires May 15, 2015
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION,) No. 12-3038 Civil Term
Plaintiff, )
VS. )
JASON W. MYERS and ALICIA THRUSH, )
Defendants. )
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Mortgage, et al , Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the real property located at 119 South
Fayette, Shippensburg, PA 17257.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Jason W. Myers
Alicia Thrush
119 South Fayette
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
None
Name
None
4. Name and address of the last recorded holder of every mortgage of record:
Address (Please indicate if this
cannot be reasonably ascertained)
Name
None
5. Name and address of every other person who has any record lien on the property:
Address (Please indicate if this
cannot be reasonably ascertained)
6. Name and address of every other person who has any record interest in or record lien on
the property and whose interest may be affected by the sale:
Name
None
Address (Please indicate if this
cannot be reasonably ascertained)
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Shippensburg Boro
Shippenburg Borough
Pennsylvania Department of Revenue
Commonwealth of PA -DPW P.O. Box 8016
Clerk of Courts
Criminal/Civil Division
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
Court of Common Pleas of
Cumberland County
Domestic Relations Division
c/o Grace Kiter
PO Box 282
Shippensburg, PA 17257
(water and sewage)
111 North Fayette Street
Po Box 129
Shippensburg, PA 17257
Office of Chief Counsel
PO Box 281061
Harrisburg, PA 17128
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
PA Dept. of Sheriff Sales
Bureau of Compliance
Tenant/Occupant
Dept. #281230
Harrisburg, PA 17128-1230
119 South Fayette Street
Shippensburg, PA 17257
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
May 19, 2014
Date
SWORN to and subscribed
before me this 19t day
of May, 2014.
'Notary PubIf
ter,... , Li b0 r91:,
Notarial Seal
Sherry L. House, Notary Public
City of Pittsburgh, Allegheny County
, My Commission Expires May 15, 2015
ME}D27n4, "E*!ni5,:'LvP, T OP NOTARM
ded,„
Louis P. Vitti, Esquire
Attorney for Plaintiff
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Jason W. Myers
Alicia Thrush
119 South Fayette Street
Shippensburg, PA 17257
AND: ALL LIEN HOLDERS
fit; pzr r-; 2: j6
UNBERLAND COUNT \i/
PENNS YL NIA
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 3,
2014 at 10:00 A.M., the following described real estate, of which Jason W. Myers and Alicia Thrush
are owners or reputed owners:
Boro of Shippensburg, Cumberland County, Pennsylvania, HET a dwg k/a 119 South Fayette Street,
Shippensburg, PA 17257. Parcel# 34-34-2415-056.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of
PNC Mortgage, et al vs. Jason W. Myers, et al at 2010-5835 in the amount of $175,534.37
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of
the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you wish to
exercise your rights you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In
order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help
you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened in you promptly file a
petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense
on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of
the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before
twenty (20) days after service or in certain other events. To exercise this right, you would have to
file a petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other
legal or equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a
grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you
should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the
property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10)
days from the date when the Schedule of Distribution is filed in tl ffice of the Sheriff.
Louis P. Vitti, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
Cilar
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
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 MORTGAGE, NATIONAL ASSOCIATION
Vs. NO 12-3038 Civil Term
CIVIL ACTION — LAW
JASON W. MYERS AND ALICIA THRUSH
WRIT OF EXECUTION
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: $175,534.37
Interest 7/6/2012-9/3-2014 - $22,766.57
Atty's Comm:
Atty Paid: $1,135.13
Plaintiff Paid:
Date: 5/21/14
(Seal)
L.L.: $.50
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary
REQUESTING PARTY:
Name: LOUIS P. VITTI, ESQUIRE
Address: VITTI AND VITTI AND ASSOCIATES
215 FOURTH AVENUE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No.
?
Deputy
Pli'07-110N01/iFv.;-
0/4 AUG 1 I h
2: 4 3
CUHBERL liD CO WIT 'I
PEIV,i/SYL VA NiA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC Mortgage, National Association
Plaintiff,
vs.
CIVIL DIVISION
NO. 12-3038 Civil Term
AFFIDAVIT OF SERVICE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Jason W. Myers and Alicia Thrush Louis P. Vitti, Esquire
Supreme Court #01072
Defendant.
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC MORTGAGE, NATIONAL ASSOCIATION, No. 12-3038 Civil Term
Plaintiff,
VS.
JASON W. MYERS and ALICIA THRUSH,
Defendants.
AFFIDAVIT OF SERVICE
I, Louis P. Vitti, do hereby certify that a Notice of Sale was mailed and served upon the
defendants by the Sheriff of Cumberland County on June 24, 2014 and all lien holders by
Certificate of Mailing for service in the above -captioned case on May 28, 2014, advising them of
the Sheriffs sale of the property at 119 South Fayette Street, Shippensburg, PA 17257, on
September 3, 2014.
VITTI & V I & ASSOCIATES, P.C.
SWORN to and subscribed
before me this 6th day
of August, 2014.
Notary P4h'i)py LILOrM6141-.
Notarial Seal
Sherry L. House, NOtary Public
City or Pittsburgh, Allegheny County
My Commission Empires May 15, 2015
uis P. Vitti
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue. Pittsburgh, PA 15222
Ono piece of ordinary mat addressed to:
Pennsylvania Department of Revenue
Office of Chief Counsel
PO Box 281061
Harrisburg, PA 17128
PS Form 3817, January 2001
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062S000706121/
0
15222 .5 c.,
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mat addressed to:
Commonwealth of Pennsylvania- DPW
PO Box 8016
Harrisburg, PA 17105
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MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Clerk of Courts
Criminal/ Civil Division
One Courthouse Square
Carlisle, PA 17013
PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
PS Form 3817, January 2001
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Court of Common Pleas of Cumberland County
Domestic Relations Division
PO Box 320
Carlisle. PA 17013
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
PA Department of Sheriff Sales
Bureau of Compliance
Departm # 281230
Harrisburg, PA 17128-1230
PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
tax Collector of Shippensburg Boro
c/o Grace Kiter
P.O. Box 282
Shippensburg, PA 17257
PS Form 3817, January 2001
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
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215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Shippenburg Borough
(water and sewage)
11 North Fayette Street
Shippensburg, PA 17257
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE -POSTMASTER
Received From:
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue, Pittsburgh, PA 15222
One piece of ordinary mail addressed to:
Tenant/Occupant
119 South fayette Street
Shippensburg, PA 17257
PS Form 3817, January 2001
NLD. Myers/Thrush. 9/3/14
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062500070615,221 •
15222
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FILED -OFFICE
CF THE PROTHONOTARY
2014OCT 21 P112:57
CUMBERLAND COUNTY
PENNSYLVANIA
PNC Mortgage
vs.
Jason W. Myers (et al.)
Case Number
2012-3038
SHERIFF'S RETURN OF SERVICE
06/23/2014 12:15 PM - Deputy Dennis Fry, 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 119 South Fayette Street, Shippensburg, PA 17257,
Cumberland County.
06/24/2014 07:14 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Alicia Thrush at 119 S. Fayette Street, Shippensburg Borough, Shippensburg, PA 17257, Cumberland
County.
06/24/2014 07:14 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Jason W. Myers at 119 S. Fayette Street, Shippensburg Borough, Shippensburg, PA 17257, Cumberland
County.
09/03/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on Wednesday, September,
3, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Louis P. Vitti, on behalf of PNC
Bank National Association, being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $997.48 SO ANSWERS,
September 16, 2014 RONNY R ANDERSON, SHERIFF
c) CountySuit Sherif 'eleosof. Enc.
LXIII 29
CUMBERLAND LAW JOURNAL . 07/18/14
Writ No. 2012-3038 Civil
PNC MORTGAGE
vs.
JASON W. MYERS
Alicia Thrush
Atty.: Louis P. Vitti
All that certain lot of ground,
with thedwelling house and other
buildings erected thereon situated
on South Fayette Street, in the Bor-
ough of Shippensburg, Cumberland
County, Pennsylvania, bounded and
described as follows:
Beginning at a point on the East
side of Fayette Street in said Bor-
ough: thence by land formerly of
Dr. D.D. Hayes, now or formerly of
Philadelphia and Reading Railroad
Company, North 62 degrees East 175
feet, more or less, to a post; thence by
line of Dykeman Mill race, North 17
degrees west 32 feet to -a post; thence
by land formerly of John Bash, now
or formerly of Paul Martin, South 62
degrees West 175 feet, more or less,
to the line of Fayette Street aforesaid;
thence by the said street, -South 28
1/4 degrees East 32 feet to the place
of beginning.
Having erected thereon a dwelling
known as 119 South Fayette Street,
Shippensburg, PA 17257.
Parcel# 34-34-2415-056.
Being the same premises which
Jodi L. Bowman by her deed dates
10/23/08 and recorded 10/29/08
in the Recorder of Deeds Office of
Cumberland County, Pennsylvania
in Deed Book T-234, page 5, Instru-
ment# 200835430, granting and
conveying unto Jason W. Myers,
single person and Alicia Thrush,
single person.
75
The Patriot -News Co.
1900 Patriot Drive
Nechaiicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
cue patriot*News
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
Amy Kotula, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, 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.
1
2012.3038'viI Term
9.
PNC MOR GAGE
vs. -
JASON W. MYERS
Alicia Thrush
Any. Louis P Wtti
All.that certain lot of ground with the
dwelling
e house
and other buildings
ther
"erected situated
Fayette Street, on South
ShippShippensburg, in the Borough of
ensburg' Cumberland County,
as follows; bounded and described
Beginning at a point on the East side of
Fayette Street in said Borough: thence
by land formerly of Dr.
now or formerly D. D. Ha
ormerly of Philadelphia and
62 Readingailroad bC ' -1,pe���`)North
degreesEast 175 feet, more or less,
to a post; thence by line of hvtrPnpo.._
This ad ran on the date(s) shown below:
07/13/14
07/20/14
07/27/14
rk,e
Sworn to and bscribed before me this 20 day of August, 2014 A.D.
110Jh1E1.A_
otary`P-aubl c
COMMONWEALTH OF PENNSYLVANIA,
NOTARIAL SEAL
Sheryl Marie Leggore, Notary Public
Hampden Twp., Cumberland County
My Commission Expires July 16, 2018
MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff's Deed in which PNC Bank, NA is the grantee the same having been sold to said grantee on the
3rd day of September A.D., 2014, under and by virtue of a writ Execution issued on the 21st day of
May, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number
3038, at the suit of PNC Mortgage, NA against Jason W. Myers & Alicia Thrush is duly recorded as
Instrument Number 201424033.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
07/
day of
corder of Deeds
ecorder oTDeeds, Cumberland County, Carlisle, PA
My Commi ion Expires the First Monday of Jan. 2018
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:
July 11, July 18 and July 25, 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.
isa Marie Coyne, E itor
SWORN TO AND SUBSCRIBED before me this
25 da of July, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018