HomeMy WebLinkAbout12-5015IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC Bank, National Association,
Plaintiff,
vs.
Rebecca L. Staub
Defendants.
TO DEFENDANT(S):
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT
IN MORTGAGE FORECLOSURE WITHIN TWENTY (20) DAYS FROM
SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED
AGAINST YOU.
BY: /S/ tom V. Vim
Attorney for Plaintiff
CIVIL DIVISION
NO. Ja - 5015 01VII
COMPLAINT IN MORTGAGE
FORECLOSURE
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MORTGAGE FORECLOSURE ' T
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Filed on behalf of Plaintiff ? w °C
Counsel of record for this pa rty ;
Lois M. Vitti, Esquire '
PA I.D. #209865
Vitti & Vitti & Associates, P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
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PNC Bank, National Association, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
Rebecca L. Staub,
CIVIL ACTION - LAW
Defendant.
: 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 Lois M.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141
through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a national association having a principal place of business
located at 3232 Newmark Drive, Miamisburg, OH 45342. Plaintiff is the holder of the
mortgage and is seeking enforcement of the mortgage through foreclosure.
2. The Defendant(s) is/are individuals who resides at 1141 Rana Villa Avenue,
Camp Hill, PA 17011. The property address is 11 Hummel Avenue, Camp Hill, PA 17011
and is the subject of this action.
3. On the 24th day of March, 2006, in consideration of a loan of Ninety Four
Thousand Eight Hundred One and 00/100 ($94,801.00) Dollars made by Accubanc
Mortgage, a division of National City Bank of Indiana, to Defendant, the said Defendant
executed and delivered to Accubanc Mortgage, a division of National City Bank of Indiana,
a "Note" secured by a Mortgage with the Defendant as mortgagor and Accubanc Mortgage,
a division of National City Bank of Indiana, as mortgagee, which mortgage was recorded on
the 28th day of March, 2006, in the Office of the Recorder of Deeds of Cumberland County,
at Book No. 1944 Page No. 3448. The said mortgage is incorporated herein by reference
thereto as though the same were set forth fully at length. The Plaintiff, PNC Bank, National
Association is successor by merger to National City Bank, successor by merger to Accubanc
Mortgage, a division of National City Bank of Indiana.
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 July 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 Ten Thousand Seventy
Five and 33/100 ($110,075.33) with interest and costs.
Respectfully submitted,
VITTI & V SSOCIATES, P.C.
BY: /
Lois K-Vitfi, Esquire
Attorney for Plaintiff
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance
Interest @ 6.5000% from 06/01/11 through
(Plus $15.6982 per day after 8/31/2012 )
Late charges through 8/9/2012
0 months @ 33.00
Accumulated beforehand
(Plus $33.00 on the 17th day of each month after
Attorney's fee
Escrow deficit
8/31/2012
8/9/2012 )
(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)
88,151.37
7,174.07
521.60
4,407.57
9,820.72
BALANCE DUE 110,075.33
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or parcel of land Onto in Lower Aden Township, Curnbeftnd County.
Pennayl , more particularly bounded and deed as fallows, to wit
BEGINNING at a point on the Southeriy line of Hummel Avenue, vchM point Is 175 feet Weal: of
the Southwesterly corner of 1 e Street and Hummel Avenue; Race MraAh the corttor of a
partition wall and beyond South 27 degrm 30 minutes E M,1021116M to a point on the No rk"
tins of a 20 feet vdtte public alley; ftnoe along same South iii deW4m 30 minutes. West. 35 feet
to a point; Men e North 27 degrees 30 mhAes W4M.102 feet to a point on ft Srfthedy fine of
Hummel Avenue *ressid; thenai a" some North 62 degrees 30 minutes Easy 35 feat to a
ptllnt, the plme of BEGINNING.
SLING premims known as t 1 Hummel Avenue, Camp HE, Psnnsy vsnls.
SUBJECT, HOWEVER, to the rights of the Pennsylvania Department of Mlghways in and to
Pennsylvania Route Number 757 soma the rear of the sold lot.
UNDER AND SUBJECT to any wd ell covenants, conditions, realrWons, rights of voy,
•asoments and agmements vlslbleE or of record.
BJC NG THE SAME PREMISES which Howard R. Raber, by his deed to be recorded
simultaneously herewith In ft Oft e of the Recorder of Deeds of Cumberland County
PennsyWnis, WeAted and wtveyed unto Rebecca L. Staub.
VERIFICATION
AND NOW Lois M. Vitti verifies that the statements made in this Complaint are true
and correct to the best of her 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 her by the Plaintiff.
Lois itti
Dated: August 9, 2012
FORM 1
PNC Bank, National Association,
IN THE COURT OF COMMON PLEAS Q r ?'
CUMBERLAND COUNTY, PENNSYLVA- lik
Plaintiff(s)
vs.
Rebecca L. Staub,
Defendant(s)
ivil
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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 most 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.
Respectfully
August 9, 2012 / // V
Date [Signatur o unly se for 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
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender:
Type of Loan:
State: Zip:
Yes ? No ? Listing date: -Price: $_
Realtor Phone:_
Yes ? No ?
Home:
Cell:
State: Zip:
Office:
Other:
How long?
Home:
Cell:
State: Zip:
How long?
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment: _
Primary Reason for Default:
Office:
Other:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Horne: $ $ _
Other Real Estate: $ $ _
Retirement Funds: $ $ _
Investments: $ $
Checking: $_ $
Savings: $ $
Other: $ $
Automobile #1: Model:_ Year:
Amount owed: Value:
Automobile #2: Model:_ Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. _ 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" mortgage Utilities
Car Payment(s) Condo/Nei . Fees
Auto Insurance Med. not covered
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
Child Su rt/Alim. Spending Money
Da /Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:-
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Servicing Company (Name):
Contact:
Phone:
Phone:
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this document along with the following information to lender and
lender's counsel:
V Proof of income
V 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)
FORM 3
PNC Bank, National Association,
Plaintiff(s)
vs.
Rebecca L. Staub,
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.
Rebecca L. Staub, NO.
Defendant(s)
CASE MANAGEMENT ORDER
AND NOW, this day of
, 20 , the defendantiborrower 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/] ender 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.
S
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
Plaintiff, NO. 12-5015 CIVIL
vs. PRAECIPE FOR DEFAULT
REBECCA L. STAUB, JUDGMENT, CERTIFICATION OF
Defendant. MAILING AND AFFIDAVIT OF NON-
MILITARY SERVICE
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vitti, Esquire
Supreme Court #01072
Vitti & Vitti & Assoc., P.C.
215 Fourth Avenue
Pittsburgh, PA 15222
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs. )
REBECCA L. STAUB, )
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 $110,781.74, in favor of
the PNC Bank, National Association , Plaintiff in the above-captioned action, against the
Defendants, Rebecca L. Staub and assess Plaintiffs damages as follows and/or as calculated in the
Complaint:
Unpaid Principal Balance $88,151.37
Interest from 6/1/11-10/15/2012 7,880.48
(Plus 6% per day after 10/15/2012)
Late charges (Plus $33.00 per
month from 8/9/12-3/6/13 $264.00) 521.60
Attorney's fee 49407.57
Escrow Deficit 9.820.72
(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 $110,781.74
The real estate, which is the subject matter of the Complaint, is situate in Lower Allen
Twp, Cumberland County, Cmwlth of PA. HET a dwg k/a 11 Hummel Ave, Camp Hill, PA 17011.
Parcel# 13-22-0536-011.
ouis P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
VS. )
REBECCA L. STAUB, )
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 September 18, 2012, giving ten (10) day notice that
judgment would be entered should no action be taken.
VITTI & VITTI & ASSOCIATES, P.C.
BY: ole
d-cu 61
Louis P. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 15th day
of October, 2012.
1Notary Public
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA.
CIVIL. DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
VS. )
REBECCA L. STAUB, )
Defendant. 1
IMPORTANT NOTICE
TO: Rebecca L. Staub
1141 Rana Villa Ave
Camp Hill, PA 17011
Date of Notice: September 18, 2012
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING 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
OR
717.249.3166
VI 4 & ASSOCIATES, PC
BY,:, R1 I - i I
ouis P. itti, quirk
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.**
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Service Members Civil Relief Act of 2004 and designated therein as military service,
and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act,
and that the averments herein set forth, insofar as they are within his knowledge, are correct, and
true; and insofar as they are based on information received from others, are true and correct as he
verily believes. In the alternative, should the defendant(s) be currently serving in the military the
Service Members Relief Act does not apply as the mortgage in question did not originate before the
period of the Service Members military service and is secured by a mortgage pursuant to 50 U.S.C.
App §533 formerly cited as 50 U.S.C. App §532 (a)(1)(2).
This Affidavit is made under the provisions of the S ce embers Civil Relief Act of 2004.
jj r(oU4AQUJ A
Louis P. Vitti, Esquire
SWORN to and subscribed
before me this 15th day
of October, 2012.
Notary Public
f?
'•._ L y r1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs. )
REBECCA L. STAUB, )
Defendant. )
AFFIDAVIT
I, Louis P. Vitti, hereby certify that as representative of PNC Bank, National Association am
familiar with the above-captioned case and various servicing activities related thereto and that the
provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been
complied with in the above-captioned case.
ouis P. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 15th day
of October, 2012.
ary Public
I ."
,I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION
vs.
REBECCA L. STAUB,
Plaintiff, NO. 12-5015 CIVIL
PRAECIPE FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
Defendant. 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
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was
(412) 281-1725
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-liv
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs. )
REBECCA L. STAUB, )
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) in the
above-captioned matter as follows:
Amount Due
$110,781.74
Interest 10/16/12-03/06/2013
Total
2,567.71
$113,349.45
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
in:
Lower Allen Twp, Cumberland County, Cmwlth of PA. HET a dwg k/a 11 Hummel. Ave, Camp Hill, PA
17011. Parcel# 13-22-0536-011
ouis P. Vitti, Esquire
Attorney for Plaintiff
Ii T COUF.T OF CO _MJN ?LAS OF CUMBERLMD COUNTI , PENNS`_LVANLT,
CIVIL DIVISION --
PRk=IPE FOR WRIT OF E.,==ION
3CtlOn:
vs.
1 '0 T'HE PROTNOC#?IAFY OF T-E SAID COURT:
( ) Con=essed JudgTent
( ) Sher
ile
Amoun t Due L, 1 L D
Interest ICS IL I Z 3 Cc L3 - $ J(e 1 \
A t tv ` s Calm
CCSt5
The unde zzigned hereby ce~ -fies that the below do-as not a??se out of a re a:
nstaLl=t sale, cont_-mct, o. account based on a cO=essi on of jud nt, but s i t does,
t is based on the ao_oroar; -te ori:gina_l p=ee-ding '-,led rDL suant to Act 7 of 196c as
--nded; and Lcr _P?i pmt arty pursuant to act 6 of 1974 as airy-?de-d_
Issue w_t of exPcstion in the above rrztter to the She.-ire of
:=-Ity, dn= dabt, i-nte=st and costs urn the *oi iow_na desc_-ib°rd p-? `^Y of the
ie_=??dantf s )
C, C ?? r
PIRAECIPEE, MR A=E- =L
Issue writ of attach?7nnt to the Sheri r od County, for debt
_nt??est as above, d_=-Lng at tacrm_-nt age is t the abov -
e-narr_-d ga_-=shee ( s) =cam
?o>>owing p=oa?--yy (L real estate, sucDly si: copies or the des-- a ion; suonly dons=
:0 C' es C _an??.hy ?:maz= 0C1 - _i5 t) _
7G _?. Other pr7 - Gi the de=e luant(5) .n t le SSe55_On, CLIStJ1}' Oi CO? r y OT t}7a
(- ?=C?te) If1C1°?: tr Vr aQalPS t the gar, ? shee s) as a > > s nae S agai-nst
derP.-)danti. s) desC ite-c in the attached. 05 jt _
)A E: Sianatu`e
P-inc Name:
or = Lor:?CiC\?? 1 ??
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
VS.
REBECCA L. STAUB,
Defendant.
LEGAL DESCRIPTION
All that certain tract or parcel of land situate in Lower Allen Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the Southerly line of Hummel Avenue, which point is 1.75 feet West of the
Southwesterly corner of 18th Street and Hummel Avenue, thence through the center of a partition wall
and beyond South 27 degrees 30 minutes East, 102 feet to a point on the Northerly line of a 20 feet wide
public alley; thence along same South 62 degrees 30 minutes West, 35 feet to a point; thence North 27
degrees 30 minutes West, 102 feet to a point on the Southerly line of Hummel Avenue aforesaid; thence
along same North 62 degrees 30 minutes East, 35 feet to a point, the place of beginning.
Subject however to the rights of the Pennsylvania Department of Highways in and to Pennsylvania Route
Number 767 across the rear of the said lot.
Under and subject to any and all covenants, conditions, restrictions, rights of way, easements and
agreements visible of record.
Having erected thereon a dwelling known as 11 Hummel Avenue, Camp Hill, PA 17011
Parcel # 13-22-0536-011
Being the same premises of Howard R. Raber and Teresa A. Raber, husband and wife, by their deed dated
3/24/06 and recorded on 3/28/06 in the Recorder of Deed Office of Cumberland County, Pennsylvania
in Deed Book Volume 273 page 3592 granting and conveying unto Rebecca L. Staub.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs.
REBECCA L. STAUB,
Defendant.
AFFIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief,
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute . That the
Defendants' last known address is 1141 Rana Villa Ave, Camp Hill, PA 17011.
ouis P. Vitti, Esquire
SWORN to and subscribed
before me this 15th day
of October, 2012.
Notary Public
'. tie i f?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs. )
REBECCA L. STAUB, )
Defendant. )
AFFIDAVIT PURSUANT TO RULE 31291
PNC Bank, National Assoication, 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 11
Hummel Ave, Camp Hill, PA 17011.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Rebecca L. Staub 1141 Rana Villa Ave
Camp Hill, PA 17011
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)
PNC Mortgage 3232 New Mark Drive
Miamisburg, OH 45342
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 Lower Allen Township
Lower Allen Township
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
2233 Gettysburg Road
Camp Hill, PA 17011
c/o Sewer Department
2233 Gettysburg Road
Camp Hill, PA 17011
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
PA Dept. of Sheriff Sales
Bureau of Compliance
Tenant/Occupant
Dept. #281230
Harrisburg, PA 17128-1230
11 Hummel Ave
Camp Hill, PA 17011
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 unswom falsification to authorities.
October 15, 2012
Date
SWORN TO and subscribed
before me this 15th day
of October, 2012.
i
Notary Public
Louis P. Vitti, Esquire
Attorney for Plaintiff
Uar
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO . ,
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1 -
TO: Rebecca L. Staub
1141 Rana Villa Ave
Camp Hill, PA 17011
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 March 6, 2013 at 10:00 A.M., the
following described real estate, of which Rebecca L. Staub are owners or reputed owners:
Lower Allen Twp, Cumberland County, Cmwlth of PA. HET a dwg k/a 11 Hummel Ave, Camp Hill, PA
17011. Parcel# 13-22-0536-011
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of PNC
Bank, National Association vs. Rebecca L. Staub at No. 12-5015 Civil in the amount of $110,781.74.
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 property. In order to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriff s Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20)
days after service or in certain other events. To exercise this right, you would have to file a petition to
strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the She
Louis 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. 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.**
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-5015 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 REBECCA L. STAUB
(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: $110,781.74 L.L.:.50
Interest FROM 10/16/12-3/6/2013 - $2,567.71
Atty's Comm: % Due Prothy: $2.25
Arty Paid: $209.25 Other Costs:
Plaintiff Paid:
Date: 10/22/12
id DAB ll, Prothonotary
LB
(Seal) ?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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff u i it �'F�0 {ii:.,i� =;
Jody S Smith ` ? ( +A _7
Chief Deputy )-"y
AM '
Richard W Stewart 0MttRLAHDLI t'�J
Solicitor F F�'ERIrF PENNSYLVANIA
PNC Bank, National Association
Case Number
vs.
2012-5015
Rebecca L. Staub
SHERIFF'S RETURN OF SERVICE
01/04/2013 05:52 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 11 Hummel Avenue, Camp Hill, PA 17011, Cumberland
County.
01/15/2013 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: Rebecca L. Staub, 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 1141 Rana Villa Ave, Camp Hill, PA 17011, defendant no longer resides at
address stated, left forwarding at the post office of: 327 Hogestown Road, Mechanicsburg, PA 17050.
01/17/2013 10:03 AM -Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Rebecca L. Staub at 327 Hogestown Road, Silver Spring Township, Mechanicsburg, PA 17055,
Cumberland County.
02/20/2013 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: $1,036.13 SO ANSWERS,
&Z,
April 30, 2013 RON R ANDERSON, SHERIFF
s U Z-Z-
Con yS;.c e.... ,,.fi, tr!t,.,.,oft.In._.
f
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK,NATIONAL ASSOCIATION, ) NO. 12-5015 CIVIL
Plaintiff, )
vs. )
REBECCA L. STAUB, )
Defendant. )
AFFIDAVIT PURSUANT TO RULE 3129.1
PNC Bank,National Assoication, 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 11
Hummel Ave, Camp Hill, PA 17011.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Rebecca L. Staub 1141 Rana Villa Ave
Camp Hill,PA 17011
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)
PNC Mortgage 3232 New Mark Drive
Miamisburg, OH 45342
ti
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 Lower Allen Township 2233 Gettysburg Road
Camp Hill,PA 17011
Lower Allen Township c/o Sewer Department
2233 Gettysburg Road
Camp Hill, PA 17011
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
v
PA Dept. of Sheriff Sales Dept. #281230
Bureau of Compliance Harrisburg, PA 17128-1230
Tenant/Occupant 11 Hummel Ave
Camp Hill,PA 17011
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.
October 152012 .... " "
Date Aouisi ,Esquire
Attorney for Plaintiff
SWORN TO and subscribed
before me this 15th day
of October,2012. _ m
Notary Public
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Rebecca L. Staub
1141 Rana Villa Ave
Camp Hill, PA 17011
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 March 6, 2013 at 10:00 A.M., the
following described real estate, of which Rebecca L. Staub are owners or reputed owners:
Lower Allen Twp, Cumberland County, Cmwlth of PA.HET a dwg k/a 11 Hummel Ave, Camp Hill,PA
17011. Parcel# 13-22-0536-011
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of PNC
Bank,National Association vs. Rebecca L. Staub at No. 12-5015 Civil in the amount of$110,781.74.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten(10)days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
The Writ of Execution has been issued because there is a judgment against you. It may cause your
property to be held or taken to pay the judgment. You may have legal rights to prevent your property from
being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights
you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF'EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717)249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to
exercise those rights,prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty(20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend,you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the 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 Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten(10) days from the date
when the Schedule of Distribution is filed in the Office of the Sh
V
Louis 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. 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, ) NO. 12-5015 CIVIL
Plaintiff, )
VS. )
REBECCA L. STAUB, )
Defendant. )
LEGAL DESCRIPTION
All that certain tract or parcel of land situate in Lower Allen Township, Cumberland County,
Pennsylvania,more particularly bounded and described as follows,to wit:
Beginning at a point on the Southerly line of Hummel Avenue, which point is 175 feet West of the
Southwesterly corner of 18th Street and Hummel Avenue, thence through the center of a partition wall
and beyond South 27 degrees 30 minutes East, 102 feet to a point on the Northerly line of a 20 feet wide
public alley; thence along same South 62 degrees 30 minutes West, 35 feet to a point; thence North 27
degrees 30 minutes West, 102 feet to a point on the Southerly line of Hummel Avenue aforesaid; thence
along same North 62 degrees 30 minutes East, 35 feet to a point,the place of beginning.
Subject however to the rights of the Pennsylvania Department of Highways in and to Pennsylvania Route
Number 767 across the rear of the said lot.
Under and subject to any and all covenants, conditions, restrictions, rights of way, easements and
agreements visible of record.
Having erected thereon a dwelling known as 11 Hummel Avenue, Camp Hill,PA 17011
Parcel# 13-22-0536-011
Being the same premises of Howard R.Raber and Teresa A.Raber,husband and wife,by their deed dated
3/24/06 and recorded on 3/28/06 in the Recorder of Deed Office of Cumberland County, Pennsylvania
in Deed Book Volume 273 page 3592 granting and conveying unto Rebecca L. Staub.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-5015 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION Plaintiff(s)
From REBECCA L.STAUB
(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: $110,781.74 L.L.: .50
Interest FROM 10/16/12-3/6/2013-$2,567.71
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $209.25 Other Costs:
Plaintiff Paid:
Date: 10/22112
David D. Buell,Prothonota
(Seal}
Deputy
REQUESTING PARTY:
Name: LOUIS P.VITTI,ESQUIRE
Address: VITTI &VITTI&ASSOC.,P.C.
215 FOURTH AVENUE
PITTSBURGH,PA 15222
Attorney for: PLAINTIFF TRUE COPY RUN! RECORD
In Testimony whereof,I here unto set my hand
Telephone: 412-281-1725 and the seal of said Court at Carlisle,Pa.t
This„._: day of i ,r-onotary
Supreme Court ID No. 01072 � jJ � �pr1,p���
On October 26, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA,
Known and numbered as, 11 Hummel Avenue,
Camp Hill, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: October 26, 2012
By:
Re state Coordinator
LO :Z d U 130 1101
CUMBERLAND LAW JOURNAL
Writ No. 2012-5015 Civil
PNC Bank,National Association
VS.
Rebecca L. Staub
Atty.: Lois M.Vitti
All that certain tract or parcel of
land situate in Lower Allen Township,
Cumberland County, Pennsylvania,
more particularly bounded and de-
scribed as follows,to wit:
Beginning at a point on the South-
erly line of Hummel Avenue, which
point is 175 feet West of the South-
westerly corner of 18th Street and
Hummel Avenue,thence through the
center of a partition wall and beyond
South 27 degrees 30 minutes East,
102 feet to a point on the Northerly
line of a 20 feet wide public alley;
thence along same South 62 degrees
30 minutes West,35 feet to a point;
thence North 27 degrees 30 minutes
West, 102 feet to a point on the
Southerly line of Hummel Avenue
aforesaid; thence along same North
62 degrees 30 minutes East, 35 feet
to a point,the place of beginning.
Subject however to the rights
of the Pennsylvania Department of
Highways in and to Pennsylvania
Route Number 767 across the rear
of the said lot.
Under and subject to any and all
covenants, conditions, restrictions,
rights of way, easements and agree-
ments visible of record.
Having erected thereon a dwelling
known as 11 Hummel Avenue,Camp
Hill, PA 17011.
Parcel# 13-22-0536-011.
Being the same premises of How-
ard R. Raber and Teresa A. Raber,
husband and wife, by their deed
dated 3/24/06 and recorded on
3/28/06 in the Recorder of Deed
Office of Cumberland County,Penn-
sylvania in Deed Book Volume 273
page 3592 granting and conveying
unto Rebecca L. Staub.
103
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
Lisa Marie Coyne,Aditor
SWORN TO AND SUBSCRIBED before me this
8 da y of Februai 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My C(�mmission Expires Apr 28,2014
t Patriot-News Co. atr1* wO Xtws
2020 20 Technology Pkwy
the Suite 300
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
it
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
Marianne Miller, 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:
01/22/13
2612-M5 CWN,' 01/29/13
P Bank,Nstlonal Assoc) on
Robe=L.Staub. 02/05/13
Atiy. Lots M.V"
AHthatrertaintmaorpube-1of/andsituate . . . . . . . . . . . . . . . . . . .
in Lower_Aden Township,-Cui rberlwd
County, Pennsylvania, more,pardaddT'lY
bounded mid di=ibcdasfo(toa tows: Sworn to and ubscribed before m this 14 day of February, 2013 A.D.
Beginning at a point orb the isoudw*line.
of Hummel Avenge,hvhich.Point is,175
feet Wfst'of the Sou�6xsterly.Omer of
18th Street and Hummel Avenue,thence
through'the center b1*pait cu'wall and; Ilc
beyond South 27 degrees 30 minutes Plast,
102 feet to a point on theNortheriyline of a
20 feet wide public.aft thencet;along same
South 62 degrees 30 minutes West,35.feet to
a point;thence North 27degrees30minutes COMMONWEALTH OF PENNSYLVANIA
Westi 1o2 feet to h point on the toutherly
line of Hummel Ayer a aforesaid;thence Notarial Seal
{ along same North'62 degref 30 minutes Holly Lynn Warfel,Notary Public
I F24 35'feet to a j"t'the place.of Washington Twp.,Dauphin County
be
& y My Commission Expires Dec.12,2016
bject
Su however,to the rights of the MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
Pennsylvania Department of Higlrways;,in
and to Pennsylvania Route Dumber 767
across the rear of the said lot.Under and
subject to any,and all Ovenagits,49n0rtrons,
° restrictions, of{ttaY+faleD e0t`and
Having erectedtlloiri ad >ting�
11 Hummel Avenue,Camp"Hill,PA 17011
Parcel#13-22-0536.011
Beim.the Same premises of Howard,R
Rabet and' brew A.�Raber, husband
aPA wife by .their deed"dated"3/24/06
and recorded on 3CA%in the Recorder,
of Deed Office of Llrmberland County'
Pennsylvania in Deed Bonk Volume,273
page 3592 granting and conveying unto
Rebecca L Staub. . .
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I SS:
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 National Association 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
22nd day of October, A.D., 2012,out of the Court of Common Pleas of said County as of Civil Term,
2012 Number 5015, at the suit of PNC Bank National Association against Rebecca L. Staub is duly
recorded as Instrument Number 201314827.
IN TESTIMONY WHEREOF, I have reunto set my hand
and seal of said office this / day of
A.D.c2 t) 13 -
1
7
ecorder of Deeds
A- 44
of s,Cumberland County,Cer lste,PR
My Commission Expires the Fw Monday of Jan.2014