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HomeMy WebLinkAbout12-3323 .12 MAY 2S Psi 1: 1-tN ERUAl'i t, : W l , ENNSYL VAHII-? Karl M. Ledebohm, Esquire P.O. Box 173 New Currtberland, PA 17070-0173 (717)9386929 MEMBERS 1„ FEDERAL CREDIT UNION PLAINTIFF Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.. i a. -3323 DONALD K. ESTRIGHT and CIVIL ACTION - LAW ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS MORTGAGE FORECLOSURE NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 claims 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 ISO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORT" 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 PTO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY ,%?16 3. 7,S- d-JW CK=ik 1.5,96 iz'o -2- 7s- 14"1. OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demand as expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objections a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS IMPORTANTES PARA USTED. ).LEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUtNTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30) DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL ASSUME THE DEBT TO BE VALID. IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND/OR RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT CIVIL ACTION -LAW DEFENDANTS MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes Members 1 s' Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1 Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendants, Donald K. Estright and Robbin L. Estright aWa Robin Lynn Estright (collectively "Defendants"), are adult individuals having a last known addresses of 405 Sheely Lane, Mechanicsburg, PA 17050 and 615 Magaro Road, Enola, PA 17025. 3. On or about August 7, 2008, Defendants borrowed from and agreed to repay to Members 1st NINETY-SIX THOUSAND AND 00/100 ($96,000.00) DOLLARS (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement executed and delivered to Members 1St by Defendants on August 7, 2008 (the "Note"). A copy of the Note is attached hereto as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendants executed and delivered to Members 1 st a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in Hampden Township, Cumberland County, Pennsylvania, known and numbered as 405 Sheely Lane, Mechanicsburg, PA 17050 (the "Property"). A description of the Property is attached hereto as Exhibit "B" and made part hereof. On or about August 19, 2008, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office to Instrument No.: 200828266. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof. 2 6. The Mortgage has never been assigned by Members 1St and is still held by it as a valid and subsisting obligation of Defendants. 7. The Mortgage is in default because Defendants have failed to deliver to Members 1St the monthly payments of principal, interest and escrow due thereon in the amount of $891.30 for December 5, 2011 and $898.26 each for January, 2012 through May, 2012, as more particularly described, in part, in the Act 6 Notice attached hereto as Exhibit "D" and made part hereof. As a result of Defendants' default of Defendants' obligations under the Note and the Mortgage, on or about March 26, 2012, Members 1St provided to Defendants via regular, US certified mail, postage prepaid, return receipt requested, written notice addressed to Defendants at Defendants' last known addresses being the Property and 615 Magaro Road, Enola, PA 17025, of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P. S. section 101, et. M., ("Act 6") and in particular section 403 thereof. A copy of the said notice is attached hereto as Exhibit "D" and made part hereof ("Act 6 Notice"). 9. Pursuant to notice published by PHFA in the Pennsylvania Bulletin (41 Pa.B. 2789), Members 1St is not required to provide to Defendants notice of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. sec. ("Act 91"). 10. US Postal Service confirmations evidencing the mailing of said Notices is attached hereto as Exhibit "E" and made part hereof. II 12 13 14. 15 Simultaneously, Members 1St forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 8 by United States mail, first class, postage prepaid, bearing the return address of Members 1St . The Notices forwarded in said manner have not been returned to the offices of Members 1St as undeliverable or otherwise. Defendants are indebted to Members 1 st in connection with the Mortgage in the amount of NINETY-SIX THOUSAND EIGHT HUNDRED FIFTY- THREE AND 12/100 ($96,853.12) dollars itemized as follows: a. Outstanding principal $92,498.48 b. Interest to May 21, 2012 2,975.00 c. Late Charge 179.64 d. Attorney's fees 1,200.00 e. Total due to Members 1St $96,853.12 Defendants also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendants would pay, in addition to the amounts set forth in paragraph 12 above, costs incurred by Members 1St as a result of the institution and prosecution of these legal proceedings. The obligation owed to Members 1St continues to accrue interest at the rate of $19.4880 per day, through the date of payment and continues to accrue attorney's fees and costs. Members 1St is not seeking a judgment of personal liability (or an in personam judgment) against Defendants; however, Members 1St reserves the right to bring a separate action to establish that right, if such right exists. If one or 4 more of Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the Property in accordance with Pennsylvania law. 16. As set forth above, Members 1 st has made demand upon Defendants to make payment of the amounts due to Members 1St under the Mortgage. However, as of the date hereof, Defendants continue to fail and refuse to make payment of the amounts due to Members 1 st WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, In Remy against Defendants, Donald K. Estright and Robbin L. Estright a/k/a Robin Lynn Elstright, in the amount of NINETY-SIX THOUSAND EIGHT HUNDRED FIFTY-THREE AND 12/100 ($96,853.12) dollars plus interest at the rate of $19.4880 per day from May 21, 2012 through the date of judgment and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. submitted, Date: ?_ Z 3 / Z_ Karl A Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ww---.e Merin L00N 5000 Louise Drive. P.O. Bar 40 Mechanicsburg, PA 17055 eORRONERV NAME ANDADDRESS DONALD K ESTRIGHT 4%1 SHEF?LY LN N CHAN CSBURG. PA 17050 ANNUALPERCENT GE FINANCE CHARGE: Amount Financed: The amount of Total of Payments: The amount RATE; The cost of your credit as a The dollar amount the credit WIN credit provided to you or on your you will have paid alter you have yearly rate. ' coal you. behalf. made all payments as scheduled. 7.68 % • S 95,832,48 ° $ 98,000.00 e $ 215,837.39 Variable Rate: a your Iorn has a vari ble rate as idiea4d above the Annual POrcon ape Role may ilcnme dwhg the term of ants in nsadiun lithe (fndek) charges. The vsea lobo alb add a nwt9ln of to W uwa valve. The rate WE change anorttty on Use fast day 01 1* month The role will never be NpIMr than area matdmum me allowed by law, and it will never be less than . V Intrust rate Increases will result a more payments of the same amount. For Example, lf your loan was !a 55,000 at 15% for 48 moniha and the Annual Pareardalle R Wceased by 2% agar one year, the term tt your loan would Increase by two rnonihs •Pr•f and Rate: N chwdnad, on wim ov appkes io your Ionic (? Aubmatlc Payment Disaunt " d b make Y requhad mnnlaq paymalls though an 4utomalb deduction from your CneckaplSavngs Ins ANNUAL PERCENTAGE RATE boa is d b f PERCENTAGE RATE dbch air fLesua" A eaounf, yaw ANNUAL PERCENTAIW the Autonatlc Payment Discounted Ra b l I ll th l oss a ove n RATE has ball dscaad bbyy 20%. The ANNUAL te. This rate vent aatell .2d% N cease sae WlaaMb wyrbrd arranpemM a lab b maintah auflbisnt Nnda N your account ;0.% lf 1yOUr AubaNlb Payment Ohwunled Rate is Mae 0010 Oa10110 all tarts OI y0ur roar For enmpN tl r m - f th : e au c piymM e. ma cover n suc 000 on a &5 00 ban for e0 month , lo aaaa i a pSO, a Y ?° ark Inenaw b 1020%, mwNhg le 1 addalonal payment. artangertwra u case e ; . . Variable Rate Praterrect Loans. I , ank a vban and you qualNy for a pM•rnd rala, your Prdmad diteounl is taken a/ rive IYna you fake oN your bon. This =. - halal preferred ANNUAL PERCE RATE will then vary wording to charges b Nee itches (as dbalased above). For exempla, it a vri&Ma raw teen's IMtlal ANNUAL 1 PERCENTAGE RATE Is 12%at t , ou tales tIN nitYl pr°f°rr•d ANNWL PFRCFMAGE RATE Ws be NIA%. Your (NUat preramed ANNUAL PERCENTAGE RATE Will then vary according b Fixed Rate Preferred Loans. If y s, as dMdOeed in 1M'Variabla Rate provMfan ,hove. Is ¦ faad rid Ian arch live Ouakfy for a preferred tale, your ANNUAL PERCENTAGE RATE will>b the Pralarred ANNI/AL PERCENTAGE RATE disclosed as long as yaw prdrmd wdeas remalna In effect. Number at Payments A nt of Paymems Payme d Frequency When Paymwt& Are Due Property Insurance: You may obtain perty ou want that ismacceptable to one I r nce from an Pay wm 239 $899.35 Monthly - Beginning 09AW2003 y nsu a y the credit union. 11-you get the Insurance from the credit union you will pay ?u0 1 .9 b. $892.74 Final Due - On 081052028 S NIA Security: Collateral seaarfnp oNer Will also secure min ban. You are a wen lee aedk union the goods at property Other g a asoumy Interest to being purchased. ?(Dasuibey your shares and/or deposit In ace cm ? union. and: X Late Chsrr: a o p°yma d is tote tell 1 4aya er mess you veal 0.eyutted DeposR Balance: The Amoral Pwantiga Rata does Filing Foos: l f N NIA t Noruf Mng Insurance: WA be charged s 1410 tea of 5% of your duiad payment ana, any. = not leka depoa l ra 1.%. aoeoum your re"Inall $ •.• yma6• youppo • ,You to WYapa IY• y y we nw"ynw WMMM Lo cur alaatluYO dell aid pwpimaa pwrlwa enY r•rYsr aWY n era 19 cwncn 1 avw yr AMOUNT FINANCED $ ge,ollom Amount Paid to alms on your behalf iDesaids) =0,57&92 To CHASE $ TO AMOUNT GIVEN TO YOU DIRECTLY$ 24,372.11 $14.m6i TO ywSHN(rrON MUr $ To $ To $ To S To S To $ To $ To AMOUNT PAID ON YOUR ACCOUNT$ 48,003.46 To $ To T o $ To $ To $ TO S To $ To PREPAID FINANCE CHARGE $ OAO $ To $0.00 TO Fem $ To Allied Solutions S To Aaad 6outio n (_ . SECURITYINFORNIATION-- - -- - - -- MAKE MODEL YEAR I.D. NUMBER TYPE VALUE OTHER (Describe): 405 SHEELY LN You Pledge Shares AMOUNT' ACCOUNT NUMBER AMOUNT- - ACCOUNT NUMBER arid/or Deposits of $ S You agree that the Mime and cand'6ons No d'ad0sure alalemsnt and ace IM and Seafill, >-ewlMMa bated M papa 2 Of lob dOWmwa atlas apply to this loan. NOUre is more then ace borrower, we sirae mad all all bona or ace ban dead security "Merranis governing am lam ones apply to bath jointly and swomy. You ackrwwledgs that you have received a copy or ace ban and security groernenb end disdaaun slalameni. Co-signs R you we sigohg an Z or. you acknowledge remipt d the notice to co-signer contained on papa 2. BORR 'S E DAIIE FROWNER ? -CO-SIGNER DATE (S (sEAt) .4' t• GO-MAKER (3 'OTHER OWNEIV0 "CO-SIGNER DATE [3 COWAKER 0 -OTHER OWNER 0 "CO-SIGNER DATE X (SEAL) X (SEAL) C] C0 MITER 0 'OTHER O ER 0 '-CO-SIGNER DATE 0 C"AKER 0'OTHER OWNER 0 -CO-SIGNER DATE X (SEALI X (SEAL) anNrnYrrlr?yawntMtr ul?•puere ye?4i•r•rwrMrwlwwrl lnM•?..i•K1aNwWnr Wru lwe.iM Mwwnr,uNrrrW ?ww6?.NWwlpnMrMVau rates rYnaMr1M ewr?,mr?YM rl nnleu M,lele er YewwrMwwrrbwYlWy Ap,wnw,l"CO?ONW ape rYM.I6r rndtu,Yn neyawYinnWMMrewtern nr aeawrM MNr naM wro ice en t?Iwn TM N TO You are being asked to gal titlis debt. Think carafttNy It fare you do. If die borrower doesn't pay the debt, you will have to. Be sure you can afford to pay if you have to. and Baal you w t to accept gds fesponldbR 1 You may have to pay up to the full mound of the debt N the borrower does not pay. You may also have to pay late fees or collection vests, which Increase this amount. The creditor can collect this debt from you without first trying to collect from the borrower. The creditor can use the same collection methods against you that can be used against the borrower, an as suing you, garnishing your wages, etc. If this debt is ever in default. [hat fact may become a part of your orecilt record. This notice Is not the contra that makes you liable for the debt. Exhibit "A" 90RROW£R'S NAME LOAN NUMBER ACCOLNTNUMBER DATE OF LOAN DONALD K ESTRIGHT 278353 08/07/2008 IINTT& ?REQEO?TT&THE WORDS 'CREDIT UNION' MEANS MEMBERS 1ST FEDERAL CREDIT UNION, THE WORDS YOV,' YOUR' AND YOURS' MEAN THOSE LOAN AGREEMENT SECURITY AGREEMENT Allocation of Payments and Add credits sham be applied In the fo4a fees or charges owing, Including at or finance charges: outstanding pri regularly scheduled payments she Preferred Rate: If you qualmv form this document or in a separatte pro that you must meet the conditions preferred rate, and must continue I your preferred rate. If you fail to ml Increase, thereby extending the lei making payments and to meet and c you no longer receive the prefenm Late Charges: If you make a late if one is dia osedyon page 1 of thi: Property Insurance' If you obtain other tangible property. you must c For a received, you promise to pay, at s. AN paoyamrrtrenwtna ahau be made 6f this docurnerill. You pti pldlal al N tatlmee nl Ympsnla s old , if you l haw 0wg p faai Tor sH the mndilions of that preferred ,ce dm it le due, you w pay iad Payments: Payments and order: any amounts past due: any surance premiums; accrued Interest at. Payments made In addition to applied in the same order. 'erred rate as disclosed on page 1 of any Borrowers pri 1 resasana emeta Me pro mcwswn noucea re mlo?iriy iouMseyh%M goods. npal b an as adl, or are non-pure au 2. You rhl nol4llenW IM ion d, sell or Iransbr Ns Collateral unless you have the ered'A ralren's prhr wriBan consent 3. You warrant Ihal Y Mve plod life b Ne eollllataar, kee of d sgwrky intemsls :Neptdl 131vs"b:° collateral who has signed MM1:?rMn: t the Indicated dr place. 4. described iiand ftg?r aeproa b keap'Mia a apains?t podr alt onbrooused b a y sWlabb shdbr. You to amcuta . a feman and security pegr vulYd d?ereraedm in s request andtapalm defend the property ve rty vehicle cur other propart h which tin 5. You ale maintain Wtraocs b co e cede union has alayalpany Interest. 'Iha IonsulryattsoyapwIN be h a tog,, Wh an or such ani Lad ooe snit a sums; owwedculo uedlldualMS 3nd?sacurrad bvMb? Hof As be bpest verrtspaarrfoo?? 11161010011 ano atldraettaa utorsucYn to"her sayI a?+sv.Th assgn mums Chian ara rghl W reeNw IM proceeds a1 any Ineurenee on such pro d and any ' her to pry those podieyy to credit CIm unlopoarroovCc s the union b endarae ,,,=a u MR Drorlded as Viie rrsdsods of such Insure nor, and apply those proceeds to the sums owed to Vll union You fuller aulh a the Goon union to provide your:nsurance Samim Center with the necessary Infdmtatbn br ve,j kirk d adeeuale carerage. You acknowledge that atsurartca er an sxlenslon themd, plead by the credit will =.01A arest to you UN vldua?y but Isprrritriarrvay W the protection of the 6. II oiYcii b inroolf union real s?Mlf ?l sladd'wa ssasentarthas curgg Is required. a to the rlatlll tit fee a is namssary b prdict Ne trade utbn age possible Iwo. 7. at your choice and direct the agent poetry. Debtor Responsibility: You prc g, or shall your loan. You pose to continue ons under this Agreement even if 1t, you agree to pay a late charge ntutm. secured by a motor vehicle or nsumnce which protects the credit r wvera?9 of the propeny . g unon. Such a pamcy mush t credit union a Copy 01 ara any Hy credit not W apply for loane(ln hat you will be tmoble to repay r credit extension. You promise n which relates to your ability to ibmilfalse or Inaccurate agarding your creditworthiness, if any of the followtnp occur 1) Iii] to are for the M.- union may exercise this right M Delay in Enforcement Credit union rights under this agreem Irregular Payments: The cred payments, even though marke credit union rights under this m Co-makers: if you are string be equalyy responsible with thl either or boN of voce. The rxedl on at taw gives the credit union the dvidenels in you account(s) at e you are in default, the cret er notice to you. delay erdorcing any of the credit losing them. j accept late payments or partial n full, without losing any of the lent as a co-maker, you agree to out the credit union may sue s not have to noli you that this nlon may exterri a terms of notifying or releasing you from Cont IU 111969 e or snares: You W e all your shares and deyypalb In rno cradn union, Ineludlns lancers 1-'"- a..crntly for role bur. In pas You derautt, Ne ereWt union may aPPIY the is a shame an0 eepashe W Ina paYmant of all s u due at the tlma of --k I dueling spats of eotaetlon and reasonable ettorswy's M1M, mat w e h union may Maur, tq to 20% of No unpaid prlnclpal end Interest No man rlgM b Impress a pan on shares and deposits snaill wPy to any of your she a vdrleh may be helQ In an'TndlNdual Retlremenl Aecounr' or "Keogh Plan... 1. To secure payment or I 1 6100 2W Page 2 of 2 e. krIhe 'Iawpd??M Yar Aa10 paad the Cosalar. arW 1M 9. p VUVa Is mom thaanan one 0onswe"IN o wr,f r??obag dorm under Wx a0namam are pas and sa omi, each being equerry rmUpoaaitle to tulfM de terms or 1ma agreement 10. This saarray agreement not only binds you. but your executors, admir"Iretors. hatm, and asslr ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and Stato of Pennsylver?lo, more particularly boupded and dascrioo,i ag fc)ilows, to wit: aEGINNINCa at an iron pin which pin Is on the dividing line batwaen lands of Anthony J. Clan and Pearl V_ Dieri, his wife, and land now or late of L.D. Sharman and said, pin being located on a bearing of South forty-eight (48) degrees fifty-tour (54) Minutes East and dlat4nt two hundred five and six tanth$ (205.8) feet from another pin in the center line of Trindle Road; THENCE South forty-eight (48) degrees fifty-four (54) minutou EOst and along aforesaki dividing line, a distance of ones hundred forty-nine (148) to an Iron pin; THENCE South forty-cmd (41) degrees West, a distance of one humrad twelves (112) Bret to another iron pin; THENCE North fifty-thred (53) degrees W03t and along tine of land reserved for road istpp$, a distance of one hundoW forty, nine (148) feet to an iron pin; THENCE North forty (40) degrees fifteen (15) minutes Eatit, a distance of one hundred twenty-two and eight tenths (122.8) feet to an iron pin, the paint and PluGe of BEGINNING. LAVING HEREON ERECTED a dwelling house known as No. 405 Shealy Lane_ The premfses herein described are granted and convoyed under and conveyed under and subjgrt W a twgtva (12) foot right way, which right of way is located on the bearing South farty--eight (48) degrees fifty-four (54) minutes East and is a Mritinuation of the right of way from Trintlie Road over other lands of Anthony J_ Cieri and Paart V. Clari, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1934, granted and conveyed unto Robin Lynn Estright, single individual. Exhibit `6B" P*epared By: Members 1st FCU 5000 Louise Drive Mechanicsburg, PA 17055 WHEN RLCORDLD, RETURN TO: EQUITYLOANSERVICES, INC. 1100 SUPERIOR AVENUE, SUITE 200 CLEVELAND, OHIO 44114 NATIONALRECORDING - TEAM5 PuQA ?JU04zr: Z5-6561 -UV5?-6660 o-10 MORTGAGE Made 08/07/2008 Between DONALD 'K ESTRIGHT AND ROBBIN L ESTRIGHT (hereinafter called "Mortgagor") And MEMBERS 1ST FEDERAL CREDIT UNION 383a3 (hereinafter called "Mortgagee") Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of $ 96,000.00 lawful money of the United States of America, and has provided therein for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and containing certain other terms and conditions, all of which are specifically incorporated herein by reference; Now, Toerefore, Mortgagor, in consideration of said debt or principal sum and as security for the payment of?the same and interest as aforesaid, together with all other sums payable hereunder or under the terms of?the Note, does grant and convey unto Mortgagee, All that pertain property of the Mortgagor located in HAMPDEN TOWNSHIP , Cumberland County, Pennsylvania SEE EXHIBIIT "A" which currently has the address of 405 SHEELY LN [Street] Mechanicsburg Pennsylvania 17050 [City] [Zip Code] ° 27635309 Acct No j AppID Page 1 of 4 0 Exhibit "C9 Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversions, remainders, rents, issues and profits thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever. Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and 'conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The 'Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans, or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by:Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, When and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and chargesi thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) prommptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this substantial repair, as determined by Mortgagee. Mortgagee shall have the right to mortgaged remises at any reasonable hour for the purpose of inspecting the order of the buildings and improvements erected thereon. Mortgage in good and enter upon the , condition and repair Acct No Appm 27635309 Page 2 of 4 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In CE se default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become im7,ediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage a d prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit, and an attorney's commission for collection of five percent (5%) of the total indebtedness or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upoln payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor hall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. The cove nants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. Acct No AppID 27635309 Page 3 of 4 Witness the due execution hereof the day and year first above Commonwealth o ennsylvania County of l? On this, the day of LL . ss: y? rf _, 2008 ,before me, ? / personally appeared roven to me to be the person(s) whose name(s) is/are subscribed to that he/she executed the same for the purposes therein contained. and In Witness Whereof, I hereunto set my hand and official se My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Deborah K. Myers, Notary Public mpden Twp., Cumberland County M Commission Expires April 18, 2011 Memb r, Pennsylvania Association of Notaries Certificate of Residence of Mortgagee Members' 1ST Federal Credit Union, Mortgagee withi named, hereby certifies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. By Acct No AppID 27635309 Page 4 of 4 EXHIBIT A All that certain property situated in the Township of Hampden, in the County of , Commonwealth of Pennsylvania , and being described as follows: 10-23-0561-058. Being more fully described in a deed dated 03/23/00 and recorded 04/06/00, among the land records of the County and State set forth above, in Deed Volume 218 and Page 1034. ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF HAMPDEN COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT AN IRON PIN WHICH PIN IS ON THE DIVIDING LINE BETWEEN'LANDS OF ANTHONY J. CIERI AND PEARL V. CIERI, HIS WIFE, AND LAND NOW OR LATE OF L.D. SHERMAN AND SAID PIN BEING LOCATED ON A BEARING OF SOUTH FORTY-EIGHT (48) DEGREES FIFTY-FOUR (54) MINUTES EAST AND DISTANT TWO HUNDRED FIVE AND SIX TENTHS (205.6) FEET FROM ANOTHER PIN IN THE CENTER LINE OF TRINDDLE ROAD; THENCE SOUTH FORTY-EIGHT (48) DEGREES FIFTY-FOUR (54) MINUTES EAST AND ALONG AFORESAID DIVIDING LINE, A DISTANCE OF ONE HUNDRED FORTY-NINE (149) TO AN IRON PIN; THENCE SOUTH FORTY-ONE (41) DEGREES WEST, A DISTANCE OF ONE HUNDRED TWELVE (112) FEET TO ANOTHER IRON PIN; THENCE NORTH FIFTY-THREE (53) DEGREES WEST AND ALONG LINE OF LAND RESERVED FOR ROAD SLOPE, A DISTANCE OF ONE HUNDRED FORTY-NINE (149) FEET TO AN IRON PIN; THENCE NORTH FORTY (40) DEGREES FIFTEEN (15) MINUTES EAST, A DISTANCE OF ONE HUNDRED TWENTY-TWO AND EIGHT TENTHS (122.8) FEET TO AN IRON PIN, THE POINT AND PLACE OF BEGINNING. THE PREMISES HEREIN DESCRIBED ARE GRANTEDAND CONVEYED UNDER AND CONVEYED UNDER AND SUBJECT TO A TWELVED (12) FOOT RIGHT WAY, WHICH WHICH RIGHT OF WAY IS LOCATED ON THE BEARING SOUTH FORTY-EIGHT (48) DEGREES FIFTY-FOUR (54) MINUTES EAST AND IS ACONTINUATION OF THE RIGHT OF WAY FROM TRINDLE TOAD OVER OTHER LANDS OF ANTHONY J. CIERI AND PEARL V. CIERI, HIS WIFE. BEING THE SAME PREMISES WHICH MARGARET A. RYAN, BY DEED DATED APRIL 6, 1971 AND 38303039 EXHIBIT A (continued) RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK A, VOLUME 24, PAGE 421, GRANTED AND CONVEY UNTO JUAN RODRIQUEZ AND GLADYS RODRIQUEZ, HIS WIFE. THE SAID GLADYS RODRIQUEZ DIED JULY 12, 1994, THEREBY VESTING THE FEE TITLE IN JUAN RODRIQUEZ, GRANTOR HEREIN. TOWNSHIP OF HAMPDEN Permanent Parcel Number: 23,0561-0058-0000000-10 ROBIN LYNN ESTRIGHT, SINGLE INDIVIDUAL 405 SHRELY LANE, MECHANICSBURG PA 17050 Loan Reference Number 276353 First American Order No: 38303039 Identifier: L/FIRST AMERICAN LENDERS ADVANTAGE IIIIIIIIIIIII111I11111G ESTRIGHT 38303039' PA FIRST AK?RICAN ELS MORTGAGE', 111111111111111111111111lIli111111111111111H1III ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200828266 Recorded On ':8/19/2008 At 10:39:51 AM * Instrument Type - MORTGAGE Invoice Number - 27328 User ED - MBL * Mortgagor - tSTRIGHT, DONALD K * Mortgagee - MEMBERS 1ST FEDERAL CR UN * Customer - FIRST AMERICAN * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $15.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $42.50 I Certify this to be recorded in Cumberland County PA - /4 RECORDER O D DS * Total Pages - 7 Certification Page DO NOT DETACH This page is now part of this legal document. * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111111111111111 Date: 0312612012 HOMEOWNER'S NAMES: DONALD K ESTRIGHT ROBBINL ESTRIGHT LOANACCOUNT NO.: 183124-0009 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Members 1st Federal Credit Union (hereinafter we, us or ours) on your property located at 4105 SHEELY LN, MECHANICSBURG,PA 17050 IS IN SERIOUS DEFAULT [because you have not made the monthly payments of $891.30 for 12-05-2011, $898.26 for 01-05-12, $898026 for 02-05- 12 and $898.26 for 03-05-12 ,,and/or because 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 $3,586.08 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $3,586.08 , 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: Attn: Collections Department c/o Memberslst Federal Credit Union P.O. Box 40 5000 Louise Drive Mechanicsburg, PA 17055 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 your 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 stale [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 six months from now. 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 increas& 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: (717) 795-5165. 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. Exhibit "D" 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 THi, 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. Certified Mail: 9171999991703111241507 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 'I 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. Certified Mail: 9171999991703111241484 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, PROVID D THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COTS 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. Certified' Maii: 9171999991703111241477 Servioemembers Civil U.S. Department of Housing MB Approval No. 2502-0565 Relief 'Act and Urban Development (exp 4/30/2007) Notice Disclosure Office of Housing Legal Rights and Protection nder the SC'RA Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicetnembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA). Who May Be Entitled to Legal Protections Under the RA? Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard; Active service members of the commissioned corps of the National Oceanic and Atmospheric Administration; Active service members of the commissioned corps of the Public Health Service; United States citizens serving with the armed forces of a nation with which the Unified States is allied in the prosecution of a war or military action; and • Their spouses. What LMa-l Protections Are ervicememhers Entitled m Under the SC RA? • The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. • The SCRA contains many other protections besides those applicable to home loans. How Does A ervicemember or D pendent RtU-W RehefUnder the l?t1 SC "' ? as a_G¦ a,u In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members 1" Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. Ha& Does a Servicemember or Dependent Obtain Information About the SC A? J'he U. S. Department of Defense's information resource is "Military OneSource". Website: http://www.militaryonesource com The toll free telephone number for Military OneSource are: o From the United States: 1-800-342-9647 o From outside the United States (with applicable access code): 800- 3429-6477 o International Collect (through long distance operator): 1-484-530-5908 Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at http:/(legalassistance law of mil/content/locator php USPS.com® - Track & Confirm English Customnr a.,!.. USPS Moblln cusps*mY Quick TOOK Ship a Package Send MFII Manage Your MBA Track & Confirm YOUR LABEL NU69BER SERVICE 9171999991703111241463 First-Class Mali* Page Rnglmar: Sign In Search l1SPS.com or Track P;tckttges Shoo Business Solutions STATUS OF YOUR ITEM GATE&7%15 _OCATION FEATURES DeMered March 31. 2012, 3:35 pm ENOLA, PA 17025 ! Return Receipt Electronic Depart USPS Sort March 27, 2012 HARRISBURG, PA 17107 Facility Processed at USPS !March 26, 2012, 10:51 pm HARRISBURG, PA 17107 Origin Sort Facility Accepted at USPS ! March 26, 2012, 9:36 pm + MECHANICSBURG, PA 17055 Origin Sort Facility Electronic Shipping Into ! March 26, 2012 Received Check on Another Item What's your label (or receipt) number? LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES ?nvacy i'o!Iiy > Govemmont Services > About USPS I lorio Business Cusiornur Gateway) T ;rm, of Use , Buy Slamps & Shop, Nwsrooni : Postal Inspectors - FOIA , Pint a f.abel with Postage. Mai! Service, Updaies % mspaclar Go,we'a! w No FEAR At.,. EEO Gala r Custorriar Service, Forms & P:bimmllorls > Pon Lal Expi vur , Sate Index; Carvers Copy6ght,:%25_112 US!'$. AI! Rights Reserved. Exhibit "E" https://tools.usps.com/go/TrackConf 5/10/2012 D? H,;'Lle Date: 05/10/2012 DONALD ESTRIGHT: The following is in response to your 05/10/2012 request for delivery information on your Certified Mail(TM) item number 7199 9991 7031 1124 1484. The delivery record shows that this item was delivered on 03/31/2012 at 03:35 PM in ENOLA, PA 17025. The scanned image of the recipient information is provided below. ------------ Signature of Recipient: ftd Doa Sr1??Gri Address of Recipient: Thank you for: selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service USPS.com® - Track & Confirm English Customer Service LISPS Mobile Page Rngietar! Sign In USPS-C m, Search USPS.cota or Track Packages Quick Toots Ship a Package Sond Mall Manage Your Mall Shop Business Soluiions Track & Confirm r7 E¢(mL 1 YOUR LASEL NUMBER SERVICE STATUS OF YOUR ITERt DATE a TUAE LOCATION FEATURES - ! 9171999591703111291L77 First Class MalP Delivered March 31, 2012, 3:33 pm ENOLA, PA 17025 Return Receipt Electronic Depart USPS Sort March 27, 2012 HARRISBURG, PA 17107 Facility Processed at USPS March 26, 2012, 10:51 pm HARRISBURG, PA 17107 Origin Sort Facility j Accepted at USPS March 26, 2012, 9:36 pm 1 MECHANICSBURG, PA 17055 Origin Sort Facility Electronic Shipping Info March 26, 2012 Received Check on Another Item What's your label (or receipt) number? LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Privacy Policy, Government Services > About USPS Home; Busine3L' Cus"Omer Gateway, Terms of Use) Buy Stamps & Shop, Newsroom 1 Postal Inspectors FOIA , Pfinl <: Label with Postage> tvlail Service Upd-,flea irmtieckij General No FEAR Art EEO Data, Customer Service: a Forms & Publlrxlons, Poaiai Explorer, Site Index ; Careers, :'Ap'y'i[J'',?I'-%1.; `:: USPS. All ,'il5th 15 RLSG :ed, https://tools.usps.com/golTrackConfi miAction input?qtc_tLabelsl=917199999170311124... 5/10/2012 u SaAr'Es SE rrvreE. Date: 05/10/21012 ROBBIN ESTRIGHT: The following is in response to your 05/10/2012 request for delivery information on your Certified MaiIjTM) item number 7199 9991 7031 1124 1477. The delivery record shows that this item was delivered on 03131/2012 at 03:33 PM in ENOLA, PA 17025. The scanned image of the recipient information is provided below. --------.r- Signature of Recipient: r ? - -- - ? x= re 00 }?s RS??r Address of Recipient: b s j ?6 P?QO? Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service •e UJPS.com® - Track & Confirm Page 1 of 1 English Customer Service USPS Mobi a Register I Sign In US1Sii Search USr S.rrrn or Trarlc Packtsyt•?s Quick "fools Ship a Package Send Mail Manage, Your Mali Shop Business Solutions Track & Confirm YOUR LABEL NUMBER SERVICE STATUS OF YOUR ITEM DATE 3 TIME LOCATION FEATURES . 9177999991703111241507 :First-Class Mall Delivered April 02, 2012, 8:15 am MECHANICSBURG, PA 17055 j Return Receipt - Electronic Notice Left ? March 27. 2012, 10:23 am MECHANICSBURG, PA 17050 ?. Arrival at Unit March 27, 2012, 5:55 am MECHANICSBURG, PA 17055 i Depart USPS Sort March 27, 2012 ! HARRISBURG, PA 17107 ':. Facility _ Processed at USPS j March 25, 2012, 10:58 pm :HARRISBURG, PA 17107 - Origin Sort Faculty Accepted at LISPS March 28, 2012, 9:41 pm MECHANIGSBURG, PA 17055 Origin Sort Facility I Electronic Shipping Ink March 26. 2012 i Received Check on Another Item What's your label (or receipt) number? LEGAL ON USPS.COM Privacy Policy: Government Services Terme oi' Use, Btry Stamps & Shop , FOIA , Print a Label with Postage No FFA: Act =EO Data : Customer Service r Site Index > ON ABOUT.USPS.COM ADeut USPS Home Newsroom , Mal Service Updates Forms It Publicatlons Carew's. OTHER USPS SITES Business Custon g Gatcwav Postal inspector, 1:1.spector General Postal Explorer, Con:r4,?i+M 2C :2 LISPS. fili Ri?jt?ts Reserved httnc•//tnnlc rtena nnm/rrn/Trar`lr( nnfrm A r+;nn on+inr, C/1 (1 /1) n1 1) STAM SE -MVICE, OS M L Date: 05/10/2012 DONALD ESTRIGHT: The following is in response to your 05/10/2012 request for delivery information on your Certified Mail(TM) item number 7199 9991 7031 1124 1507. The delivery record shows that this item was, delivered on 04/02/2012 at 08.15 AM in MECHANICSBURG, PA 17055. The scanned image of the recipient information is provided below. Signature of Recipient: Address of Recipient: acs C1' ev-i `A KO Thank you for',selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service USPS.com® - Track & Confirm Page 1 of 1 Englixh Cuatnmar Service USPS Mohile Register! Sign ht "USPICOV Search USPS.corn or Track Package::; Quick Tools Shit: a Package Send Mail Manage Your Mali Shop Buswoe: S So u!ions Track & Confirm YOUR LABEL !.UMBER. SERVICE STATUS OF YOUR ITEM DATE a TIME '_OCATION FEATURES 9171339991703111241491 First-Class Maile Delivered April 02, 2012, 8:15 am : MECHANICSBURG, PA 17055 Return Receipt Electronic Notice Loh '. March 27, 2012, 10:23 am MECHANICSBURG, PA 17050 Arrival at Unit March 27, 2012, 5:55 am MECHANICSBURG, PA 17055 Depart USPS Sort March 27, 2012 HARRISBURG, PA 17107 -- Facility Processed at USPS j March 26, 2012, 10:56 pm HARRISBURG. PA 17107 '.. Origin Sort Facility i Accepted at USPS March 26, 2012, 9:41 pm MECHANICSBURG, PA 17055 Origin Sort Facility !. Electronic Shipping Info March 26, 2012 - Received Check on Another Item WhaV$ your label (or receipt) number? " . LEGAL ON USPS.COM ON ABOUT.USPS.COM OTHER USPS SITES Pn:acc Po icy ' C overnrrieca Services : ALoUt JSPS Horne, Business Cusrorner Gatev:a•: . berms _: Us,, Bay Stamps E Shop, kevrsroom - Poswl Inspectors . FOIA , Pinta Laacl with Postage , Mail Eerv .e Jpdatas ins ec D, Geneo ai ; No FEAR iact EEO DaU:: Grsr? ?e:r :>eNirr:: • f-or;rs fi PuhScotau : ?octal Exp!r,: er , to Index Car ee e , .:ryr ghMi2'? JS;)S At Rtghte RaserveG https://tools.usps.cor /go/TrackConfum,Action input?qtc tLabelsl=917199999170311124... 5/10/2012 Date: 05/10/2012 d IT- ROBBIN ESTRIGHT: W The following is in response to your 05/10/2012 request for delivery information on your Certified Mail(TM) item number 7199 9991 7031 1124 1491. The delivery record shows that this item wap delivered on 04/02/2012 at 08:15 AM in MECHANICSBURG, PA 17055. The scanned image of the recipient information is provided below. Signature of Recipient: Address of Recipient: ?U5 qr\ep-\,? `A\wo Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service 05/17/2012 11:04 7179320317 KARLLEDEBOHM PAGE 08/16 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAIN TIFF Vs. NO.. DONALD K. ESTRIGHT and R0130IN L. ESTRIGHT aWa ROBIN LYNN ESTRIGHT CIVIL ACTION - i,AW DEFENDANTS : MORTGAGE FORECLOSURE VER TCA TION 1, Lynn. Unger, Bankruptcy Specialist, for Members 14k Federal Credit Union, being authorized to do so on behalf of Members 1 st Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false ,statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Members I" Federal Credit Union .By. ' Lynn "er, B Specialist 6 rr° fir,.- s? 2L121!AY 25 Fi d 2 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 CUtjii3ERLr s-? U '::6U1411 PENNSYLt A141A MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS NO.. : CIVIL ACTION - LAW MORTGAGE FORECLOSURE 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. THIS PROGRAM IS FREE. Date: 1 M. Lede o , Esq Supreme Court ID #59012 P.O. Box 173 c New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff S 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: Loan Number: Second Mortgage Lender: Type of Loan: I_,oanNumber: Total Mortgage Payments Amount: $ Date of Last Payment: 1'rirn v Reason forDefault- State _ Office: _ Other: Date You Closed Your Loan: State: Zip: Yes F'; No ? Listing date: Price: $_ Realtor Phone: Yes ? No [7Home: Cell: How long? Home: Cell: Office: Other: Zip: State-.__-- Zip: How long? 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: $ $ Retirement Funds: $ $ Investments: $ _-- Checking: $ Savings: $ $_ Other: $ $._ Automobile, #l: Model: Amount owed: Value: Automobile 92: Model: Amount owed: Value: Other transportation (automobiles boats motorcycles): Model: Year: Amount owed: Value_ Monthly Income Name of Employers: 1. 2. ----- - ----- - I _ 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" Mort a 'e Car Payment(s) Utilities Condo/Nei h. Fees Auto Insurajnce Med. not covered Auto fuel/r' airs Other prop. payment Install. Loap Pa ment Cable TV Child Su ort/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax:___ Year: Year: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? if yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): 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. UWe understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFFiCE,:,l THE SH:R?PF Jody S Smith Chief Deputy Richard W Stewart Solicitor }E}2 J1.? i 2 9 Members 1st FCU vs. Donald K Estright (et al.) Case Number 2012-3323 SHERIFF'S RETURN OF SERVICE 06/01/2012 08:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 1 2012 at 2045 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: Robbin L. Estright, by making known unto herself personally, at 405 Sheely Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. _ STEPHEN BENDER, DEPUTY 06/01/2012 08:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 1 2012 at 2045 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: Donald K. Estright, by making known unto imself personally, at 405 Sheely Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY 06/06/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 405 Sheely Lane, Mechanicsburg, Pennsylvania 17050, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclousure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Occupant. Request for service at 405 Sheely Lane, Mechanicsburg, Pennsylvania 17050 is only occupied by Donald and Robbin Estright. SHERIFF COST: $75.00 June 06, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CounfySuite Sheriff. Teleoso't. Inr,_ FORM 3 MEMBERS 1st FEDERAL CREDIT UNION, Plaintiff(s) VS. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT, Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAT No. 12-3323 CIVIL REQUEST FOR CONCILIATION CONFERENCE X ;Z s MW ?` f P7 ;f'!t C " -? Pursuant to the Administrative Order datedFeb. 28 , 2012 governing the Cumberla County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: Defendant is the owner of the real property which is the subject of this 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 unworn falsification to authorities. LIE& Signature of N&Kdant's CounseUAppointe Da e Legal Representative i tore a endant Date Signature of Defendant Date a MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff V S. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA... C ~-'A . ~~: :~ e, CIVIL ACTION ~,~rYY f~ ~` _ a: , NO. 12-3323 CIVIL ~~=. .,. . _.. ; ... t i47 - ,- - ,' ~. .f, .- CASE MANAGEMENT ORDER AND NOW, this ~~ day of August, 2012, 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 acourt-supervised conciliation Conference on ~~(;ti~2 3 d Odd , at o2~m. in Chambers No. 4 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 F Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in w7iting 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 rnutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation. conference. BY THE COURT, / Karl Ledebohm, Esquire For the Plaintiff i/ Anthony DeLuca, Esquire For the Defendants a~ ~~ ies C~ ,~ s ~~~ -- rlm MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff : vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT, Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 12-3323 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this l B ~ day of October, 2012, following phone conference with counsel, the conference set for Friday, October 19, 2012, at 10:00 a.m. is continued until Thursday, November 1, 2012, at 11:30 a.m. in Chambers of the undersigned. BY T'HE COURT, Kevin /Karl Ledebohm, Esquire For the Plaintiff /Anthony DeLuca, Esquire For the Defendants :rlm ~A~~C'S N~Q~'~~d ~~~/~~~~ ~°/~ s~ /r,l - a �, 11 U∎ J'Ii „Lt NU COUNT ';, PENNSYLVANIA Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF • Vs. : NO.: 12-3323 DONALD K. ESTRIGHT and • ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION- LAW DEFENDANTS : MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION(MORTGAGE FORECLOSURE) TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, Amount Due: $103,807.26 Interest from: 10/26/12 to 11/8/12 at the rate of$19.8514 per day and at the legal rate thereafter to be added Attorney's fees $ to be added Costs $to be added Directed to the Sheriff of Cumberland County, Pennsylvania; To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the following real property: All that certain real estate and improvements erected thereon situate in Hampden Township, Cumberland County,Pennsylvania,known and numbered as 405 Sheely Lane, a) Mechanicsburg, PA 17050 and as more particularly set forth and described on Exhibit "A"attached hereto and made part hereof by reference. auk- S \:)(k CA-4C6T ''gyp << ``1 WH.k• CS( 4 Dated: February 28, 2014 / • Karl M. Ledebohm, Esquire Supreme Court ID#59012 P.O. Box 173 New Cumberland,PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road;thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin;thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin;thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin,the point and place of BEGINNING. HAVING thereon erected a dwelling house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way,which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez,widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058 Exhibit "A" I Karl M.Ledebohm,Esquire ill:1 trt.1 P.O.Box 173 s - ±''_,M; New Cumberland,PA 17070-0173 {,�l ,[ L�� h s (717)938-6929 PEI` SYL�,''r"�.NIA MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF • Vs. : NO.: 12-3323 DONALD K. ESTRIGHT and • ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION- LAW DEFENDANTS : MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1St Federal Credit Union,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 in Hampden Township, Cumberland County, Pennsylvania,known and numbered as 405 Sheely Lane, Mechanicsburg, PA 17050. 1. Name and address of owner(s)or reputed owner(s): Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 2. Name and address of defendant(s) in the judgment: Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Robbin L. Estright&Donald K. Estright do Anthony L. DeLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs,PA 17007 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1"Federal Credit Union Attn.: Dan Summers, Collection Manager 5000 Louise Drive Mechanicsburg, PA 17055 Discover Bank do Edward Stock, Esquire 804 West Avenue Jenkintown, PA 19046 Discover Bank 12 Reads Way New Castle, DE 19720 4. Name and address of the last recorded holder of every mortgage of record: Members 1 St Federal Credit Union Attn.: Dan Summers, Collection Manager 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: 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: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 405 Sheely Lane Mechanicsburg,PA 17050 U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 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 unworn falsification to authorities. Date: February 28, 2014 Respe fu s mi0ed, /1/V- arl M. Ledebohm, sq. Supreme Court ID#: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff w cU 4. ,. . e.u i1'rjs, Flt 3: :4 C 7PEt NS YLYA NIA _fC' Dr t;1 f J CO riAiq i fi Karl M.Ledebohm,Esquire P.O.Box 173 New Cumberland,PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-3323 DONALD K. ESTRIGHT and • ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION - LAW DEFENDANTS : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Robbin L. Estright&Donald K. Estright c/o Anthony L. DeLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT ti PURPOSE. HOWEVER,IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 405 Sheely Lane, Mechanicsburg, PA 17050, as more particularly set forth and described on Exhibit"A"attached hereto and made part hereof, is scheduled to be sold at Sheriff's Sale on June 4,2014 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $103,807.26 plus interest at the rate of$19.8514 per day from October 26, 2012 to November 8, 2012 and at the legal rate thereafter until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs and additional reasonable legal fees, if any, and other costs and charges collectible under the mortgage, if any, or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at(717)938-6929. 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped,your house(real estate)will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the County Courthouse,which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate)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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before (within thirty(30)days after the Sheriff 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 the schedule of distribution is filed by the Sheriff 7. You may also have other rights and defenses, or ways of getting your house 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 OR(800)990-9108 The Sheriff's phone number is: (717)240-6390. 'coop Ara I - Aild Karl M. edebohm, Esquire Supreme Court ID#59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road;thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin;thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin;thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin,the point and place of BEGINNING. HAVING thereon erected a dwelling house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-3323 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION Plaintiff(s) From DONALD K.ESTRIGHT AND ROBBIN L. ESTRIGHT A/K/A ROBIN LYNN ESTRIGHT (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: $103,807.26 L.L.: $.50 Interest FROM 10/26/12 TO 11/8/12 AT THE RATE OF$19.8514 PER DAY AND AT THE LEGAL RATE THEREAFTER TO BE ADDED Atty's Comm: Due Prothy: $2.25 Atty Paid: $223.75 Other Costs: Plaintiff Paid: Date:3/3/14 David D. Buell,Prothonota (Seal) _ Deputy REQUESTING PARTY: Name: KARL M. LEDEBOHM, ESQUIRE Address: P.O. BOX 173 NEW CUMBERLAND,PA 17070 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 0 17 1"." HiJ _ 201R 28 PM 1: 05 CUMBERLAND COUNTY PE t+INS LVAN1 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO Pa. R.C.P. 3129.2 (c) I, Karl M. Ledebohm, Esquire, hereby swear and affirm that on the 14th day of March, 2014, I served the attached NOTICE OF SHERIFF'S SALE OF REAL PROPERTY pursuant to Pa. R.C.P. 3129.2(c) in the above captioned matter upon the individuals/entities by first class mail, postage prepaid as set forth on the PS Form 3817, copies of which are attached as Exhibit "1" and made part hereof. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infoimation 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. Date: March 26, 2014 Respe arl M edebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 12-3323 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE TO: ALL PARTIES IN INTEREST AND CLAIMANTS Owner(s): Property: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Donald K. Estright & Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane Mechanicsburg, PA 17050 (Legal description attached) Judgment Amount: $103,807.26 The above-captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on June 4, 2014 at 10:00 a.m in the Office of the Sheriff, Cumberland County Courthouse, One Courthouse Square, South Hanover Street, Carlisle, PA 17013. Our records indicate that you may hold a mortgage, judgment, or other interest with respect to the property which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after the sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriff Sale upon your lien, I urge you to CONTACT YOUR OWN ATTORNEY as I am not permitted to give you legal advice. Date: March 14, 2014 Respec arl M. Ledebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road; thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin; thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin; thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin, the point and place of BEGINNING. HAVING thereon erected a dwelling house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058 Exhibit "A" • UNITED STATES Certificate Of Prital POSTAL SERVICE, Mailing This Certificate of Mailing provides evidence that mae has been Presented to USPSO for mating This form may be used for domestic and ■nternational rirdfl From: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building — 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 PS Form 3817. April 2007 PSN 7530-02-000-9065 UNiTED STATES Certificate Of POSTAL SERVICE Mailin' This Certificate of Mailing provides evidence that malt has been presented to USPS® for This form may be used for domestic and internationaf il From Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To: Occupant 405 Sheely Lane Mechanicsburg, PA 17050 ;L• rn — c :C> r, • MX (Z IA —:E-O• z- vi) :D -!! to • M '0 h.— , s ' ■ i .. 7i rIC :3 C AV" :0 Cl • 35:12 C.: (/) pow.111 -..1* c.o.orrh--.-0 z- -4:000 --; •or- 41) :0 —I CO b Cl • M "0 :0 PS Form 3817, April 2007 PSN 7530-02-000-9065 Exhibit "1" uNi t ED STATES POSTAL SERVICE, Certificate Of Mal This Cedtficate of Mailing provides evidence Vial oai haS been presented to USPSO fo, reatItes This for, may be uSed for domestic and ■nlernattooal rebil from Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To Inheritance Tax Bureau Commonwealth of PA — Department of Revenue Bureau of Individual Taxes - Dept 280601 Harrisburg, PA 17128-0601 .;" PS Form 3817. April 2007 PSN 7530-02-000-9065 UNITED STATES Certificate 0' POSTAL SERVICE Malin rni5 eocaIo of Mailing provides eincicr ■:■& reSerle0 ic 1.1SPSI f■-; f f-0,11 may be used for dorneSile ar0 rcvi Fiorn Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To _ Department of Public Welfare TPL Casualty Unit — Estate Recovery Program P.O. Box 8486 — Willow Oak Building Harrisburg, PA 17105-8486 co t2 PS Form 3817. Aprii 2007 PSN 7530,02 000-9065 urVI LI.) LS Certificate 0! POSTAL SERVICE, ' ,n,:mlo,m may be used Mr domesttt: and toter,attorta ntaii Mailin I op, ced,lisate of Marling pro.de ev,def t,et mat ,a ros beer. eteseeted lc tJSPSZ matt,. _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 ‘C:1 To ‘4? — Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 co PS Form 3817, April 2007 PSN 7530-0:2-uuu-m,), urvi IL,' LS Certificate Of POSTAL SERVICE Mailing [re. Cedd.cate of Matting provides €vfder t.0 naS Dee, Ufe,seofed to ;JSPSZ r. [fro form may be used or domesItc 0/ 001' ryp(I Karl M. Ledebohm, Esq. New Cumberland, PA 17070-0173 P.O. Box 173 To - Domestic Relations _ Cumberland County Courthouse One Courthouse Square — Carlisle, PA 17013 rfA Cl F 1:,0 CZ (/) 3 ^:C77. 0.--,JCO2> 2- ■J:000 :o z 1-4 0 C-) • m -0 :D PS Form 3817, Aprii 2007 PSN 7530 02-000-9065 , plow..11 00 r; :1) F cz 3 —=E-0. Z• -J:000 •C01— :0 00 • m -0 :0 UNilEDSTlTES POSTAL SERVICE: rn< Certificate C Mailin �- CeniftCale of Matting proms, rht, farm may be des E ar.er .E in: n;.. nay JeEr. used for dcmes;,c and �nlernahe:.a rr+att presented le USPS? f from o• nau, n._ O N o O 7 • _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 To _ Members 15( Federal Credit Union Attn.: Dan Summers, Collection Manager — 5000 Louise Drive Mechanicsburg, PA 17055 PS Form 3817• April 2007 PSN - 530- 02 -G00 -9065 !1 UNiTED SPATES Certificate Of POST/!L SERVICE, Mailing This Certificate of Mailing provides evidence that mail has been presented to USPS® for ma�iing This form may be used for domestic and international r ibit From. To Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 _ Discover Bank 12 Reads Way New Castle, DE 19720 PS Form 3817. April 2007 PSN 7530 -02- 000 -9065 00 m -o :0 rn :D Cl • 3D:0 — Ci'DV7 O ^ —JCOD c_nornDc • J -000 •or0 --I 7-.m. m -0 :0 �— iiNi ED S TL T ES � 150STL1 L SERVICE. Certificate Of e Certificate or Mailing provides ev�dEr _ Ma I I i n C r h:, loan may be used for domestic 'e ina: nr., nas Jeer, I turn artl inlPrnali r�tl prESenled to UiP$:? /,: mailing — Karl M. Ledebohm, Esq. _ P.O. Box 173 New Cumberland, PA 17070 -0173 To — Robbin L. Estright & Donald K. Estrig c/o Anthony L. DeLuca, Esquire 113 Front Street, P.O. Box 358 — Boiling Springs, PA 17007 PS Form 3817• April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE This Certificate of Mailing provides evidence that mad has ` This form may be used for domestic and international rs as been presented to USPS® for mailing. From' cp O Certificate Of Mailin me!er postage here N z m O N j m N n D (- • 3_0 ( (/) O --JCOD Z_no ( Z. -..1:000 :000 :000 O _o :— („ O D -� —1 CO CD C) -o m :0 To pay lee affix stamps of Karl M. Ledebohm, Esq. P.O. Box 173 is New Cumberland, PA 17070 -0173 I� To: — Discover Bank c/o Edward Stock, Esquire 804 West Avenue — Jenkintown, PA 19046 PS Form 3817. April 2007 PSN 7530 -02- 000 -9065 o 71311i APR 15 T11:5 PENNSYLVANIA Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF/Movant Vs. : NO.: 12-3323 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION - LAW DEFENDANTS/Respondents : MORTGAGE FORECLOSURE PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its attorney, Karl M. Ledebohm, Esquire, moves the Court to direct the Prothonotary to amend the judgment and the writ of execution in this matter, and in support thereof avers the following: 1. Plaintiff, Members 1st Federal Credit Union (sometimes hereinafter "Members 1st "), filed its complaint in mortgage foreclosure (the "Complaint ") in the above captioned matter against the above captioned defendants (collectively "Defendants ") on May 25, 2012. 1 2. Although the concurrence of Anthony L. Deluca, Esq., (appointed to represent Mr. and Mrs. Estright in connection with the Cumberland County Residential Mortgage Diversion Program) has been sought pursuant to Local Rule 208.2(d), on April 10, 2014, attorney Deluca informed counsel for Plaintiff that he does not represent Defendants. 3. Judgment (the "Judgment ") in the principal amount of $103,807.26 and for foreclosure and sale of the mortgaged property identified in the Complaint (the "Property ") was entered on November 8, 2012 based upon the amounts set forth in the stipulation of the parties (the "Stipulation ") attached to the Praecipe for judgment filed on November 8, 2012. 4. On March 3, 2014, Plaintiff issued a writ of execution (the "Writ of Execution ") in the above captioned matter and the Property is currently scheduled for Sheriff's Sale on June 4, 2014. 5. Since the date of the Stipulation and the Judgment, additional sums have been incurred or expended on Defendants' behalf and Defendants have been given credit for any payments that have been made since the Judgment. The amount of damages to which Plaintiff is entitled is now in the amount of $99,962.63, itemized as follows: a. Outstanding principal $91,526.79 b. Interest to April 9, 2014 2,988.91 c. Late fees 149.70 d. Attorney's fees and expenses 5,073.48 e. Filing and Sheriffs costs 223.75 f. Total due to Members 1St $99,962.63 2 6. Interest continues to accrue on the above obligation and legal fees and costs also continue to accrue. 7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of the Judgment against the Defendants and Defendants are entitled to credit for any payments made. 8. Plaintiffs foreclosure judgment is in rem only and does not include personal liability. 9. Unless the Judgment and the Writ are amended to include the above additional costs of collection, interest and other amounts, in the event a third party bidder successfully purchases the Property at the Sheriff's Sale, Plaintiff will be deprived of its contractual right to collect out of the proceeds of the Sheriff s Sale all of its costs of collection and other amounts to which it is entitled under the obligations evidenced by the Judgment. WHEREFORE, Plaintiff, Members 1st Federal Credit Union, respectfully requests this Honorable Court amend the Judgment and the Writ to reflect damages due to Plaintiff in the amount of $99,962.63 plus interest, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage. 3 Date: April lit , 2014 4 Respe l ubmitted, Karl I . Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 ' New Cumberland, PA 17070 -0173 (717) 938 -6929 Attorney for Plaintiff ESTRIGHT,DONALD Loan 0009: HOME EQUITY M. i Transa.ction Summary 04/01/2014 Trans Amt Balance Chg Int/Pnity Fees New Balance Description Prev Available Post Date ID Eff Date Transaction %% PartialPmt 11/05/2013 L 0009 11/05/2013 Cash Payment %% PartialPmt 10/05/2013 L 0009 10/05/2013 Cash Payment %% PartialPmt 09/05/2013 L 0009 09/05/2013 Cash Payment %% PartialPmt 08/03/2013 L 0009 08/03/2013 Cash Payment Check Received %% PartialPmt 07/05/2013 L 0009 07/05/2013 Check Paym... Check Received %% PartialPmt 06/05/2013 Check Paym... %% .PartialPrnt 05/04/2013 Cash Payment %% PartialPmt 04/05/201.3 Cash Payment %% PartialPmt 03/04/2013 Cash Payment Check Received %% PartialPmt 02/05/2013 L 0009 02/05/2013 Check Paym... %% PartialPmt 01/03/2013 L 0009 01/03/2013 Cash Payment %% PartialPmt 12/05/2012 L 0009 12/05/2012 Cash Payment %% PartialPmt 11/03/2012 L 0009 11/03/2012 Cash Payment 06/05/2013 L 0009 rn X 05/04/2013 L 0009 04/05/2013 L 0009 Cr F 03/04/2013 L 0009 336.74 to 738.48 1,300.00 833.26 to 336.74 1,300.00 431.52 to 833.26 1,300.00 29.78 to 431.52 1,300.00 300.00 526.30 to 29.78 1,300.00 500.00 124.56 to 526.30 1,300.00 621.08 to 124.56 1,300.00 219.34 to 621.08 1,300.00 715.86 to 219.34 1,300.00 600.00 314.12 to 715.86 1,300.00 810.64 to 314.12 1,300.00 408.90 to 810.64 1,300.00 7.16 to 408.90 1,300.00 - 697.66 602.34 - 712.59 587.41 - 604.73 650.36 - 681.47 618.53 0.00 0.00 44.91 0.00 0.00 1,300.00 0.00 0.00 1,255.09 0.00 1,300.00 0.00 1,255.09 0.00 1,300.00 44.91 0.00 44.91 0.00 0.00 1,255.09 44.91 0.00 1,300.00 0.00 0.00 1,255.09 44.91 0.00 850.90 449.10 Page 1 91,526.79 92,224.45 92,937.04 93, 541.77 94,223.24 94,223.24 94,223.24 94, 223.24 94,223.24 94, 223.24 94,223.24 94,22324 94,223.24 0.00 0.00 0.00 0.00 • 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 04/04/2014 10:02 7179320317 KARLLEDEBOHM PAGE 07/07 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : .PENNSYLVANIA Vs. : NO, :12 -3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE VERIFICATION I, Dan Summers, Collections Manager for Members 1s1 Federal Credit Union, being authorized to do so on behalf of Members 1g': Federal Credit Union, hereby verify that the statements made in the foregoing motion, are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn 'falsification to authorities. Members 1.$` Federal Credit Union April. `1 ,2014 By: 7J,C►'yV 4 Dan Summers, Collections Manager Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 12 -3323 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 14th day of April, 2014, I served a true and correct copy of the foregoing Plaintiff's Motion to Reassess Damages and the proposed Order in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robbin L. Estright a/k/a Robin Lynn Estright 615 Magaro Rd. Enola, PA 17025 Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane Mechanicsburg, PA 17050 Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Date: April 14, 2014 Respe arl M. Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS OF CREDIT UNION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION — LAW DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT, Defendants : NO. 12 -3323 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO REASSESS DAMAGES ORDER OF COURT AND NOW, this 17th day of April, 2014, upon consideration of Plaintiff's Motion To Reassess Damages, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 30 days of service. BY THE COURT, Christy ee L. Peck, J. ✓Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 Attorney for Plaintiff /Donald K. Estright - -/9tcA �►J `•' ESV 405 Sheely Lane Mechanicsburg, PA 17050 And /615 Magaro Road Enola, PA 17025 Defendant, pro Se Robbin L. Estright 405 Sheely Lane Mechanicsburg, PA 1050 and 615 Magaro Road Enola, PA 17025 Defendant, pro Se :re Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 74- r 2131!,1 APR 214 Pi-'; 2: I L,7,71-;), L !q) COUNTY (r) ENP.S YL4'A NIA MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION - LAW DEFENDANTS : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 23rd day of April, 2014, I served a true and correct copy of the attached In Re:Plaintiff's Motion to Reassess Damages Order of Court in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robbin L. Estright a/k/a Robin Lynn Estright 615 Magaro Rd. Enola, PA 17025 Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane Mechanicsburg, PA 17050 Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Date: April 23, 2014 Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW DONALD K. ESTRIGHT and : ROBBIN L. ESTRIGHT a/k/a : ROBIN LYNN ESTRIGHT, Defendants : NO. 12-3323 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO REASSESS DAMAGES ORDER OF COURT AND NOW, this 17th day of April, 2014, upon consideration of Plaintiffs Motion To Reassess Damages, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 30 days of service. BY THE COURT, Pea/C-- Christ4ee L. Peck, J. M. Ledebohm, Esq. AO. Box 173 New Cumberland, PA 17070-0173 Attorney for Plaintiff Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 And 615 Magaro Road Enola, PA 17025 Defendant, pro Se =■ Map —V P.? CZ, Robbin L. Estright 405 Sheely Lane Mechanicsburg, PA 1050 and 615 Magaro Road Eno la, PA 17025 Defendant, pro Se :rc Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 FILED-OFFICE N: THE PROTH01•DTAR‘i Hit, APR 30 FM 12: 26 CUMBERLAND COUNTY PENNSYLVANIA MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE AMENDED AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO Pa. R.C.P. 3129.2 (c) I, Karl M. Ledebohm, Esquire, hereby swear and affirm that on the 14th day of March, 2014, I served the attached NOTICE OF SHERIFF'S SALE OF REAL PROPERTY pursuant to Pa. R.C.P. 3129.2(c) in the above captioned matter upon the individuals/entities by first class mail, postage prepaid as set forth on the PS Form 3817, copies of which are attached as Exhibit "1" and made part hereof. The notice sent to "Occupant", 405 Sheely Lane, Mechanicsburg, PA 17050 has been returned for the reason set forth on the returned envelope, a copy of which is attached hereto as Exhibit "2" and made part hereof. 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. Date: April 28, 2014 Rep submitted, Karl M. e ebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : NO.: 12-3323 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE TO: ALL PARTIES IN INTEREST AND CLAIMANTS Owner(s): Property: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Donald K. Estright & Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane Mechanicsburg, PA 17050 (Legal description attached) Judgment Amount: $103,807.26 The above-captioned property is scheduled to be sold at the Cumberland County Sheriff Sale on June 4, 2014 at 10:00 a.m in the Office of the Sheriff, Cumberland County Courthouse, One Courthouse Square, South Hanover Street, Carlisle, PA 17013. Our records indicate that you may hold a mortgage, judgment, or other interest with respect to the property which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after the sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriff Sale upon your lien, I urge you to CONTACT YOUR OWN ATTORNEY as 1 am not permitted to give you legal advice. Date: March 14, 2014 Respec a 1 M. Ledebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road; thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin; thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin; thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin, the point and place of BEGINNING. HAVING thereon erected a dwelling house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises winch Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058 Exhibit "A" UNITED STATES Certificate Of P POSTAL SERI/10E,, Mailing ros Cedikale of Mailing provides evidence that rnv as been Wesedled to USPS® rci mamng Tn,s form may be used for domestic and international otiii From Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To — U.S.A U.S. Dept. of Justice U.S. Attorney, Federal Building — 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108-1754 PS Form 3817. April 2007 PSN 7530•02-000-9065 UNITED STATES % POSTAL SERVICE Certificate Of Mailin- ThIs Certificate of Mailing provides evidence that mo o Has been presented 0 USPS® for rn3.1,, This form 030 00 used for domestic and ,nternalional dttii From Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To Occupant 405 Sheely Lane Mechanicsburg, PA 17050 PS Form 3817 April 2007 PSN 7530-02-000-9065 Exhibit "1" 11) rn Z = a> Cl Z. ).:0 CZ CA p■r. ,-.1. CO) CaPJ Z . -4:00 CD --I *col— V) 0= 4— a> —I .11. ;Z: 1 00 10 CI " • m -o L'D :D UfVI r ED STATES Certificate Of POSTAL SERVICE(. Mailinr ihs C en:hcate or Maihr g oroo,des e,ldence that ma:, has been presentee 10 USPSO feu ma:l e orm may be used fo, domed c and ,nl ernal,onal moo From To Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 Inheritance Tax Bureau Commonwealth of PA — Department of Revenue Bureau of Individual Taxes — Dept. 280601 Harrisburg, PA 17128 -0601 PS Form 3817. April 2007 PSN 7530 02 000 -9065 �n •z• --000 -�o: CO CJ GI • m -o -D UM r Lu. I /II LS Certificate 0' POSTAL SERVICE Mailinc e,abcale of Osalene 0 0..015 e,:l0, 0 Ina - 0 0e'. Jeer b esel ie0 LISPS! ., :C form may be llSe0101 bGmeS'.:: and :r:lernal:C, -, rpj,l ~ O From O Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 To _ Department of Public Welfare TPL Casualty Unit — Estate Recovery Program P.O. Box 8486 — Willow Oak Building Harrisburg, PA 17105 -8486 Pn � f _ �� ..... . 0 CD ( ) o'`D -D �- N 3 - L"D• J -° O- .c rn. 0 W z. o_000 W�. •or b-t t n\ s O D O cc . O m PS Form 3817. April 2007 PSN 7530 04 r 0c •9065 -o :0 UNITED STATES ES _±1_ POSTAL SERVICE: Certificate 0' r m. ,;,en:cale or nna:en o: G,,, Mailin 100 may 0 used C, OeS a „Oer •.0 I:ra • nas J2e� 0 eserieo 10 IJSPS� IC._ Domes :,L ar.0 :nle,'ral,o: 0,e1.0. FeOm a r42�i To _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 — Cumberland Count One Cou Y Tax Claim Bureau — rthouse Square Carlisle, PA 17013 PS Form 3817, April 7007 PSN 7530.uz.uuu.w�,,. UNITED STATES POSTAL SERVICE m< ..--or:1:COle of t.1a,i,n9 o,o,des er 00, - C ':ra: " -? loan may be uSe0101 dom ▪ r � eCi,l and �: •lernal:r: rw,l From certificate Cif Mailing 011e JSr'S: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 To - Domestic Relations _ Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 PS Form 3-817. Apni 2007 PSN 753(r 0 .(1.0i: 906 :0 C1 • 2):13 —( ;TO• O• -v[D1- c_oorn MO - r-OO .o o :o N D 1 3) •J o rn � M :0 :D UN1 TED STATES /1 POSTAL SERVICE Certificate C Mailin in.,. Cen,6cale of Mailing p'eai,des e.,oer. e 'nai r^t ::o'm may be used to' dome naa' JeE` = "ESen :ed lc V$A$° s:,c ar.a ,n:e��a:. Ra,, F�pm- _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 To _ Members 1St Federal Credit Union Attn.: Dan Summers, Collection Manager -- 5000 Louise Drive _ Mechanicsburg, PA 17055 PS Form 3817, April 2007 PSN 7530 02 000 9065 UNI T to STATES POSTAL SERVICE - This Certificate of Mailing provides evidence that mail has been presented Io IJSPSC for .20,09 This form may be used for domestic and international rd:aii 0 0 N 0 D t Certificate Of Mailin• From To Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173. Discover Bank 12 Reads Way New Castle, DE 19720 PS Form 3817 April 2007 PSN 753002 -000 -9065 : L- _D C? • 3 D—: D • O --JCOe- Z• J_000 - :0 —I -° : 2?) -0 :0 se--;77 UNITLDSTATES . Certificate G7 POSTAL SERVICE. Mailinc rm. Cerafrcate of Mailing provides e n0e, . e i -ia - _ This loin, may be used for domes:, and inrernaeor'd rw,;per "ester :ed to aSv$F f.. r-a From o — — O _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 -0173 To — Robbin L. Estright & Donald K. Estrig _ c/o Anthony L. DeLuca, Esquire 113 Front Street, P.O. Box 358 — Boiling Springs, PA 17007 PS Form 3817. April 2007 PSN 7530 -02 (J00 9065 UNITED STATES Certificate Of POSTAL SERVICE, Mailing This Certificate of Malting provides evidence that mail has been presented to USPS® for maong 2 II This form may be used for domestic and international rcFya P !� C I From h _ _s L. :D ri • 3 0 (i�N O- -JC03D c _corn. -.v Z• oof000 • :0 -I ES GO m -o :D Karl M. Ledebohm, Esq. _ P.O. Box 173 New Cumberland, PA 17070 -0173 To: Discover Bank c/o Edward Stock, Esquire 804 West Avenue — Jenkintown, PA 19046 PS Form 3817. April 2007 PSN 7530 -02- 000 -9065 rn :0 C--) • 3 :D- -� ;-0. -or03) W Z- ■:000 COO -� _D -or- CO O 0 CO CD m - m o :0 To Tar lee affix stamps of meter postage here Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 17r Tfirzifigi16 Occupant 405 Sheety Lane Mecha ircht fro. PA I XI:a -17ncn 17."6: SE 1 0'.:044,j'' Def174/1111 4 RETURN TO SENDER VACANT UNABLE TO FORWARD BC: 17070017373 *1519-06374-14-3.6 1111111 litli13 111 11 11 11111111111111111111111111111111111111 ii1 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF/Movant Vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS/Respondents : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE MEMBERS 1ST FEDERAL CREDIT UNION'S MOTION FOR ALTERNATE SERVICE PURSUANT TO RULE OF CIVIL PROCEDURE 430 AND NOW, comes Members 1St Federal Credit Union, by and through its attorney, Karl M. Ledebohm, Esq., and respectfully avers the following in support of this Motion for Alternate Service: 1 1. Movant is Members 1St Federal Credit Union ("Members Pt"), a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendants/Respondents, Donald K. Estright and Robbin L. Estright a/k/a Robin Lynn Estright (collectively "Defendants"), are adult individuals having a last known addresses of 405 Sheely Lane, Mechanicsburg, PA 17050 and 615 Magaro Road, Enola, PA 17025. 3. Pursuant to Local Rule 208.3(a)(2), on April 17, 2014, the Honorable Christylee L. Peck issued an Order upon Defendants to show cause why the relief requested in Plaintiff's Motion to Reassess Damages should not be granted. 4. No attorney has entered an appearance in this matter on behalf of Defendants and; therefore, Local Rule 208.2(d) does not apply in that seeking the concurrence of opposing counsel is not possible. 5. On June 1, 2012, the Cumberland County Sheriff successfully served upon Defendants at 405 Sheely Lane, Mechanicsburg, PA 17050 (the "Mortgaged Property") the complaint in mortgage foreclosure (the "Complaint") filed to the above captioned matter. A copy of the relevant Sheriff's Return of Service dated June 6, 2012 is attached as Exhibit "A" and made part hereof. 6. Members 1St issued execution on the judgment entered in the above captioned matter on November 8, 2013 for Sheriff's Sale of the Property on June 4, 2014 (the "Sheriff's Sale"). 7. In response to Members 1St's request that the Sheriff serve Defendants with the writ and notice of sale at the Mortgaged Property and/or the alternate address of 2 615 Magaro Road, Enola, PA 17025, on April 28, 2014, the Sheriff provided to Members Pt the Sheriff's Return of Service, a copy of which is attached as Exhibit "B" and made part hereof, confirming that the Defendants were "Not Found" at the Mortgaged Property and that the Mortgaged Property is vacant. 8. The Sheriff in the above return further confirmed that service of the Writ upon Defendants was attempted at 615 Magaro Road, Enola, PA 17025; that this property is occupied by Donald Estright's step mother; that the stepmother indicated that the Defendants never lived at that address; and, that she is unaware of the Defendants' current location. 9. For the reasons set forth above and in the affidavit attached hereto as Exhibit "C" and made part hereof (the "Affidavit"), the Property, appears to be the current and only address available for Defendants. 10. As set forth in the Affidavit, no address information is available for Defendants either in the records of the Cumberland County Voter Registration Office or the Cumberland County Real Estate Tax Assessment office and Defendants do not appear to have a phone number listing in Mechanicsburg or Enola, Pennsylvania. 11. As set forth in the Affidavit, Members 1St continues to mail to Defendants via US regular mail at the Mortgaged Property account statements, which mail has not been returned to Members 1St as undeliverable or otherwise. 12. For the reasons set forth above and in the Affidavit, Members Pt believes and therefore avers that Defendants either continue to reside at the Mortgaged 3 Property and are deliberately and improperly avoiding service or have left the area. WHEREFORE, Members Pt Federal Credit Union respectfully requests this Honorable Court to enter an Order permitting service of the Writ of Execution, Notice of sale and all subsequent and additional documents pertaining to and required to be served upon Defendants in the foreclosure action filed to the above captioned matter by posting the Mortgaged Property and by publication as provided by Pa. R.C.P. 3129.2 and by certified and regular U.S. Mail, postage prepaid, addressed to Defendants at the Mortgaged Property. Date: c- 4 Respect lly submitted, C arl . Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Petitioner SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Members 1st FCU vs. Donald K Estright (et al.) GQ�ttttn of Umbel?��`li OFFICE OF THE SHERIFF Case Number 2012-3323 SHERIFF'S RETURN OF SERVICE 06/01/2012 08:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 1 2012 at 2045 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: Robbin L. Estright, by making known unto herself personally, at 405 Sheely Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY 06/01/2012 08:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 1 2012 at 2045 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: Donald K. Estright, by making known unto imself personally, at 405 Sheely Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY 06/06/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 405 Sheely Lane, Mechanicsburg, Pennsylvania 17050, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclousure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Occupant. Request for service at 405 Sheely Lane, Mechanicsburg, Pennsylvania 17050 is only occupied by Donald and Robbin Estright. SHERIFF COST: $75.00 June 06, 2012 Exhibit "A" SO ANSWERS, RONIV ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF4CE Op THE S4ERIFF Members 1st FCU vs. Donald K Estright (et al.) Case Number 2012-3323 SHERIFF'S RETURN OF SERVICE 03/24/2014 04:50 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested ReaEstate Writ, Notice and Description, and Sale Handbill in the above titled adion, upon the property located at 405 Sheely Lane, Mechanicsburg - Borough, Mechanicsburg, PA 17050, Cumberland County. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real EmtateVV/it. Notice and Oescription, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Demcripdon, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location, cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robin L. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Doychpdon, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robbin L. Eo\right, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Deacripdon, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location, cab. SHERIFF COST: $964,24 SO ANSWERS, April 28, 2014 RON R ANDERSON, SHERIFF Exhibit "B" 05/02/2014 16:18 7179320317 KARLLEDEBOHM PAGE 07/08 AFFIDAVIT 1, Dan Summers, Collections Manager for Members 14 Federal Credit Union ("Members 1s4"), do hereby report the following information in support of Members 1st Federal Credit Union's Motion For Alternate Service Pursuant to Rule of Civil Procedure 430 ("Motion for Alternate Service"): 1. The only addresses which Members I' possesses with regards to the Defendants, Donald K. Estright and Robbin L. Estright a/k/a Robin Lynn Estright (collectively "Defendants") are the Mortgaged Property at 405 Shealy Lane, Mechanicsburg, PA 17050 (the "Mortgaged Property") and 615 Magaro Road, Enola, PA 17025. 2. On May 2, 2014, Members 14, through its attorney; Karl M. Ledebohtn, Esq., contacted the Cumberland County Tax Assessment Office and confirmed that real estate tax bills for the Mortgaged Property continue to be sent to the attention of Robin Lynn Estright at the Mortgaged Property. 3. On May 2, 2014, Members 14, through, its attorney, Karl M. Ladebohm, Esq., contacted directory assistance for Mechanicsburg, Pennsylvania and was informed that there is no listing for Defendants in Mechanicsburg, Pennsylvania. 4. On May 2, 2014, Members 14, through its attorney, Karl M. Ledebohm, Esq., contacted Cumberland County Voter Registration and was informed that the voter registration for Defendant, Donald Estright, was cancelled in Cumberland County in January, 2013 and that there is no record for Defendant, Robbin Estright. Cum.ber-land. County Voter Registration further confirmed that neither Defendants are currently registered to vote in, Pennsylvania. 5. On or about May I, 2014, Members Ist obtained a Trans Union Consumer Credit Report for Defendant, Donald Estright, which reflects the most current, reported address for Donald Estright as being 615 Magero Road, Enola, PA 1.7025 - which the Sheriff for. Cumberland County has determined is not the address for either of the Defendants as set forth in the foregoing Motion for Alternate Service which is incorporated herein by reference. 6. On or about May 1, 2014, Members Pt obtained a Trans Union Consumer Credit Report for Defendant, Robbin Estright, which reflects the most current, reported address for Robbin Estright as being the Mortgaged Property which the 1 Exhibit "C" 05/02/2014 16:18 7179320317 KARLLEDEBOHM Sheriff for Cumberland County has determined is now vacant as set forth in the foregoing Motion for Alternate Service. 7. Members 1" continues to mail via US regular mail account statements to Defendants at the Mortgaged Property which have not been returned as undeliverable or OtlIGIWiSe. PAGE 08/08 8. For the reasons set forth herein and in the Motion for Alternate Service, Members 1" has reason to believe that Defendants either continue to reside at the Mortgaged Property and are deliberately and improperly avoiding service or have left the area. Date: ha- '5ZO 4-1 Sworn and subscribed to before me, a Notary Public, this 5 day of May, 2014. o . ) My commission expires: /..-(95,,9v COMMONWEALTH OF PENNSYLVANIA Notarial Seal Laura L. Hoke, Notary Public Upper Allen Twp., Cumberland County My Commission Expires Jan. 25, 2015 MEMBER PENNSYLVANIA ASSOCIATION OF NOTARIES 2 Respectfully submitted, Dan Summers, Collections Manager for Members 1" Federal Credit Union 05/02/2014 16:18 7179320317 MEMBERS 18T FEDERAL CREDIT UNION PLAINTIFF/Movant Vs. DONALD K. ESTRIGHT and. ROBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS/Respondents KARLLEDEBOHM PAGE 06/08 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE VERIFICATION I, Dan Summers, Collections Manager for Members l Federal Credit Union, being authorized to do so on behalf of Members 1" Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 5 Members 1' Federal Credit Union By: 1.4evt./ Dan Summers, Collections Manager Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF Vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION - LAW DEFENDANTS : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 8th day of May, 2014, I served a true and correct copy of the attached Members 1St Federal Credit Union's Motion for Alternate Service Pursuant to Rule of Civil Procedure 430 and proposed order in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane Mechanicsburg, PA 17050 Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Date: May 8, 2014 Karl edebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 s Ort_ THE PROTHONOTARY 1Y7 14 MAI l l+ AM 9: 2.2 CUMBERLAND �COUNTY PENNSYLVANIA Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF/Movant Vs. DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS/Respondents : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO.: 12-3323 : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE ORDER GRANTING PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, this /dV-u day of f %%, 2014, upon consideration of Members 1St Federal Credit Union's Motion for Alternate Service Pursuant to Pennsylvania Rule of Civil Procedure 430, it is hereby ORDERED THAT Members 1st Federal Credit Union shall make service of the Writ of Execution and Notice of Sheriff's Sale, and any and all subsequent and/or additional documents required to be served upon Defendants, Donald K Estright and Robbin L. Estright a/k/a Robin Lynn Estright, pertaining to the foreclosure action filed to the above captioned matter: a. By posting the Property known and numbered as 405 Sheely Lane, Mechanicsburg, PA 17050 (the "Property") by the Sheriff for Cumberland County as required by Pa. R.C.P. 3129.2(b); b. By publication of the Sheriff's Sale of the Property by the Sheriff for Cumberland County as required by Pa. R.C.P. 3129.2(d); and, c. By certified and regular U.S. Mail, postage prepaid, addressed to Defendants at 405 Sheely Lane, Mechanicsburg, PA 17050. By the Court: elA,A,L,_ <6'11( Notice addresses: Attorney for Plaintiff/Movant: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 Defendants/Respondents: Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 obbin L. Estright 405 Sheely Lane Mechanicsburg, PA 17050 � L --e5;1;417140 Karl M. Ledebohm, Esquire. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 P6IvIvs YL ©U, 7,', MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF • Vs. : NO.: 12-3323 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT : CIVIL ACTION - LAW DEFENDANTS : MORTGAGE FORECLOSURE NOTICE OF THE DATE OF CONTINUED SHERIFF SALE The Sheriff Sale scheduled for June 4, 2014 at 10:00 a.m. in the above -captioned matter has been continued until July 2, 2014 at 10 a.m. Date: May 16, 2014 Respe , depere,_ arl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: 12-3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 19th day of May, 2014, I served a true and correct copy of the foregoing Notice of the Date of Continued Sheriff Sale in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Date: May 19, 2014 Respect ►� � bmitted, arl M. ' edebohm, Es Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938- 6929 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Vs. : NO.: 12 -3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 27th day of May, 2014, I served, pursuant to the Order of Court dated May 12, 2014, a true and correct copy of the attached Notice of Sheriff Sale of Real Estate upon the following by first class mail, postage prepaid, addressed as follows: Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 Certificates of mailing are attached hereto as Exhibit "A ". Date: May 27, 2014 Respect - lly s itted, 1 M. ede . ohm, Esq. ttorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938-6929 MEMBERS 1ST FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF Vs. : NO.: 12 -3323 DONALD K. ESTRIGHT and ROBBIN L. ESTRIGHT a/k/a ROBIN LYNN ESTRIGHT DEFENDANTS : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Robbin L. Estright a/k/a Robin Lynn Estright Donald K. Estright 615 Magaro Rd. Enola, PA 17025 Robbin L. Estright a!k/a Robin Lynn Estright Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 405 Sheely Lane, Mechanicsburg, PA 17050, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sheriff's Sale originally scheduled on June 4, 2014 at 10:00 a.m. and postponed to July 2, 2014 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $103,807.26 plus interest at the rate of $19.8514 per day from October 26, 2012 to November 8, 2012 and at the legal rate thereafter until the date of payment, additional legal fees and costs of suit as well as other costs and charges collectable under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs and additional reasonable legal fees, if any, and other costs and charges collectible under the mortgage, if any, or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938 -6929. 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 be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) 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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before (within thirty (30) days after the Sheriff 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 the schedule of distribution is piled by the Sheriff. 7. You may also have other rights and defenses, or ways of getting your house 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 LLGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249 -3166 OR (800)990-9108 The Sheriffs phone number is: (717)240 -6390. f/ Karl M. Ledebohm, Esquire / Supreme Court ID #59012 / P.O. Box 173 New Cumberland, PA 17070 -0173 (717)938 -6929 Attorney for Plaintiff ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sheinian and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road; thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin; thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin; thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin, the point and place of BEGINNING. HAVING thereon erected a dwelling house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-'0561-058 Exhibit "A" WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12 -3323 Civil COUNTY OF CUMBERLAND) CIVIL ACTION – LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION Plaintiff (s) From DONALD K. ESTRIGHT AND ROBBIN L. ESTRIGHT A/K/A ROBIN LYNN ESTRIGHT (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: $103,807.26 L.L.: $.50 Interest FROM 10/26/12 TO 11/8/12 AT THE RATE OF $19.8514 PER DAY AND AT THE LEGAL RATE THEREAFTER TO BE ADDED Atty's Comm: Atty Paid: $223.75 Plaintiff Paid: Date: 3/3/14 (Seal) REQUESTING PARTY: Name: KARL M. LEDEBOHM, ESQUIRE Address: P.O. BOX 173 NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717- 938 -6929 Supreme Court ID No. 59012 Due Prothy: $2.25 Other Costs: David D.:uell, Prothonot Deputy 1-F71 IE. � ` a ur � s31 cs.. , J Gust _ :: ai! . Pa This day of —` _— a STATES Certificate Of POSTAL SERV10E, From- hfs form may be used tor domestic and internatinii, lt4,4 CerlifiCa,e Of maamg OrOvides evider i,e trtai ,as oee, Presemeo tiSPS.! fc, Mailin _ Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-.017 — Donald K. Estright 615 Magaro Rd. Enola, PA 17025 PS Form 817, April 2007 PSN 7530-02-000-90 NiTED STATES OST/1L SERVICE, • Certificate Of Mailin From may be used ler domestic and iniernaboca rtitpit rrm Certificate of provides evipei !r1,3 Drese or Ned IC ■ /SPS NE f To _ Robbin L. Estright a/k/a Robin Lynn Estright 405 Sheely Lane — Mechanicsburg, PA 17050 _ Karl M. Ledebohm, Esq. P.O. Box 173 CO New Cumberland, PA 17070-0173 PS Form 3817. April 2007 PSN 7530 (32 GOO 9065 UNITED STATES tho POSTAL SERVICE Mailing cervficate of Mailing provides evidence that mail has been presented to USPS for mailing I IL:10i : This form may m ay be used for domestic and international rceail From Certificate Of tP; • c • 1)--c cz eJ-.JCODD C".1Cdt,11-4-1:1 Z• •cdf V) :D 1) CD CI • m -0 :D ZE> CZ Z ro.goa co LA.) Z• •c:31"- OC= -- .7D CO i5 -o :D To: Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-017 Robbin L. Estright a/k/a Robin Lynn Estright 615 Magaro Rd. Enola, PA 17025 PS Form 3817. April 2007 PSN 7530-02-000-9065 IVNiTED STATES " POSTAL SERVICE This Certificate of Mailing provides evidence that mar! has This form May be used for domestic and international nth From O. Certificate Of Mailin for mailing en presented to USP Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-017 — Donald K. Estright 405 Sheely Lane Mechanicsburg, PA 17050 PS Form 3817, April 2007 PSN 7530-02-000-9065 rri C :D Cl • C .10) C Z • -.1:0C10 •of V) :c? .b. 00 ED 0 m • -0 :D a 11J (-) F ON-J(0M Z • ■J:IDOC• •c)'-' V) :D C CI • 01 -0 :D SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson _ J -CIE F CE Sheriff� [�s U � O F ' �i` Tiiiia. E'rtiJ o it�.lr�s.i fii!t ? AUG PH 2:03 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor of COM ()Fp ICE OF THE $+fERIFF Members 1st FCU vs. Donald K Estright (et al.) Case Number 2012-3323 SHERIFF'S RETURN OF SERVICE 03/24/2014 04:50 PM - Deputy Ryan Burgett, 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 405 Sheely Lane, Mechanicsburg - Borough, Mechanicsburg, PA 17050, Cumberland County. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robin L. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robbin L. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location. cab. 05/22/2014 As directed by Karl M. Ledebohm, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 05/22/2014 Order of Court dated 5/12/14 to Post Property as Alternative service received 5/21/14. cab. 05/23/2014 12:43 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Robbin L. Estright, pursuant to Order of Court by "Posting" the premises located at 405 Sheely Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland County with a true and correct copy according to law. 05/23/2014 12:43 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Donald K Estright, pursuant to Order of Court by "Posting" the premises located at 405 Sheely Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland County with a true and correct copy according to law. 06/01/2014 Sheriff Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Donald K. Estright, 405 Sheely Lane, Mechanicsburg, PA 17050, return card was signed by Jason Estright on unknown date as postal carrier did not mark a date. cab. (c) CountySuu: e Sheriff. Teleosoft. enc. D6/17/2014 Ronny Anderson, Sheriff, being duly sworn according to Iaw, states he served the requested RealEstate Writ, Notice of Sheriffs Sale and Legal Description,in the above titled action, in the foliowing manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Robbin L. Estright, 405 Sheely Lane, Mechanicsburg, PA 17050 on June 02, 2014, to 'dote, return card has not been returned to Sheriffs Office. cab. 07/02/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given accordinto law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on July 02, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Karl Ledebohm on behalf of Members 1st Federal Credit Union, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,085.29 SO ANSWERS, July 11.2O14 re) oountySwSheriff, Teleosott.inc. RON R ANDERSON, SHERIFF On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered 405 Sheely Lane, Mechanicsburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2012-3323 Civil Term Members 1st FCU vs. Donald K. Estright Robbin L. Estright Atty.: Karl M. Ledebohm ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road; thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin; thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin; thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin, the point and place of BE- GINNING. HAVING thereon erected a dwell- ing house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, 50 Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 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 a of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 the Patriot -News Co. ga2FJTechnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 be PatriotNetus 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 2012.3323 CM i' e Members 1st FCU Vs Donald I( Estright Ro Karl M Ledebohm rIght Athl: KT CERTAIN tract of land ALLKT situate in the T° of Hampden, and State County sofY ania, Cumberland particularly of Pennsylvania, bounded and described as follows, to wit:in which pin BEGINNING at an iron p oone between lands on 1viJ.dCleriland Pearl V. Cle i f Anthony his wife, and land now or late of L.D. This ad ran on the date(s) shown below: 04/13/14 04/20/14 • 04/27/14 Sworn ubscribed before methi 2y of May, 201- A.D. blic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Rotary Public Weshingto_n Twp., Dauphin County My Cc ;nisr:vn Lkoiree Dec. 12 2016 n MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } S I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Members 1st Federal Cr Un is the grantee the same having been sold to said grantee on the 2nd day of July A.D., 2014, under and by virtue of a writ Execution issued on the 3rd day of March, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 3323, at the suit of Members 1st Fed Cr Un against Donald K & Robin L aka Robin Lynn Estright is duly recorded as Instrument Number 201417329. IN TESTIMONY WHEREOF, I have � /hereunto set my hand and seal of said office this ) day of A t,J US ± , A.D. a l7i 6 , Wm(OO() Recorder of Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson _ J -CIE F CE Sheriff� [�s U � O F ' �i` Tiiiia. E'rtiJ o it�.lr�s.i fii!t ? AUG PH 2:03 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor of COM ()Fp ICE OF THE $+fERIFF Members 1st FCU vs. Donald K Estright (et al.) Case Number 2012-3323 SHERIFF'S RETURN OF SERVICE 03/24/2014 04:50 PM - Deputy Ryan Burgett, 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 405 Sheely Lane, Mechanicsburg - Borough, Mechanicsburg, PA 17050, Cumberland County. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donald K Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robin L. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 405 Sheely Lane, Mechanicsburg, PA 17050 address is vacant, defendant did not leave a forwarding address with the post office. cab. 04/28/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Robbin L. Estright, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 615 Magaro Road, Enola, PA 17025, per Stepmom of Donald, defendant has never lived at address stated, she is unaware of present location. cab. 05/22/2014 As directed by Karl M. Ledebohm, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 05/22/2014 Order of Court dated 5/12/14 to Post Property as Alternative service received 5/21/14. cab. 05/23/2014 12:43 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Robbin L. Estright, pursuant to Order of Court by "Posting" the premises located at 405 Sheely Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland County with a true and correct copy according to law. 05/23/2014 12:43 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Donald K Estright, pursuant to Order of Court by "Posting" the premises located at 405 Sheely Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland County with a true and correct copy according to law. 06/01/2014 Sheriff Ronny R. Anderson, being duly sworn according to law, states he served the requested Real Estate Writ, Notice of Sheriffs Sale and Legal Description, in the above titled action, in the following manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Donald K. Estright, 405 Sheely Lane, Mechanicsburg, PA 17050, return card was signed by Jason Estright on unknown date as postal carrier did not mark a date. cab. (c) CountySuu: e Sheriff. Teleosoft. enc. D6/17/2014 Ronny Anderson, Sheriff, being duly sworn according to Iaw, states he served the requested RealEstate Writ, Notice of Sheriffs Sale and Legal Description,in the above titled action, in the foliowing manner. The Sheriff mailed a notice of the action by certified mail, return receipt requested, to the within named Defendant, to wit: Robbin L. Estright, 405 Sheely Lane, Mechanicsburg, PA 17050 on June 02, 2014, to 'dote, return card has not been returned to Sheriffs Office. cab. 07/02/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given accordinto law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on July 02, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Karl Ledebohm on behalf of Members 1st Federal Credit Union, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,085.29 SO ANSWERS, July 11.2O14 re) oountySwSheriff, Teleosott.inc. RON R ANDERSON, SHERIFF On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered 405 Sheely Lane, Mechanicsburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2012-3323 Civil Term Members 1st FCU vs. Donald K. Estright Robbin L. Estright Atty.: Karl M. Ledebohm ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin which pin is on the dividing line between lands of Anthony J. Cleri and Pearl V. Cleri, his wife, and land now or late of L.D. Sherman and said pin being located on a bearing of South 48 degrees 54 minutes East and distant 205.6 feet from another pin in the center line of Trindle Road; thence South 48 degrees 54 minutes East and along aforesaid dividing line, a distance of 149 to an iron pin; thence South 41 degrees West, a distance of 112 feet to another iron pin; thence North 53 degrees West and along line of land reserved for road slope, a distance of 149 feet to an iron pin; thence North 40 degrees 15 minutes East, a distance of 122.8 feet to an iron pin, the point and place of BE- GINNING. HAVING thereon erected a dwell- ing house known as No. 405 Sheely Lane, Mechanicsburg, PA 17050. The premises herein described are granted and conveyed under and subject to 12 foot right of way, which right of way is located on the bearing South 48 degrees 54 minutes East and is a continuation of the right of way from Trindle Road over other lands of Anthony J. Cleri and Pearl V. Cleri, his wife. BEING the same premises which Juan Rodriguez, widower, by his deed dated March 23, 2000 and recorded in the Cumberland County Recorder's Office in Deed Book 218, 50 Page 1034, granted and conveyed unto Robin Lynn Estright, single individual. Tax Parcel No. 10-23-0561-058. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 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 a of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 the Patriot -News Co. ga2FJTechnology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 be PatriotNetus 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 2012.3323 CM i' e Members 1st FCU Vs Donald I( Estright Ro Karl M Ledebohm rIght Athl: KT CERTAIN tract of land ALLKT situate in the T° of Hampden, and State County sofY ania, Cumberland particularly of Pennsylvania, bounded and described as follows, to wit:in which pin BEGINNING at an iron p oone between lands on 1viJ.dCleriland Pearl V. Cle i f Anthony his wife, and land now or late of L.D. This ad ran on the date(s) shown below: 04/13/14 04/20/14 • 04/27/14 Sworn ubscribed before methi 2y of May, 201- A.D. blic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Rotary Public Weshingto_n Twp., Dauphin County My Cc ;nisr:vn Lkoiree Dec. 12 2016 n MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } S I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Members 1st Federal Cr Un is the grantee the same having been sold to said grantee on the 2nd day of July A.D., 2014, under and by virtue of a writ Execution issued on the 3rd day of March, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 3323, at the suit of Members 1st Fed Cr Un against Donald K & Robin L aka Robin Lynn Estright is duly recorded as Instrument Number 201417329. IN TESTIMONY WHEREOF, I have � /hereunto set my hand and seal of said office this ) day of A t,J US ± , A.D. a l7i 6 , Wm(OO() Recorder of Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018