HomeMy WebLinkAbout12-381011
'' , .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC Bank, National Association,
CIVIL DIVISION
NO.)
a -S!9)0 cml
Plaintiff,
vs.
Vaughn A. Crawford,
Defendant.
TO DEFENDANT(S):
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT IN MORTGAGE FORECLOSURE
WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF
OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST
YOU.
By: /S/ KodnsY pap negiani
Attorney for Plaintiff
COMPLAINT IN MORTGAGE
FORECLOSURE
MORTGAGE FORECLOSURE
Filed on behalf of Plaintiff
Counsel of record for this parry:
Rodney Permigiani, Esquire
PA I.D. #33311
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
Q?Io3,75 pd alb,
CkNas9c?b I
PNC Bank, National Association,
Plaintiff,
vs.
Vaughn A. Crawford,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No.
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION
WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE
SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE
ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED
THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A
JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER
NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
(717) 249-3166
COMPLAINT IN MORTGAGE FORECLOSURE
NOW, comes the Plaintiff by its attorneys, Vitti & Vitti & Associates, P.C. and Rodney
Permigiani, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers
1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a national association having a principal place of business
located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is the holder of the
mortgage and is seeking enforcement of the mortgage through foreclosure.
2. The Defendant(s) is/are individuals with a last known mailing address of 512
Mill Race Road, Unit #57, Carlisle, PA 17013. The property address is 512 Mill Race Road,
Unit #57, Carlisle, PA 17013 and is the subject of this action.
3. On the 10th day of March, 2008, in consideration of a loan of One Hundred One
Thousand Six Hundred Ninety Five and 00/100 ($101,695.00) Dollars made by National
City Mortgage, a division of National City Bank to Defendant, the said Defendant executed
and delivered to National City Mortgage, a division of National City Bank a "Note" secured
by a Mortgage with the Defendant as mortgagor and National City Mortgage, a division of
National City Bank, as mortgagee, which mortgage was recorded on the 17th day of March,
2008, in the Office of the Recorder of Deeds of Cumberland County, at Instrument No.
200807866. The said mortgage is incorporated herein by reference thereto as though the
same were set forth fully at length. The Plaintiff is successor by merger to National City
Mortgage, a division of National City Bank.
4. The premises secured by the mortgage are:
SEE EXHIBIT "A"ATTACHED HERETO.
5. Said mortgage provides, inter alia:
"that when as soon as the principal debt secured shall become due and payable,
or in case default shall be made in the payment of any installment of principal and
interest, or any monthly payment, keeping and performance by the mortgagor of any of
the terms, conditions or covenants of the mortgage or note, it shall be lawful for
mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the
mortgage, of principal debt, interest and all other recoverable sums, together with
attorney's fees."
6. Since September 1, 2011, the mortgage has been in default by reason, inter
alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage
(including principal and interest) and, under the terms of the mortgage, the entire principal
sum is due and payable.
7. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in
1998, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s) on the date set forth thereon, and the temporary stay as
provided the said notice has terminated because Defendant(s) has/have failed to meet with
the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied
assistance by the Pennsylvania Housing Finance Agency.
8. The amount due on said mortgage is itemized on the attached schedule.
9. Pursuant to Pennsylvania Rule of Civil Procedure 1144, the Plaintiff releases
from liability for the debt secured by the mortgage any mortgagor, personal representative,
heir or devisee of the mortgagor who is not a real owner of the property at the time of the
filing of this Complaint.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6),
Plaintiff demands judgment for the amount due of One Hundred Eleven Thousand Four
Hundred Seventy Six and 37/100 ($111,476.37) with interest and costs.
Respectfully submitted,
vrmT? / SSC?f S; P.C.
BY:
Rodney Per rani quire
Attorney f lain
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance
Interest @ 5.8750% from 08/01/11 through 6/30/2012
(Plus $15.5708 per day after 6/30/2012 )
Late charges through 6/13/2012
0 months @ 29.54
Accumulated beforehand
(Plus $29.54 on the 17th day of each month after 6/13/2012 )
Attorney's fee
Escrow deficit
(This figure includes projected additional charges that may be incurred by the Plaintiff
and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale)
96,737.58
5,200.64
91.74
4,836.88
4.609.53
BALANCE DUE 111,476.37
EXHIBIT "'A"
LEGAL DESCRIPTION
ALL THAT CERTAIN unit, being Unit Number 57 (the "Unit"), of Willow Crossing, a
Condominium, located in the Township of South Middleton, County of Cumberland and
Commonwealth of Pennsylvania, which unit is designated in the Declaration of
Condominium of Willow Crossing, a Condominium (the "Declaration of Condominium")
and Declaration Plate and Plans as recorded in the Recorder's Office of Cumberland
County in Miscellaneous Book 386, page 898 and Plan Book 61, page 62 and First
Amendment to Declaration of Condominium for Willow Crossing, a condominium (the
First Amendment to Declaration of Condominium) and Declaration Plate and Plan as
recorded in the Recorder of Deeds of Cumberland County in Miscellaneous Book 388,
page 412, and Plan Book 61, page 97.
Together with an undivided 2.50% interest in Common Elements as more particularly set
forth in the aforesaid Declaration of Condominium of and Declaration Plate and Plans.
Together with the rights to use the limited common elements applicable to the Unit being
conveyed herein, pursuant to the Declaration of Condominium and Declaration Plate and
Plans.
Being known as 512 Mill Race Road, Carlisle, PA 17013.
Assessment Number 40-22-0485-070-U57.
VERIFICATION
AND NOW Rodney Permigiani verifies that the statements made in this Complaint
are true and correct to the best of his information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the
pleading is submitted by counsel based upon the information provided him by the Plaintiff.
Dated: June 13, 2012
FORM 1
PNC Bank, National Association
Plaintiff(s)
VS.
Vaughn A. Crawford
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLV, IA_1_
,
civil _
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSI
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.
6/13/2012
Date
Respec y s itt
ignature n or Plaintiff]
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
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:
Loan Number:
Total Mortgage Payments Amount: $
Date of Last Payment:
Primary Reason for Default:
State: Zip:
Yes E] No[] Listing date: Price: $
Realtor Phone:
Yes ? No ?
Home:
Cell:
Office:
Other:
State: Zip:
How long?
State: Zip:
Home:
Cell:
Office:
Other:
How long?
Date You Closed Your Loan:
Included Taxes & Insurance:
Is the loan in Bankruptcy? Yes ? No ?
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:
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed; Value:
Other transportation (automobiles boats motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
Year:
Year:
2. -
3.
Additional Income Description (not wages):
I . monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Morta e Food
2° Morta e Utilities
Car Pa ent s Condo/Nei . Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Money
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Phone:
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:
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature
Co-Borrower Signature
Date
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
1 (hardship letter)
V Listing agreement (if property is currently on the market)
FORM 3
PNC Bank, National Association
Plaintiff(s)
vs.
Vaughn A. Crawford
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
Date
FORM 4
PNC Bank, National Association IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s) ;
CIVIL ACTION
vs.
NO.
Vaughn A. Crawford
Defendant(s)
CASE MANAGEMENT ORDER
AND NOW, this day of
, 20 , the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on
at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
fl`r??ir of ;u,nbrr1446
.` r
_ t LED -OF F X'..
SHE PROT ODNd I,A
2312 JUL -9 AM : 45
C'UMBERLANG CO NTY
PENNSYLVAN A
PNC Bank, NA
vs.
Vaughn A. Crawford
Case Numb
2012-3810
SHERIFF'S RETURN OF SERVICE
06/22/2012 10:40 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 22,
2012 at 1040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Vaughn A. Crawford, by making known unto Montesa Trapp, Mother o
Defendant at 512 Mill Race Road, Unit 57, Carlisle, Cumberland County, Pennsylvania 17013 its cont nts
and at the same time handing to her personally the said true and correct copy of the same.
K, DEPU
SHERIFF COST: $34.00
June 28, 2012
SO ANSWERS,
K ANULKSON, SHERIFF
CCl'1 tyCUiln j(;f?:'i?f. 1-E?I?p ''?ff ???(:
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-3810 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s)
From VAUGHN A. CRAWFORD
(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: $111,959.0(v L.L.: $.50
Interest 8/1/12 - 12/5/12 - $2,318.93
Atty's Comm: % Due Prothy: $2.25
Atty Paid: 185.25 Other Costs:
Plaintiff Paid:
Date: 8/3/2012
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--
David D. Buell, Prothonotary
(Seal) By: ,-_?%!/?r? Z/
Deputy
REQUESTING PARTY:
Name: LOUIS P. VITTI, ESQUIRE
Address: VITTI & VITTI & ASSOC., P.C.
215 FOURTH AVENUE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 01072
F LEO-OFFICE
' ' I E PIR OTI-IONOTAR',I/
21012 AUG -3 Phi 2: 42
,'UMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
NO. 2012-3810
Plaintiff, PRAECIPE FOR DEFAULT
JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON
vs. MILITARY SERVICE
VAUGHN A. CRAWFORD,
Defendant.
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
aNk? U16' !S? PA 61?
R#?
a? a
Nv?' 'Ma`lLJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
vs
VAUGHN A. CRAWFORD,
Plaintiff, : NO: 2012-3810
Defendant.
PRAECIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Enter judgment in Default of an Answer in the amount of $111,959.06, in favor
the PNC Bank National Association, Plaintiff in the above-captioned action, against the Defendan
Vaughn A. Crawford and assess Plaintiffs damages as follows and/or as calculated in t
Complaint:
Unpaid Principal Balance $96,737.58
Interest from 8/01/11-7/31/12 5,683.33
(Plus $18.4042 per day after 7/31/12)
Late charges (Plus $29.54 per
month from 6/13/12-12/05/12 $177.24) 91.74
Attorney's fee 4,836.88
Escrow Deficit 4,609.53
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
Total Amount Due 111.959.06
The real estate, which is the subject matter of the Complaint, is situate in Twp
South Middletoon, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 512 Mill Race Road, Uj
57, Carlisle, PA 17013. Parcel No. 40-22-0485-070-U57. .o%
U'4W
LAS P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff, : NO: 2012-3810
vs
VAUGHN A. CRAWFORD,
Defendant.
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed) to the
Defendant(s), in the above-captioned case on July 17, 2012, giving ten (10) day notice that
would be entered should no action be taken.
VITTI & VITTI & ASSOCIATES, P.C.
BY:
6uis fP.Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 31 st day
of July, 2012.
n
t
Notary Publjmc? '
aOVfALT I OF PENNSYLVAP
E Notarlal seal
Sherry L. House, Notary Public
1 City of PlMurgh, Allegheny County
,p1??__ My Commisaton Expires May 15, 2015
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
VS
VAUGHN A. CRAWFORD,
Plaintiff,
Defendant.
Il"ORTANT NOTICE
TO: Vaughn A. Crawford
512 Mill Race Road
Unit 57
Carlisle, PA 17013
Date of Notice: July 17, 2012
NO: 2012-3810
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARAI
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES (
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHT
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FOI
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU `
INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
(717) 249-3166
VITTI VTTTI & ASSOCIATES, PC
BY; /??? ,
uis P. Vitti, Esq
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT
OF A LIEN AGAINST PROPERTY.**
FILCO-O FIGC
1f'1' PROTHONOTAfj,'
2012 AUG -3 PM 2: 42
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV.
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff,
vs.
VAUGHN A. CRAWFORD,
Defendant.
C Is
I VA A a
3y.oo
a Lt A
llp a <?
a' s a?
CIVIL DIVISION
NO. 2012-3810
PRAECIPE FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
LIA161? a(?sa I
Uy?10? ?
B'stcj
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff, : NO: 2012-3810
vs
VAUGHN A. CRAWFORD,
Defendant.
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) ?n the
above-captioned matter as follows:
Amount Due $111,959.06
Interest 8/01/12-12/05/12 2,318.93
Total $114,277.99
The real estate, which is the subject matter of the Praecipe for Writ of Execution is
in:
Twp of South Middletoon, Cty of Cumberland & Cmwlth of PA. HET a dwg k/a 512 Mill Race
Unit 57, Carlisle, PA 17013. Parcel No. 40-22-0485-070-U57.
ouis P. Vitti, Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV.
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff, : NO: 2012-3810
vs
VAUGHN A. CRAWFORD,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute
Defendants' last known address is 512 Mill Race Road, Unit 57, Carlisle, PA 17013.
ouis P. Vitti, Esquire
SWORN TO and subscribed
before me this 31 st day of
July, 2012.
Notary
the
i Notarial Seal
Sherry L. House, Notary Public
City of Pittsburgh, Allegheny County
I My Commission Expires May 15, 2015
MEMBER, PENN.SYLV4.Nl'A RSSOCTATIQN OF NOTARIES
r
IN THE COURT OF CONLNION P= CUMBERLADID CO=, PENNSYLVANLk
CIVIL DIVISION
PRA.ECIPE FOR WRIT OF E:CECUL'ION ?"? ro
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70 THE PROTHONOTARY OF TIC SAID COJ RT :
The undersigned hereby certifies that the below does not arise out of a retail
LnstalLrent sale, contract, or account based on a confession of judgnent, but F it doe ,
i - is based on the appropriate original proceeding filed pursuant to Art 7 of 1966 as
=rmnded; and for =eal prope.` Ly pursuant to act 6 of 1974 as amended-
issue writ of exec=ution in the above wetter to the Sheriff of j 1
County, for debt, interest and costs upon the follow.`n described prope_-Ly of the
defendant(s)
PRAE = FOR ATTA41.11 EXE=ON
Issue writ of attachment to the Sheriff of County, for deb t,
:rite-rest and costs, as above, d ecting attache nt against the above-named oarni.shee(s) fc
the fallowing prop?-ty (if real estate, supply six copies of the description; supply fC UZ?
espies of lengthy personalty Lst)
2nd all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
( Indicate) Index this writ acai rut tine carni shee s } as a Lis pendens ag?yins t
real estate of the defendant(s) described in the attached bit. 4.
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DATE: Z
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ASS: ?? QUJ 41-,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV.
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
vs
VAUGHN A. CRAWFORD,
LEGAL DESCRIPTION
Plaintiff, : NO: 2012-3810
Defendant.
ALL that certain unit, being Unit Number 57 (the "Unit"), of Willow Crossing, a Condominium, to ated
in the Township of South Middleton, County of Cumberland and Commonwealth of Pennsylvania, hich
unit is designated in the Declaration of Condominium of Willow Crossing, a Condominium (the
"Declaration of Condominium") and Declaration Plate and Plans as recorded in the Recorder's Office of
Cumberland County in Miscellaneous Book 386, page 898 and Plan Book 61, page 62 and irst
Amendment to Declaration of Condominium for Willow Crossing, a Condominium (the First Amen ent
to Declaration of Condominium) and Declaration Plate and Plan as recorded in the Recorder of Deeds of
Cumberland County in Miscellaneous Book 388, page 412, and Plan Book 61, page 97.
TOGETHER with an undivided 2.50% interest in Common Elements as more particularly set forth i the
aforesaid Declaration of Condominium of and Declaration Plate and Plans.
TOGETHER with the rights to use the limited Common Elements applicable to the Unit being con
herein, pursuant to the Declaration of Condominium and Declaration Plate and Plans.
HAVING erected thereon a dwelling known as 512 Mill Race Road, Unit 57, Carlisle, PA 17013.
PARCEL NO. 40-22-0485-070-U57.
BEING the same premises which Jacob E. Geyer and Karen E. Geyer, husband and wife, by Deed
3/06/2008 and recorded 3/17/2008 in the Recorder's Office of Cumberland County, Pennsyl
Instrument No. 200807865, granted and conveyed unto Vaughn A. Crawford.
F F1 C,
PR4TH4!R
f
2Q12 AU6 -3 P? 2' 43
CUMBERLAN VANIA
IN THE COURT OF CO& PLEAS OF CUMBERLAND COUNTY, PENNSYLV
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION,
Plaintiff, : NO: 2012-3810
vs
VAUGHN A. CRAWFORD,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Bank, National Association, Plaintiff in the above action, sets forth as of the date the Praei
the Writ of Execution was filed the following information concerning the real property located at 5
Race Road, Unit 57, Carlisle, PA 17013.
1. Name and address of Owner(s) or Reputed Owner(s):
Name:
Vaughn A. Crawford
Address (Please indicate if this
cannot be reasonably ascertained)
512 Mill Race Road
Unit 57
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record
the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
NONE
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
for
Mill
on
NONE
5. Name and address of every other person who has any record lien on the property:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien ?n the
property and whose interest may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who h" any
interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of South Middleton Township
South Middleton Municipal Authority
Pennsylvania Department of Revenue
Office of Chief Counsel
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Tax Claim Bureau of Cumberland County
Cumberland County Courthouse
Court of Common Pleas of
Cumberland County
Domestic Relations Division
PA Dept. of Sheriff Sales
Bureau of Compliance
20 Buckthorn Drive
Carlisle, PA 17013
P.O. Box 8
Boiling Springs, PA 17007
Inheritance Tax Dept.
PO Box 281061
Harrisburg, PA 17128
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Dept. #281230
Harrisburg, PA 17128-1230
Tenant/Occupant
512 Mill Race Road
Unit 57
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge or information and belief. I understand that false statements herein are made subject ? o the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
July 31, 2012
Date ouis P. Vitti, Esquire
Attorney for Plaintiff
SWORN TO and subscribed
before me this 31 st day
of July, 2012.
Notary Publ' c
COMMONWEALTH OF PENNSYLV IA
?g Notarial Seal
Sherry L. House, Notary Public
City of Pittsbounrgh, Allegheny County
?_ My commissi Expires May 15, 2015
,?cudya?t -, .,t c F'- ,:,'fA"*nrifni QF lr?TCRYES
C:.
I"a
G
NOTICE OF SHERIFF'S SALE OF -o
REAL ESTATE PURSUANT TO p '
PENNSYLVANIA RULE OF CIVIL y x
PROCEDURE 3129.1
TO: Vaughn A. Crawford
512 Mill Race Road
Unit 57
Carlisle, PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed,
be exposed to Public Sale in Cumberland County Courthouse on December 5, 2012 at 10:00.
following described real estate, of which Vaughn A. Crawford are owners or reputed owners:
Twp of South Middletoon, Cty of Cumberland & Cmwlth of PA. HET a dwg k1a 512 Mill Race
Unit 57, Carlisle, PA 17013. Parcel No. 40-22-0485-070-U57.
" l
r
i
a n-
Will
the
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action o PNC
Bank National Association vs. Vaughn A. Crawford at 2012-3810 in the amount of $111,959.06.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30? days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may
property to be held or taken to pay the judgment. You may have legal rights to prevent your pr(
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise
you must act promptly.
of the
of the
your
from
rights
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO Y UR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU AN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriff s Sale and the loss of your property. In or er to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale odors, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objecti you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition w th the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriff s Sale would ordinarily be delayed pending a trial of the issue of w ether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twee (20)
days after service or in certain other events. To exercise this right, you would have to file a peti ion to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the S eriff s
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other 1 al or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you shou]
petition with the Court after the sale and before the Sheriff has delivered his Deed to the proper
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from 1
when the Schedule of Distribution is filed in the Office of the Sheri
uis P. Vitti, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVI
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND S]
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCI
OF A LIEN AGAINST PROPERTY.**
file a
The
e date
ANY
JSLY
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Hoc
diaxar� €r�r4 ttQ
Jody S Smith " � Tt€� '/
Chief Deputy c ° ~] `
Richard W Stewart CU1 BERLAND CQUN- Y
'
Solicitor
� ENNS YLY t
ANIA
PNC Bank, National Association
vs. Case Number
Vaughn A. Crawford 2412-3814
SHERIFF'S RETURN OF SERVICE
49/21/2012 47:54 PM-Deputy Tim Black, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 512 Mill Race Road, Unit 57, South Middleton Township, Carlisle, PA 17013,
Cumberland County.
11/0512012 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:Vaughn A. Crawford, 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 512 Mill Race Road, Unit 57, Carlisle, PA 17013, neighbor states
that defendant moved weeks ago, mail is still delivered there.
11/14/2012 As directed by Louis P Vitti,Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013
02/21/2013 Affidavit of Service to Lienholders Filed in Sheriffs Office
03/07/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold
the same for the sum of$ 1.00 to Attorney Louis Vitti, on behalf of PNC Bank, National Association, being
the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,079.99 SO ANSWERS,
May 03, 2013 RbNW R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
PNC BA KV NATIONAL ASSOCIATION,
Plaintiff, :NO: 2012-3810
vs :
VAUGHN A. CRAWFORD,
Defendant. :
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Bank,National Association, Plaintiff in the above action, sets forth as of the date the Praecipe for
the Writ of Execution was filed the following information concerning the real property located at 512 Mill
Race Road, Unit 57, Carlisle, PA 17013.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address(Please indicate if this
cannot be reasonably ascertained)
Vaughn A. Crawford 512 Mill Race Road
Unit 57
Carlisle,PA 17013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
NONE
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
NONE
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on the
property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who-has any
interest in the property which may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of South Middleton Township 20 Buckthorn Drive
Carlisle, PA 17013
South Middleton Municipal Authority P.O. Box 8
Boiling Springs, PA 17007
Pennsylvania Department of Revenue Inheritance Tax Dept.
Office of Chief Counsel PO Box 281061
Harrisburg, PA 17128
Commonwealth of PA-DPW P.O. Box 8016
Harrisburg,PA 17105
Clerk of Courts One Courthouse Square
Criminal/Civil Division Carlisle, PA 17013
Tax Claim Bureau of Cumberland County One Courthouse Square
Cumberland County Courthouse Carlisle, PA 17013
Court of Common Pleas of P.O. Box 320
Cumberland County Carlisle, PA 17013
Domestic Relations Division
PA Dept. of Sheriff Sales Dept. #281230
Bureau of Compliance Harrisburg, PA 17128-1230
Tenant/Occupant 512 Mill Race Road
Unit 57
Carlisle, PA 17013
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.
July 31, 2012
Date Xouistti, Esquire
Attorney for Plaintiff
SWORN TO and subscribed
before me this 31 st day
of July,2012.
Notary Publ'c
COMMONWEALTH OF PENNSYLVANIA
IA
Notarial Seal
Sherry L.House,Notary Public
City of Pittsburgh,Allegheny County
My Commission Expires May 15,2015
A4F{9kER,n:;1e.c(t.\rnpe c r{�+6ei lad OF WMARJtb
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Vaughn A. Crawford
512 Mill Race Road
Unit 57
Carlisle,PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County,Pennsylvania and to the Sheriff of Cumberland County,directed,there will
be exposed to Public Sale in Cumberland County Courthouse on December 5, 2012 at 10:00 A.M., the
following described real estate, of which Vaughn A. Crawford are owners or reputed owners:
Twp of South Middletoon, Cty of Cumberland& Cmwlth of PA. HET a dwg k/a 512 Mill Race Road,
Unit 57, Carlisle, PA 17013. Parcel No. 40-22-0485-070-U57.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of PNC
Bank National Association vs.Vaughn A. Crawford at 2012-3810 in the amount of$111,959.06.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten(10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your property from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriff s Sale and the loss of your properly. In order to
exercise those rights,prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing,before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty(20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend,you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened,the Sheriff s Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty(20)
days after service or in certain other events. To exercise this right, you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution.and the Sheriff s
Sale if you can show a defect in the Writ of.Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriff s Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of tASherni &7
tt i, Esquire
Attorney for Plaintiff
215 Fourth Avenue
Pittsburgh,PA 15222
(412) 281-1725
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT
OF A LIEN AGAINST PROPERTY."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK,NATIONAL ASSOCIATION,
Plaintiff, : NO: 2012-3810
vs
VAUGHN A. CRAWFORD,
Defendant.
LEGAL DESCRIPTION
ALL that certain unit,being Unit Number 57 (the"Unit"), of Willow Crossing, a Condominium, located
in the Township of South Middleton, County of Cumberland and Commonwealth of Pennsylvania,which
unit is designated in the Declaration of Condominium of Willow Crossing, a Condominium (the
"Declaration of Condominium") and Declaration Plate and Plans as recorded in the Recorder's Office of
Cumberland County in Miscellaneous Book 386, page 898 and Plan Book 61, page 62 and First
Amendment to Declaration of Condominium for Willow Crossing,a Condominium(the First Amendment
to Declaration of Condominium) and Declaration Plate and Plan as recorded in the Recorder of Deeds of
Cumberland County in Miscellaneous Book 388,page 412, and Plan Book 61,page 97.
TOGETHER with an undivided 2.50%interest in Common Elements as more particularly set forth in the
aforesaid Declaration of Condominium of and Declaration Plate and Plans.
TOGETHER with the rights to use the limited Common Elements applicable to the Unit being conveyed
herein,pursuant to the Declaration of Condominium and Declaration Plate and Plans.
HAVING erected thereon a dwelling known as 512 Mill Race Road, Unit 57, Carlisle, PA 17013.
PARCEL NO. 40-22-0485-070-U57.
BEING the same premises which Jacob E. Geyer and Karen E. Geyer,husband and wife,by Deed dated
3/06/2008 and recorded 3/17/2008 in the Recorder's Office of Cumberland County, Pennsylvania,
Instrument No. 200807865, granted and conveyed unto Vaughn A. Crawford.
CUMBERLAND LAW JOURNAL
Writ No. 2012-3810 Civil Term land County, Pennsylvania, Instru-
ment No. 200807865, granted and
PNC BANK,NATIONAL conveyed unto Vaughn A. Crawford.
ASSOCIATION
VS.
VAUGHN A. CRAWFORD
Atty.:Louis P.Vitti
ALL that certain unit,being Unit
Number 57 (the "Unit"), of Willow
Crossing, a Condominium, located
in the Township of South Middleton,
County of Cumberland and Com-
monwealth of Pennsylvania, which
unit is designated in the Declaration
of Condominium of Willow Crossing,
a Condominium (the "Declaration
of Condominium") and Declaration
Plate and Plans as recorded in the Re-
corder's Office of Cumberland County
in Miscellaneous Book 386,page 898
and Plan Book 61,page 62 and First
An to Declaration of Condominium
for Willow Crossing,a Condominium
(the First Amendment to Declaration
of Condominium) and Declaration
Plate and Plan as recorded in the
Recorder of Deeds of Cumberland
County in Miscellaneous Book 388,
page 412,and Plan Book 61,page 97.
TOGETHER with an undivided
2.50%interest in Common Elements
as more particularly set forth in
the aforesaid Declaration of Con-
dominium of and Declaration Plate
and Plans.
TOGETHER with the rights to use
the limited Common Elements ap-
plicable to the Unit being conveyed
herein,pursuant to the Declaration
of Condominium and Declaration
Plate and Pla
HAVING erected thereon a dwell-
ing known as 512 Mill Race Road,
Unit 57,Carlisle,PA 17013.PARCEL
NO.40-22-0485-070-U57.
BEING the same premises which
Jacob E. Geyer and Karen E. Geyer,
husband and wife, by Deed dated
3/06/2008 and recorded 3/17/2008
in the Recorder's Office of Cumber-
29
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
. ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 26, November 2 and November 9, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
e -
isa Marie Coyne,Pditor
SWORN TO AND SUBSCRIBED before me this
da of November, 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
i
xois- io Clvn Tom
iPNC BANK,NATIONAL
ASSOCIATION
Vs.
VAUGHN A.CRAWFORD
Attye Wins P Vim
ALL that curtain unik being Unit Number
57(the"Unit"),of Willow CrON4 a
Condominium,located in the Unship of
South Middleton,County of Cumberland
and Commonwealth of Pennsylvania,
which unit is designated in the Declaration
Of Condominium of Willow Crossing,
a Condominium(the"Declaration of
Condominium I and Declaration Plate and
Plans as recorded in the Recorder's Office
Of Cumberland County in Miscellaneous
Book 386,page 898 and Plan Book 61,
page 62 and First An to Decluationof
Condominium for Willow Crossing,a
Condominium(the First Amendment
to r4FIRration of Condonnnium)and
De, !%tion Plate and Plan as recorded
in the Recorder of Deeds of Cumberland
County in Miscellaneous Book 388;page
412,and Plan Book 61,page 97.
TOGETHER with an undivided 2A%
interest in Common Elements as more
particularlyset forth is the aforesaid
Declaration of Condominium of and
Declaration Plate and Plans.
TQGETfiER with the rights to use the
limited Common Elements applicable to
the Unit being conveyed hereim,pursuant
to the Declaration of Condominium and
Declaration Plate and Pla
HAVING erected thereon a dwelling
known as 512 Mill Race Road,Unit 57,
Carlisle,PA 17013.PARCEL No.40-22_
04854MU57.
BEING the same premises which Jacob
E.Geyer and Karen E.Geyer,husband
and wife,by Deed dated 3*2008 and
recorded 3/17/2006 in the Recorder's Office
of Cumberland County,Pennsylvania,
Instrument No.200=65,granted and
conveyed unto Vaughn A.Crawford.
The Patriot-News Co.
2020'Technology Pkwy e atr1*otwXews
. Suite 300
Mechanicsburg, PA 17050 NOW you KnOW
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
10/26/12
11/02/12
11/09/12
Sworn to bscribedbore t is Nov tuber, 2012 A.D.
i
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarlal Seal
Sherrie L.Owens,Notary Public
Lower Paxton Twp.,Dauphin county
M commission E Tres N_ov.26,2015
MEMBER PENNSYLVANIA ASSOCIA"LION Of M?TARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which PNC Bank,N A is the grantee the same having been sold to said grantee on
the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the 3rd day of
August, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number
3810, at the suit of PNC Bank,N A against Vaughn A. Crawford is duly recorded as Instrument Number
201314814.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D. o? d
r
c
ecorder of Deeds
,iecorder of Deeds,Cumberland C q,Cadisie,PA
biy Commission Expires the First Monday of Jan.2014