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Home My WebLink About12-3453F,* led- o `-cc ? r ? one ??on ? IAWI 1 ?'? ? ?P PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. DEBRA A. SEDESHE RICHARD C. SEDESHE, JR 24 TERR1DRIVE CARLISLE, PA 17015-7106 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 1a .3`, S a e jo l CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 285862 da g?o3.?sP cX11A ass ??8' NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 285862 1. Plaintiff is THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET- BACKED CERTIFICATES, SERIES 2005-7 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: DEBRA A. SEDESHE RICHARD C. SEDESHE, JR 24 TERRI DRIVE CARLISLE, PA 17015-7106 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/20/2005 DEBRA A. SEDESHE and RICHARD C. SEDESHE, JR made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR AMERICA'S WHOLESALE LENDER which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1914, Page 3892. By Assignment of Mortgage recorded 06/23/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201117732.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 285862 5. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage as of 12/02/2011: Principal Balance $116,215.22 Interest $12,125.70 04/01/2010 through 12/02/2011 Late Charges $114.51 Property Inspections $255.00 Escrow Deficit $4,173.15 TOTAL $132,883.58 7. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) hasihave received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. File #: 285862 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $132,883.58, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: fl/v tthe B wood, Esquire Attorney or Plaintiff File #: 285862 LEGAL DESCRIPTION ALL that certain lot, parcel or tract of land situate in Mount Holly Springs Borough, Cumberland County, Pennsylvania, being more particularly bounded and described as follows: BEGINNING at a point in the southwestern edge of dedicated right-of-way of Liberty Drive at corner of Lot No. 7 on said Plan; thence along Lot No. 7 South seventy (70) degrees twenty- seven (27) minutes ten (10) seconds West one hundred one and twenty-six hundredths (101.26) feet to a paint in dedicated right-of-way line of Pennsylvania Route 94; thence along said right- of-way line of Pennsylvania Route 94 North twenty (20) degrees three (03) minutes thirty-one (31) seconds West eighty-seven and zero hundredths (87.00) feet to a point in Lot No. 5; thence along Lot No. 5 North seventy (70) degrees twenty-seven (27) minutes ten (10) seconds East one hundred two and four hundredths (102.04) feet to a point in dedicated right-of-way line of Liberty Drive; thence by dedicated right-of-way line of Liberty Drive South nineteen (19) degrees thirty-two (32) minutes fifty (50) seconds East eighty-seven and zero hundredths (87.00) feet to the point and place of BEGINNING. BEING designated as Lot No. 6 on Plan of Liberty Woods. PROPERTY ADDRESS: 8 LIBERTY DRIVE, MOUNT HOLLY SPRINGS, PA 17065- 1022 PARCEL # 23-35-2316-064 File #: 285862 VERIFICATION hereby states thao /she of BANK OF AMERICA, N.A., servicing agent for Plaintiff in this matter, that"e is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of_?her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: /° 41I - File#: 2858162 Name:SEDESHE Name: Title: BANK OF AMERICA, N.A. File #: 285862 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET- BACKED CERTIFICATES, SERIES 2005-7, Plaintiff vs. DEBRA A. SEDESHE and RICHARD C. SEDESHE, JR., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 12-3453 CIVIL ORDER AND NOW, this b ' day of June, 2012, proceedings herein are stayed pending compliance with our Administrative Order dated February 28, 2012, and, specifically, pending service of the Notice of Residential Mortgage Foreclosure Diversion Program and the Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet set forth in Form 1 and Form 2, as amended, attached to said Administrative Order. BY THE COURT, a Kevin Hess, P. J. ff^c C' Matthew Brushwood, Esquire For the Plaintiff ' ? Debra A. Sedeshe Richard C. Sedeshe, Jr. 24 Terri Drive Carlisle, PA 17015-7106 :rlm P,F'S Ma . led SHERIFF'S OFFICE OF CUMBERLAND COUNTY, Ronny R Anderson, Sheriff Jody S Smith Chief Deputy -- Richard W Stewart Solicitor - The Bank of New York Mellon Case Number vs. 2012-3453 Debra A. Sedeshe (et al.) SHERIFF'S RETURN OF SERVICE 06/05/2012 03:42 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 5, 2012 at 1542 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Debra A. Sedeshe, by making known unto Richard C. Sedeshe, Jr., Husband of Defendant at 24 Terri Drive, Carlisle, Cumberland County, Pennsylvan' 17015 its contents ,-'--? and at the same time handing to him personally the said true and correct co a same. MICHAEL BARRICK, DEPUTY 06/05/2012 03:42 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 5, 2012 at 1542 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Richard C. Sedeshe, Jr., by making known unto himself personally, at 24 Terri Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. r 10?001-"000 MICHAEL BARRICK, 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: Richard C. Sedeshe, Jr., but was unable to locate hhim in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard C. Sedeshe, Jr. Request for service at 8 Liberty Drive, Mount Holly Springs, Pennsylvania 17065 is vacant. 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: Debra A. Sedeshe, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Debra A. Sedeshe. Request for service at 8 Liberty Drive, Mount Holly Springs, Pennsylvania 17065 is vacant. SHERIFF COST: $99.00 June 06, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF i PHELAN HALLINAN & SCHMIEG, LLP 1° ILED-OFFICE John M. Kolesnik, Esq., Id. No. 308877 6 THE PROTHONOTARY 1617 JFK Boulevard, Suite 1400 2012 AUG -3 AM 10; 1 One Penn Center Plaza Philadelphia, PA 19103 RLANO COUNTY 215-563-7000 my .?A ?A THE BANK OF NEW YORK MELLON FKA COURT OF COMMON PLEAS THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CIVIL DIVISION CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 CUMBERLAND COUNTY Plaintiff VS. DEBRA A. SEDESHE No. 12-3453 CIVIL RICHARD C. SEDESHE, JR Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the captioned matter. & SCHMIEG, LLP By: ?kl Jo M. Kolesnik, Esq., Id. No. 308877 ttornev for Plaintiff Date: August 1, 2012 jhk/kpl, Svc Dept. File# 285862 Q? Sr t PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 vs. DEBRA A. SEDESHE RICHARD C. SEDESHE, JR Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS ~ ~ ` ~ ; -o CIVIL DIVISION ~~ ,°-~ ,~ -,_ ~~ z ~ ~ -v r~7 ~' No. 12-3453 CIVIL w °~ ~ -C G`F _~ ~ ~" ~ ~ -r7 ~,~ -~ ~„ . ~~ ~ ~{ ~. ' . .r- ~~ A ,~,~ , PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO d ~~ ANSWER AND ASSESSMENT OF DAMAGES ~ ~ ~ ~ ~zSv ~/d TO THE PROTHONOTARY: ~-~"~'3 ~ ~~ Kindly enter judgment in favor of the Plaintiff and against DEBRA A. SEDESHE and RICHARD C. SEDESHE, JR, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $132,883.58 $132,883.58 I hereby certify that (1) the Defendants' last known addresses are 8 LIBERTY DRIVE, MOUNT HOLLY SPRINGS, PA 17065-1022, 24 TERRI DRIVE, CARLISLE, PA 17015-7106, and 1553 MAINSVILLE RD, SHIPPENSBURG, PA 17257-9255, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Z 1 Z. ,, ~ i~`~%~/ ~~ athan Lobb, Esq., Id. No.312174 Attor for P intiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~~ 3 / ~- w PHS # 285862 PROTHONOTARY 285862 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 12-3453 CIVIL vs. DEBRA A. SEDESHE RICHARD C. SEDESHE, JR AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendants DEBRA A. SEDESHE and RICHARD C. SEDESHE, JR are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant DEBRA A. SEDESHE is over 18 years of age and the last known addresses of the defendant 8 LIBERTY DRIVE, MOUNT HOLLY SPRINGS, PA 17065-1022 and 1553 MAINSVIL,LE RD, SHIPPENSBURG, PA 17257-9255. (c) that defendant RICHARD C. SEDESHE, JR is over 18 years of age and the last known addresses of the defendant 8 LIBERTY DRIVE, MOUNT HOLLY SPRINGS, PA 17065-1022 and 24 TERRI DRIVE, CARLISLE, PA 17015-7106. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date ~Z Z ~ .~G~~%(/ J than Lobb, Esq., Id. No.312174 Attorney for Plaintiff 285862 Department of Defense Manpower Data Center a7~tiitilr R ~#"51L~9fl~ #i0 ~'~"lCG~Y1~1i1bC2~ ~1i~1.1 ~lG~IC~ ACS Last Name: SEDESHE First Name: DEBRA Middle Name: A. Active Duty Status As Of: Nov-29-2012 ResrrlLS as of :Nov-29-2012 02:30:45 SCRA 2.3 On Active Duly On Active DtHy Stetua Dek. Active Duty Start Dak Active Duty End Dak Situ- Seivlce Component NA NA - No NA This response reflects the: individuals' active duty status based on the Active Duty Status Dale Left Active Duty WiMrti 3fi7Days of AcNie Duty 9~us Date ActNe DWy Start Dak Active Duty End Dak Statue ServiceComporlerH NA NA tJo NA This response retkcts whero the irdlvidud kft acuveduty w'~in $67 days preceding the Activa;i)i,ty Status Dete .The AAernEer or tOSll(er Unit Was NotiRed Wa FuNire Ca6Up 1o Active Dirty m Adiw Duty Shkut Dafe Order Nulirication Start Date Order Notification Fsd Date States Service Component NA NA blus. NA This response reflects whether the ndwidusl or his/her unit has receivedeanlynoti(s:iBpn to report for agive duty Upon searching the data banks of the Department of Defense Manpower Data Center;-based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Unrformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. r~ r~ ,cam,-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center ~~ ~~ ~~II!"6t181A~ t0 ~'~V~iCG1Y214ilI~'fCI'S ~11i11 ~~liGf A4K Last Name: SEDESHE, JR First Name: RICHARD Middle Name: C. Active Duty Status As Of: Nov-29-2012 ResuNs as of : Nov-29-2012 02:32:08 SCRA 2.3 On Active Duty On Active Duly Slalua Dak 'Active Outy Start bate Active buy End Date Status Setvibs Component-. NA NA NO NA This response relleds the k+dividuals' attire duty status based on lire Active Duty Status Date Lett Active Duy wtmin 367 Days of AGire Duy Status Date Active Dtdy Start Dak Active Duty Fsd Date Status - Service Component NA NA - No NA This response reflects whero Iha individual kk aictive.drNy.atahre wlMlin 367 days preced"ag the Adiva Duly Staffs Date TM 1+lember or hM9/lier UtNt Wss Noted of a Fuhxe CaWP to Active Duty on Alive Duy Status bete Dider Notifltslion Start Dak Qrder Notification End.DaM Stable Service Component NA tU1 No.. NA This response retbcis wMther the irWMidud or hislher unrl has recened ervy roMcalion to report for adire duy Upon searching the data banks of the Department of Defense Manpower Data Canter, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or hislher unit receiving not cation of future orders to report for Active Duty. N~,~. „cam,-,~;~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 THE BANK OF Iv'EW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 Plaintiff v. DEBRA A. SEDESHE RICHARD C. SEDESHE, 3R Defendant{s) TO: DEBRA A. SEDESHE 8 LIBERTY DRIVE MOUNT HOLLY SPRINGS, PA 17065-1022 DATE OF NOTICE: ~ ~' COURT OF COMMON PLEAS CIVIl. DIVISION NO. 12-3453 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. 'THIS NOTICE. IS SENT TO YOU IN A.N ATTEMPT TO COLLECT TIC LNDEBTEDNESS REFERRED TO I-REIN, AND ANY LNFORItigATION OBTAINED FKOM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGALNST PROPERTY. I_'VIPORTA.?VT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE W WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TU THE CLAIMS SE"F FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAC' BE EIti"I'ERED AGAIl~IST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER LvIPORT.Al<?T RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOt DO NOT HAVE A LAV4'YER, GO TO OR TELEPHOI~'E THE OFFICE SET FOR'I'H BELOW. THIS OFFICE CAN PROVIDE YOU WITH IIvFORIVIATION ABOUT HIRING A LAWYER. 1F YOU CANNOT AFFORD TO HIRE A L~IWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WTI'H INFORMATION ABOUT AGENCIES TIJAT MAY OFf~ER LEGAI. SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland Caunty Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6135 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTI-IOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~~ ~% , By: Meredith bloaters, Esq.; Id. No.307207 Attorney for Ftau~til'f Phelan Hallman & Schmieg, LLP 1617 JFK Boulevard. Suite 1400 One Penn Center Plaza Philadelphia, PA 191{)3 PHS # 2xsK62 THE BANK. OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE C'ERTIFICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2UU5-7 Plaintiff v. DF.,BRA A. SEDESHE RICHARD C. SEDESHE, 7R Defendant(s) TO: DEBRA A. SEDESHE 1553 MAINSVILLE RD SHIPPENSBL'RG, PA 17257-9255 DATE OF NOTICE: COC.'It'T OF COMMON PLEAS CIVIL DIVISION NO. E2-3453 CIVLL., CUMBERLAND COUNTY THIS FIRM IS A DEBT COI.I.~ECTOR ATTEMPTING TO COLLECT A DE.B'T. PHIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED 'T.'() HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, '1'KIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRLT;I3 TO BF AN ATTEMPT' TC} COLLECT A DEBT, BUT Olv'I.Y AS ENFORCEMENT OF LIEN AGAINST PRUPERTI'. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATT'ORN'EY AND FILE IN WRITING WITH THE C:OIIRT YOUK DEFE:'VSES OR OBJECTIONS TO TI-IE CLAIMS SET FORTH AGAINST' ~'OU. UIvT_ESS YOU ACT' WTI'HIN "1'ly~( DAYS FRO;VI THE DATE OF THIS NOTICE, A JUDGMENT` MAY" BE ENTERED AGAINST YC)U WTI'HOUT A I-iEAR![NG AND YOU MAY L,OSF. YOUR PROPERTY OR OTHER IMPOR"TA.NT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU L)O NOfi I-IAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SEq' FORTH BELOW. "TI-fIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT I-IIRING A LAWYF,R. IF YOU CANNOT AFFORD TO MIRE A LAWYER., THIS OFFICE MAY BF., ABI_,F, TO PKOVIDI YOLI WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERt~'ICES TO EL.IGIBI,E PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse l Courthouse Square Carlisle, PA 17U13 (7l7)24U-6195 CUMBERLAND COLTTTY BAR ASSOCIATION CUMBERLAND COUNTY COUR.TIIOLTSE 2 LIBERTY AVENL`E CARLISLE, PA l7U 13 {717)249-3166 Meredith Wooters, Esq., Id. No.30?207 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 7.400 One Penn Center Plara Philadelphia, PA 191U3 ~xs tF zKSx~z THE :BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTTPICATEHOLDERS OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 Plaintiff ~7. DEBRr1 A. SEDESHE IZICI-1.~1RD C. SEDESHE, JR Defendant(s) TO: RICHARD C. SEDESHE. JR S LIBERTY DRIVE M10UNT HOLLY SPRINGS, PA 17065-1022 DATE or NOTICE: _~~~~~.. COURT OF COMMON PLEAS CTVII., DIVISION NO. 12-3453 CIVIL CUMBERLAND COUNTY THIS FIRIvI I5 A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT'. 'T'HIS NO"I"ICI:; IS SEMI' 'I'O YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREL'V, AND ANY LNFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IItiT BANKRUPTCY, THIS CORRF,SPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. I1VIPORTAiyT NOTICE YOU ARE I'~I DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARr'~yCE PERSONALLY OR BY ATTORNEY AND FILE W WRITING WITH T'I-IE COUR'T' YOUR DEF'E.NSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WTT'HIN TEN DAYS FROI~i THE DATE OF THIS NOTICE, A JUDGMENT N1AY BE ENTERED AGAL'~IST YOU WITHOUT A HARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IIv1PORTAIv"I' RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO Iv'OT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU C.~'VNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI"fFi INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. O~fice of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (71.7)240-6195 CUMBERLAND COUNTY BAR ASSOCLATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 ~j 1 }(717) 2491-3166 BY~ f ~~!~.i~l,+~~ r~l ~,~ r{~ t Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hailinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 285&62 'THE .BANK OF NEW YORK MF..LL,ON FKA THE BANK OF NEW YORK AS TRUSTEE FUR THE CERTIFICATEHOL,DERS OF THE CWABS, INC., ASSET-B:ICKED CERTIFICATES. SERIES 2005-7 Plaintiff V. DEBRA A. SEDESLIE RICHARD C. SEDESHE, JR Defendants} TO: RICHARD C. SEDESHE, JR 24 'TF.,RRI DRIVE CARLISLE, PA 17015-7106 DATE OF NOTICE: _~~~ COURT OF COM~10N PT.EAS CIVIL DIVISION NO. 12-3453 CIVIL CUMBERLAND COUNTY TI-I1S FIRA~1 IS A DEBT CC)I.vL EC"TOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEIv1PT TO COLLECT THE INDEBTEDNESS REFERRED "TO HEREIN, AND ANY li'~FORMATION OBTAINED FROM YO[I WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, "1'N1S CORRESPONDENCE IS NOT AlV'D SHOULD NOT I3E CONS'1'kU1/D '1'O Bh' AN ATTEMPT TO COLLECT A DEBT, .BUT ONLY AS ENFORCEMENT OF LIEN AGAL'~fiST PROPERTY. Ih1PORTANF NOTICE YOU ARE IN I:)EFAUL'T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR B1' ATTORNEY A:'vD FILE IN WRCTING WTCH THE COURT YOUR I~EFENSES OR OBJECTIONS TO THE CLAII+IS SET FORTH AGAINST YOtJ. UNLESS YOU ACT ~'VITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YO[JR PROPERTY OR OTHER IMPOR'I'AN'I' RIGH'T'S. YOC.1 SHOULD 'TAKE THIS PAPER TO YO[JR LAWYEK AT ONCE. IF YOU DO NOT ITAVE A LAWYER. GO TO OR TELEPHONE TI-IE OFFICE SET FURTII BELOW'. THIS OFFICE CAN PROVIDE YO[J Wl"I'H INFORMATION ABOUT HIRING A LAWYER. II~ YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OITICE MAY BE ABLE TO PROVIDE, YOU WI'T`H I'VFORMA'I'IUN ABOUT AGENCIES "TH.AT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RET.)UCED FEE UR NO FEE. Office of tt~e Prothonotary Cumberland County Courthouse l Courthouse Square Carlisle. PA 1701:± (71.70 24(}-fi l 95 CUMBERLAIv'D COUI<'TY BAR ASSOCIATION CCJMBERLAND COUNTY COURTIIQUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717} 249-31fi6 Meredith Wooters, Esq., 1d. No.307207 Attorney for Plaintiff Phelan Hallman & Schmieg, LI.P 1617 JFK Boulevard, Suite 1400 One Penn. Center Pla-ra Philadelphia, PA 19103 1'HS # 287862 (Rule of Civil Procedure No. 236) -Revised THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDER5 OF THE CWABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 vs. DEBRA A. SEDESHE RICHARD C. SEDESHE, JR CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 12-3453 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on ~o~- 3 ~ ~'" By: ~. J > d ~. ~3 ,~ -~~ If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 285862 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE PHS#285862 CWABS,INC,ASSET-BACKED CERTIFICATES,SERIES 2005-7 DEFENDANT SERVICE TX" DEBRA A.SEDESHE COURT NO.:12.3453 CIVIL : - n RICHARD C SEDESHE,JR SERVE RICHARD C SEDESHE,JR AT: TYPE OF ACTION , 24 TERRI DRIVE XX Notice of Sheriffs Sale CARLISLE,PA 17015.7106 SALE DATE: June 5,2013 its **DIVORCED-One cannot accept service for the other** SERVED r S„gved and made known 1VffhVn=dant on the day o�'20 at `a ,o'clock ,at RICHARD in the manner described below: Defendant p6^oc ally served. Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age�v - Height rD �ZH Weight Race�NNex M Other I, a competent adult,hereby verify that I personally handed a true and correct copy of the N ace 6f.Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 mating to unsworn falsification to authorities. DATE: ( A,3 NAME:Zf PRINTED NAME: TITLE: `(vb coss s-epi — NOT SERVED On the day of 20L_,at o'clock�.M,I, a competent adult hereby state that «idant l FOUND use: _Vacant Does Not Exist _Moved Does Not Reside(Not Vacant) _No Answer on at at _Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR '� -Phelan Hallinan,L LP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 Fit-E'0-01FFICS Tw: PROIHONOTAKf Atl 9. 45 Phelan Hallinan,LLP JUN 24 Attorney For Plaintiff 1.617 JFK Boulevard,Suite 1400 CUMBERUNNO COUNTY One Penn Center Plaza PENNSW'"'A. Philadelphia,PA 19103 215-563-7000 0 THE BANK OF NEW YORK MELLON FKA : Court of Common Pleas THE BANK OF NEW YORK AS TRUSTEE : FOR THE CERTIFICATEHOLDERS OF THE . : Civil Division CWABS, INC., ASSET-BACKED : CERTIFICATES,SERIES 2005-7 : CUMBERLAND County Plaintiff No. 12-3453 CIVIL vs DEBRA A.SEDESHE RICHARD C.SEDESHE,JR Defendant PRAECIPE TO THE PROTHONOTARY: Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. Please mark the in rem judgment Satisfied and the action Discontinued and Ended. F7 Please Vacate the Judgment entered. Date: PHELAN HALLINAN, LLP By: 1204400 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHS # 285862 Phelan Halli.nan, LLP Attorney for Plaintiff 1617 JF K Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THE BANK OF NEW YORK MELLON FKA Court of Common Pleas THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE C WABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2005-7 Plaintiff Civil Division V. CUMBERLAND County DEBRA A. SEDESHE No. 12-3453 CIVIL RICHARD C. SEDESHE, JR Defendant PHS # 285862 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe was served by regular mail to the person(s) on the date listed belo w: DEBRA A. SEDESHE 1553 MAINSVILLE RD SHIPPENSBURG, PA 17257-9255 RICHARD C. SEDESHE , JR 8 LIBERTY DRIVE MOUNT / /l HOLLY SPRINGS, PA 17065-1022 Date: f7 / / ! f/7 PHELAN HALLINAN, LLP By: Adam H. Davis, Esq., Id.No.203034 Attorney for Plaintiff