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Home My WebLink About12-5443 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARTIN J. WEIS, ESQUIRE IDENTIFICATION N0.51379 ATTORNEY FOR ELIZABETH J. t30LDSTEIN, ESQUIRE PLAIlVTIFF IDENTIFICATION N0.73779 DILWORTH PAXSON LLP 112 MA1tKET STREET, 8~ FLOOR HARRISBURG, PA 17101 (717) 23b-4812 QRRSTOWN BANK No. .5~~3 ~ fir-, Plaintiff CIVIL ACTION -LAW v. ~ e ~ ROBERT L. BEAGLE and ~ ~ s~. SUSAN D. BEAGLE y ° w -4> ~c~ Defendants. c4 ~~a ]or ?'Yt X~ ~ QC`s NOTICE TO DEFEND Az ~ ~ ~ ~ ~ ~ You have been sued in court. If you wish to deftitd against the clnims set fords in the following pogo, You must ~ take action within twenty (20) days afba this complaint and notice are served, by tittering a wrlttmt appearance persattally or by att~ney and filing in writing with the court your defenses ar ohjecxions to the claims set forth against you. You' are warned that if you fail to ~ sq the cnae may proceed without you and a jnd8,maat may be entered agaiaat you by the court widhout further notice for any moony claimed is the complaint or for nay other claim or relief r by the plaintiff. You may lose money or propaiy of other rights important to you. YOU SIdOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH 1NFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYBR, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WPI'H INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER RBFERRAL SERVICE Cnatberlattd Coanty Bar Association 3Z S. Bedford Street Caribk, PA 17013717-?44.31f6 or 800-990-9105 ~0 3 - 7s~a/ 9~6sr~ i ~ ~ 3~~ a8o~ `7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARTIN J. WEIS, ESQUIRE IDENTIFICATION N0.51379 ATTORNEY FOR ELIZABETH J. GOLDSTEIN, ESQUIRE PLAINTIFF IDENTIFICATION N0.73779 DILWORTH PAXSON LLP 112 MARKET STREET, 8~ FLOOR HARRISBURG, PA 17101 (717) 236-4812 QRRSTOWN BANK Plaintiff No. v. CIVIL ACTION -LAW RO$ERT L. BEAGLE and SUSAN D. SLAGLE Defendants. AVLSO Le lien demandado en come. Si usted desea defender contra las demmdas dispuestas en las p8gioas si8uientos, usted debe tomar la acci6n en el plazo de veinte (20) dies despubs de Data queja y se sirve el aviso, incorpo:ando un aspedo escribo personahnente o y archivando en escribir con in cafe sus defenses u objxiones a las dana~as diapuestas contra usted of abogado le advierte que que si usted no puede haoor asi que of caso puede proceder sin usted. y ~ juicio se puede incorporar contra usted comps la cafe sin aviso adicional pma cualquier dinem demsudado en la queja o pare cualquier otra demands o relevacibn pedida por el demandante. Z,lsted puecie perder el di~ro o la caractesristica de otra endereza impatante a uated. USTEp DEBE LLEVAR ESTE PAPEL SU ABOGADO IlciMEDIATAMEI~TPE. SI LISTED NO RACE QUE UN ABOGADO VAYA A O LLAME POR TELLFONO La OFICINA DISPUESTA ABA70. ESTA OFICINA PUEDE PROVEER DE LISTED LA INFORMAC16N SOBRE EMPLEAR A UN ABOGADO. SI USTEp NO PUPAE ~ AL HIRE A UN ABOGADO, ESTA OFICWA PUEDE PODER I~tOVEBR DE LISTED LA INFORMAC16N SOBRE LAS AGENCIAS QUE LOS SERVICIOS 7UR~DICOS DE LA OFERTA DE MAYO A LAS PERSONAS ELEGIBLES EN UN HONORARIO 1tEDUCIDO O NiNGfJN HONORARIO SERVICIO DE REFERENCIiA LEGAL CUMBERLAND COUNTY Cumberland Cooaty BAr Auocinioa 32 S. Bedford StreetCarlisle, PA 17013 ?17-249-3166 or800-990-9100 9768729 l MARTIN J. WEIS, ESQUIRE IDENTIFICATION N0.51379 ATTORNEY FOR ELIZABETH J. GOLDSTEIN, ESQUIRE PLAIlVTiFF IDENTIFICATION N0.73779 DILWORTH PARSON LLP 112 MARKET STREET, 8~ FLOOR HARRISBURG, PA 17101 (717) 236812 ORRSTOWN BANK CUMBERLAND COUNTY 2695 Philadelphia Avenue COURT OF COMMON PLEAS Chambersburg, Pennsylvania 17201 vs. CIVIL DIVISION ROBERT L. SLAGLE and SUSAN D. BEAGLE NO. 8 Foxfield Court Mechanicsburg, Pennsylvania 17050 . COMPLAINT IN MORTGAGE FORECL03URE 1. Plaintiff is Orrstown Bank, a bank authorized to do business under the laws of the Commonwealth of Pennsylvania with an office at 2695 Philadelphia Avenue, Chambersburg, Pennsylvania, 17201. 2. Defendants are Robert L. Slagle and Susan D. Slagle, adult individuals last known to have an address at 8 Foxfield Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Defendants, Robert L. Slagle and Susan Slagle, are the real owners of the property located at 1261 Claremont Road, Carlisle, Pennsylvania, 17015. 4. On or about May 25, 2001, Defendants, Robert L. Slagle and Susan D. Slagle, executed a mortgage in favor of Plaintiff, Orrstown Bank, in the amount of One Million Fiffiy m6sn9 i Thousand Dollars ($1,050,000.00), which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, at Mortgage Book 1710, page 137 and recorded on May 25, 2001. A true and correct copy of the Mortgage is attached hereto as Exhibit "A". 5. The Mortgage secures real property located at 1261 Claremont Road, Carlisle, Pennsylvania as more particularly described in legal description attached to the Mortgage. 6. There have been no assignments of the Mortgage. 7. The Mortgage is in default by reason of, inter alia, the Defendants' failure to pay the monthly payment due for July 2012 and all subsequent montlily payments due on the note for which the Mortgage is collateral. 8. Robert and Susan Slagle were advised of the default under the Mortage and given an opportunity to cure. No cure has occurred. 9. Under the terms of the Mortgage, the entire unpaid balance is now due and payable together with other charges as follows: Principal Balance $ 672,018.46 Interest to 8/10/12 $ 3,229.18 (per diem $99.81) Termination and Satisfaction Fees $ 310.00 Attorneys' fees ~ 18.000.00 Total Due: $ 693,553.64 I p. The per diem interest on the underlying obligation is $70.00. 11. Notice pursuant to Section 403 of Act 6 of 1974, 41 P.S. §403, is not required in this matter since the principal amount of the Mortgage is in excess of Fifty Thousand Dollars ($50,000.00). Act 91 Notice is not required. 2 s~6sn9 i WHEREFORE, Plaintiff, Orrstown Bank, demands judgment in the sum of Six Hundred Ninety Three Thousand Five Hundred Fifty Three and 64/100 Dollars ($693,553.64) plus interest and costs and for foreclosure and sale of the mortgaged premises. D' rth ~ . sy: J. Wei Elizabeth J. Goldstein 112 Market Street, 8'" Floor Harrisburg, PA 17010 (717) 236-4812 Attorneys for Plaintiff 3 i COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF FRANKLIN Bradley Tanguay, being duly sworn according to law, deposes and says that he is Vice President of Orrstown Bank, Plaintiff named herein; that as such he is authorized to take this Affidavit on its behalf; that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Bradley Tanguay Vice President Sworn to and Subscribed before me this day OOM~~ONYYEAI.TM pp PENNSYLVANIA of t _,2012. ~ Grease FranNMn County _ My Ca,~gn 29.2016 MEMBER, PEM~IS~f WAIBA A56000?710N OF UO?AR1E5 No blic i s ii# ~ b ~ ~ ~ x o a is ~ a ~ a ~ S til f ~ ~ - ~ ~ ~ i ~ ~ ~ ~ A ~ ~ ~ ~ N .z 8 F ,a i~. ~ ~ s ~y ~ ss ~ ~ . ~ ~ ~ ~ ~ ~ y# E , ~ ~ ~ ~ # ~ ~ ~ ~ a ~ ~ ~ ~ ~ ~ Vii. , ~ ~ # ~ ~ ~ ~s~ ~ ~ ~ ~ ~ ~ as a 8 ~ ~ _ ~ _ ~ ~ ~ ~ _ is ~ ~ g s= ~ ~ ~f as ~ ~ ~ ~ ~ ~ ~ ~a a~ ~ $ ~ ~ ~ _ ~ s ~ ~ ~ ~ ~ s ~ 5~ $ ~ ~ ~ ~ t yJI ~ F ~ ~ ~ ~ ~ ~ - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ a ~ ~ ~ ~ ~ x ~ i a ~ ~ ~ ~ ~ ~ ~ ~ ~ ; _ P ~ ~ ~ ~ a s ~a a s a a • a a ~ _ ~ ~ # ~ a ~ ~ a ~ ~ ~ ~ ~ ~ ~ - ~ a ~ ~ ~ B ~ ~ ~ ~ ~ a ~ ~ ~ _A ~ ~ ~ ~ ~ a c ~ r ffi ~ 'a ~ ~ ~ a a ~ ~ ~ ~a ~ ~ A ~ ~ ~ i ~ ti ~ ~ ~ ~ r ~ ~ $ ~a ~a . ~ ~ ~ ~ ~ a r ~ ~ ~ ~ ~ a~ ~'a ~ A ~ ~ ~ ~ ~ ~ ~ ~ - ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ s Q a ~ ~ ~ ~ ~ R ~ ~ ~ ~ ~ ~~~R ~ g ~ a ~ ~ ~ ~ ~ ~ ~ Ra ~ ~ ~ s ~ g ~ _ ~ ~ ~ a a ~ ~ ~ !t ~ ~ gR S 4 YR ~'~~!1 ~ a ~ a $ s ~ ~ 8 ~ DS S. ~a ~~~~~;5 ti ~'~~$1S g ~ ~i b~~-~$ s~ia ~~a~R' A i 1 ~ ~ y ~ r ~~~~~~~~~~~~7 ~~t~: S ~g~ f ~ ~ ~ ARE ~ ~ ~ a ~ ~ ~ ~ ~ ~ ~~i ~ 3~ ~ ~ 9~~ ~ ~ ~ ~ E e ~ ~ ~ Y9i ~ ~ ` ~ ~a ~ ~ g ~ ~ a ~e ~ ~ ~3 s~ ~ I MCF#7'I;i~tiE ~Cp~tlnu~ Plgit 6 , INDIVIbIJAI /kC1Ar01fFl.ED131111±WT cwwro~a~t?i of r®w~tv~? ~ has COIxiiY OF ~d r~ ~ K~.~, the u~d ?loWp ~IpwW N~I~AN O~~II~MIIIt ~L7~ i~ ~3DliN.1~ known b nn for orMrlr~roiy gown) b e. ri. ponon vrfaoo nrmw on 1ie~cAne to fie w11iN t~nwMw aid aalaawtod~rA rrt rwyr a.culee tln srmolor rn polrooro fwnki aonlMnod. ~ awn.. ahwrot, ~ Iwwnw wt ~ lrrd.~a oM1oW srw. r~«.,, ~ g ~U~i~p woevy mere h ~a+c? u,. sir. a en n i00 r!y w.Fwusparr~wri~~M. wlywlMa ~M~rIFA r'F^~. i BOOK;%3.~~A(~ i F--~ LEGAL DESCRII'TION Ea1~IT A ALL THAT CERTAIlV tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded end described as follows: BEGINNING at a poirrt in the center line of Claremont Road, L.R 21066, at corner of lands of I3artco Printing Company; thence along said cenroerline, South 62 degrees 35 minutes 30 seconds West 209.78 feet to a P.K. nail set; thence through an iron pin set on the dedicated right-of-way lira of L.R 21066 and along lends now or f~metiy of John E. and Marmeen Mumma and Donsld A. Comp, Naath 27 degrees 24 minutes 30 .seconds West 371.72 fact to an existing iron pin; thence alaag lath now or fonne~ly of Cumberland Recycling, Inc., also known as Lot No. 8 on said Plan, North 53 degrees 30 minutes East 264.99 feet to en iron pin set; thence by leads now or formerly of York County Industrial Development Authority, Soudr 36 degrees 30 minutes 00 seconds East 213.62 feet to aA iron pin; thanba hY landsnow or formerly of Hattco Printing Co., Inc., and drrough an iron pin sat on tine dedicated right-of--way line of L.R 21066, South 04 degrees 30 minutes 00 seconds East 220 feet to a P.K, nail set in the center lira of L.R 21066, the. place of BEGINNING. CONTAINING 2.3982 aces, more or less, and being designated at Lot No. 7 on Plan for Travitz and Trimmer, also known as Steel Building Erectors Plan, as set forth in Cumberland Cormty Plan Book 56, Page 96. HAVING ERECTED thereon an industrial building known and numbered as 1261 Claremont Road, Carlisle, PA 17013. BEING the same premises which Charles W. Travitz, Jr. (joined by his wife, Isabelle L. Ttavitz), by Iris deed dated January 15, 1997 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania on the same date, in Deed Book 152, Page 48, grarrted and conveyed unto Susan DeRemer Slagle, the Borrower and Mortgagor herein. I Certify this to be recorded In Cutnbertand County PA R+ecord~' of Deeds ~.a a t..:I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy _ 2 Or T iJ - Richard W Stewart F Solicitor _ PEN NS Y L;',A N I A Orrstown Bank Case Number vs. Robert L Slagle (et al.) 2012-5443 SHERIFF'S RETURN OF SERVICE 09/1912012 10:54 AM - William Cline, Corporal, who being duly sworn according to law, states that on September 19, 2012 at 1054 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan D. Slagle, by making known unto Robert Slagle, Husband of Susan D. Slagle at 1261 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. Deputies were advised at this time, Susan D. Slagle is still residing at 8 Foxfield Court, Mec anicsburg, Pennsylvania 17050. IA CLI E, DEPUTY 09/19/2012 10:54 AM - William Cline, Corporal, who being duly sworn according to law, states that on September 19, 2012 at 1054 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert L. Slagle, by making known unto himself personally, at 1261 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. Deputies were advised at this time, Robert L. Slagle is still residing at 8 Foxfield Court, Mechanicsburg4Pennsylvania 050. LINE, DEPUTY SHERIFF COST: $50.45 October 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ORRSTOWN BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. CIVIL DIVISION ROBERT L. SLAGLE and NO. 12-5443 SUSAN D. SLAGLE PRAECIPE TO REASSESS DAMAGES TO THE PROTHONOTARY: Please reassess the damages in the original judgment entered in this matter in favor of Plaintiff, Orrstown Bank, and against Defendants, Robert L. Slagle and Susan D. Slagle, as follows: Original Judgment $699,553.64 Additional Interest (August 10, 2012 through May 21, 2013 @$ 70.00 per diem) 19,880.00 Total $719,443.64 Plus additional interest at the per diem rate of$70.00 and costs from May 21, 2013. DILWORT AXSON LLP + ' I VV4, d'-1 Martin J. Azefs (PA. I.D. No. 51379) 1500 Market Street, Suite 3500E Philadelphia, PA 19102 (215) 575-7000 Attorneys for Plaintiff Dated: June 4, 2013 C 'ra M cO c.._ -, CD c—, p4 ul - g/3 99 10809885_1 V T ORRSTOWN BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION ROBERT L. SLAGLE and NO. 12-5443 SUSAN D. SLAGLE CERTIFICATE OF SERVICE I, Martin J. Weis, Esquire, hereby certify, that on the 4th day of June, 2013, I served a copy of the within Praecipe to Reassess Damages via first class mail, postage prepaid, and addressed as follows: Robert Chernicoff, Esquire 2320 North Second Street Harrisburg, PA 17110 Maftin J. Wefs 10809885_1 ORRSTOWN BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. CIVIL DIVISION ROBERT L. SLAGLE and NO. 12-5443 SUSAN D. SLAGLE PRAECIPE FOR WRIT OF EXECUTION-MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in this matter against Defendants, Robert L. Slagle and 6rj.j641 Zad9mshi o491 0 553. 6 N Susan D. Slagle, as follows: Add0vana! Xn4wv (& W4 w, Q012 Ehrg qh May Q j� Q013 70.GO per�,jieM I q,0'80, O d �To.}gl Amount Due: $719,443.64 Interest from 5/21/13 Costs to be added Dilworth Pax LL By. Martin J. Weis, Esquire Elizabeth J. Goldstein, Esquire Attorneys for Plaintiff 112 Market Street, 8th Floor Harrisburg, PA 17101 215-575-7000 NOTE: PLEASE ATTACH DESCRIPTION OF PROPERTY ' C T 3 1-493 2,T- a SD /�. s r i-t1 LEGAL DESCRIPTION E)OMrr A ALL THAT CERTAIN tract of land situate in Middlesex Township,Cumberland County,Pennsylvania,more .particularly bounded and described as follows: BEGINNING at a point in the center line of Claremont Road,L.R 21066,at ebmer of lands of Hartco Printing Company;Umcc along Said center line.South 62 degrees 35 minutes 30 seconds West 209.78 feet tb a P.K.rdil set;thence through an iron pin set on the dedicated right-of-way line of L.R.21066 and along lands now or formerly of John&and Maurecn Mumma and Donald A.Comp,North 27 degrees 24 minutes 30 seconds West 371.72 feet to an existing iron pin;thence along lands now or fonnerly ofCumberland Recycling, Inc.,also knoyta as Lot No.8 on said Plan,North 53 degrees 30 minutes East 264.99 feet to an iron pin set; thence by lands now or formerly of York County Industrial Development Aighority,South 36 degrees 30 nntautes 00 seconds East 213M feet to•an iron pin;thence by lands now or formerly of Harreo Printing Co., Inc.,and through.anfirofi p'rn set on the dedicated riot-of-way line df L.R 21066,South 04 degrees 30 minutes 00 second's least 220 feet to a•PJC nail set in the center line of L.R.2106-6,theplace of BEGINNING. CONTAINING 23982 acres,more or less,and being d+;signated at Lot No.7 on Plan for Tma itz and Trimmer,also Imown as Steel'Building Erectors Plan,as set forth in Cumberland County Plan Bonk 36,Page 96, HAVING ERECTED thereon an industrial building known and numbered as 1261 Claremont Road, Carlisle,PA 17013. BEING the Same issr"ntises Which Charles W.Travitz,Jr.Goined by his wife,Isabelle L.Travitz),by his deed dated January 15,1997 and recorded in the Office of the Recorder of Deeds in and for Cumberland County,Pmmsylvania•M the same date,is Deed Book 152,Page 48;granted and conveyed unto Susan DeRemer Slagle,the Borrower and Mortgagor herein. I Certify this to be recorded In Cumberland CuuntY PA W"7ceor4erofDeeds • LEGAL DESCRJWTION EXHIBIT ALL THAT CERTAIN tract of land situate in Middlesex Township,Cumberland County,Pennsylvania,more ,particularly bounded and described as follows: BEGINNING at a point in the center line of Clamnont Road,LR.21066,at corner of lands of Hartco Printing Company;theatre along said center line,South 62 degrees 35 minutes 30 seconds West 209-78 feet t'0 a P.K.rWl set;thct=through an iron pin set on the dedicated right of-way line of LX 21066 and along lands now or formerly of John E.and Maureen'Murnma and Donald A.Comp,North 27 degrees 24 minutes 30 seconds West 311.72 feet to-an existing iron pin;thence along lands now or formerly ofCurnbcdand Recycling. Inc.,also known as Lot No.8 on said flan,North 53 degrees 30 minutes East 20.99 feet to an iron pin set; thence by lands now or formerly of York County Industrial Development Authority,South 36 degrees 30 minutes 00 seconds East Z13,62 feet to-ekn iron pin;thence by lands now or formerly offlartco Printing Co.. Inc.,and duough•an-bod pin set on the dedicated right-of-way line of L.R.21066,South 04 degrees'30 minutes 00 seconds East 220 feet to a-P.K-nail set in the center line of L.R.21066,theplace of BEGINNING. CONTAINING 2.3982 acres,more or less,and being designated at Lot No.7 on Plan for Travitz and Trimmer,also known as Steel Building Erectors Plan,as set forth in Cumberland County Plan Book 56,Page 96. HAVING ERECTED thereon an industrial building known and numbered as 1261 Claremont Road, Carlisle,PA 17013. BEING the same Puarises Which Charles W.Travit4 Jr.Goined by his wife,Isabelle L.Tmvitz),by his deed dated January 15.1997 and recorded iii the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania-"the samor date,in Deed Book 152,Page 48.,granted and conveyed auto Susan DeRemer Slagle,the Borrower and Mortgagor herein. I Certify this to be recorded In Cuniberiand Co=tY PA 04:ecor4et of Deeds .......... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-5443 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Orrstown Bank Plaintiff(s) From Robert L.Slagle and Susan D. Slagle (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$699,553.64 Plaintiff Paid$ Interest Additional Interest(August 10,2012 through May 21,2013 @ 70.00 per diem) $19,880.00 Attorney's Comm. % Law Library$.50 Attorney Paid$218.95 Due Prothonotary$2.25 Other Costs$ Date:June 4,2013 / David D.Buell,Prothonotary (,seal) Deputy REQUESTING PARTY: Name : Martin J.Weis,Esq. Address: 112 Market St.,8`h Floor Harrisburg,PA 17101 Attorney for: Plaintiff Telephone: 215-575-7000 Supreme Court ID No. 51379 T[, F R tq 6HO'der �r ' 2011 JUN --4 P11 2: 2 L} CUMBERLAND COUNTY. PENNSYLVANIA MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8TH FLOOR HARRISBURG, PENNSYLVANIA 17101 (717) 236-4812 ORRSTOWN BANK, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT L. SLAGLE and SUSAN D. SLAGLE, Defendants. NO. 12-5443 AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA . : SS COUNTY OF PHILADELPHIA Orrstown Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 1261 Claremont Road, Carlisle, Cumberland County, Pennsylvania: Name and address of Owners or Reputed Owners: Robert L. Slagle and Susan D. Slagle 8 Foxfield Court Mechanicsburg, PA 17050 10746741_3 Name and address of Defendant in the Judgment: Robert L. Slagle and Susan D. Slagle 8 Foxfield Court Mechanicsburg, PA 17050 Name and address of every Judgment Creditor whose judgment is a record lien on the real property to be sold: Orrstown Bank 2965 Philadelphia Avenue Chambersburg, PA 17201 Susquehanna Bank, f/k/a Graystone Bank 1570 Manheim Pike Lancaster, PA 17604 Name and address of the last recorded holder of every mortgage of record: Orrstown Bank 2965 Philadelphia Avenue Chambersburg, PA 17201 Susquehanna Bank, f/k/a Graystone Bank 1570 Manheim Pike Lancaster, PA 17604 Name and address of every other person who has any record lien on the property. Tenant Unit No. 1 1261 Claremont Road Carlisle, PA 17103 Tenant Unit No. 2 1261 Claremont Road Carlisle, PA 17103 Tenant Unit No. 3 1261 Claremont Road Carlisle, PA 17103 10746741_3 Tenant Unit No. 4 1261 Claremont Road Carlisle, PA 17103 Tenant Unit No. 5 1261 Claremont Road Carlisle, PA 17103 10746741_3 Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 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: None 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. §4904 relating to unsworn falsifications to authorities. Dilworth P son L P By: M in J. s, Esquire Attorney for Plaintiff 112 Market Street, 8th Floor Harrisburg, PA 17101 717-236-4812 Date: June�, 2013 COMMONWEALTH OF PENNSYLVANf NOTARIAL SEAL ,i3 Stephanie McFadyen-Notary Public City of Philadelphia,Philadelphia County MY COMMISSION EXPIRES FEB.03,2014 10746741_3 CUM18EIRL-At,@ Cou"n,'v PENNSYLVANIA" MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8 T' FLOOR HARRISBURG, PENNSYLVANIA 17101 (717)236-4812 ORRSTOWN BANK, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION VS. ROBERT L. SLAGLE and SUSAN D. SLAGLE, Defendants. NO. 12-5443 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert L. Slagle and Susan D. Slagle 8 Foxfield Court Mechanicsburg, PA 17050 The real estate located at 8 Foxfield Court, Mechanicsburg, PA 17050, Cumberland County, Pennsylvania, is scheduled to be sold at Sheriffs Sale on September 4, 2013 at 10:00 A.M. the Cumberland County Courthouse, Carlisle, Pennsylvania, to enforce the court judgment of$719,443.64 obtained by Orrstown Bank against Robert L. Slagle and Susan D. Slagle. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Orrstown Bank the amount of the judgment plus interest. To find out how much you must pay, you may call Martin J. Weis, Esquire, at(717) 236-4812. 107467413 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have to stopping the sale. (See notice at the end of this letter on how to obtain an attorney). YOU MAY HAVE ADDITIONAL RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Martin J. Weis, Esquire, at(717)236-4812. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Martin J. Weis, Esquire, at (717) 236- 4812. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of Distribution of the money bid for your house will be filed by the Sheriff on or about October 4, 2013. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this Schedule unless Exceptions (reasons why the proposed distribution are wrong) are filed with the Sheriff within ten(10) days after October 4, 2013. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 107467413 CUMBERLAND COUNTY BAR ASSOCIATION 32 BEDFORD STREET CARLISLE, PA 17013 717 249-3166 (IN PA) 800-990-9108 Dilworth Paxson L P By, IM in J. , Esquire Attorney for Plaintiff 112 Market Street, 8th Floor Harrisburg, PA 17101 717-236-4812 10746741_3 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis@dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Susquehanna Bank 1570 Manheim Pike Lancaster, PA 17604 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth P son L By: Ma in J. Uis, Esquire Attorney for Plaintiff 107467413 F^ CUMBERLAND COUNT), PENNSYLVANIA MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8' FLOOR HARRISBURG, PENNSYLVANIA 17101 (717) 236-4812 ORRSTOWN BANK, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION VS. ROBERT L. SLAGLE and SUSAN D. SLAGLE, Defendants. NO. 12-5443 CERTIFICATE AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the attorney of record for the Plaintiff in this action against real property and further certify that this property is not subject to Act 91 of 1983. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any false statement given herein. Dilworth Paxson L By: , — Marlin J. W61, Esquire Attorney for Plaintiff 112 Market Street, 8`h Floor Harrisburg, PA 17101 717-236-4812 10746741_3 _{f=!LEU-yr 7963 Jai —4 P11 - 28' CUMBERLAiiD PENNSYLVANIA � MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8TH FLOOR HARRISBURG, PENNSYLVANIA 17101 (717) 236-4812 ORRSTOWN BANK, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION VS. ROBERT L. SLAGLE and SUSAN D. SLAGLE, Defendants. NO. 12-5443 CERTIFICATION OF ADDRESSES I hereby certify that the precise address of the within named Judgment Creditor is 2695 Philadelphia Avenue, Chambersburg, Pennsylvania, 17201 I hereby certify that the last known address of the Judgment Debtors was 8 Foxfield Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. Dilworth Paxs LLP -V r1/147 By: Marti6 J. Wes Esquire Attorney for Plaintiff 112 Market Street, 8th Floor Philadelphia, PA 17101 717-236-4812 10746741_3 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis@dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Orrstown Bank 2965 Philadelphia Avenue Chambersburg,PA 17201 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxson LL By: Mdthn J. lqis/Esquire Attorney for'161aintiff 107467413 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis@dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 1 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Pa nn L P By: IKI;lm VV Mkin j. Vep,, Esquire r 0 Attorney 0 Plaintiff 107467413 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 2 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Pa son L P-IKA�l By: ,�,. Ma in J.k9s, Esquire Attorney for Plaintiff 107467413 DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 3 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxson P-IM.J'in By: Marlin J. is, Esquire Attorney for Plaintiff 10746741_3 e DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 4 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxs LLP -JA By: w Marti4 J. Wei squire Attorney for Plaintiff 10746741_3 DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 5 1261 Claremont Road Carlisle,PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxs LLP By: 114 Martin J. Weld Esquire Attorney for Plaintiff 10746741_3 C MARTIN J. WEIS,ESQUIRE ATTORNEY FOR PLAINTIlf IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8TH FLOOR HARRISBURG,PENNSYLVANIA 17101 (717)236-4812 '~co ' ORRSTOWN BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS. ROBERT L. SLAGLE and NO. 12-5443 SUSAN D. SLAGLE CERTIFICATE OF MAILING OF NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ON DEFENDANTS AND SERVICE OF NOTICE OF SHERIFF SALE ON LIEN HOLDERS TO THE PROTHONOTARY: Martin J. Weis, Esquire, hereby certifies that Notices of Sheriffs Sale scheduled for September 4, 2013, copies of which are attached to the Affidavit Pursuant to Pennsylvania Rule of Civil Procedure 3129.1 filed of record, were served on the following lien holders via first class mail on August 1, 2013 as evidenced by the attached U.S. Postal forms 3817 and addressed as follows: Susquehanna Bank Orrstown Bank 1 570 Manheim Pike 2965 Philadelphia Avenue Lancaster, PA 17604 Chambersburg,PA 17201 Tenant—Unit No. 1 Tenant—Unit No. 2 1261 Claremont Road 1261 Claremont Road Carlisle,PA 17103 Carlisle,PA 17103 Tenant—Unit No. 3 Tenant—Unit No. 4 1261 Claremont Road 1261 Claremont Road Carlisle,PA 17103 Carlisle, PA 17103 Tenant—Unit No. 5 Robert L. Slagle and Susan D. Slagle 1261 Claremont Road 8 Foxfield Court Carlisle, PA 17103 Mechanicsburg, PA 17050 11238088_1 DILWORTH P SON UP B >n� Y� Mart J. Weis squire Attorney for Plaintiff 112 Market Street, 8th Floor Harrisburg,PA 17101 (717) 236-4812 Date:August��, 2013 11238088_1 2 13 It:S.7 -4 PFD DIRECT DIAL: CJt'► F� n �-49&J.Weis 215-575-7000 �`N;�se it,yorplawxom -VAPilA June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Susquehanna Bank 1570 Manheim Pike Lancaster, PA 17604 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. /Dilworth P son lJLP By: l M in J. Wis, Esquire Attorney for Plaintiff 107467413 DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Orrstown Bank 2965 Philadelphia Avenue Chambersburg,PA 17201 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxson LL By: d Mai Fin W is Esquire Attorney for laintiff 107467413 DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 1 1261 Claremont Road Carlisle,PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth P n L P By: M�rL J. *e' , Esquire Attorney fo Plaintiff 107467413 DIRECT DIAL: Martial J.Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 2 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien., leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Pa son L P By: Martin J.kys, Esquire Attorney for Plaintiff 10746741_3 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 3 1261 Claremont Road Carlisle,PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxson LJLP By: __1MVVAq'1 V�� Marfin J. is, Esquire Attorney for Plaintiff 10746741_3 DIRECT DIAL: Martin J. Weis 215-575-7000 mweis @dilworthlaw.com June 5, 2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 4 1261 Claremont Road Carlisle,PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Paxs LLP By: L,-A,- Y Marti J. Wei squire Attorney for Plaintiff 107467413 DIRECT DIAL: Martin J.Weis 215-575-7000 mweis @dilworthlaw.com June 5,2013 NOTICE OF SHERIFF'S SALE AFFECTING YOUR PROPERTY INTEREST TO: Tenant Unit No. 5 1261 Claremont Road Carlisle, PA 17103 FROM: Orrstown Bank OWNER(S): Robert L. Slagle and Susan D. Slagle PROPERTY: 1261 Claremont Road, Carlisle, PA 17015 RE: Orrstown Bank v. Robert L. Slagle and Susan D. Slagle Court of Common Pleas of Cumberland County No. 12-5443 The above-referenced property is scheduled to be sold at the Cumberland County Sheriff Sale on September 4, 2013 at 10:00 A.M. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Our records indicate that you may hold a mortgage,judgment, lien, leasehold or other interest in the property which may be extinguished by the Sale. You may wish to attend the sale to protect your interests. The Sheriffs Sale is to satisfy the judgment in mortgage foreclosure obtained by Orrstown Bank in the amount of$719,443.64. A schedule of distribution will be filed by.the Sheriff on a date specified by the Sheriff but not later than thirty days after the Sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten days after the filing of the schedule. YOUR LIEN OR INTEREST IN THIS PROPERTY MAY BE LOST OR OTHERWISE AFFECTED ADVERSELY BY THIS SHERIFF'S SALE. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY HOW YOUR RIGHTS MAY BE AFFECTED. Dilworth Pax L P By: -P,-., Martin J. WeW Esquire Attorney for Plaintiff 10746741_3 f wi vl;ie —4 Pi� n } " J CL',•13ERLAND f'Gi3;- Y PEN,NSYLWtj L!- MARTIN J. WEIS, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO. 51379 DILWORTH PAXSON LLP 112 MARKET STREET, 8'FLOOR HARRISBURG, PENNSYLVANIA 17101 (717)236-4812 ORRSTOWN BANK, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION VS. ROBERT L. SLAGLE and SUSAN D. SLAGLE, Defendants. NO. 12-5443 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert L. Slagle and Susan D. Slagle 8 Foxfield Court Mechanicsburg, PA 17050 The real estate located at 8 Foxfield Court, Mechanicsburg, PA 17050, Cumberland County, Pennsylvania, is scheduled to be sold at Sheriffs Sale on September 4, 2013 at 10:00 A.M. the Cumberland County Courthouse, Carlisle, Pennsylvania, to enforce the court judgment of$719,443.64 obtained by Orrstown Bank against Robert L. Slagle and Susan D. Slagle. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Orrstown Bank the amount of the judgment plus interest. To find out how much you must pay, you may call Martin J. Weis, Esquire, at(717) 236-4812. 10746741_3 r 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have to stopping the sale. (See notice at the end of this letter on how to obtain an attorney). YOU MAY HAVE ADDITIONAL RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Martin J. Weis, Esquire, at(717)236-4812. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Martin J. Weis, Esquire, at (717) 236- 4812. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of Distribution of the money bid for your house will be filed by the Sheriff on or about October 4, 2013. This Schedule will state who will be receiving that money. The money will be paid out in accordance with this Schedule unless Exceptions (reasons why the proposed distribution are wrong) are filed with the Sheriff within ten(10) days after October 4, 2013. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 107467413 d CUMBERLAND COUNTY BAR ASSOCIATION 32 BEDFORD STREET CARLISLE, PA 17013 717 249-3166 (IN PA) 800-990-9108 Dilworth Paxson L P By: M in J. , Esquire Attorney for Plaintiff 112 Market Street, 8h Floor Harrisburg,PA 17101 717-236-4812 107467413 f g�q3 T UNIrEDSTATES �P=ALSERyKEr Certificate Of Mailing C This Certificate of Melling provides evidence that mail has been presented.to USPS®for mailing. Z �w @vrT/hNE�YAeOVVr<S This form may be led for do estic and intern tionaLnfsiC-t,.t • 02 1R V I 20a From: i ;' , + 0002095408 AUG01 2013 DILWORTH' :'." `t oo UN17� MAILED FROM ZIP CODE 19102 a °o N bS� 1500 Market Street-Suite 3500E r,, ' ` 9 v PN[edelphia,PA 1912-210;1 "t _- ,, o � •�` � CA To: pz � 00 C: O tr 00 •'" � � o d y PS Form 3817,April 2007 PSN 7530-02-000-9065 U @ E—:_0 y w...' o o. �'S C'" o �. �1r 90 E r o cn sE'(L k 6 1 _. r _ a UNITEDSTdTES POSTdLSERVICEr �� ;sC Kifieate Of Mailing m 0 �} o This Certificate of Mailing provides evidence'that'' es been prisdFWto'bSPSstor mailing �y N This form may be us d fordo estic end international m \ q9 g From: • ✓ 4- - ' ,. o `l �. �_ \ /� 16 S, rte. 1 O o UN17r F, N E Ft LL F a Philad 1 hid,PA 19102-2101 o �r To: ' ',�t c . O 3,oai VJ N 0 D� � I �L 0 0 A M (D ,3 0 PS Form 3817,April 2007 PSN 7530-02-000-9065 N W 0 a UNITEDSTATES POSTALSERWEr Certificate Of Mailing This Certificate of Mailing provides evidence That mail has bee presented to USPS®for mailing. This form may be used for domestic and international mad. From: ' t U � 'S. C>N UNtTpO n s to 1�rYS Mark-twee -Suite 3500E \ Fn o Philadelphia,PA 19102-2101 - O 0 cn C> o N A a I NO I I _ IST 1 n . LD G) I g�OS PN UNITEDSTA ` o �� ° -Certificate Of Mailing This form Certificate a Mailing provides and tharmell mail btlehyYeyanjaZl to USPS®for mailing. P4TNEV BOWES This form maybe used fa domestic and intemajioffeY'mail. From: ti •� 02 ,R $ 01.20° �� 0002095408 AUG01 2013 r, c.c:, uNr1Fp MAILED FROM ZIP CODE 19 10 2 DILWORTH PAXSON LLP N �• s'9 a n t off} 11500 Met- -n cirt Ptsd fib PA 01 Q2-91(M a" A t / O E ll N D, O W M ■ 0 C3 O O d °( O ; rn PS Form 3817,April 2007 PSN 7530-02-000.9065 not w .5 : b o c a N h a UNITED STATES ' aPOSTALSERVICEO Certificate Of Mailing }. i o This Cemfiay a used f prov'es evidence t ma been Led to USPS®for meting. 5 N This form maybe used for i nd i n il. ao c` Q From: II 1 o' r' 007'rG'G i • r 1500 Market Street-Suite'350( j € PMiadelPhia.PA �r2. 10f E ff ,,7— f N w 9 o tt C> E TO OD a1 0 0Q T M PS Form 3817,April 2007 PSN 7530-02-000-9065 N u,Gp �UNfrEDSTATES • ` POSTALSER1/ICE° Certificate Of Mailing This Certificate of Meiling pr 'des eviden that mail has be rrpf'Septed�TJSPyS®tor mailing. This form may be used ford es c end i a atonal a - `�- From: h/1�J nil =92TW M' rf wf) o o owl"to 1500 rn Phi �+�,I To: �/ 1 N .> 'n t 2 �.� �5S RIFFS OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ' : Sheriff rr ' tr of Clr ba�o, rn -cc Jody S Smith ' o v7r -,., Chief Deputy c� c a t=� Richard W Stewart s>ts �I�E 9�THE S�6RIFF �-° Solicitor Orrstown Bank Case Number vs. 2012-5443 Robert L Slagle(et al.) SHERIFF'S RETURN OF SERVICE 06/27/2013 10:30 AM -Deputy William Cline, 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 1261 Claremont Road, Middlesex-Township, Carlisle, PA 17013, Cumberland County. 06/27/2013 10:30 AM -Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be John DeRemer, Step-Son,who accepted as"Adult Person in Charge"for Robert L Slagle at Lightstyles, LTD., 1261 Claremont Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. 06/27/2013 10:30 AM - Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be John DeRemer, Step-Son, who accepted as"Adult Person in Charge"for Susan Deremer Slagle at 1261 Claremont Road, Middlesex Township, Carlisle, PA 17015, Cumberland County. 09/04/2013 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, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$726,000.00 to Richard Slagle, 201 Waterford Way, Lebanon, PA 17042 on behalf of KIS Holdings, LLC, 201 Waterford Way, Lebanon, PA 17042 being the buyer in this execution, paid to the Sheriff the sum of$ 10/01/2013 Proposed Schedule Of Distribution Posted on 9/25/13, all parties notified. SHERIFF COST: $8,767.64 SO ANSWERS, Faa4 October 02, 2013 RONNY R ANDERSON, SHERIFF - 7l Fd - tic/, a- c SD i L to/ 4{* 3 S (c;CountySuite Sheriff,Teleosoft,Inc. Rh' ' d 17c 05