HomeMy WebLinkAbout12-5676 C c;a
MARTHA E. VON ROSENSTIEL, P.C. ~~305t~~KC ~1~'I
t
Martha E. Von Rosenstiel, Esquire / No. 52634 ~ ~
Heather Riloff, Esquire / No. 309906 ~ xr., w ~
649 South Avenue, Suite 7 r-- -+c-,
Secane, PA 19018 ~ t~
(610) 328-2887 ~ ~ :t~
W
Attorneys for Plaintiff A~ ~W~ rr,,
tv
FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS O~'
ASSOCIATION CUMBERLAND COUNTY
3900 Wisconsin Avenue, NW
Washington, DC 20016-2892
Plaintiff
v. NO. lo1-Jr(D7~p tV~ ~ ~L°/KI
ALAN G. DAMS
1966 Spring Road
Carlisle, PA 17013
Defendant
CIVIL ACTION -MORTGAGE FORECLOSURE
NOTICE AD
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 follo~+ing pages, you must take action within twenty estas demandas expuestas en las paginas siguientes, usted time
(20) days after this complaint and notice are served, by entering a veinte (20) dies de plazo al partir de la feCha de la demands y la
written appearance personally or by attorney and filing in writing with notification. Hate fella a sentaz una comparencia escrita o en
the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la torte en forma escrita sus
You aze warned that' if you fail to do so the case may proceed without defenses o sus objeciones a las demandas en contra de su persona.
you and a judgment Keay be entered against you by the court without Sea a visado que si usted no se defiende, la Corte tome ra medidas y
further notice for any money claimed in the complaint or for any other puede continuar la demands en contra suya sin previo aviso 0
claim or relief requested by the plaintiff. You may lose money or notification. Ademas, la cone puede decadir a favor del demandante
property or other rights important to you y requiere que usted cumpla con lodes las provisiones de esta
demands. Usted puede perder dinero o sws propiedades o otros de
rechos importantes pars usted.
YOU SHOULD TA,1KE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO
ONCE. IF YOU DSO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE, ABOGADO VAYA EN
TELEPHONE TH~ OFFICE SET FORTH BELOW. THLS PERSONA O TELEFONA A LA OFI~INA ESCRITA ABAJO .
OFFICE CAN PR !VIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEI~R INFORMATION
HIRING A LAWYIER. IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UNiABOGADO. SI USTED
LAWYER, THIS FFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENT~ PARA CONTRATAR A
WITH INFO ON ABOUT AGENCIES THAT MAY UN ABOGADO, LE PODEMOS DAR' INFORMACION
OFFER LEGAL S~ItVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A
REDUCED FEE QR NO FEE PERSONAS ELEGIBLE PARR SER~VICIOS A COSTO
REDUCII1b O GRATUTTO
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
~ho3.~15 Prfl N'n'`/
C-t s33~f y
12"~ o~lS~oO
THIS IS AN ATTEMPT TO COLLECT A DEBT
ANY INFORMATION OBTAINED MAY BE
USED .FOR THAT PURPOSE
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE AIbVISED THAT:
PURSUANT TC} THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692,
et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR
ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAIP~ITIFF
WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICA'~ION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID.
LIKEWISE, IF (REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF TIiIS
PLEADING, CQ~UNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE N~IME
AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABO'rVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE
THIRTY(30) D1~Y PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE
SUING YOU T~,1 COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDIES
THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTT ION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT!' TIME.
FURTHERMOjRE, NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT I~1~TIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF'~HE
DEBT OR THi~ NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITI~IN
THE THIRTY I(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS
COMPLAINT,; THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH '
LITIGATION I~,1R OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL'THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTOIRNEY
FOR ADVICE'~CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVi~ FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT
AN ATTEMP'T' TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A L)EN ON
REAL ESTATE.
_ _ _7.
. ,
MARTHA E. VON ROSENSTIEL, P.C. 30525CFC-BI
Martha E. Von Rasenstiel, 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 OF
ASSOCIATION CUMBERLAND COUNTY
3900 Wisconsin Avenue, NW
Washington, DC X0016-2892
Plaintiff
v. NO.
ALAN G. DAMS
1966 Spring Road
Carlisle, PA 17013
Defendant
CML ACTION - MORTGAGE FORECLOSURE
THIS IS AN ;ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
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, V~ashington, DC 20016-2892.
2. Defe~hdant, Alan G. Davis is the mortgagor and real owner of premises 58 Media
Road, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the
caption.
3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and
real owner, to f4~reclose a certain indenture of mortgage made, executed and delivered by the
above named defendant, mortgagor, and real owner to Mortgage Electronic Registration
_ _ ~rv~ _ - _ , _
_ ~ _ , _ _T _
f_
Systems, Inc. as Nominee for SunTrust Mortgage, Inc. on January 3, 2008, which mortgage is
recorded on January 7, 2008 in the Office of the Recorder of Deeds of Cumberland County as
Instrument #200800703, secured on premises 58 Media Road, Carlisle, PA 17013 a true and
correct description of which is attached hereto as Exhibit I.
4. The mortgage has been assigned to Plaintiff herein by written assignment, a copy of
which is attached hereto as Exhibit II.
5. Plaintiff alleges each and every term, condition and covenant in the aforesaid
mortgage, and hereby incorporates them herein by reference thereto.
6. The aforesaid mortgage is in default in that monthly installments of principal and
interest have not been made in conformity with the terms of the mortgage, from November, 2011
and each month thereafter, up to and including the present time.
7. Under the terms of the aforesaid mortgage, upon default of payments set forth. in the
mortgage docurrlents, the entire principal balance and all interest due thereon are collectible
forthwith.
8. The following is an itemized statement of the amount due plaintiff under the terms of
the aforesaid mortgage:
Principal Balance $ 114,385.47
Interest from 10/1/2011 to 8/25/2012
at $19.59 per diem $ 6,443.98
Accrued Escrow deficit to 8/25/2012 $ 6,743.66
Attorney's Fee $ 1,650.00
Property Inspections $ 90.00
Suspense $ (879.04 )
Total $ 128,434.07
9. Plaintiff sent to defendant a Notice of Intention to Foreclose advising of rights
available under Act 6 of 1974 (Exhibit III).
_ _
WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged
premises in the amount of $128,434.07, plus per diem interest at $19.59 from August 26, 2012 to -
the date of judgment plus costs thereon.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P
BY:
Martha E. Von Rosenstiel, Esquire
Heather Riloff, Esquire
Attorneys for Plaintiff
EXHIBIT I
_ _ _
DESCRIPTION
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Fifth
Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a stake on the West side of Media Road, which stake is 120 feet South of
Hamilton Street; thence by the West side of Media Road, North 27degrees 40 minutes West 60 feet to a
stake; thence by lands of Reuben H. Tucker and wife, South 61 degrees 30 minutes West 120 feet to a
stake; thence by lands of Charles W. Anderson and wife, South 27 degrees 40 minutes East 60 feet to a
stake; thence by lands of Wm. L. Fordyce and wife, North 61 degrees 30 minutes East 120 feet to the
Place of BEGINNING.
HAVING thereon erected a 1 1/2 story frame dwelling house known as Number 58 Media Road.
BEING this same premises which Nyle D. Monismith and Anita C. Bowermaster, by deed dated
October 31, 2006 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at
Record Book 277,, Page 1744, granted and conveyed to Alan G. Davis and Kristi L. Davis, now known by
marriage as Kristi L. Knox, the Grantors herein. Michael Knox joins in this deed to convey any marital
interest he may have, by reason of marriage to Kristi L. Knox.
PARCEL IDENT~ICATION NO: 06-20-1800-068., CONTROL 06001329
EXHIBIT II
,,-r
PL+~S'Y.L~~A
PREPARID BY & WJ:iFTT R~ECORD~ REITJRN 'Pd:
ssTERVS, rNC.
24523 3W SIN WAY, #200
BEAVSRTON, OR 97005
ouNZr CUMBERL~IND
PARCEL NO. 06-20-.800-068
POOL NO.
LOAN No. (7224332 ) LLB01061
I~~~~~~~ A33IGNM8NT OF MORTGAGE
~a ALL MEN EY ,s PRESENTS, thatl~ EI,AX~'RQ1ffC S'S'A INC.
5~8LY AS ~r.~~~ FCXt ~ INC. I'!5 bRJCX~~GRS AID ASBI ,
located at
1902 S tRaat~ee~s ,St I Ste C, L~tt+3lle, 61834 LYt A.O. riot 2026, Phut, 14ff 48501-2026
hereinafter referred to as Assignor, for and in consideration of the sum of QNE DOLLAR ($1.00)
lawful rroney of the'United States of America together with other good and valuable consideration,
to it in hand paid by FEDERAL NATIONAL MORTGAGE ASSOCIATION
_ located at _ 14221 DOLrAS PA~1AY, S[A'!S I000 I]iiL~i.A3, TX 75254
hereinafter referred to as Assignee, at or before the delivery of these presents, the receipt of
which is hereby acknowledged, has granted, bargained, sold, assigned, transferred, conveyed and
set over unto said assignee, its successors and assigns, all of its right, title and interest in
and to that certain.. Mortgage dated the 3X'f~ day of JANUARY , 2008: made and
executed by ALAN G DAMS. MARRIED _ _
Mortgagor, to M~GAG4! S R1~.S~L't~T
52^316, 211'C AS Ia1~ PCR SC11II7dE'!' 1 ITS SDC A1~D ASSIQ~
Mortgagee, covering ,premises situated in the County CUMBERLAND CoRmonwealth
of Penn lvania, re particularly described therein and commonly known as:
BOROUGH ~ CARLISLE
PROPERTY ADD. 3S: 58 MEDIA R.D CARLISLE, PA 170.131544
Said Mortgage was duly recorded on the 7t12 day ofJANVARY 2008 in the office
of the Register, Clerk of Recorder of Deeds of C'UM$ERLA211D County, in Book
at Page or Docurnt No. 200800703 of the Official
Records of said Register, Clerk of Recorder of_ Deeds together with that certain Note of even date
and secured thereby in the principal amount of G11E I€11~ TA~1i'!Y Z~AdD and hD/100-----
, ( 12 0 , 0 0 0. 0 0 ) made and executed by
mortgagor and payakale to the order of the aforementioned Mortgagee.
As previously recorded from
to on
in Book at Page at Document No. and
from
CO On
in Book at Page at Document No. and
from
to on
in Book at Page at Document No.
(2~1RI.PA.PH) J= h8040110ai.s.$9452 Page 1 of 2
_
i.
Loan No. (7224392 ) (LB0106 J
'I'O HAVE AND TO HOLD the same unto said Assignee, its successors and assigns to its and their
proper use and benefit forever.
IN wITNBSS wHEx~oF, the Baia ~ ~TRQIII'C R8GI83RATICN .~3YSZ~15, ]NC'. 3'4?LELY
a~1S 1VQ~' I~ ~'t~1t13~"1' 2NC. 2'1"S 3UCC~SSLYRS AAD A332C,'11p3
has caused these presents to be duly executed by its proper officer this 2 9th day of
~TLTNL' 2 012
Mortgage Electz+eesic Registrat,ia~e Syst~+s, Inc.
BY
YSTAL LL
VICE PRESIDENT
STATE OF IDAHO COUNTY OF BONNEVILLE
on JUNE 19, _ 2 12 ,before me, VICRIE SORG ,personally
appeared KRYST HALL and
personally known to me for proved to me on the basis of satisfactory evidence) to be the persons
who execute the within instrument as VICE PRESIDENT and
on
behalf of ELtSL'.'TRCNfC REt~Ifii42ATTCN' u~ S1NC'. SOLE~,Y AS FCaR
S't~1?IR[~3T' 21110. ITS' SUC3C.ZS A~ A,4SI~s
and acknowledged to me that the Corporation executed it.
rf VlCKiE SCJF~G
yr xIE so (COMMassloN ExP. 08-18-1?) ~1~TARY PU8l.1G
Notary Public ~ STATE t~F IDAN+~
2 DO HEREBY CEIkTIFY THAT THE PRECSSB ADDRESS OF THE ASSIGNEE RESIDENCE IS:
FEDI?RAL_ NATIONAL _MOR7'GAGE ASSOCIATION _
_Z 4221 _DALLA~3 PARRWAY~_ St17TTs_ I D D D _ DALLA3 ~ _ TX _75254 _
ARY T ~ SETERUS, INC.
VICE PRBSIDE.x17`I' 14523 SW MILLIRAN WAY, #200
BEAVERTON, OR 97005
ATTN
P=S. 002. 0000# .1598 MIN 20001040207278?975 1?!~S PFiC><1tE: 1-888^-679-6377
(NhIl2I ,PA.2) C-s .375. 0021 J=Tb804 0110ai . s .89452 Page s of s
EXHIBIT III
s ete r ~ sTM Physical Address
14523 SW Millikan Way; Suite 200; Beaverton, OR 97005
Business Hours (Pacific Time)
Mon-Thu 5:OOam to 9:OOpm; Fri 5:OOam to 6:OOpm
Sat S:OOam to 9:OOam; Sun 5:OOam to 9:OOpm
Payments
PO Box 7162; Pasadena, CA 91109-7162
May 7, 2012
Corcespondence
CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL PO Box 2008; Grand Rapids, MI 49501-2008
Phone
L179A 866.570.5277
DAMS, ALAN G Fax
58 MEDIA RD 866.578.5277
CARLISLE, PA 17013-1544 Website
www.seterus.com
RE: Loan No.: 7224392
NOTICE IUF INTENTION TO FORECLOSE MORTG~IGE
Seterus, Inc. is the servicer of the above-referenced loan.
The MORTGAGE debt'held by Federal National Mortgage Association on your property located at:
58 MEDIA RD
CARLISLE, PA 17013-1544
IS IN SERIOUS DEFAIULT because:
You have not made regular mortgage payments for the months of November 2011, December 2011, January
2012, February 2012, 1Y~arch 2012, April 2012, May 2012 and the following amounts are now past due. Late
charges and other charges have also accrued to this date in the amount of $66.94.
Past Due Installments: Totals
Principal $1,017.58
Interest $4,154.51
Escrow Installment $4,766.33
$9,938.42
Other Open Charges:. Prior Servicer Charges Seterus. Inc. Charges
Late Charges 36.94 0.00 36.94
Property Inspections 0.00 30.00 30.00
(Continued)
THIS COMMUNICATION IS FROM AI DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAIN1iD WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS FETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN
AGAINST THE COLLATERAL PROP RTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW.C ATTO V/ Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW ORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of
the Depaztment of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR.
_ _ _ _
DAVIS, ALAN G
Loan No.: 7224392
Page 2
May 7, 2012
$66.94
Less Suspense (Balance) $915.98
TOTAL AMOUNT PAiST DUE $9,089.38
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 $9,089.38.
You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount
of $9,089.38, plus any aFlditional monthly payments and late charge which may fall due during this period.
Such payment must be made either by cash, cashier's check, certified check or money order and made at:
Seterus, Inc.
PO Box 7162
Pasadena, CA 91109-7162
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 original amount borrowed will be considered
due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our
attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your
mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our
attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay
the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started
against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's
fees will be added to whatever you owe us, which may also include our reasonable costs. If
you. cure the
default within the thirty day period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still
have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's
foreclosure sale. You rhay do so by paying the total amount of the unpaid monthly payments plus any late or
other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale
and perform any other requirements under the mortgage. It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately eight (8) months. A notice of the date of the Sherriff sale
will be sent to you before the sale. Of course, the amount needed to cure the default will increa$e the longer
you wait. You may find out at any time exactly what the required payment will be by calling us at the
following number: 866:570.5277. The payment must be made in cash, cashier's check, certified check or
money order and made: payable to us at the address stated above.
(Continued)
THIS COMMUNICATION IS FROM Ai DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEM'PTDVG TO COLLECT A DEBT
AND ANY INFORMATION OBTAINI~D WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS INTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN
AGAINST THE COLLATERAL PROP)rRTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW COLORADOATTOR_NFYGEN~7R_Ai GOV/CA Seterus, Inc. maintains a local office at 355 Union Boulevazd, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW l~'ORK CITY: 1331537, 1340bb3, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of
the Deparunent of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR.
_
DAMS; ALAN G
Loan No.: 7224342
Page 3
May 7, 2012
You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs Sale, a lawsuit could be started to evict
you.
You have additional rigl}t to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL
THE PROPERTY TO OIBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW
MONEY FROM ANOT~1iERLENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE
THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE
OUTSTANDING PAYIwrIENTS, CHARGES, AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR
TO, OR AT THE SALE, AND THAT THE OTHER REQUIRMENTS UNDER THE MORTGAGE ARE
SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT
EXIST. YOU HAVE TIE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING
ON YOUR BEHALF.
If
you cure the default, tine mortgage will be restored to the same position as if no default had occurred.
However, you are not el~titled to this right to cure your default more than three times in any calendar year.
Sincerely,
Seterus, Inc.
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAINI#.D WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS IETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE EIvTF'ORCEMENT OF OUR LIEN
AGAINST THE COLLATERAL PROPERTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW.C V A Seterus, Inc. maintains a local office at 355 Union Boulevazd, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW ORK CITY: 1331537, 1340663, 1340]48. TENNESSEE: This collection agency is licensed by the Collection Service Board of
the Department of Commerce and Insurtlnce. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR.
_ _ _ _ _
14523 SW Millikan Way; Suite 200; Beaverton, OR 97005
~s ete r ~ srM Physical Address
Business Hours (Pacific Time)
Mon-Thu 5:OOam to 9:OOpm; Fri 5:OOam to 6:OOpm
Sat 5:OOam to 9:OOam; Sun 5:OOam to 9:OOpm
Payments
PO Box 7162; Pasadena, CA 91109-7162
May 7, 2012
Correspondence
PO Box 2008; Grand Rapids, MI 49501-2008
CERTIFIED RETURN RECEIPT AND REGULAR FIRST CLASS MAIL
Phone
L179A 866.570.5277
DAMS, ALAN G Fax
1966 SPRING RD 866.578.5277
CARLISLE, PA 17013 Website
www.seterus.com
RE: Loan No.: 7224392
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Seterus, Inc. is the servicer of the above-referenced loan.
The MORTGAGE debt'held by Federal National Mortgage Association on your property located at:
58 MEDIA RD
CARLISLE, PA 17013-1544
IS IN SERIOUS DEFAULT because:
You have not made reglular mortgage payments for the months of November 2011, December 2011, January
2012, February 2012, March 2012, April 2012, May 2012 and the following amounts are now past due. Late
charges and other charges have also accrued to this date in the amount of $66.94.
Past Due Installments: Totals
Principal $1,017.58
Interest $4,154.51
Escrow Installment $4,766.33
$9,938.42
Other Open Charges: Prior Servicer Charges Seterus. Inc. Charges
Late Charges 36.94 0.00 36.94
Property Inspections 0.00 30.00 30.00
(Continued)
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTIIJG TO COLLECT A DEBT
AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS IETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR L[EN
AGAINST THE COLLATERAL PROP~RTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW.C L ATT Y V/C Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW ORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of
the Department of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR.
DAVIS; ALAN G
'Loan No.: 7224392
Page 2
May 7, 2012
$66.94
Less Suspense (Balance) $915.98
TOTAL AMOUNT PAST DUE $9,089.38
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 $9,()89.38.
You may cure this defauidt within THIRTY (30) DAYS of the date of this letter by paying to us the above amount
of $9,089.38, plus any additional monthly payments and late charge which may fall due during this period.
Such payment must be made either by cash, cashier's check, certified check or money order and made at:
Seterus, Inc.
PO Box 7162
Pasadena, CA 91109-7162
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered
due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full
payment of the amount pf default is not made within THIRTY (30) DAYS, we also intend to instruct our
attorneys to start a law$uit to foreclose your mortgaged property. If the mortgage is foreclosed your
mortgaged property wirl be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our
attorneys, but you cure lthe default before they begin legal proceedings against you, you will still have to pay
the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started
against you, you will hive to pay the reasonable attorney's fees even 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 and all other sums due under the mortgage.
If you have not cured tlae default within the thirty day period and foreclosure proceedings have begun, you still
have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's
foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or
other charges then due; as well as the reasonable attorney's fees and costs connected with the foreclosure sale
and perform any other requirements under the mortgage. It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately eight (8) months. A notice of the date of the Sherriff sale
will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer
you wait. You may finial out at any time exactly what the required payment will be by calling us at the
following number: 866,570.5277. The payment must be made in cash, cashier's check, certified check or
money order and made'' payable to us at the address stated above.
(Continued)
THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAIN>~b WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS Iy)rTTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN
AGAINST THE COLLATERAL PROP RTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW COLORADOATTORNEYGE ~AL.GOV/CA. Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW IpRK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of
the Department of Commerce and Insurance. Seterus, Inc. is licensed to do business at 14523 SW Millikan Way, Beaverton, OR.
DAMS, ALAN G
Loan No.: 7224392
Page 3
May 7, 2012
You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs Sale, 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 QBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW
MONEY FROM ANOT1kIER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE
THE RIGHT TO SELL pR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WIND WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE
OUTSTANDING PAYIY~IENTS, CHARGES, AND ATTORNEY' S FEES AND COSTS ARE PAID PRIOR
TO, OR AT THE SALE, AND THAT THE OTHER REQUIRMENTS UNDER THE MORTGt~GE ARE
SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT
EXIST. YOU HAVE T~-IE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING
ON YOUR BEHALF.
If
you cure the default, the mortgage will be restored to the same position as if no default had occurred.
However, you are not eriltitled to this right to cure your default more than three times in any calemdar year.
Sincerely,
Seterus, Inc.
THIS COMMUNICATION IS FROM A,, DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAINI~D WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR 1tECEIVED A BANKRUPTCY
DISCHARGE OF THIS DEBT, THIS FETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT, BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN
AGAINST THE COLLATERAL PROP$RTY. COLORADO: FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE
WWW ATT Y V CA. Seterus, Inc. maintains a local office at 355 Union Boulevard, Suite 302, Lakewood, CO 80228. The office's
phone number is 888.738.5576. NEW ,TURK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board o1
the Department of Commerce and Insura~tf¢e. Seterus, Inc. is licensed to do business at 14523 S W Millikan Way, Beaverton, OR.
~Q~Z~
VERIFICATION
RebeGCa Groves hereby states that he/she is the
Fours S~jedalist 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 INational Mortgage Association and verifies that the statements made in the
foregoing Complaint in Federal National Mortgage Association v. Alan G. Davis relating to the
property located at ~8 Media Road, Carlisle, PA 17013 are true and correct to the best of his/her
information and belii~f. The undersigned understands that the statements therein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
8-~l:a~
BY:
Title: ~ 5peciallst
Seterus, Inc.
as servicer for Federal National Mortgage
Association
Dated: 9_(0.. / 2
_ _
=rom 'V"J? '_aw To 1-717-24~-6573 page: 1/3 ^a'.e: Q/"3/2~~2 1".3c:35 A1%'
fORW! i
FEDERAL NA'I-TONAL MUR1'GAGE iN THF, C'Ca~F'.T OF' t,O~1MON PLEAS OF
ASSOCIATION CLIIvIBEP:L,AND C'OI!N T~t>
39()0 Wisconsin ,^>_~enue, i'v~V I'ENNSYL`V,1I~iIA
1~'ashington, DC 2(?01Ci-292
Plaintil~f~
ALAN G. DAMS ~ ~ r~
1966 Spring Road
Garlisie, PA 170I:3 ~
llefendant c,~r- b ~,r•.--
-K.2m. r- t^-;
NOTICE OF RESIDENTfAt MORTGAGE FCIREGLOSURE rd
l+~ la.
t)IVERSJON PROGRAM c~
~ ~i
Ypc! h v! >_tt crl w .3 . ;rtcelpsir. e i:va';i;iateE ;hat caus^ yci, p~- yct~r h,orr;re. "1 r~ T r
1f you owr .,rti: ?,v:~ ;n tht. rieSid'cnti47! , +'p;~+~ ',y in,hice, i~; t1;4 u~iect ~f !pis `orecfo>uri•• dC:iUfl. 'i(7U r,}a; !7e ,atilt ts~
;;arm+ratt~ in a cotr'r ;i:per,+ied ~cnc~!'sation cvnfere.r,r~_ in air ~ffert try rcrsofve this rn;tt~~r.rit'^ y:u; 'r:nc:•r.
i# you do ntst have a lawyer you must take the #otiowing sups to be eiigib{e #esr a
conciliation can#erence. Firs'. within twenty (d71 :day; rf your rt:<: iui of thif notice, ypu cnusi contact M1;'iuFen;t L:~gai
Se"v,c<::; at t7 ],?'t74-odr^3:a~lr-r>.;io:^: 251J nr iSUQf $22-~~sS r"XtBtYiiD%: >'7;O ,ar,ri r~.^;t:e>t ~,cnNai:}irnetn* 0? a ;[.,~*,3~ rc:~~r~~>~rt+ai~.'r~,
<.t tp ru. }.e ~-^er ~pi,~-,.t...c a I_~ , .t, a :~;,t f. ~ ~ r<~_._, _ i
rE_i;r2°t,~,ta+,.. .:irhin iVJCI.y {cv clay>ns tltB a(sp.~;~tmc:l, ,t±.:e. ~:.r'r.~ :j;,~r me^tiry, You mus*, p:o~<<b';~ t ?e~a4
tt_prCentati+re w•!.tn ~,i c-equesicd Pir.anciai iniorrnattCS? So ;hat < to<an tBS6iiltipt; prcnil~al C3.• SJe i;repared pn r~u; reha;if. if
vpu and four I+',~3i repr25e!tt~3tive compkete a fi^ancia! +:~OCI!ST?°4*i in ih(: f¢rlT~at 81i.~C112d h:ret J; the legal R^jIrE S~n`Yi'v C~ Will
arepar~ ar;d £;le a R+~a,aest tUr Oi1Clii~tiOR Cor.ferc-nce rlt.h the Court, which must be lied 41'itit tl1E' %ptl(t Withi ; ~iY.ty iiJ; Ja{s
of th~+ ser.i~e up,;. `pu of fire `oredps~rr+_ Cvrtlplaint. ii= •:eu do so artd a tvr:cii;ation tvrferen._e is r::hc>au~e:i, ou .~-1i hav_ ,in
oppurtui~ity to meet w+th a represzntac=ue. r=f year !errtier r,} ern :;t`emgt tc vrork a+~t r€~sor,aal~ arrangerr.ert'i with ,c.:r le:ide;
before trt ;rep: [gage forec:ase:re >;ili ,^.,;U L'^U3 d'- fUr"A: i3rCl.
l# you are a'epresented by a lawyer, you and your lawyer must take the #ollowing steps to
ire etigib{e for a conciliation conference. {t is nat necessary for you to c:pnt:-ct U1idP+sr}n i+_:a; 5^rrice for the
af:l;pi!atn~;:tt of a !egai r presentati<<e. Hpwe`~er, ya:: must pi ovi+ie year lawyer •.vith a{i r+=G~cSted fir}art<ia! ie~forrra±ip!} sn ihat
!can r~'SOutipn i]GpOSdi can be l,reearr:d 3^ yo::r faeh~sEf. If ou and ypu< 9a.:.~yer cornpic-te 8 f)!ial7Clal ~,~otks'i~:t in t1}iq for;-,.ir.
attart:ed i}t•r~°[0, \{Q::t. id~':j%Gr ~v?i. pr°pae arrc3 fil;: a f?e~uest for pr}ciliatiott Cvn.ferrnc,> •:sith the Court, ~a~hic.h must bt fil~cJ
,,,.ih ;ha, rnurt writfiir, >irtY ;FOi tfa+;> cF ii]l ser~;k:;~ u~ nn you of *;he trr.~clost:re corr:pi~iirat, .f you i;c sp na a c.:~:e_iii,}t!on
cprfarerece is ichedi,led, Yv;! +vil! h,rve. ar. cp~crtu:e±t, tp mFet .pith ~ rt'Jfl'S~'I}t3tiVE' 4f }Oi„ .:•;t:fnf ir.:an attempt ira ta•crk put
F~350[lau!? .3(i '},~,lJ4^C:?tt5 :Viii}'}`L i'iitl2r 17nfn{.• t"....,..'rt ;,e fnr=C.i?St:rc ii: it UiO~::::d5 fU rsVE?":~~~.
1F YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUlCKtY AIVDf'TAKE THE
STEPS REQUIRED BY THiS NOTICE, THIS PROGRAM 1S FREE.
Res~~c:tfuiiy submitted: t
i
Sentetnber l3 2(712 ~
I~~tte Sig?iatt.tre of Cautzsel for Plaintiff
_ _ . _ ~ _ _ _ --r
_ r>*? _ ,
=rom ~L" '_aw To: ^ -717-243-6573 °age: 2/3 ^2'e: Q/^ 3124^ 2 ' ^ .3:35 A`V'
FU}2M 2
Cumberland County Residential Mortg+agre Forecla?s~~re Diveasion Program
fifnancial Worksheet
rte
Cilrrhoriand Ca:l;li~ CCUr[ of Ci;mm;^ Fteas uocket `
kSDR;204rlE~ Rc~~E=~' rOa r•A'r'.Jsi-!f!~ i~`s~{~.~+~CE
Te cofr..pietE'{Oi)I' t'f;r[~?St 1f?r !laf:ii!li~] e55t5t~i{1C£'., ~r?Ur IL','ielri tT',i,~s~ C: i.1f75i(,?c'1- YCUUr rlrrUtfi~t::l7CE:~ iJ ~er'cfrl':ii-ie
~'OSSlhie C'p!'~UrL wli:'E W4i'k~fl~ va;[h yOU:
PICdSC ~?r'L;vid? :Y?e fQf30W~?flg tRfOrrt'td't0+? 2t! t'?P. (?P_5[ O? Youf kn.wiecige:
+r ~
Horrcuvef name {s;
Ci.y: Sta*,e: Zic:
IS Ltle ~.}i ppeC?~ !cr 1.3 r'_ , cs ~ .JU ~ . ~ ,.13#~: ~
Rea!t~x "vamr-~: Real+or ili)ote:
flC_+rft)wi'.r Q^E~tl[;!s?t;i: ~'E:5 ~ 'jtl
^d1~3iilf?~!1[~~rc'~S (!S Ali er~r?[J
si;,
~hOne !~!.i rYi k}er'S: i-'<~Te:.__...._..-._.__......__.__.__..__.___-_._.. ~ k...-..--"-~----~------------_.___.----_.-..-----.._......
.
CeN' vtP r-r
a± of people In hcu;Whedd; Now !cng? _
r
fv'I a i l i n g Address ; - -
r~„. ' SF8C2:.------- lip.
, ,
Prioite !cur??hers: none.: uffrce:
Coil- v ;:P'.
of ~3eo~:de In t;ousei?c!~: Ho4v long?
• r
;`irsi Mor±gage !ender:
Type ~ ! ! Darr:
i_L'a!i Il~rtl~;?tier: L~d[e'You ~iQSe'~ ~Oiif `t0%3 n:
_ .
"~r of ~ ovrl:
. y
T.)Y3~ is%IJ~LAdg° P~V!?1c?r?YS.~rT"i`U^.[: S _ ~:^1141fjP_L{Taxes 373i~ Ir1S:lr8i)t:2:
L'aie a _a[ ~ayir?._ t'
prir?1]iy R°dSUR':'Jr ~eidU![:
*i;e'- 3~rrkl tipf~y~ 'r~s ~ f~lo Q ye~, n:o`.^ri2 rarn~s.. !L;r2s,ier, roof , r~5e :'t'Yi?^er' x n-_,. "nr_=
Y
From. 'V'V'~ '_aw To: 1-717-24.~-5573 Page 318 ^a'.e: g/" 3l2^^ 2 ' f
;1~sets ,!rt~uJni C~°eti: i~~t~le.
Ho+^:e: Y
P?NttrPm~l?1: ~Jft~~.: ~ J
!f?vesttVl2niS: ~
58vin$s; 1
;v ~!i14:
Jtrl B' trd~?;tw t~Ct3 t!O{; .It E: TI:}t)!IE'S, hJ3t5 t7i0i~3'C aC'_~';: ~ti'•^it 9!:
~T~83r; iS:T;QU1?~ p;V 2C;' VHitJc:
tvlonthtu fnrome
..,.TiE L'. t;~~.~yv5.
't~rrtia}. ~r; '':?orithly .'`Jrt
~~?crrthiy Gn;.<.<. tL?!,rtn;r ^ret
.ir,i:u.. .
i, Otii„ y
1'Y~ ;•Y
2. ^al)rtit?ly Ari'.OU'?t'
Borrot:•rer ?<3'# Uays:.- l__-- Co f3orrovver Pay Days: -J„_-.___
r'Ltortthiv ExReerses: Plea.sr~ Ut7iy i!lCI4lCj° P_X;J°Sl~t?i y0U ;JiE' CUrteCli~'i L~dYs?l?i
;~PE'slSc ~~.'?D;.iP~i'r ~xPE?V5~ A.>,!rJ,.P:7
rtg2„~ F .,C>~....
' 2 1~orro-,,~ of ie5
C.ir ~~'R`r'~YtrS, tiJ ~c10,r'V~ Art t'P_e5
~_li.) tt?iU~d tlC° ~ i~'~E, S~. C.1,j _tJ'lEf ii~
A!ItJ fu°!. •_~,aits fiChet P~,Jt. ~ay!7?;?nt
'ns att Pa rf e~i C~kt e TV _
' Cu'tl S~poort/A'PJn, 5' _.r3i!~g Mn,~_ey
J.3,Jr~r,i~'t C~r21T~r,. Cthr'k.!Jr_r,,es.-
r:otrr,C A.vaiizJrttts f;~r'vi~r.eh;y ~dlortgas~e Pay(n.~z{?rs Basa.(3 nrt ir}cl;rse a!~cl ~xK>er;ez:
H;'a`~'N yGt; L:~.°!' `^iDi ~f:".5 ~frl'ttl f''ii!JS~rl~ (.QUIi~ZiiR ~ ii~'„~,'cn~?j~
rl~ ?
if yp5, D{i_'ii J"~ ~+CC~''i%1~ t;7@`:?~; rJ trl; iSl~ irtFCrr*:tdt!C?il:
C :7U;?S~iQr:
~ _
prom: MVO i_aw To: 1-717-2~0-6573 °age. ~/E~ ~a.e: p/. 3/20^2 ':30:?~ A~/" x
~aVe yJU i~a[IE' c3 C7Gi:CatiQrl ~C?' ?~Cr''ie::'vtt?F?r~ ti712rf~"c1?CV iJt7ft~i;y~ F~SS{~Y311C" f
3"O~TYdt'~l
~f'I~~~A~i i'sS`1Stc?i+iE7.~
Yes ~ Pdo
if yes, please Indicate the status of t;'e aapl~catior::
t'i~ve yUU ~??d any prior ne~otiatrons .?th YGUr !endec or ier:cer's Iran servic.irfg cumf;r3r1`f %0 r(?~nSV~ }JC)tlr
Ue'~4'IGlienCy?
Y~ei3ie E;fr7'JICe tr'i2 fG!i0'ffli?~ Infort*18t!Gn, !f itn~J'v4', rk:~:af'~.~il*i6 ~UUi ti?"i:Er G+( ie(1^°r~ti if>;}f%
L.^c rlder~S ~OntdCC +rv cam. liiy}: ~ IiOnC':
~;~,uIcing (.OmJa;;Y ~l~lame}: _ -
LJnt:~L't; Pine:
f~.~J$, _ , authorize the abo:ie
r `
_ tee;:~e,c~ t„is +n orr,~atnr. to rr;~/ keruJt~~~ervir.F~!" t~~r `i,e so'e
pu;pQSe cf ~val:~„ting my finantal sit~,iatian fc~r possible n~c~rtpage o~:.ti<,~~s_ /wN
understand :hat I'we amJare under np c~k>€igat;on to use tine serves prov'scie~ bpi tine above
named _
8or•ro~.~~rr Signatu*e Date
BorrnwPr Si~naiu~re Daie
Please forward this document along with the following information to dander and
lender counse}:
~ Proof an income
V Rast 2 Dank statements
U Proof of any expected income for the last d5 days
d Copy of a current utility yili
Letter explaining reason for deNnquency and any supporting documentation
d (hardship letter)
Listing agreement (if property is currently on the market)
V Copy ofi 2 years of federal income tax returns
Copy ofi deed
=rom: N'V~'_aw To: 1-717-c4^-6573 ?age 5/? ~o: a ~ r n P
_ _ .,a.., _ / 3 2„"2 .30:3 Ali n
FORM 3
FEDERAL I'4~:TICNAL I~IGRTCAGI: 1N TFIE. CE~~JkT (3F CC)~lMOIVT PLE:?,.S ()F
ASSC)CIATIC3N CUPv1BEl2L,AND CQUNTY,
391)0 Wiscc~l~sin Ave~llie, NW PENNSYL'JANIA
W~shir~gtan, DC 2001fi-2802
Plaintit'P
v5- NO.
ALAN G. DAMS
l9hh Spring Rnad
Carlisle, F'A l7()l
Del-endarit
REQUEST fOR C~NClt1ATiON CDNFEREN~E
Purs;Fant a tf;p !-~~r,}inisirati;~= ~,;rdF?r ctate=~ ?O:1Z ;ov:_rnir}, t.
CotF;?'4 ~esiC{Ci?tiai r>r~01"(n3f~c fUreClClSttra D7V°rjiCtr? P{'O~rarT?, it?~ llrClt?rSi~rlf'd l1~!'efjy Cr-::i t!fi?3S ~?i
follows:
i. pefe'ld8rt !C Lhe OYJr?~'r Of Cj}° F~F?e:l Qr0/ic.rt`/ ;N^lt~li i4 in£? SI.F~.l;F?C' (:f Li?IS ?"rOrtsrfgP.
?~4r~F'_Ci4sUSP 2eCit4ri~
2. Deferdar}t !ices it the subiect real crupert~r: vrt}ich is ~efe,,dant s prir}~r3ry
3. ~efer,clr.rt I?as been i~i'VE.'G~ wish a `~~~:DL<C° O` RC'sICIL'rtlcll ('v9UrYt;;r7~'G GOFE.'CSOSi;Ce [f!!',~,f~>IOR
Program: arc has taker a31 of the str_{~} regtti,~d in that Notico t4 02 eligible C4 partici,;ate it} a
coifs*.,su~er'i~;;=c; C4r?ciii:3Li4n CIInferenca.
TFl@ UEIC~ef'ii~r?f C'~ bE?rille5 tf?aC Che ~LaC2tfi;f':}ts l?}:lut P':erf?fl? dre trU~ 3?}~ CC?rreCt, i u!lderst~rd that
:Lc't~fT}ef?LS 3r_. !}'.nt~~ GU~;F?CL LC rt,f~ ~F.'r21~!(=5 1$ ~:3. ~~:,~te= re`lifr~ t4 Uf?~;•~urn t;?Is'ftCcltir'~i} rQ
:~i;11:~
tc;F'lttE.'S.
Sif~rati:re of i)plendant's CotfrselJA.p~onta~ Crate
i.t ~~l Repr"as?rtat;'~fe
:31~t},-~.CUr~ O{ ~~{~rf. C4~f?t C7ate
~'!~r2Ctir? O` ~f3frnrj3f?t Qc?t@
~rom~ ~`VI'JR Law To: ^-717-240-6573 image: 5/3 ^a'e: 0l^3~2^'2 ~1~P
FORM! 4
FEDERAL NATIC3NAL MOR'TGAUL- IN T1iE COURT OE COMMON PLE:~S OF
ASSOCIATION CL~IBERL.AND COUNTY,
31011 VViscQnsin .`avenge, NW PENNSYL`dAN1A
Washingtc>t~, DC ?k~015-2892
Plaintiff
~•ti. NO.
ALAN' G. DAMS
1 x)66 Sprin;~ Road
C_'zirli.~le, PA 17()1
Defcndans
CASE fvthiU,~uFll^EPJT OkCcR
H~~~~ i`JQ:`v'; `Lk115 f;aV Ot t17,ii•Te CIeF£:nt:cntJD0l~rOtNL'f
the aba~le-capt'soned res~Cenudl rTTOrtgag° ft?rEiaSL're^~. att7Cill ~"!C3VlfTg tiiCCi n fi2C;.1c5t fCir
c~r.c"iia,Eon onf,. ence ve ifying that t},e aefer?cfan./fj~rr",ver rTas ca.ii;..lied Yvith the
Admi.r:.ist:°ativ~ Ruke requirements far the schec~ul=ng ~~f a Carcil+at~or? Car:`erencc, it is here'}y
CtRCEFEC APJC CECREEC that:
TFT2 jloft.ES ant{ trTe!r caunse; are Lld!ECtE'd to p~irk.iCi~rite iR 3 COi:rt-se.lparvised
conciiiat;or, ~:..onTt>ren~E~ ar7 .at ~.4. a
i_ at the Cumberland County Court^ouse, Carlis;e, PEnnSjtlVar)1c3"
2. At least t~ae:•r.ty orTe ?21~ days prig to tF° ddtP. of thF CC7n~i~iatlan CEnTary;;,cE, tha
d2fendarTt; bafrcwer ;rust 5E'.rVe L'{JOn tiTL ?idintlif/i~.r3dE'f ~lTd its CJUnS)a cccy of Ck'e
~riit;?~T~rtc3nd CC~_l~iij~ Rf?S~CfE<n`ial f4"^:ri~?~[~ `Or!'Ci[i.~.Uf" j:ivi',fsiG7l r~r~;~in'.•'1^ -;1Tc1'•i'<3~
~~'Ofi<ifTeei ~ t~arrY] r f t:itlia;~i }?<3S rJcPri COm.pic'tc?d b?:' t}T° de~endan~%[)C,ffO°Y\?i. I;~OR
a>ee~nert s]f ,ii2 parties sn •Uvr~kiRJ if tyre ~:Cratla?T of tic' C.aU'`t, ttin rUT?Cllii'~tien
Co^fefence cfd~.fed fnay be rescheduled to ? +"ter date and!af the date upan E~;hich
:>er`vic~: of t;;r? ccmplet~'d =,-;rm ? is tc 6e rr,ade ,nay b~ ?xt~;}ded. :_~pcn notice 'to the
_ . r,,, _ _ _ _ _ ~T _ _ _
ii
prom MVR Law To: "-717-240-6573 Page: 7/8 ~a`.e: 0/13/2^'2'":30:37 A'V' ,
C;,art of tha uefendant/borrower's fai!u°re t4 SE?r`~'s° the completed corm 2 ~~ith `roe
tir??e frame set forth herein cr s~sch of«er d,3te as agreed upor~ icy the p~?rt+es ir. ~r~r±ir~~
yr ordered by the Court, the case sha'si be removed tram the Conciliation Corafererace
schedulA and tt'?@ ti'mporafy sia~~ of pC0(:eE'di(1~5 5(l~sli Ue tE?,-t?~ir?ated.
3, T(te C,iE'fP^.>~<lrli~fJLSrrcu~~er ~}rlt~ Ct)kiriSF?1 `~?f t}?e Nui ttE'S rT1U5T, dtt£~rlt~ tr1C COriC1;1r~7tiC!i
lv~r?terer?ce in p~rSQR and an r'lt,rthQri~E'.d rf'.pre5etlt~iiVe Df T.!~e pi:~intitf/fender t"?USt
etti'ipr ctiend ti`? COfli({lat,(}I+ ~.`Ji:f£'1k'^Le in p2(SDri ar Le oval€ai~le ay telep~?are
tlurin~ ire course of the Conciliation `or.ferenr_e, The representative of the
~laintii.'"izrader `s~ho participates in tyre t;cznciiiatior, Conference must possess the
c:t .i a>.rthority to reach o mutually acce~rta'vie r~501L:iiLirli and counse! far thy:.
'1'JEt~tiFf/lender must discuss reiCilUifOn ~r0}?OScll~ 4"-:Iti'1 tt?E' 7Uiilor'IZG=CI i~C-'.'%reSE'(?~dtlti~
3Ci'vanCe of ;.he CO^,Ctli3tlGn Ccnferenr_e, if tC•P rltily ~?Ut? ('i,.=?~ •'.j~rP~%""'t_ttiJC' O
;e plaintiff/'sender is r?ct avaiiab6e by tefepf;one durirag the Conciliation Conference,
Ct:ifr't ,.;;ill S(ti>rdUl2 another Car:cilint+on ~~Onf~"er!Ce QnG reCjiJtr~ tfl@ personal
attendar-_e G1 the authorized representative of t'~e plaintiff,/lenrlt.>r ai the r t>cne~.u!ec!
Cor,ciliatior. Conference
4. at the Conciliation Conference, the aarties and their counsel shall he preparecJ to
discuss anti explore ai+ 2vaifabte res<.iution aoti;,ns ~us^ich shall include: ;cringing the
mortgage cr.,rrent t??rat;gh a rE?instater?ert; pa+/ing oft tho morrgaGe; prapostng a
fnraeara!~ee agreen?er,t ar repayr??ent plan to thing the nceo!~nt current aver time;
~r2.cti'sE t(>' tCt;fier i3 rrlLiriE'tary ~?d`yCT"lent ciriC~i t{} vciCr3t>r irl ti1P tle'rr f4it:frE' in £'X{:?";wi?~~
Tor not rontPSting the matter; offering the lender a deed in lieu of foreclosure;
r.. ._.rnr_... a..,- _ _
From MVR Law To: 1-717-240-6573 °age: 8/3 ~a`.e: a/'3/2^^2 "":3c:37 A1r
. .
entering into :a Iran mgtliFica~inn or a reverse mcrtga~;e; paying the rn~rtg~ge derauf.
QVE'r SIXt}r iilC?`lthS~ sxr'ta iEi!? if1SLl?:l.'L!O(7 Cf tJ~-"lf<r'tI~LC~ ~frJ.feE'r~tr}~$.
~fi pr~cee~'ings ir1 this :'natter 3;e stayer! per;~'ir,g the corn-t;iecien of the ;h=wdul+~d
co{ ~ciliati;Jn ccnferzr~ce,
8Y THE LU`tJRT;
- i J
~30525CFJ-DN
IN THE COL.~RT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FEDF,RAL NATIONAL MORTGAGE
ASSOCIATION
Plaintiff _ - '
V. NO. 12-5676 Civil "hern~ ~ '~
..._.
ALAN G. DAMS ~ - ~ ~ ~~ ~~
~..
Defendant(s)
PRAECIPE FOR DEFAULT JUDGMENT
To the Prothonotary:
(XX) Enter judgment in favor of Plaintiff and against: Alan G. Davis for want of an
answer.
(X) Assess Damages as Follows
Debt
Interest from 8/26/12 to 10/23/2012
At $19.59 per diem
Total
'~ 128,434.07
S 1,155.81
~~;~ 129,589.88
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this
Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his
attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing
of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
BY n `_, ~
Martha E. Von Rose st~~l, Esquire
Heather Riloff, Esquire .w ,
Attorneys for Plaintiff
This ~~day of ~~~-~v~~ , :?012 judgment is entered in favor of the Plaintiff and against
Defendant(s). Alan G. Davis by default for want of an answer and damages as sed at the sum of
$ 129,589.88 as per the above certification.
~.~,~ a~
Prot onotary, Cumberland County ~,~J.~
~ ~8 ~~
~~ ~~ ~
AR~I"HA E. ~'ON ROSENSTIEL, P.C.
Martha E. Van Rosenstiel, Esquire ! No. 52534
Heather RiI<~fl, Esquire ,' Na, 309905
649 Sauth Avenue, Suite 7
Secane, PA 190 ( 8
(610) 328-2887
Atxoa-na~is for Plainti I.1•
FEDERAL I~i~~TIONAL MORTGAGE ASSOCIATION
3900 Wisconsin Avenue, N W'
Vb'ashington, DC 20016-2892
Plaintiff
AI1.AN ~,. DAMS
1966 Spring Road
Carlisle, PA i 701
v.
Defendant
!'C):
,~lar~ G. Davis
16 Lang Gap Rd
Carlisle, PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Case No: i2-5676 Civil Team
IMPORTANT NOTICE.
YOU ARE IN DEFAULT BECAUSE YOU NAVE FAILED TO ENTER A WRIT"T"EN APPEARANCE PERSONALLY OR BY
ATTURNE~" AND FILE IN WR['TING WITH THFs COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST ~'OU. t1NLESS YOU ACT WITHIN TEN DAYS FROM THIS DA'I"E OF THIS NOTICE;. A .IUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARMG AND YOU MAY LOSE YOt1R PROPERTY OR OTI-TER
IMPORTANT RIGHTS.
YOU SHOULD TAKE'THIS 1*IOTICE TO A LAWYER A'T ONCE. IF YOU DO NOT HAVE A 1..AWYER, GO TO OR
TELEPHONE "T'HE OFFICE SET FOR'T'H BELDW. THIS OFPTCE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
[F YOU CANNOT AFFORD TO 1-IIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE ~'OU W[TH INFORMATI0~1
ABOUT AGENCII-:S TFdAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCl D FEE OR NO FEE.
CUMBERLAND COUN7•Y BAR ASSUCIA"['ION
2 LIBERTY AVENUE,
CARLISLE, PA 17013
7I7-249-3I66
800-990-9108
Respectfully Submitteds
MARTHA E. VON ROSENSTIEL, 1'_~~
£~ ,~
IvLartha E. Von Rosenst~~l, Es~uire
Heather Riloff, Esquire ~°•
Attorneys for Plaintiff
Dated: Octc~6er 9, ~ti12
~'~IARTHA ~. 'FtON }?GSL:NS"I'TEL, P.C.
'vlairtha E. Von Roser~sliel_ Esquire; No. 52634
Heather Riiofl~, Esquire f No. 309906
b49 South Aven~~e_ Suite
Secane, PA 14018
(610} 328-288
~tfornevs for T'Tainti+i
FEDERAL'~ATIONAL MORTGAGE ASSOCIATION
3904 Wisconsin Avenue, NW
Washin~tot~_ DC 20016-2892
Plaintiff
ALAN G. 17AV1S
1966 Springy Road
Carlisle, PA 17013
s.
Defendant
T-O:
Alan G. Davi;
~$ Media Road
Carlisle, PA 17013
COURT OF C0~10N PLEAS
CUMBER_I,AND COUNTY
Case No: 72-676 Civil Term
IMPORTANT NOTICE
E.~c-,~ TD - BI
YOU AR;_. 1N L~EFAUI: i' BECAUSE YOU HAVE FAILED TO ENTER A WR["1TEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE TN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE (:LATHS SET
FORTH AGACNST YOU. UNLESS YOU' ACT WITHIN TEN DAYS FROM THE DATE OF THIS NO'T`ICE, A ItIDGMENT
MAYBE ENTERED AGAINS"i' YOU WITHOUT A HEARFNG AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGH'T'S.
YOU 5HOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. If' YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE: THE OFFICE ShT FORTH BELOW. THIS OFFICE C'AN PROVIDE YOU WITH INFORMATION ABOU~T~
HIRING A LAWYER.
Ila YOU CANNOT AFFORI? TO HIRE A LAWYER, "FHIS OFFICE MAY I3I; ABLE TO PROVIDE YOU 'VdITH INFORMA"PION
ASOU'T' AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A"I' A REDUCE.; k'I3I OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 1701
iT7-249-3166
844-994-9108
Respectfully Submitted,
MARTHA E. VON ROSENST'lia._ P.i~:.
- -~
Martha E. Von Rosenstii, ~qujre
~v~ :.
Heather Riloff, Esquire ~'
Attorneys for Plaintiff
MAR11-IPA L `~'~J*v 2{_iS N`~"!'iFI,. P.C.
>~Iartha ~~, Vc~az Kosenstiel, Esquire :' No. ~263~
Heather Rilo'f. Esquire l No, 309906
bd9 South Avenue. Suite ?
Secane, PA 191318
(6?0)3^_8-288
•lttorn?': s ft~r I'I ~ir3t f;~
FEDERAL N.~~"1~IC)N,~L MORTGAGE ASSOCIATION
3900 Wisconsin Avent±e. NW
Washington, IBC 300 1 6-2 892
Plaintiff
ALAN G. DAV[5
1966 Spring Road
Carlisle. PA 17033
v.
Defendant
lt}
4ian Cs. Davis
1 ~>66 Spring Road
Carlisle, PA t 7013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Case No: 12->676 Civil Term
IMPORTANT NOT[CE
:5~ ~CTD - BI
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APP€:ARANCh PF'R5ONAI,LY OR BY
A"I'TORNEY AND FiLF IN WRITING WITH THE: COURT YOUR DEFENSES OR OBJECTIONS TO THI CLAIMS SET
FORTH AG,AINS"T YOU. UNLESS YOU ACT WITHLN TEN DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING ANll YOIJ MAY LOSE YOUR PROPER'fl~' OR OTHER
IMPORTAN"I RIGI1"CS.
YOU SI-IOIJLD TAItiE THIS NOTICE TO A LAWYER AT ONCE. ~IF YOU DO NOT HAVE A LAWYi::R, GO t~C) OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIE~E YOt! WITH INFORNLA~TION ABOUT
HTRING A LAtw'YER.
1F YOt! CANNOT AFFORD TO HIRE A LAWYER, TI-IIS OFFICE MAY" BE A33LE: TO PROVIDE !'C)Li V+'11~(1 INFORMA"CION
ABOUT AGENCIES THA'T' M.AY OFFER LEGAL SERVICES TO EL1Cr1BLE PERSONS AT .A REDLCr:D I~ [ }~; OR NO FEE,.
CUMBERLAND COUNTY BAR ASSOCIATION
LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9 l 08
Respectfully Submitted,
MAR'hHA E. VON ROSENSTI£ i... ~'t-~_
.~- ~ ; ~,
Martha E. Vote Rosensti~tl, E.~qu+~c
Heather Rils~tT, Esquire ~'~ `` "`. _
Attorneys for Plaintiff
Dazed; C)cu~`:~er1= _'(si2.
~30525CFJ-DN
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 far Plaintiff
FEDERAL.. NATIONAL MORTGAGE
ASSOCIA"LION
Plaintiff
vs.
ALAN G. DAMS
_ llefendant(S)
COURT' OF COMMON PLEAS
CUMBERLAND COUNTY
No: I2-5676 Civil Term
NON MILITARY AFFIDAVIT
__-~L~,', '~~A~~~.~ __ ,Esquire hereby certifies that:
1. I am the attorney for the plaintiff herein.
2. The individual involved in this action is the owner of the premises described in the mortgage underlying
this action.
3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are desig~ied to discos er facts
concerning the military status of the mortgagor(s) and/or real owner(s).
4. Said procedures were followed in connection with the instant foreclosure proceeding.
5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the
military.
6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service
member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. Appx. Section
50'. e~ sey.
'this verification is made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsilication to
authorities.
Respectfully Submitted,
Dated: October 23. 2012
MARTH~A~E. V ON ROSENSTIEL, P.C
Martha E. Von Rosen tie Esq~ire
Heather Riloff, Esquire
Attorneys for Plaintiff
~ ~~,
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Court House, 1 Courthouse Square, Carlisle, PA 1701
David D. Buell, Prothonotary
Alan G. Davis
58 Media Road
Carlisle, PA 17013
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
PLAINTIFF
VS.
ALAN G. DAMS
DEFENDANT(S)
COURT Oh COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment
has been entered against you in the above proceeding as indicated below in the amount of
$129,589.88 on October 23, 2012.
David Buell
PYOt{20320 YV ~' ~~~
i
C~ Jud ent b Default ~ ~_
~-----
C~ Money Judgment ,(~~l,a.
~~ Judgment in Replevin
C~ Judgment for Possession
^ Judgment on Award of
J Arbitration
C~ Judgment on Court Findings
If you have a~~~~~t~r's~>~ning this notice, please call: Attorney
Esquire at this telephone number:fil0-328-2887.
.. ~~,
"w'~~.
OFFICE OF THE PROTHONOTARY
COUEZT OF COMMON PLEAS
Court House, 1 Courthouse Square, Carlisle, PA 1701
Alan G. Davis
1966 Spring Road
Carlisle, P.a 1 7013
FEDERAL NATIONAL MORTGAGE
ASSOCLATION
PLAIN"TIFF
VS.
ALAN G. DAVIS
DEFENDANT(S)
David D. Buell, Prothonotary
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a. Judgment
has been entered against you in the above proceeding as indicated below in the amount of
$129,589.88 on October 23, 2012.
David D. uell «~. ~„
Pj~othonota '~
1. j
~X Judgment by Default ,..,~.
Money Judgment , oI ' l ~ -___
Judgment in Replevin
Judgment for Possession
^ Judgment on Award of
Arbitration
Judgment on Court Findings
[f you have any questi~q s coyq ~cernin this notice, please call:
Attorney t1@e~~f]Gf F~ilOff ,Esquire at this telephone number:610-328-
2887.
• ;::,~
"w°~.~.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Court House, I Courthouse Square, Carlisle,
PA 17013
David D. Buell, Prothonotarv
Alan G. Davis
516 Long Gap Rd
Carlisle, PA 17013
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
PLAINTIFF
VS.
ALAN G. DAMS
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified ghat a Judgment
has been entered against you in the above proceeding as indicated below in the amount of
$129,589.88 on October 23, 2012.
David D. Buell
Prothonotarv
~'-~. M,,. , .,,,~
~X Judgnnent by Default ~~
Money Judgment -- -
~o~~/i~
Judgment in Replevin
Judgment for Possession
^ Judgment on Award of
Arbitration
Judgment on Court Findings
If you have any ,questions concerning this notice, please call: Attorney
t1@e'~tE'lEC F311[~f~ ,Esquire at this telephone num~ber:_6.10-328-2887.
30525CWE-DN
Commonwealth of Pennsylvania
CO[TNTY OF CUMBERLAND
FEDERAL NATIONAL MORTGAGE ASSOCIATION COURT OF COMMON PLEAS
v. DOCKET NO. 12-SF7b Civih erm
ALAN CJ. DAB"IS ATTORNEY I.D. # _~~~`~~~
- -- ._,
Praecipe for Writ of Execution ~= ~--,
TO THE PROTHONOTARY: t
[ssue Writ of Execution in the above matter:
AMOUNT DUE.
INTEREST from 10/24/2012 to 3/6/2013
At6%
TOTAL*
*Plus costs t~~ bye endorsed
S 129,589,88
$ 2,854.20
$ 1 X2,444.08
Respectfully Submitted.
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rose stie ;Esquire
Heather Riloff, Esquir
Attorneys for Plaintiff
PREM: 58 Media Road, Carlisle, PA 17013
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#30525-DN
MARTHA F. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Heather Riloff, Esquire i No. 309906
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-288?
Attorneys for Plaintiff
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
Plaintiff
VS.
ALAN G. DAMS
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
LEGAL DESCRIPTION
ALL THAT CER"PAIN tract of land with the improvements thereon erected situate in the Fifth Ward of the
Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a stake on the West side of Media Road, which stake is 120 feet South of Hamilton
Street; thence by the West side of Media Road, North 27degrees 40 minutes West 60 feet to a stake; thence by
lands of Reuben H. Tucker and wife, South 61 degrees 30 minutes West 120 feet to a stake; thence by lands of
Charles W. Anderson and wife, South 27 degrees 40 minutes East 60 feet to a stake; thence bv_ lands of Wm. L.
Fordyce and wife. North 61 degrees 30 mim.~tes East 120 feet to the Place of BEGINNING.
FIAVING thereon erected a 1 1/2 story frame dwelling house known as Number S8 Media Road.
BEING the same premises which Nvle D. Monismith and Anita C. Bowennaster, by deed dated October
31, 2006 and recorded in the Office of the Recorder of Deeds in and for Cumberland County at Record Book
277. Page 1?44, granted and conveyed to Alan G. Davis and Kristi L. Davis, now known by marriage as Kristi
L. Knox. the Grantors herein. Michael Knox joins in this deed to convey any marital interest he may have, by
reason of marriage to Kristi L. Knox.
PARCEL IDENTIFICATION NO: 06-20-1800-068., CONT'ROI #: 06001329
IMPROVEMENTS: Residential dwelling
TITLE TO SAID PREMISES IS VESTED IN Alan G. Davis, single individual, by Deed from Alan G. Davis and Kristi
I_.. Davis, nbm, Kristi L. Knox, dated 07/09/2010, recorded 07/09/2010 in Instrument Number 20 1 01 8499.
MARTHA E. VON ROSENSTIEL, P.C.
Martha E.'Von Rosenstiel, Esquire / No. 52634
Heather Riloff, Esquire / No. 309906
649 South Avenue, Srzite 7
Secane, PA 1901 K
(610) 328-287
Attorneys for Plaintiff
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
Plaintiff
VS.
ALAN G. DAVIS
Defendants
#30525CAM - DN
COURT OF COMMON PLEAS .,..~
CUMBERLAND COUNTY ~"
NO: 12-5676 CIVIL TERM
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
HeathBr ~~~~~ ,ESQUIRE, attorney for the Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of E~:ecution was filed the following information
concerning the real property located at 58 Media Road, Carlisle, PA 17013:
1. Name and address of owners(s) or reputed owner(s)
Alan G. Davis
1966 Spring Road
Carlisle, PA 1 7013
2. Name and address of defendant(s) in the judgment:
Alan G. Davis
1966 Spring Road
Carlisle. PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to
be sold:
NONE
4. Name and address of the last recorded holder of every mortgage of record:
NON1
5. Name and address of every other person who has any record lien on the property:
NON1~;
6. Name and address of every other person who has any record interest in the prc:~perty and whose
interest may be affected by the sale:
NONE
7. ivIame and address of every other person of whom plaintiff has knowledge w(1o has any interest in the
property which may be affected by the sale:
Cumberland County Tax Claim
1 Courthouse Square
Carlisle, PA 1?013
Cumberland Register of Wills
County Courthouse
Carlisle, PA 17013
Attorney General of the U.S.
C'/O Assistant Attorney General
Tax Division
~'.S. Department of Justice
P.O. Box 227
Washington, DC 20044
PA Dept of Revenue
Inheritance Tax Bureau
Strawberry Square, 11th Floor
Harrisburg, PA 17128
Family Court/Domestic Relations
1 Courthouse Square
Carlisle., PA 17013
PA. Department of Revenue
Bureau of Compliance
Attn: Sheriff Sale Section
P..O. l3ox 21,8230
Harrisburg, PA. 17128-1230
Dept of Public Welfare
P.U. Box 2675
Harrisburg, PA 1710
Pennsylvania Department of Revenue
Bureau of Individual Taxes
PO Box 280603
Harrisburg, PA 17128-0603
Occupant
58 Media Road
Carlisle. PA 17013
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.
Respectfiilly Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Ros s iel, Esquire
Heather Riloff, Esquir
Attorneys fc~r falaintiff
Dated: October 22.2012
30525CAM-DN
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No.
Heather Riloff, Esquire / No. 309906
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
Plaintiff
~~s.
ALAN G. DAMS
Defendant(s)
52634
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No: 12-5676 Civil Term
~10TICE OF SHERIFF'S SALE OF REAL PROPER"TY"
TO ALL. PARTIES IN INTEREST AND CLAIMANTS:
The real estate and improvements, if any, located at and known as 58 Media Road Carlisle, PA
17013 will be sold by the Sheriff of Cumberland County on
Date of Sale: March 06, 2013
Time of Sale: I O:OG a.m.
Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, I'A 17013.
This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 12-5676
Civil Term in the Court of Common Pleas of Cumberland County by Federal National
Mortgage Association, Plaintiff against Alan G. Davis, Defendant(s). Judgment was entered on
October 23, 2012 in the amount of $129,589.88. The property was seized and taken in
execution as the property of Alan G. Davis.
The property. to be sold at Sheriff's Sale is described as follows:
ALL THAT CER"hAIN tract of land with the improvements thereon erected situate in the Fifth
Ward of the F3orough of Carlisle, Cumberland County, Pennsylvania, bounded and described as
follows:
BEGINNING at a stake on the ~~est side of Media Road, which stake is 120 feet South of
Hamilton St1-eet thence by the Nest side of Media Road, North 27degrees 40 z~ninutes West 60
feet tc a stake. thence by lands of Reuben H. Tucker and wife, South 61 degrees ~0 minutes
A
West 120 feet to a stake; thence by lands of Charles W. Anderson and wife, South 27 degrees
40 minutes East 60 feet to a stake; thence by lands of Wm. L. Fordyce and wife, North 61
degrees 30 minutes East 120 feet to the Place of BEGINNING.
HAVING thereon erected a 1 1/2 story frame dwelling house known as Number 58
Media Road.
BEING the same premises which Nyle D. Monismith and Anita C. Bowennaster, by deed
dated October 31, 2006 and recorded in the Office of the Recorder of Deeds in and for
Cumberland County at Record Book 277, Page 1744, granted and conveyed to .:Alan G. Davis
and Kristi L. Davis, now known by marriage as Kristi L,. Knox, the Grantors herein. Michael
Knox joins in this deed to convey any marital interest he may have., by reason of marriage to
Kristi L. Knox.
PARCEL IDENTIFICATION NO: 06-20-1800-068., CONTROL #: 0600132t?
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. 12-5676 Civil Term. 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 1'OR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von 13osenstiel, 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}
C'OUN"I'Y OF CUMBERLAND)
NO. 12-5676 Civil
CIVIL ACT(O'~ -LAW
TO THL-: SHER[FF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION
Plaintiff (s)
From ALAN G. DAMS
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(_'} You are also directed to attach the property of the defendant(s) not levied upon in the possession
oI
GARN[SHEE(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 I or otherwise disposing thereof;
(~ j 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
«arnishee and is enjoined as above stated.
.Amount Due: $129,589.88 L.L.:.50
Interest FROM 10/24/2012 TO 3/6/2013 AT 6% - $2,854.20
Atrv's Comm: °% Due Prothy: $2.25
Atty Paid: $271.70 Other Costs:
Plaintiff Paid:
Date: 10/24/12
David D. Buell,, Prothonotary ,
(peal) By: _~--L~~~.~,~,
Deputy
RL~'(iUFST!TJG PAKTY:
1~a,ne: :-3EATIiEFc RILOFF, ESQUIRE
Address: MARTHA E. VON ROSENSTIEL, P.C.
6d9 SOUTH AVENUE, SUITE 7
SECANE, PA 19018
Attorne~~ tor: PLAINTIFF
Telephone: 610-328-2887
Supreme Court ID No. 309906
..:~:
- `w'`~,
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Court House, 1 Courthouse Square, Carlisle, PA 17013
Alan G. Davis
516 Long Gap Rd
Carlisle, PA 17013
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
PLAINTIFF
VS.
ALAN G. DAMS
DEFENDANT(S)
David D. Buell, Prothonotary
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment
has been entered against you in the above proceeding as indicated below in the amount of
$129,589.88 on October 23, 2012.
David D. uell
Pr~othonotar
~~
0 Judgment by Default ~
Money Judgment h,~ ,~~I ~a-
Prothonotary
1 Courthouse Square
Cuh~beriand County Courthouse
Carlisle, PA 17013-3387
is-.~7~
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~Ga~~,RY
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Court House. I Courthouse Square, Carlisle, PA 17013
Alan G. Davis
58 Media Road
Carlisle, PA 17013
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
PLAINTIFF
VS.
ALAN G. DAMS
DEFENDANT(S)
David D. Buell, Prothonotary
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 12-5676 CIVIL TERM
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment
has been entered against you in the above proceeding as indicated below in the amount of
$129,589.88 on October 23, 2012.
David D. ell
PYOlj207101 Y
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notnry
thouse Square
.rland County Courthouse
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MAR"fHA 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) 32,8-2887
Attorneys for Plaintiff
FEDERAL NATIONAL MORTGAGE
ASSOCIATION
Plaintiff
VS.
#30525CAM - DN
NO: 12-5676 CIVIL TERM
ALAN G. DAMS
Defendants
AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE; 3129.1
i~eather ~~IOi! _ ESQUIRE, attorney for the Plaintiff in the
above action, hereby verifies that on ~ ~ '' ~ ' ~~ _ ,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 I.
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. ~'.S.
Section 4904 relating to unsworn falsification to authorities.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL. P.C.
Martha E. Von Rosen ie , Esgyiire
Heather Riloff, Esquir , --
Attorneys for Plaintiff
For Accountable Mall
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _ f + E j) 11`
a "Y• L ~VI 1
Sheriff �t�axaxxt�tr/,�rj� ''�'` lop f,�Th'"��C�
Jody S Smith 7013 HA y
Chief Deputy 6 QM g; 59
Richard W Stewart �RLA
Solicitor
4 c _ x CLIMB PE"SYLVANIA�T�I
Federal National Mortgage Association Case Number
vs. 2012-5676
Alan G. Davis
SHERIFF'S RETURN OF SERVICE
12/31/2012 Sgt. Jason Vioral, being duly sworn according to law, served the requested Real Estate Writ, Notice and
Description, in the above titled action, by making known its contents and at the same time personally
handing a true copy to a person representing themselves to be the Defendant, to wit: Alan G. Davis at
the Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County
on 12/31/12.
12/31/2012 01:51 PM - Deputy Gerald Worthington, 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 58 Media Road, Carlisle, PA 17013, Cumberland County.
03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold
the same for the sum of$ 1.00 to Attorney Martha Von Rosenstiel, on behalf of Federal National
Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,053.47 SO ANSWERS,
April 30, 2013 R-ONO R ANDERSON, SHERIFF
sv e -
MARTHA E. VON ROSENSTIEL, P.C. #30525CAM - DN
'iron
Martha E. Von Rosenstiel, Esquire/No. 52634 ERIFFS
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: 12-5676 CIVIL TERM
ALAN G. DAVIS
Defendant(s)
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
Heather Ruoff , ESQUIRE, attorney for the Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information
concerning the real property located at 58 Media Road, Carlisle, PA 17013:
1. Name and address of owners(s) or reputed owner(s)
Alan G. Davis
1966 Spring Road
Carlisle, PA 17013
2. Name and address of defendant(s) in the judgment:
Alan G. Davis
1966 Spring Road
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to
be sold:
NONE
4. Name and address of the last recorded holder of every mortgage of record:
NONE
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.G. Box 227
Washington, DC 20044
PA Dept of Revenue
Inheritance Tax Bureau
Strawberry Square, 11 th Floor
Harrisburg, PA 17128
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
58 Media Road
Carlisle, PA 17013
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.
'
Martha E. Von Ro s iel, Esquire
Heather Riloff, Esquir
Attorneys for Plaintiff
Dated: October 22, 2012
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _ f + E j) 11`
a "Y• L ~VI 1
Sheriff �t�axaxxt�tr/,�rj� ''�'` lop f,�Th'"��C�
Jody S Smith 7013 HA y
Chief Deputy 6 QM g; 59
Richard W Stewart �RLA
Solicitor
4 c _ x CLIMB PE"SYLVANIA�T�I
Federal National Mortgage Association Case Number
vs. 2012-5676
Alan G. Davis
SHERIFF'S RETURN OF SERVICE
12/31/2012 Sgt. Jason Vioral, being duly sworn according to law, served the requested Real Estate Writ, Notice and
Description, in the above titled action, by making known its contents and at the same time personally
handing a true copy to a person representing themselves to be the Defendant, to wit: Alan G. Davis at
the Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County
on 12/31/12.
12/31/2012 01:51 PM - Deputy Gerald Worthington, 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 58 Media Road, Carlisle, PA 17013, Cumberland County.
03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold
the same for the sum of$ 1.00 to Attorney Martha Von Rosenstiel, on behalf of Federal National
Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,053.47 SO ANSWERS,
April 30, 2013 R-ONO R ANDERSON, SHERIFF
sv e -
MARTHA E. VON ROSENSTIEL, P.C. #30525CAM - DN
'iron
Martha E. Von Rosenstiel, Esquire/No. 52634 ERIFFS
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: 12-5676 CIVIL TERM
ALAN G. DAVIS
Defendant(s)
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
Heather Ruoff , ESQUIRE, attorney for the Plaintiff in the above
action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information
concerning the real property located at 58 Media Road, Carlisle, PA 17013:
1. Name and address of owners(s) or reputed owner(s)
Alan G. Davis
1966 Spring Road
Carlisle, PA 17013
2. Name and address of defendant(s) in the judgment:
Alan G. Davis
1966 Spring Road
Carlisle, PA 17013
3. Name and address of every judgment creditor whose judgment is a record lien on the real property to
be sold:
NONE
4. Name and address of the last recorded holder of every mortgage of record:
NONE
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.G. Box 227
Washington, DC 20044
PA Dept of Revenue
Inheritance Tax Bureau
Strawberry Square, 11 th Floor
Harrisburg, PA 17128
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
58 Media Road
Carlisle, PA 17013
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.
'
Martha E. Von Ro s iel, Esquire
Heather Riloff, Esquir
Attorneys for Plaintiff
Dated: October 22, 2012
30525CAM-DN
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: 12-5676 Civil Term
ALAN G. DAVIS :
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 58 Media Road Carlisle, PA
17013 will be sold by the Sheriff of Cumberland County on
Date of Sale: March 06, 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. 12-5676
Civil Term in the Court of Common Pleas of Cumberland County by Federal National
Mortgage Association, Plaintiff against Alan G. Davis, Defendant(s). Judgment was entered on
October 23, 2012 in the amount of$129,589.88. The property was seized and taken in
execution as the property of Alan G. Davis.
The property to be sold at Sheriff's Sale is described as follows:
ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Fifth
Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as
follows:
BEGINNING at a stake on the West side of Media Road, which stake is 120 feet South of
Hamilton Street; thence by the West side of Media Road, North 27degrees 40 minutes West 60
feet to a stake; thence by lands of Reuben H. Tucker and wife, South 61 degrees 30 minutes
West 120 feet to a stake; thence by lands of Charles W. Anderson and wife, South 27 degrees
40 minutes East 60 feet to a stake; thence by lands of Wm. L. Fordyce and wife, North 61
degrees 30 minutes East 120 feet to the Place of BEGINNING.
HAVING thereon erected a 1 1/2 story frame dwelling house known as Number 58
Media Road.
BEING the same premises which Nyle D. Monismith and Anita C. Bowermaster, by deed
dated. October 31, 2006 and recorded in the Office of the Recorder of Deeds in and for
Cumberland County at Record Book 277, Page 1744, granted and conveyed to Alan G. Davis
and Kristi L. Davis, now known by marriage as Kristi L. Knox, the Grantors herein. Michael
Knox joins in this deed to convey any marital interest he may have, by reason of marriage to
Kristi L. Knox.
PARCEL IDENTIFICATION NO: 06-20-1800-068., CONTROL #: 06001329
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. 12-5676 Civil Term. 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. 12-5676 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 ALAN G.DAVIS
(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: $129,589.88 L.L.: .50
Interest FROM 10/24/2012 TO 3/6/2013 AT 6% -$2,854.20
Arty's Comm: % Due Prothy:$2.25
Atty Paid:$271.70 Other Costs:
Plaintiff Paid:
Date: 10/24/12
David D. Buell,Prothonotary
(Seal) By: ��'"IF
D puty
REQUESTING PARTY:
Name: HEATHER RILOFF,ESQUIRE
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.309906
TRUE COPY FROM RECORD
In Testimony whereof,1 here unto set my hand
and the sue)of said Court at Carlisle,Pa
This CY day of. .20
� Pr t onotary
�j
L,C 0,
CUMBERLAND LAW JOURNAL
Writ No. 2012-5676 Civil TITLE TO SAID PREMISES IS
VESTED IN Alan G. Davis, single
Federal National individual, by Deed from Alan G.
Mortgage Association Davis and Kristi L. Davis nka,Kristi
VS. L.Knox,dated 07/09/2010,recorded
Alan G. Davis 07/09/2010 in Instrument Number
201018499.
Atty.: Martha E.Von Rosenstiel
ALL THAT CERTAIN tract of land
with the improvements thereon
erected situate in the Fifth Ward of
the Borough of Carlisle,Cumberland
County,Pennsylvania,bounded and
described as follows:
BEGINNING at a stake on the
West side of Media Road,which stake
is 120 feet South of Hamilton Street;
thence by the West side of Media
Road, North 27degrees 40 minutes
West 60 feet to a stake; thence by
lands of Reuben H.Tucker and wife,
South 61 degrees 30 minutes West
120 feet to a stake;thence by lands
of Charles W. Anderson and wife,
South 27 degrees 40 minutes East
60 feet to a stake;thence by lands of
Wm. L. Fordyce and wife, North 61
degrees 30 minutes East 120 feet to
the Place of BEGINNING.
HAVING thereon erected a 1 1/2
story frame dwelling house. known
as Number 58 Media Road.
BEING the same premises which
Nyle D. Monismith and Anita C.
Bowennaster,by deed dated October
31, 2006 and recorded in the Office
of the Recorder of Deeds in and for
Cumberland County at Record Book
277, Page 1744, granted and con-
veyed to Alan G. Davis and Kristi L.
Davis, now known by marriage as
Kristi L. Knox, the Grantors herein.
Michael Knox joins in this deed to
convey any marital interest he may
have,by reason of marriage to Kristi
L. Knox.
PARCEL IDENTIFICATION NO:
06-20-1800-068., CONTROL #:
06001329.
IMPROVEMENTS: Residential
dwelling.
38
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929),P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal,of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal,a legal periodical of general circulation,and that he is not interested in the subject
matter of the aforesaid notice or advertisement,and that all allegations in the foregoing
statements as to time, place and character of publication are true.
r`
sa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
8 day of February, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
I
I
I
2012-5676 CtAl
Federal National Mortgage
AssoelatloOt
Vs
Alan G.Davis
Atty: Martha E.Von Rosenstlel
ALL THAT CERTAIN tract of land with
the improvements thereon erected situate
in the Fifth Ward of the Borough of
Carlisle,Cumberland County,Pennsylvania,
bounded and described as follows:.
BEGINNING at a stake on the West side
Of Media Road, which stake is 120 feet
South of Hamilton Street;thence by the
West side of Media Road,North 27degrees
40 minutes West 60 feet t4 a stake;thence
by lands of Reuben H. Bicker and wife,
South 61 degrees 30 minutes West 120 feet
to a stake;thence,by lands of Charles W.
Anderson and wife,South 27 degrees 40
minutes East 60 feet to a stake;thence by
lands of Wm.L Fordyce and wife,North
61 degrees 30 minutes East 120 feet to the
Place of BEGINNING.
HAVING thereon erected,ea 1 1/2 %gory
frame dwelling house.knowfi as Nunfod 58
Media Road.
BEING the same premises which Nyle D.
Momsrmth and Anita C.Bowennaster,by
deed dated October 31,2006 and recorded
in the Office of the Recorder of Deeds in
and for Cumberland County at Record
Book 277,Page 1744,granted and conveyed
to Alan G.Davis and Kristi L Davis,now
known by marriage as Kristi L Knox,the
Grantors herein. Michael Knox joins in
this deed to convey any marital interest he
may have,by reason of marriage to Kristi
L Knox.
PARCEL IDENTIFICATION NO:06-20-
1800-068.,CONTROL A 06001329
IMPROVEMENTS:Residential dwelling
TITLE TO SAID PREMISES IS VESTED
IN Alan•G. Davis, single individual, by
Deed from Alan G. Davis and Knsti L.
Davis,nka,Kristi L Knox,dated 07/09/2010,
recorded 07/09/2010 in Instrument Number
201Q18499.
a
i
- The Patriot-News Co.
2020 Technology Pkwy t4e a
Suite 300
Mecttanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
/ 01122113
I 0 01/29/13
02105/13
Sworn to and s bscribed before me this 14 ay of February, 2013 A.D.
ry blic
(7
COMMoNWEALTH of PENNSYLVANIA
Notarial seal
Holly Lynn Warfel,Notary Public
Washington Twp.,Dauphin county
4n- L } My Commission Expires Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I SS:
1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been
sold to said grantee on the 6th day of March A.D., 2013,under and by virtue of a writ Execution issued
on the 24th day of October,A.D., 2012, out of the Court of Common Pleas of said County as of Civil
Term, 2012 Number 5676, at the suit of Federal National Mortgage Association against Alan G. Davis is
duly recorded as Instrument Number 201314714.
IN TESTIMONY WHEREOF, I hav hereunto set my hand
and seal of said office this �C day of
A.D. _J? 13
corder of Deeds
of a co",r.ar�e,w►
My Commission ices the FQSt Monday of Jeri.2014