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~E~ ~~~Q~fto~tor~~~r° MARTHA E. VON ROSENSTIEL, P.C. ~ ~ , , ~ 2 30426CFC-BI Martha E. Von Rosenstiel, Esquire / No. 52634 HeatherRiloff,Esquire/No.309906 fit!*~~ftL~?,H~ COUNTY 649 South Avenue, Suite 7 ~yN LYA N ( A Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 v Plaintiff NO ~Q~ ? / v l KEVIN R. BEIDEL AND CHRISTA L. BEIDEL 730 Bloserville Road Newville, PA 17241 Defendants CIVIL ACTION -MORTGAGE FORECLOSURE NOTI E V You have been sued in court. If you wish to defend against the claims Le han demandado a usted en la Corte. Si usted quiere defenderse de set forth in the following pages, you must take action within twenty e5tas demandas expuestas en las paginas siguientes, usted tiene (20) days after this complaint and notice aze served, by entering a veinte (20) dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with nptificacion. Hace falta a sentaz una compazencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregaz a la Corte en forma escrita sus You aze warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende, la cone toms ra medidas y further notice foc any money claimed in the complaint or for any other puede continuaz la demanda en contra suya sin previo aviso 0 claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas, la Corte puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importances paza usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT IaLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW. THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT FSTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A SIOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER, THLS OFFICE MAY BE ABLE TO PROVH)E YOU NO TIENE EL 1DINER0 SUFICIENTE PARR CONTRATAR A WTTH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO, LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SIOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE RERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P'A 17013 717-249-3166 800-990-9108 Q~~ ~~3.75~ a ~#a~~r~~ _ _ _ T__ THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAII~IED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE 1ECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRjACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISFUTE THE ~ALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADII'~tG, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WI'~H WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) ~AYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEIVID DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF'~DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN TH(bUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS Tp BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN .Q?N EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE 'I!;O THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THT~ DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEI~fiED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ANION TO ENFORCE A LIEN ON REAL ESTATE. _ MARTHA E. VON ROSENSTIEL, P.C. 30426CFC-BI Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COU~tT OF COMMON PLEAS OF ASSOCIATION CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff v. NO. KEVIN R. BEIDEL AND CHRISTA L. BEIDEL 730 Bloserville Road Newville, PA 17241 Defendants CIVIL ACTION -MORTGAGE FbRECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT A1~1Y INFORMATION OBTAINED WILL BE USED FOR THATPURPOSE 1. Plaintiff is Federal National Mortgage Association, organized and existing under the laws of the United States of America, with offices for the conduct of business at 3900 Wisconsin Avenue, NW, Washington, DC 20016-2892. 2. Defendants, Kevin R. Beidel and Christa L. Beidel are the mortgagors and real owners of premises 730 Bloserville Road, Newville, PA 17241, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage rr~ade, executed and delivered by the above named defendants, mortgagors and real owners to Members 1st Federal Credit Union on _ - _ May 20, 1999, which mortgage is recorded on May 25, 1999 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1544, Page 227, secured on premises 730 Bloserville Road, Newville, PA 17241 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to Crestar'Mortgage Corporation by written assignment dated May 20, 1999 and recorded on May 25, 1!999 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 613, Page 1017 5. The mortgage has since been assigned to Federal National Mortgage Association by written assignment dated December 12, 2011 and recorded on December 15, 2011 in the Office of the Recorder of Deeds of Cumberland County as Instrument #201134956. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms o~the mortgage, from February, 2012 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the an3ount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 13,606.39 Interest from 1/1/2012 to 7/30/2012 at $2.19 per diem $ 462.10 Borrower funds in escrow 7/30/201',2 $ (756.75) Corporate Advances $ 746.87 Attorney's Fee $ 1,650.00 Suspense $ (358.11) Total $ 15350.50 10. Plaintiff sent to defendants a Notice of Intention'', to Foreclose advising of rights available under Act 6 of 1974 (Exhibit II). WHEREFORE, plaintiff demands judgment for fdreclosure and sale of the mortgaged premises in the amount of $15,350.50, plus per diem intere$t at $2.19 from July 31, 2012 to the date of judgment plus costs thereon. Respectfully Submitted, MAR'P'HA E. VON ROSENSTIEL, P. . BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff EXHIBIT I DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Village of Bloserville, Township of Upper Frankford, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Main Street, in said village; then a Westerly by lot now or formerly of Mary Hoover, 198 feet to an alley; thence Southerly by said~lley, 49 feet 6 inches to an alley; thence Easterly by the last named alley, 198 feet to Main Strrret; thence Northerly along Main Street, 49 feet 6 inches to the Place of BEGINNING. BEING improved with a dwelling house. BEING THE SAME PREMISES which John A. Bis{tline, Jr. and Laura A. Bistline conveyed unto Robert A. Getz, Jr., by deed dated November~130, 1987 and recorded November 30, 1987, in the Recorder's Office in and for Cumberland County, Pa., in Record Book B, Volume 33, Page 645. PARCEL IDENTIFICATION NO: 43-11-3069-012, CON"I~ROL 43000801 EXHIBIT II 8.nd~r. SETERUS, INC. ~ ~ f ~ PO BOX 2008 ' m GRAND RAPIDS, Ml 49501-2008 ~ 1 ~ -o ~ 1M S 45.75° (1.! OOOa281583 APR03 2012 O ' ~ sys.eu?.: rases.«... ~M¦w NWLED FROM ZPCODE 9 7210 o X 7 400 0000 0000 0102 fi434 ~ ~ t. INe,w.A ey: rPra.. Pnn, craM) ~ C3 RETURN RECEIPT REQUESTED D ~ c. o.a of pdiwry AAICN Add,~d tfb: .e~~G O _ 0 °'waw...tiwar..`rra~w.n„~~ar...,~wers•+e•~ L1791204017115276 ~ ( G--~.Z p _ BEIDEL, KEVIN R ~ _ - r~an.fd?Pr.-rf,oot-cry....-wler _ _ _ _ - _ _ _ a.~,,,~_. _ 0 NEWVILLE, PA R c ; U R~R TG~ ~£~N~D~E~R O U.N C t. AI 1~;= D a c.ur.~r ~aa?.a t; ii A13 t i ~,`3 3``3 fI'~r ri R u ~ 3C: ~rS'SviZGO$Qr$'='i52~-G~~$tl-u~-wZ - c~~r suc. z,~ « ~ coa. 1,i„ii,i,,,l,f,i~,,,,,,il„i,lll~„tl,,,h,l,ii,,,i„i,,,i1,t . ~ s-r ~.A s'rr,'~T ~ A 20120430 ~ s ete r u s,M Physical Address 14523 SW Milliken Way; Suite 200; Beaverton, OR 97005 BusMess Hours (Pacific Tlme) Mon Thu 5:OOam t0 9:QOpm; Fd 5:OOam to B:OOpm Sat S:OOam to 9:OOam; Sun 5:OOam to 9:OOpm Paymenu April 1, 2012 PO Box 7182; Pasadena, CA 91109-7182 Correapondence CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL PO Box 2008; t3rand Rapids, MI 4350 i-2008 Phone Liy9A '868.570.5277 BEIDEL, KEVIN R Fax BEIDEL, CHRISTA L 868.578.5277 730 BLOSERVILLE RD Website NEWVILLE,1?A 17241 www.seterus.com RE: Loan No.: 7I 15276 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Setelus, Inc. is the servicer of the above-referenced loan. The MORTGAGE debt held by Federal National Mortgage Association on your property located at: 730 BLOSERVILLE RD ~ , NEWVILLF, PA 17241-9710 IS IN SERIOUS DEFAULT because: You have not made regular mortgage payments for the months o, f Febrrrar y2012, March 201 ~ April 2012 and the following'amoimts are now past clue. Late charges and other charges have also accrued to this date in the amount of $701.87. Past Dtte Installments: Totals Principal $1,358.81 Interest $193.21 _ Escrolar.Installment $463.35 $2,015.37 Other Open Charges: Prior Servlcer Charges ~t~t,,,I~. Charges LegaUAttorney 390.00 0.00 390.00 Foreclosure 120.00 0.~0 120.00 Title , ~ 146.87 0.00 146.87 Property Inspections , . 0.00' 45x00 45:00 y _ . • ~ t. - ~ (Continued) THOS COMMUNICATION TS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DB COLLECTOR. WB ARE ATTEMPTINt1 TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF OU ARE 1N BANICR[iPTCY OR RECEIVED A BANKRUPTCY DLSCHAROE OF THIS DEBT, THIS LETTER is NOT AN ATT$~T TO COLLECT THS D8B ,BUT NOTICE OF POSSIBLE ENFORCBMBNT OF OUR LIEN AGAINST THE COLLATBIW. PROPERTY. COLORADO: FOR INFORMATION ABOUT THB OLARADO FAIR DEBT COLLECTION PRACT[CE5 ACT, SEE onA7TOaldeyOHVBR~~ ct[l~l~ 3etems, Inc. ~ialoina a lacd ~ at 35 Union Boutev~d, Suite 302, Lakowood, CO &0228. The office's phone number a tigit.73ti3376.1+TEW YO1tK CITY: 1331337,1340663, 134014a TBMYEB$E& is oolleotbn agency is license! by the Collation Service Board of the Department of Cormnera sad Insurence. Sctenn, Inc, is licensed to do business at 14323 SW Milli n Way, BearcAoq OR. 20120430 ~ ` BEIDEL, KEVIN R BEIDEL, CHRISTA L Loan No.: 7115276 Page 2 April 1, 2012 $701.87 Less Suspense (Balance) $383.98 TOTAL AMOUNT PAST DUE $2,333.26 The total amount now required to cure this default; or in other words get caught up in your payments, as of the date of this letter, is $2,333.26. You nary cure this default within THIRTY (30) DAYS of the date Qf t is letter by paying to us the above amo:mt $2,333.26; plus any additional monthly payments and late charge hich relay fall due durJng thls period Such payment must be made either by cash, cashier's check, certift check or money order and made at: Seterus, Inc. PO Box 7162 Pasadena, CA 91109-?162 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the orig Hal amount borrowed will be considered due immediately and you may lose the chance to pay offthe origins mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) AYE, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. the mortgage is foreclosed your mortgaged property will be sold by the Sher•~to pay o,,~`'the mortga a debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedi gs against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. Ho ever, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees eve if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay ,attorney's fees We may also sue you personally for the unpaid principal balance a ~ d all other sums due under the mortgage. If you have not cured the default within the thirty day period and reclosure proceedings have begun, youstill have the right to cure the defirult and prevent the sale•nt any tune to one hour before the Sherds foreclosure sale You may do so by paying the total amount of the npaid monthly payments plus any late or other charges then dui as well as the reasonable attorney's fees a d costs cor:Heeled with'the foreclosure sale and perform arty other requirements under the mortgage. It is esti ated that the earliest date that such a Sheriff s sale could be held would be approximately eight (8) mon . A notice of the date of the Sherrill sale will be sent to you before the sale. Of course, the amount needed t cure the default will increase the longer you wait. You may find out at any time exactly what the required ayment wilt be by calling us at the following number: 866.570.5277. The payment must be made in h, cashier's check, certified check or honey order and made payable to us at the address stated above. (Continued) THIS COMMUNICATION IS PROM A DEET COLLECTOR AS WE SOMETIMt3.4 ACT AS A T COLLECTOR. WE ARE ATTBMP'fM0 TO COLLECT A DEBT AND ANY INFORMATION (?BTAiJVSD WILL BB USED FaR THAT PURPOSB. HOWEVER. tF YOU ARB M BANKRUPTCY Cot RECEIVED A BANKRUPTCY DISCHARGB OF Tif13 DFBT, THIS LB1'[L?[L IS NOT AN ATTBMPT TO COLLt3CT THE D ,BUT NOTICE OF POSSIBLB BNI~RCEMBNT OF OUR LIMN AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR MFORMATION ABOUT TI E COLORADO FAiR DEBT COLLECTION PRACTICES ACT, SEE wWW.COjrQ$AL1C2.s7'1'ORNBYt7E~113itAL-,QQ~ Scterus, Inc. mainWna a local ollke at 55 Union Boulevard, Saito 302, Lala~vood, CO 8022& The office's phone numbs is 888.738.5576. NBW YORK CITY: 1331537, 1340(~i, 1340148. TEIVN • This cdiactioa ogcnoy is licensee by the Coltcction Scrvicc Board of the Department of Con?mceco end insurattca Seterus, Ina is licensed to do business at 14523 SW M llkan Way, Beaverton, OR. _ _ _ BEIDEL, KEVIN R BEIDEL, CHRISTA L Loan No.: 7115276 Page 3 Aptii 1, 2012 You should realize that a Sheriff s Sale will end your ownership of then mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs 4ale, a lawsuit could be started to evict you. You have additional right to help protect your interest in the property YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THB MOR GAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY F THIS DBBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPBRTY TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WII.,L ASSUME THE MORTGAGED T, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGBS, AND ATTORNEY'S EES AND COSTS ARE PAID PRIOR TO, OR AT THE SALE, AND THAT THE OTHER REQ S UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT C CUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT C D BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same po~itfon as if no default had occurred. However, you are not entitled to this right to cure your default more (than three times in any calendar year. Sincerely, Seterus, Inc. THIS COMMUN[CATION IS FROM A DBBT COLLECTOR AS WE SOMETIMES ACT A3 A EBT COLLECTOR. WE ARB ATTEMPTINO TO COLLECT A DEBT AND ANY INFORMATION OBTAiNBD WILL BB USED FOR THAT PURPOSE. HOWEVBR, >F YOU ARB IN BANKRUPTCY OR RBC8IVBD A BANKRUPTCY DLSCHARGB OF THIS DBBT, THIS LETfBR iS NOT AN ATTEMPT TO COLLECT THE ,BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THB COLLATERAL PROPERTY. COLORADO: FOR INFORMATIOI ABOVE COLARADO FAIR DBBT COLLBC'RON PRACTICES ACT, SBB 3otcrus, Ina maintains a local office at 353 Union Boulevard, Suite 302, Lakewood, CO 80228. The otlico's phone nutaber Ls 8g8.T38.S5T6. ir6W YORK Cl'CY: 1331537, 1340663, 134014$. TEN9Vl~S This cdtection agency is Itacnscd by the Cotkction Service Board of the Depardnent ofCommaec aad Easrrcance. Seterus, Inc, is licensed to do business at I45233W 118can Way, Beaverton, OR. ~U~~Z~ LEGAL DESCRIPTI~DN VERIFICATION'I Rebecca Gr-eves hereby states that he/sle is the t;,,~~ of Seterus, Inc.,'Servicing Agent for Federal National Mortgage Association, plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Federal National Mortgage Association and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Associiation v. Kevin R. Beidel and Christa L. Beidel relating to the property located at 730 Bloservill~ Road, Newville, PA 17241 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 I'a.C.S. Section 4904 relating to unsworn falsification to authorities. BY: Title: Seterus, Inca. as servicer fbr Federal National Mortgage Association Dated: $ -~,3 - i Z _ cram: `VIVR'_aw To: 1-7"7-240-6573 Page: g/"6 ~a`e: 915/20°2 C:2":35 ^'V' FORM 1 Federal Natianai t4lortaage Association ~ INS THE COURT ~Jl= C~Jt~fiE~10N PL~~;S (7i= ~Uh"BERt.A.MO COtli'. i PEN"~S°t~ VANE; F!aintitf(sj ~ ~ -°t ra V~ ~ ~ CJ'1 ~ f.J Kevin: F Beided and Christy L. Beidel ~ C~ C 8 Defendant~sj pr J J . _ Civil "C~ c~"'~'_ t, 2O a ~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE ~ ~ ~ ~r - DIVERSION PROGRAM R` ~ You 'r:ave been served with a foreclosi.ire 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 coi.irt-supervised concikiation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. Fkrst, within twenty (20j days of your receipt of this notice, you must contact h~lidPenn Legal Services at 017)243-940t; extension 2510 ar (800} 822-528$ extension 2511) and request appointment of a legal representative, at ne charge to you. Once you nave been appointed a legal representative, you must promptly meet with the legal representative within tvrenty (20) days of tfie 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 tie service upon you of the foreclosure comp;airt. 1F you do so anri a ccnciliatian .conference is scheduled, .you will . have an opportunity to meet with a representative of yaur lender in an attempt to work out reasonable arrangements with your lender before ttre mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps io be eligible for a conciliation conference. It is not necessary far you to contact hAidPenn Legal Service for the appointment of a lega; representative. However, you must provide your lawyer with all requested financial information so khat a Loan resolution proposal can be prepared an your behalf. if you and your lawyer complete a financial worksheet in the format attached hereto; your lawyer wit! prepare a*,.d the a Request far Concrliatkan Conference with the Court. which must be filed with the Court within sixty (64} days of the service upon you of the foreclosure campiaint. if you do so and a conciliation conference is schedu'ed, you wi(; have an opportunity to meet with a representative of yaur lender in an attempt to work out reasonable arrangements with your !ender before the mortgage foreclosure suit proceeds forward. IF YC}U WISH T© SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM fS FREE. f` t E Respect#ufly subm'rttsd: _ t c~_,. , J ~ { Date Sign~t~Cfe of Counsel tar Plalntlff =rem: 'V!VR '_aw To: 1-7' 7-240-6573 ?age: ° 6 ^a`e: 915/20^ 2 ~~:2" :?6 °M FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland ~:.cunty Court of Common Pleas Docket BORROWER RE4UEST FOR HARDSHIP ASSlS7ANCE Te complete your request for hardship assistance, your lender must consider your circumstances tc determine possible options while waxing with your Please provide the €rilawing information fo the best of your knowledge: Harrower name (s): Property address: City: State:..-------...._.._......_.......... ZiP Is the property for sale? Yes ~ ~ No listing date: Price: $ Realtor Name: ~ Realtor Phone: Borrower Occupied: Yes ; No L._, Mailing Address of diiferent) . City: State: Zip: Phone Numbers: Home : Office: Coil: 01her Email: # of people in household: ow ong. i • Mailing Address: City: State:.,..-----...-------._....___._.... Zip. Phone Plumbers: Home: Offic~. Cell; Ofher. Email; # of people in household: First f4larTpage Lender: Type of Loan: Loan N;~mber: Date You Closed Your Lean: Second Mortgage Lender Type c# Loan: Loan Plumber: nctuded °taxes and Insurance Total P~tortgage Payrnents Amount: Date o€ Last Payment. Prirrarv Reason for Default; Is the loan in Bankruptcy? Yvs Na tf yes. provide names, loc2tion o€ court. case nuri~ber & attorney: n _ From: MVR yaw To: 1-717-240-6573 Page: ' 1/°:6 Date: 915/2012 4:2" 36 PN' Assets Amount O+aed: Value: Horne: $ ~ Other Reat Estate. ~ ~ RetirR~~?ent F;nds: ~ {nUeStn-+ent5: ~ v Checking: $ w Savings: ~ ~ tither: ~ 5 Automobile P,~adet: Year: _ Amount owed: Value: Automebifa Modsi: Year: Amount awed: Va{ue: Other transportapon iautomobiles, boats. motorcyclesl: {4lodei: _ Year: Amount owed: Value: Monthly Income Name of Employers: 1 141onth{y Gross Monthly !`vet 2, Monthly Gross Monthly Net 3. Mont{rly Gross Manthiy Net Additional Income Qescript{r~n (not wages}: 1. Monthly Amount: 2. Monthly Amount: Barrr3wer Pay Days: Co-Borrower Pay Days: Monthly Expenses: ;P.I.ease orr#y.inc!ude exctenses you are CurrenttY_pay{na1_ _ ~EXPOVSE AMOUNT EXPENSE AMOUNT Mortgage Food j ~ ' 2~7_Mortgage _ _ Utilities ~ Car Payments; I Condo/Neigh. Fees~- IAuto Insurance hied. (not Covered; Auto fuel/repairs ~ j Other Prod. Payment f r Install, t_oan Pa ment- ~ Cable TV ' Chi{d Su rt,R{im. S endin Mone ' Day!Child CarerTui+ I Ocher Expenses L__ Arraunt Available for trtorihly hlcrigage Payments Based an income and Expenses: heave you green evorkir:c with a Hcus{rig Counseling :ggency? Yes Nn if yes. c{ease provide the following infflrmation: Counseling Age^Cy: ralln52{t}r: Phone (C`ffice: Fax: Ema{ - r _ _ _ _ _ ~ _ ,.T rr~m:'V'VR'_aw To:1-717-244-553 °age:12/"6 ~a`e:a/5/24'2.2":3~D'V' Have you made application for Homeowners Fmergenry h~ortgage Assistance Program fNEh~AP} assistam~e Yes No i f yes, please indicate the status of the application: Have you had any prier nego#iations with your fender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: ~~rt~t ~ Lender`s Contact (Name): r Phone: S~'U~ ~ ~7 ~ Servicing Company (Name}: C.- Contact: Phone: ~ ~ rA g~ INVe, ,authorize the above named to uselrefer this information to my lenderlservicerfov the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that Ilwe am/are under no obliyation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: ,r Proof on income d Past 2 bank statemen#s Proof of any expected incorr#e-for the las# 45 days ,t Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation ,r (hardship letter} fisting agreement (if property is currently on the market] v Copy of 2 years of federal income tax returns ,t Copy of deed FORM 3 rem: `V'VR'_aw To: 1-7'7-24C-5573 gage: 13/"6 7a'e. ~'/5/2C124 21:3' ^'v' Federal National PAartgage Assxio6on : It3 T r-iF COURT OF COP~Iitilul~J PLEAS OF :CUhfBERLAiJD ~OURtTY. PEPd~~SYL`rkP.i1~: Plaintiff(sj vs. Kevin R, Seidel and Christy L. Seidel rJefendani(5~ _ Civil REQUEST FOR GONCILIATIOIN CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Morfgage 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 f~esidential Mortgage Foreclosure Diversion Program and has taken all of the steps required its 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 statements are made subject to-the penalties of 1$ Pa. C.S, §4904reiating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date ega epresen true Signature of Defendant Date Signature cf Defendant Dam i _ _ _ i ~ro^~: 'V'VR :_aw To: 1-7"7-240-5573 Page: "4/"S ~a'e: 9/.5/2012 4:2":37 PM FORM 4 Fedora! National r;9ortgage Association : !N T!-iE COURT OF C0;l~ifAON PLEAS OF CUMBERLANr} CrJUNT: Y, PENPr'SYL`?A"v 1.4 P#aintiff(s~ vs. Kevin R R ide# and Ci~rista L. 8eide# Defendant(s? : C!vi# CASE Pr1ANAGEMErJT OF~DER AND NO`JV, this day of , 2D , the defendantlborrower 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 younsei are directed to participate in acourt-supervised conciliation Conference on at . N1. 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 most serve upon the P!aintif#llender and its counse# a copy of the `Cumberland County P.esidentiat PAartgage Foreclosure Diversion Pragra!rm Financial Worksheet" (Form 2} which has been completed by the defendant;'borrownr. Upon agreement of the parties in writing or at tha discretion of the Court; the Conciliation Conference ordered may be rescheduled to a later date andior the date upon which service of the completed Form Z is to be made may be extended. Upon notice to thG _ _ _ _ Cr~ry~. 1~'VR '_aw To: 1-717-240-6570 'gage: "5/16 ~a`.e: 9/5120124:2":3~ ^~U Court of the defendanUbarrowers faiture to serve the completed Form Z with the time frame set forth herein or such ott•,er date as agreed upon by the parties in writing ar ordered by the Court, the case sfiail be removed from the Conciiiatien Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel far the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff,fender 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 par#icipates in the Cgnciliation Conference must possess the actual authority to reach a mutually acdeptable resolution, and counsel for the plaintifftlender must discuss resolution proposals wifh 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 plaintiffilender at the rescheduled Conciliation Conference At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution optiions which shall include; bringing the mortgage current through a reinstatement;.. paying off the mortgage; proposing a forbearance agreement or repayment plan to birtng the account current aver time; agreeing to tender a monetary payment and to vacate in the near fu#ure in exchange for not contesting the matter„ offering the lender a deed in lieu of foreclosure; _ _ _r _ _ _ _ _ _ _ _ _ _ ~~om 'VIVR'_aw To ~-7"7-2~C-5573 Pace: x/15 'sa'e. a/5/2G12~:2":3F rV entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedirgs. 5. Ai? proceedings in this matter are stayed pending the completion of the scheduled conciliation con#erence. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy .o0vts' of umG ????? OU 16 All 9. Richard W Stewart Solicitor Federal National Mortgage Association Case Number vs. Kevin Beidel (et al.) 2012-5458 SHERIFF'S RETURN OF SERVICE 09/11/2012 07:52 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 11, 2012 at 1952 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Christa L. Beidel, by making known unto herself personally, at 730 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. *OE JT4ER, PUTY 10/08/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Kevin Beidel, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Kevin Beidel. Request for service at 730 Bloserville Road, Newville, Pennsylvania 17241 the Defendant was not found. Deputies additonally attempted service at 6 Sir William Drive, Newville, Pennsylvania 17241, but were unable to find an adult in charge of the residence before the Complaint expired. SHERIFF COST: $73.00 October 09, 2012 SO ANSWERS, C• RbNWY- R ANDERSON, SHERIFF ~3oa.~6cvls-DN MARTI-IA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane. PA 19018 (6lof 32'.8-2887 Attorne~~s for Plaintiff FEDER..AL NATIONAL MORTGAGE ASSOC'[ATION Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. KEVIN R. BEIDEL AND CHRISTA L. BEIDEL. Defendants NO: 12-5458 MOTION FOR SPECIAL SERVICE Movant, by its counsel, Heather Riloff C7 ~ n.a C7 ±-"v ~. . i '~}~ _ N -I Q7 " -t T ) ~~~7 rV . ~~ ~ "~7`P ~ C. J ~ 1 --i C3 ---i C"T :iJ -' ' Es~~uire, moves this Honorable Court for an Order directing service of the Complaint and al] subsequent notices upon the above captioned defendant(s) by regular mail and wertified mail at the last known addresses, 6 Sir William Dr, Newville, PA 17241 and 730 Bloserville Road, Newville, PA 17241 and by posting of the premises located at 730 Bloserville Road Newville, PA 17241 (hereinafter "Subject Premises") and in support thereof avers the following: 1. The Plaintiff filed its Complaint in Mortgage Foreclosure against Defendants, Kevin R. Beidel and Christa L. Beidel on or about August 31, 2012, for the defendant's failure to make monthly mortga;e;e payments from February 2012 for the property located at 730 Bloserville Road Newville, PA 17241 (hereinafter "Subject Premises"). 2. Plaintiff has been unable to complete service of its Complaint in Mortgage Foreclosure upon Defendant Kevin R. Beidel. The Sheriffs Return of Service is attached hereto made part hereof and marked as t Exhibit A. Pursuant to Pennsylvania Rules of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant, Kevin R. Beidel. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefore is attached hereto made part hereof and marked as Exhibit B. In compliance with Rule 208.3 A, a Judge has not ruled on ar~y motions to date in this action. To date there are no other motions pending in this action. The concurrence of any opposing counsel of record was sought and the response of said counsel; provided, that this requirement shalt not apply to preliminary objections, motions for judgment on pleadings.. motions for summary judgment, petitions to open or strike judgments, and motions for post-trial relief. WHEREFORE, as Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service upon Defendant Kevin R. Beidel of the Complaint in Mortgage Foreclosure and all subsequent notices b:y certified and regular mail at the last known addresses, 6 Sir William Dr, Newville, PA 17241 and 730 Bloserville Road, Newville, PA 17241 and by posting of the Subject Premises. Respectfully submitted, Martha E. Von Rosen ti 1 Heather Riloff ``'~"' ~~ Date: October 25, 2012 Attorneys for Petitioner MARTI-IA E. VON ROSENSTIEL, P.C'. Martha. E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire i No. 309906 649 Soti~th Avenue, Suite 7 Secane. PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDEF~.AL NATIONAL MORTGAGE ASSOCIATION Plaintiff #304~6C'MS-DN COURT OF COMMON PL,EA,S CUMBERLAND COUNT`S' VS. KEVIN R. BEIDEL AND CHRISTA L. BEIDE L, Defendants NO: 12-5458 BRIEF IN SUPPORT OF ITS MOTION FOR SPECIAL SERVICE '~/tovant, by its counsel, _ L.re•~{hnr Rilnf~ ,Esquire, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure and all subsequent notices upon Defendant Kevin R. Beidel by regular mail and certified mail and by posting of the premises located at 730 Bloserville Road Newville, PA l 7241 (hereina~hl:er "Subject Premises") and in support thereof avers the following: I. FACTS The Plaintiff filed its Complaint in Mortgage Foreclosure against Kevin R. Beidel and Christa L. Beidel on or about August 31, 2012, for their failure to make monthly mortgage payments due February 2012 for the property located at 730 BloserviCle Road Newville, PA 17241 (hereinafter "Subject Premises") II. ARGUMENT Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of~ the investigation, which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. "I'he Court in Romeo v. Looks, 369 Pa. Super 608 (198?;) stated that '`Before resort to substituted service maybe had, however, a plaintiff must have demonstrated a good fa~il:h effort to locate the defendant through more direct means." ?,n illustration of good faith effort to locate the Defendant includes (1) inq~r,iries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. I'~art 265, (2) inquiries of relatives, neighbors, friends and ernployers of the Defendant and (3) examination of local telephone directories, voter registration records, local tax: records, and motor vehicle records. Kittanning Coal Co. Inc. v. International Ylinin~ C'o.,Inc. 551 F. Supp. 834 (1982), Romeo v. Looks, 369 Pa. Super 608 (1987). As set forth in the Sheriffs Return of Service, marked Exhibit A, the Sheriff has been unable to serve Kevin R. Beidel with the Complaint after several attempts>. ,1 good faith eff:~rt to discover the whereabouts of Kevin R. Beidel has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit B. 7~~he Plaintiff submits that it has made a good faith effort to locate and serve Kevin R. Beidel and has been unable to do so. ~~'HEREFORE, Plaintiff respectfully requests service of the Complaint in Mortgage Foreclosure and all subsequent notices upon Kevin R. Beidel by certified and regular mail and by posting of the Subject Premises. Respectfully submitted, Martha E. Von Rosenst '1 Heather Riloff Attorneys for Petitioner #30426CMS-DN MAR'T'HA E. VON ROSENSTIEL, P.C. Martha F.. ~%on Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL. TIATIONAL MORTGAGE ASSOCLATION PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. KEVIN R_ BEIDEL AND CHRISTA L. BEIDEL DEFENDANTS NO: 12-5458 VERIFICATION ~_~ ~~~~ _, ESQUIRE, verifies that she is the attorney for the Plaintiff in the foregoing action; that she familiar with the facts in this matter; aa~d that the statements made in the foregoing Motion for Special Service are true and correct to the best of her in&~rmation and belief. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL. Y.C. ,~ ,, Martha E. Von Rosenstiel E uire ~ Heather Riloff, Esquire -~ Attorneys for Plaintiff Dated: October 25, 2012 #30426CMS-DN MARTH.~~ E. VON ROSF,NSTIEL, P.C. Martha ~~:, Von Rosenstiel, Esquire / No. 52634 Heather l~.iloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 32~~-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOC[,~1TION Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. KEVIN R. BEIDEL AND CHRISTA L. BEIDEI. Defendants NO: 12-5458 CERTIFICATE OF SERVICE Heather RICO' _, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion for Special Service, Brief in support thereof, attached exhibits, and proposed Order in the above matter was made upon the following by regular first class mail, postage prepaid, deposited with the United States Postal Service on October ~~ , 2012: I<:evin R. Beidel ?30 Bloserville Road ^Jewville, PA 17241 .And k:evin R. Beidel d~~ Sir William Dr r~ewville, PA 17241 1 his verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ,._ ..-`~ `_ Martha E. Von Rose still, Esquire Attorney for Plaintiff Dated: October 25, 2012. #3026-CMS-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Rilofl; Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 1 ~~~018 (610) 328-287 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION COURT OF COMMON PLEAS CUMBERLAND County Plaintiff vs. Case No: 12-5458 KEVIN R. BECDEL AND CHRISTA L, BEIDEL Defendant CERTIFICATION OF GOOD FAITH I, _ _ ~ ,ESQUIRE, attorney for the Plaintiff, hereby certify that I have made a good faith effort to give all parties affected by this Motion notice which was sent by United States Mail, first class, postage prepared on October l~ , 2012, upon the following parties: Kevin R., Beidel 730 Bloserville Road Newville, P_A 17241 And Kevin R..Beidel 6 Sir William Dr Ns'ewville.. PA 17241 Martha E. Von Rosensti 1 ,~, Heather Riloff Attorneys for Petitioner Dated: October 2:~, 2012 ~I.s. Pos7n1:,>rF,~-ICE CERTIFICATE OF MAl1~NG ~11,Y eE I;SED FOR DOMESTIC ,sND fNTERNefyi,l'MP11,, ~t NO'I ~ROv11~E Fi~R n~St.tRANCE-POSTMAS7Ek - Rccci~cd Frortc M/~RTHA VON ROSE1`'ST15L,':P_C.; 649 SOUTH A V ENUE UNIT 7 SECANE, pA 19018 One piece r,f of dettvy mail addre<sed lo: _ _ 6 Sir William Drive _ __ Newville, PA 17241 S Firm ~R17 i`.~er.19R9 ~'s. Pc`7,.,L;,E}_,,tcE CERTIFICATE OF M ILJ G rR v6E LSED FOR DOF~ST7C aNp O 1DE FOR fT'<,I~RgNCE-t' M7IRNP710TJA11<tI.FZ, DOLS N07 OS7 MPS7 Ek Received from 1~~1~1 RTHA VON ROSENS'T1Et,. 1'~C. 649 SOUTH AvR~F UNIT 7 One piece of ordeal ~ECAN);, p,q ] qp 1 E ry ma,l a~dre«cd ro. -_ -~ R. BEIDEL ---- ------ /T30 B104Pniillo ~ , __ __ _-Newville, Pq 17241 ---~ AfTia fcc hcrt in stamp<_ Or mutt ,prt: u~c, and ' Poll mai4. Jnquiec of I tilr,x fcc t,cn in stamp. Or, mncr Pos le~c and Posr rnyy,; lnqu'nc o! ~ I•''s'nT~ rn !m n,nerq --- ___ , . S Enrm _±ft17. Mar 19F9-'_-------_ ` - SHERIFF'S OFFICE OF CUIVIBERLAND COUNTY Ronny R Andersen e~t~E,r j;r Jody S Smith r,p,;: e Richard W~ Ste',rart ~~~i 3: l` ~'yCi`;?, ~`;IC; t~'~~^j~ A.SSG`CIatl0fl i' S Kevin, Eeice( rte; .. ~~ i r ! .. i ~`"~ ~ ,r'' ~~` ~~,.- , Case number SHERIFF`S RETURN O~ SERVICE s,t ~ ~ ~~' ~ ~, ~~2 ('C<~1 -Robert E3itn2r, DWputy Sheriff, tNhC being d~;Iy sworn according tc~ law, states tt ~~t ~; Sip±E~~~>:,~r 1, ~0~32 a! 192 hours, he served a true copy' ~f the ~~;~ithin Com;7laint in r~hrta~~we Fnrec:;csur~ and Nance of Reside,~~tiaf Mortgage Foreclosure Diversion Program, upon ,he ~,~,~ith~n gamed ::e`er~,r4ant, t© wit: Christy l_. Beidei, by making known unto herself personally, at 730 8'oser~ilie Read, tJw'.vvHe.. C~~mberland Counfy, Pennsylvania 17241 its CCrtents and at the s~3me time hancfi~ira ti= her ersr~'~ally t"e sad true and correct copy of tt~e same. "vi,'8l~C?2 Roar-:.~ R. Anderson, Sheriff, who being duly sworn according tc law, states that he made a c,(igEnt search and inauirr for the within Warred defendant to wit- Kevin Beidei, but wa-s unable to io;ate hin7 in i-,is bai'iv,~r._.~ He therefore returns the vrithin Complaint in Mortgage Foreclosure and Notice of ~'asrcfentia! tvlorigafe Foreclosure Diversion t'royram as not found as to the defendant Kevin Beidei_ R.~•~~~est for ser..•~icF at 730 Bloserville Read, Newr,iie; Pe^rsylvania "7?_41 the Defendani was not `Dunn Cleputies 3UCii~ ' 3`ly' ~I~c''.I7}pi%i3 ScNICc tat ~ rJl( tirVlllia!i? '~'!V°, NeYJV;ile, i~Ef~nSylV'ipil(p . t".4i, tii,'t ~JdC:rr J?}r~.IJi? t3 ind ar adrr!", ir! charge Uf the residence before the Ce,mpiaint expired. ~N~Rh~r C..l _ ., %-v SD ~,NS'~VERS, ~~ "~±;~t,~r d~7 -- - ~otvnt~ ~ ~a~~~~?scr~ :~1-il~R!=F ~at?• ~(~ .. ~, ~.~,~~5 exHrsrr LARRY DEL VECCHIO PROCESS SERVER FOR MARTHA E, VON ROSENSTIEL, P.C. P.O. BOX 344 CHALFONT, PA 18914 (215)491-4469 (215) 441-4473 FAJC Federal National Mortgage Association COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. KEVIN R. BEIDEL CHRISTA. L. BEIDEL NO. LAST KNOWN ADDRESS: 730 Bloserville Road, Newville, PA ] 7241 FILE NUMBER: 3042b AFFIDAVIT OF GOOD FAITH EFFORT TO LOCATE DEFENDANT (S~ 1 hereby certify that on June 5, 2012, a good faith effort was made to discover the correct address of said defendant (s), by: l,. Inquiry of Postal authority; Postal authority states defendants are good as addressed at property, 730 Bloserville Rd. 2, Examination of local telephone directories, 411 assistance and Internet records; Kevin R. Beidel, 730 Bloserville Rd., (717) ?76-7736, left messages with no response 3. Neighbor Contacts: - James Warner, 721 Bloserville Rd., (717) 776-6695, adult male stated he doesn't know the defendants - B.A. Stets, 726 Bloserville Rd., (717) 776-6937, left messages with no response - Sylvester S. Bear, 729 Bloserville Rd., (717} 776-6391, left messages with no response 4. Tax Information: •• Tax office mails bill to property, 730 Bloserville Rd. S. Death Records: •~ Social Security has no death records for defendant(s) name(s). 6. Voter Registration: Christy L. Beidel is registered at property, 730 Bloserville Rd. Kevin R. Beidel is registered at 6 Sir William Dr,, Newville, PA 17241 I certify that this information is true and convect to the best of my knowledge, information and belief. NOTARY PUBLIC: Swom to and described before me this a<S+- day of _ 2012. COMMONWEALTN OF PENNSYLVANJA 1,lOTANY SEAL OAVJN M. LUCIOTTI Warrington T.vp., Bucks County My Commission Expires March 28, 2015 BY: -~1,.~~ Larry Del Vecchio, Process Server EXHIBTf 3 __~ LARRY DEL VECCHIO PROCESS SERVER FOR MARTHA E. VON ROSENSTIEL, P.C. P.O. BC>X 344 CHALF'ONT, PA 18914 Postmaster Newville, Pa 17241 June 5, 2012 (215) 491-44b9 FAX (21 S) 491-4473 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address {if a boxholder) for the following: Name: Kevin R. Beidel Address: 6 Sir William Dr. Newville, Pa 17241 The following information is provided in accordance with 39 CFR 265.6(d) (4} (ii}. There is no fee fur providing boxholder information. The fee providing change of address information is waived in accordance with 39 C'FR 265.6 (d) (1) and (2) and corresponding Administrative Support Manua1352.44a and b. 1. Capacity of requester: Process Server :?. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for Martha E. Von Rosenstiel, P.C. (Rule 400.I.b} 3. The names of all known parties to this litigation: Federal National Mortgage Association V. Kevin R. & Christy L.13eidel ~~. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas _`i. The docket or other identifying number if one has been assigned: Not yet assigned Ei. The capacity in which this individual is to be served: Defendants} THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS M CONNECTION WITH ACTUAL OR PROSEPCTIVE LCiIGATION COULD RESULT 1N CRIMINAL PENALTIES INCLUDING A FINE OF UP TO SI0,000.00 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMRP,TION OF NO'1~ MURE THAN 5 YEARS, OR BOTH {TITLE 18 U.S.C. SECTION 1001). 1 CERTIFY 'THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATIOIJ. /~`--~ P.O. Box 344 LARRY DEL VECCHIO Chalfont, PA. 18914 For Martha E. Von Rosenstiel, P.C. FOR THE POST OFFICE USE ONLY _.__ NO CHANGE OF ADDRESS ORDER ON FILE (F~f 1/ r / r POST MARK ~ _ NEW ADDRESS OR BOXHOLDER'S NAME AND PH~'S~/1L STREET ADDRESS: „P/ r, _ ` _~._ '2~ LARRY DEL VECCFIIO PROCESS SERVER FOR MARTHA E. VON ROSENSTIEL, P.C. P.O. BOX 344 CHALFONT, PA 18914 Postmaster Newville, Pa 17241 June 5, 2012 (215)491-4469 FAX (215) 491-4473 REQUEST' FOR CHANGE OF ADDRESS OR BOXHOLDER INFORi14ATION NEEDED FOR SERVICE OF LECAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Kevin R. Beidel Address: 730 Bloserville Rd. Newville, Pa 17241 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). There is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. l . Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for Martha E. Von Rosenstiel, P.C. (Rule 400.1.b) `.3. The names of all known parties to this litigation: Federal National Mortgage Association V. Kevin R. & Christy L. Beidel 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas S. The docket or other identifying number if one has been assigned: Not yet assigned 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS M CONNECTION WTCH ACTUAL OR PROSEPCTIVE LrfIGAT10N COULD RESULT (N CRIMINAL PENALTIES INCLUDING A FINE OF I.1P TO SI0,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS rNFORMRA'rION OF NOT MURE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001), I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMA7"ION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LffIGATION. /Z'~~ P.O. Box 344 LARRY DEL, VECCHIO Chalfont, PA. 18914 For Martha f's. Von Rosenstiel, P.C, FOR THE POST OFFICE USE ONLY NO CHANGE OF ADDRESS ORDER ON FILE POST MARK ~~"'-'1 NEW ADDREiSS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: o , - b_ ~ . y _ ~~" J~' \. v J.1 LARRY DEL VECCIiIO PROCESS SERVER FOR MARTHA E. VON ROSENSTIEL, P.C. P.O. BUX 344 CHALFONT, PA 189 ] 4 Postmaster Newville, Pa 17241 June 5, 2012 (215)491-4469 FAX (215) 491-4473 REQUES?' FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMAT{ON NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Christa L. Beidel Address: 730 Bloserville Rd. Newville, Pa 17241 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). There is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (l)and (2) and corresponding Administrative Support Manual 352.44a and b. I . Capacity of requester: Process Server '?. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for Martha E. Von Rosenstiel, P.C. (Rule 400. l .b) :? . The names of all known parties to this litigation: Federal National Mortgage Association V. Kevin R. & Christa L. Beidel 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas :9. The docket or other identifying number if one has been assigned: Not yet assigned 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMtSS[ON OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS fNFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSEPCTTVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF lJP TO $10,000.00 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS TNFORMRATION OF N07 MORE "THAN 5 YEARS. OR BOTH (TITLE 18 U.S.C. SECTION 1001). I CERTIFY THAT'THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION. ~-.r`~ P.O. Box 344 LARRY DEL. VECCH[O Chalfont, PA. 18914 For Martha Es. Von Rosenstiel, P.C. FOR THE POST OFFICE USE ONLY NO CHANGE OF ADDRESS ORDER ON FILE POST MARK I `~. NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: o ~TZ16 ~ f 7"r ~.cQ /~6 t/~- ~=~~-k~ . ~,~ r ~$ --C. . ---~_` FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 12-5458 KEVIN R. BEIDEL AND CHRISTA L. BEIDEL Defendants ORDER AND NOW, this;j~~day of ~~~~A7l~~'i~ 2012, upon consideration of Plaintiff s Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Kevin R. Beidel by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff s sale, by certified mail and regular, first class mail at the last known addresses, 6 Sir William Dr, Newville, PA 17241 and 730 Bloserville Road, Newville, PA 17241 and by posting the premises of 730 Bloserville Road, Newville, PA 17241. /yha~~-k-a ~. Uoh 2r~.sen~; ~ f ~'sGr IC~u ~ n ,~ , ~3 P;~g~ yep; es ~, /mod ~ t~s~a ,e1G~ BY THE COURT: ~~~ ~~ ~. r.~ c ~..~ .~ Z~ ~' -L7~ ~c . r; N -'~ ~' GI1 L7 ~. "".~ ~--' C c~ " l7 c°a ^`~ x" C". Z Cx ~ :~' ~~ ~ , Y W a -~ ~ ,Y) -~; - . r F ': ; _ -' ~~~~ 3~ i'.:30426-SS CSV MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. KF,VIN R. BEIDEL AND CHRISTA L. BEIDEL Defendant(s) r „~ ,r, _. e r j ~~ J ~": a e L: ~E . e'~l 1~t ~ ~~Li! tl ~ f +~~~lti y S_~.r~l~i3~~c COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 12-5458 CERTIFICATION OF SERVICE Martha E. Von Rosenstiel, Esquire, hereby certifies that she is the attorney for the plaintiff herein and that service of the Civil Action in Mortgage Foreclosure in the above matter was made upon on the defendant KEVIN R. BEIDEL by certified mail and by regular mail, pursuant to Court Order on November 27, 2012. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. B~ -v-.. Martha E. Von Ros s el, E uire Heather Riloff, Esquire Attorneys for Plaintiff DATED: November 27, 2012 FEDERAL NATIONAL MORTGAGE ASSOCI_ATIOIv Plaintiff VS. ILEVIN R. BEIDEL AND CHRISTA L. BEIDEL Defendants ~{, __ __£:„% COURT OF COMMO?4T PLEAS ~~~~ -~ '~, CUMBERLAND COUNTY ~~'~~~ `~' NO: 12-5458 ORDER AIvTD I~~OW, this vr' day of `)'jAy~.' 2012, upon consideration of Plaintiffs iVlotion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on 1{evin R. Beidel by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail and regular, first class mail at the last known addresses, 6 Sir William Dr, Newville, PA 17241 and 730 Bloserville Road, Newville, PA 17241 and by posting thepremises of 7~0 Bloserville Road, Newville; PA 17241. BY THE COURT: •a "L7 -~ .~~ rte..? ,~,., -~ -- ;^ ~. ~ } N~ ~.: ~~ .~ 0 ~ ~• ~ - m ru = - - m c~ ¢~;.,os sec ; Q ° ° ~ Res`~~c`_ed J ive~y --- _ - ,, -~~ ° ---- ~- -- V ~ ~ ~ ~ 7o:as PostagE ~ f et,. ~ ~ / ; t -- ~ , Sent a ~ I 730 Bloserville Bond ~ - . ° f~ I -_ _ - .-_ _ St`e t "°. ille, PA 17241 !'rP _ _ ___ _~ ._ _ _ _ - ~. t~ ;~~ sta,_ Ztr~v :~~ ~t. - - MAY BE USED fOR DOMESTIC ANDINT~R I'RO~/IDE FOR INSURANCE-Pp57MA5TER Rcccivcd From: MARTHA VON RO: 649 SOUTH A UNI7 7 SECANE, PA 19018 Onc piece ref ordstarv mail addressed tc: ~fl;;tal Servir ~~FiIEn nn ~_ ~ ~~~ ~F m _ _ _._ " ~ Ee urr tte e a ree s ((}} - °'f5~mark ~~ ~ ~ ~ ' O (Enoor e°ner. ~ieau reds ~ Mere/} ~ , , - ri ~(f ~~ f _ O - - - --_- ~ £ ~ 1 r nest ilea Jen~dert ree . ~ _, O ° (EnC~rsfa~ens Re~u F~r.1) ~ z ~~ ,: 1 -rt - - ' T U7 Tota: Gostaae t r=ees ~ ~ ~ >' , m ------------ _ __ - a 6__~ir-V_Ililtiarx~-.Dive.--______ ~ ~r - ---Ile,_PA-17.2.4.1.._.__.._ -- - _ ,. -------- Crty, State, ZiP+4 ILI-~I;O Affix fec hcrc in stamps ?O 7 9~ mctcr postage and ~a.~:~. Z ~:_ . M~' of ,~cnt ~';~~ ~ 1 st ~ ill :F' r t - ~. ~ . 4.ti n. - - - KEVIN R. BEIDEL ----4~-~I~F-t I+ar~--~T~ Newville, PA~17241 ...- - '1 ~ :~ : ~ ~ -r. ~~E ~ ` ~'~ ' ~c~-~ i \ L~. MAY BE USED FOR DON~STiC AND fIJT'ER PROVIDE FOR fNSURANCE-nOS"fMASTER Rcccivcd From: MARTHA VON ROSI: 649 SOUTI-3 A V UN]T 7 SECANE PA ]9018 JN F~p~ r~Affix fec hen: in stamps OT ~ meter posh c end - _~° ~MF-Etr . _ uotrrvcnt .., : ~~ ~x ~ ...- Onc piece of onletarv mail addressed tc: ~ ~ BiG~. ~ ~ ~ Lti ; -.~ lQ;. c~. 730 Bloserv i Ile Road ~,- ,~, -~'' J Newville, PA 17241 /~` ' ' ~' i ,~~~ ~~ ___ ~~. ~;t~ y ,~. ?'S i•orm 3R 1 "r, f.1er.', 9E~ i ~~ ~,,, (,. SHERIFF'S OFFICE OF CUMBERLAND GOUNTY Ronny R Anderson _ ;~' =~ ,V .,°~ Sheriff ,~*titr ai ~ a ~u t~~~,~ "~" ~ ~ -+ ~~ ~fl Jody S Smith ~~`~ ~' ~r-= Chief Deputy - ~ ~ ~ ~~ -<~-~ w Richard W Stewart , +-"~ ~! Solicitor ~ wN'~~ .,-~~ ~ r~ _ r.~ ~:., fy~ ~- 1 Federal National Mortgage Association Case Number vs. Kevin Beidel (et al.) 2012-5458 SHERIFF'S RETURN OF SERVICE 11/21/2012 Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Kevin Beidel, pursuant to Order of Court by "Posting" the premises located at 730 Bloserville Road, Upper Frankford Township, Newville, PA 17241 with a true and correct copy according to law. L IAM CLINE, DEPUTY SHERIFF COST: $46.00 November 26, 2012 SO ANSWERS, '~ ~°~_ RON R ANDERSON, SHERIFF y ~ . ~ ~,, C-- #30426CAM - DN MARTHA E. VON ROSENSTIEL, P.C. co Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff VS. NO: 12-5458 KEVIN R. BEIDEL AND CHRISTA L. BEIDEL Defendant(s) AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 Haftthor RHO ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on 13 true and correct copies of the Notice of Sheriff's Sale were served upon recorded lienholders and any known interested parties by regular first class mail,postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit 1. I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. By:-(L��(� 12.�,/ Martha E. Von Ras oitiel,)Esquire Heather Riloff, EsqW'f&-./ Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff VS, NO: 12-5458 KEVIN R. BEIDEL AND CHRISTA L. BEIDEL Defendants ORDER AND NOW, this ' day of 17�2012, upon consideration of Plaintiffs Motion for Special Service and any response thereto(if any),it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Kevin R. Beidel by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail and regular, first class mail at the last known addresses, 6 Sir William Dr,Newville,PA 17241 and 730 Bloserville Road,Newville, PA 17241 and by posting-the 2remises of 730 Bloserville Road,Newvllle, PA 17241. BY THE COURT: xs/ J. Cn C�- Postal Postal CERTIFIED # RECEIPT CERTIFIED MAIL. REECEIPT (Domestic t _ Coverage i• Only, e l� e r pill to ru nj -.,,.,-.�._ —...,..«.. ('c�cHere t aJ Fe �SECAIV Omar D Return Recei;t F4;a r ! i- ,, C3 Return Receipt Fe Here p {'En6orsemen+RequirecJ C3 (Endorsement Reauirec 1 !`Restricted DeUT Fee i?est,-icted CaeSiJeryr Fe arnc ��� � {rlF 7otat t staara Fees FA iota!Postage&Fees fU _ _ ._.._ PA 190 n, j even e1 e nJ evin 1� -Be�eT"�.— _- 2eQ43IcseN le--Rtrad-----.-------------------- - o f rB iservifle-Roast -. _ ------------------ -- : -P-A 17241-.._----. _..� 'try, rare, + � -_� • t U.S,POSTAL 5 ERVICE CERTIFICA kl r;� �,• _ MAY BE USED FOR DOMESTIC AND FKMRNAT NO ` Pt� YSnd PROVIrTE FOR TNSURANCE—POSTMASTER " 02 1P F' r, Reeeivtd From: GG01 138293 MAR 25 20 MA#LEE F OM, ZIP CODE?'901 c MARTHA VON ROSENSTIEL,P.C. 649 SOUTH AVENUE UNIT 7 _ SECANE, PA 19018 x PC) 7 ; Chic piece of ordinary mail addressed to: .C ` Kevin R. Seidelr 734 Bloserville Road } U.S POSTAL SERVICE CERTIFICA e I MAY BE USED FOR 5TIC AND W ERNAT PROVIr*FOR 6NSIJR ANCE—POSTM ASTER � 02 1e � nt t 9;38 5r�- MAR 2E .v Received Fror Z' ' � Pr3,`,r . MAILED? F JM MARTHA VON ROSEN TIEL,P.C. 649 SOUTH AVENUE UNIT 7 SECANE,FA 19018 _ Cirx piece of ordinary mail addressed to: ,- ' F C;- Kevin R. Beidel f 730 Bloserville Road PS Form 3817. mar.)999 Name MARTHA E. VON ROSENSTIEL, P.C. ❑ Registered ❑ Return Receipt tor cerimeu ul IIrailli1y ul tut and Attorney At Law for Merchandise Registered Mail: ( additional copies of this bill. Address 649 South Avenue, Unit 7 ❑ Insured 13 With Postal Insurance Of ❑Without Postal o ecerpt k, Sender Secane, PA. 19018 ❑COD ❑ Int'I Recorded Del. Insurance ❑ Certified ❑ Express Mail 2 .,, J , s F e ,, 02 'iP C9-- Act. 0001 7 j825 MAi2 '5 Article Name of Addresses,Street, and Handling Value Insured Due MgibEr] f-10M Zip(,o[);-- i 0 ti Line Number Post Office Address Postage Fee Charge (If Vatue If COD Fee Fee Fee Remarks Regis.) Cumberland County Tax Claim 1 #30426 1 Courthouse Square Carlisle, PA. 17013 Cumberland Register of Wills p I 2 County Courthouse Carlisle, PA. 17013 Attorney General of the U.S. C/O Assistant Attorney General 3 Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC. 20044 PA Department of Revenue 4 Inheritance Tax Division, LL P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 5 1 Courthouse Square Carlisle, PA. 17013 _ PA. Department of Revenue Bureau of Compliance 6 Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Department of Public Welfare 7 P.O. Box 2675 Harrisburg,PA. 17105 Occupants/Tenants 8 730 Bloserville Road a tf Newville, PA 17241 6� PA. Department of Revenue o , Bureau of Individual Taxes 9 P.O. Box 280603 '' a Harrisburg, PA. 17128 Household Realty Corporation 10 25 GatewayDrive Square Ste107 Mechanicsburg, PA 1755 Discover Bank 1I 6500 New Albany Road New Albany, OH 43054 16 j _ Total Number ojPieces Total I Postmaster,Per(Na e 11 e ivi oyee) The full declaration of value is required on all domestic and international registered mail. The - ��••m��•�a maximum indemnity payable for the reconstruction of nonnegotiable documents under Express AFFIDAVIT OF SERVICE PLAINTIFF: Federal National Mortgage Association 0 COURT OF COMMON PLEAS DEFENDANT Cumberland COUNTY Kevin R.Seidel and Christa L.Seidel COURT NO. 12-5458 GT fib cii it SERVE UPON: Qrrl Christa L.Seidel TYPE OFACTION 730 Sloservflle Road C2 Newville,PA 17241 XX WRIT OF EXECUTION and Notice of Sheriffs Sale SPECIAL INSTRUCTIONS:please serve defendant personally Sheriffs Sale Date:9/4/2013 or adult In charge of premises **Kevin R.Beidel cannot accept service for Christa- bb made known to 67r)�jct 'L- 64 1p�day of 20f, -d I o 1� , (Defendant, on the 3 , at Served and D - M. at-7_10 Commonwealth of Penns Ivania, .in the manner described below: Defendant pervonallE served. ManageriClerk of place of lodging in which Adult family member with whom Defendant resides- Defendant resides Relationship is Agent or person in charge of Defendant's office Adult In charge of Defendant's residence who or usual place of business. refused Other to give name/relationship. Description: e Height Weight Race___W Sex—r Other a competent adult,being duly sworn according to law,depose and state that I personalty handed to C.'hCjj+Q4 L, a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriff's Sale issued in the captioned case on the date and at the address indicated above. Sworn to and subs before me this dj KIMBERLY G CURTY Of ID At 2295304 Notary; By N01 NOT SE NOTARY PUBLIC STATT E OF NEW JERSEY On the da ,20 at o'clock M.,D 4 MArch,7,2018 Moved Unknown No Answer Vacant Time of Attempt: 1 Result: Date of Attempt: Sworn to and subscribed before me this—.—day of —200— Notary: By: ATTORNEY Martha E.Von Rosenstiel,P.C. 649 South Avenue,Unit 6 Secane,PA 19018 610-328-2887 ,o!„_. 30426-DN AFFIDAVIT_ OF SERVICE PLAINTIFF: ffi=—. Federal National Mortgage Association COURT OF COMMON PLEAS DEFENDANT Cumberland COUNTY COURT NO. 12-5458 9 P z Kevin R.Seidel and Christa L.Seidel � ®�;• 3T tZi A2 z SERVE UPON: Kevin R.Seidel TYPE OF ACTION C1 a i 730 Sloserville Road XX WRIT OF EXECUTION and Notice of Sheriffs Sale Newvilie,PA 17249 ..{ —� Ca SPECIAL INSTRUCTIONS:post per court order Sheriffs Sale Date:91412013 ��������// ERVED �1.� Served and made known to �"(vi �' � Defend t, on the ' I day of 20J3 , at o'clock, J2. N., at ??O Qr ► 4?_ Commonwealth of Penneylvania, in the manner described below: Defendant personally served. Manager/Clerk of place of lodging in which Adult family member with whom Defendant resides. Defendant resides. Relationship is Agent or person in charge of Defendant's office Adult in charge of Defendant's residence who or usual place of business refused Other ` to give nametrelationship. 1 7 Description: Age Height Weight Race Sex Other I, vW a competent adult,being duly sworn according to law,depose and state that I personally band" to y2 a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriffs Sale issued in the captioned cas on the crate and at the address indicated above. Sworn to and subscrib KI AERLY Q CURTY before me this da ID#2295304 Of 0 S` NOTARY PUBLIC Notary: By: STATE OF NEW JERSEY NOrsc My Commission Ex ices March 7,2018 On the 2C_,at o'clock _ _.M.,Defendant NOT FOUND because: Moved Unknown No Answer Vacant Time of Attempt: R li:— Date of Attempt: I i J Sworn to and subscribed before me this day of 2C Notary: By; ATTORNEY 'Martha E.Von Rosenstiei,P.C. 649 South Avenue,Unit 6 Secane,PA 19018 610-328-2887 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ` Sheriff F!LED-CF FILE 4xxxt of aaata rr. Jody S Smith ad OF THE PRO THONO r�r� �: Chief Deputy ' 2013 JUL —2 PM Z'. 4 Richard W Stewart C�►�iBERLAtd�3 ��j(,I.��J'�' Solicitor OFFICE OF r"`E sK=RIa=F PENNSYLVANIA Federal National Mortgage Association Case Number vs. Kevin Beidel (et al.) 2012-5458 SHERIFF'S RETURN OF SERVICE 06/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. 06/27/2013 07:51 PM- Deputy Jason Kinsler, 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 730 Bloserville Road, Upper Frankford Township, Newville, PA 17241, Cumberland County. SHERIFF COST: $538.21 SO ANSWERS, July 01, 2013 RoNtrY R ANDERSON, SHERIFF (c}CauntySuite Sheriff,Telcosott.Inc. #30426CAM - DN MARTHA E. VON ROSEN§TIEL,P.C. r_—a rLn r-=nc) Martha E. Von Rosenstiel, Esquire/No. 52634 Heathef Riloff, Esquire/No. 309906 649 South Avenue, Suite 7. COPY Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff VS, NO: 12-5458 KEVIN R. BEIDEL AND CHRISTA L. BEIDEL Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 Heather RHO ESQUIRE, attorney for the Plaintiff in the above action, sets forth as of the date the'Praccipe for the Writ of Execution was filed the following information concerning the real property located at 730 Bloserville Road,Newville, PA 17241: 1. Name and address of owners(s) or reputed owner(s) Kevin R. Beidel 730 Bloserville Road Newville, PA 17241 Christa L. Beidel 730 Bloserville Road Newville, PA 17241 2. Name and address of defendant(s) in the judgment: Kevin R. Beidel 730 Bloserville Road Newville, PA 17241 Christa. L. Beidel 730 Bloserville Road Newville, PA 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Discover Bank 6500 New Albany Road New Albany, 01143054 4. Name and address of the last recorded holder of every mortgage of record: t Household Realty Corporation 25 Gateway Drive, Gateway Square/Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, 'PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, ' P.O. Box 280601 Harrisburg, PA 1.7128 Family Court/Domestic Relations 1 Courthouse Square Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes "PO Box 280603 Harrisburg, PA 17128-0603 Occupant 730 Bloserville Road Newville, PA 17241 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: 42,4 r- (- artha E. Von Ros n iel, Esquire Heather Riloff, EsqVr6 Attorneys for Plaintiff Dated: March 07, 2013 30426CAM-9i MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire /No. 52634 Heather Riloff, Esquire /No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION CUMBERLAND COUNTY Plaintiff vs. No: 12-5458 KEVIN R. BEIDEL AND CHRISTA L.: BEIDEL Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 730 Bloserville Road Newville, PA 17241 will be sold by the Sheriff of Cumberland County on Date of Sale: September 04, 2013 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 12-5458 in the Court of Common Pleas of Cumberland County by Federal National Mortgage Association, Plaintiff against Kevin R. Beidel and Christa L. Beidel, Defendant(s). Judgment was entered on March 08, 2013 in the amount of$15,834.49. The property was seized and taken in execution as the property of Kevin R. Beidel and Christa L. Beidel. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot of ground situate in the Village of Bloserville, Township of Upper Frankford, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Main Street, in said village; thence Westerly by lot now or formerly of Mary Hoover, 198 feet to an alley; thence Southerly by said alley, 49 feet 6 inches to an alley, thence Easterly by the last named alley, 198 feet to Main Street, thence Northerly along Main Street, 49 feet 6 inches to the Place of BEGINNING. BEING improved with a dwelling house. BEING THE SAME PREMISES which John A. Bistline, Jr. and Laura A. Bistline conveyed unto Robert A. Getz, Jr., by deed dated November 30, 1987 and recorded November 30, 1987, in the Recorder's Office in and for Cumberland County, Pa., in Record Book B, Volume 33, Page 645. Tax ID #43-11-3069-012 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 12-5458. You should check with the Sheriff's Office by'calling (717) 240-6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire /No. 52634 Heather Riloff, Esquire /No. 309906 Attorney for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-5458 Civil COUNTY-OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff(s) From KEVIN R.BEIDEL AND CHRISTA L. BEIDEL (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 gamishee(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 $15,834.49 L.L. $.50 Interest FROM 3/9/2013 TO 9/4/2013 AT 6% -$468.00 Atty's Comm % Due Prothy$2.25 Atty Paid $279.50 Other Costs Plaintiff Paid Date: MARCH 11,2013 David D. Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name : MARTHA E. VON ROSENSTIEL, ESQ. Address: MARTHA E. VON ROSENSTIEL,P.C. 649 SOUTH AVENUE,SUITE 7 SECANE,PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 TRUE COPY- ROM RECORD In`testimony whereof,•1 hereunto set my hand and this sa •of Bald �K at-ca isle,Pa. This 1�. ay of:L.;!20 AR Prothonota On May 30, 2013 the Sheriff levied upon the . defendant's interest in the real property situated in Upper Frankford Township, Cumberland County, PA, Known and numbered as, 730 Blosserville Road, Newville, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: May 30, 2013 By: Real Estate Coordinator 00 :b IV Z I dvw EIOl Vd mil .