HomeMy WebLinkAbout12-6099~~l1 ACT - I l~~ 9: 3~
'~`~'~`i~RL~+~D COUP~Ti'
~ENNS YLVgN-q
PHELAN HALLINAN & SCHMIEG, LLP
Allison F. Wells, Esq., Id. No. 309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
SUNTRUST MORTGAGE, INC.
1001 SEMMES AVENUE
P.O. BOX 27767
RICHMOND, VA 23224-7767
Plaintiff
v.
JOHN PAUL REEDER
PAMELA IRENE REEDER
414 NEALY ROAD
NEWVILLE, PA 17241-9472
Defendants
257699
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM^ O~
NO. o~' ~~ `~ r~ t
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 257699
o~}•lo~~s~x! aHy
(;-~-t ia~~a~
K~ ast~i~
Plaintiff is
SUNTRUST MORTGAGE, INC.
1001 SEMMES AVENUE
P.O. BOX 27767
RICHMOND, VA 23224-7767
2. The names and last known address of the Defendants are:
JOHN PAUL REEDER
PAMELA IRENE REEDER
414 NEALY ROAD
NEWVILLE, PA 17241-9472
who are the mortgagors and real owners of the property hereinafter described.
3. On 09/26/2006 JOHN PAUL REEDER and PAMELA IRENE REEDER made, executed and
delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR MEMBERS 1ST
FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of
CUMBERLAND County, in Mortgage Book 1967, Page 0783. By corrective Assignment of
Mortgage recorded 06/06/2012 the mortgage was assigned to PLAINTIFF which Assignment is
recorded at Assignment of Mortgage Instrument No. 201216819. The mortgage and
assignment(s), if any, are matters of public record and are incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to
attach documents to pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 7/1/2010 and each month thereafter are due and unpaid, and by the terms of said
mortgage, upon failure of mortgagor to make such paymentsafter a date specified by written
notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible
forthwith.
File #: 257699
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith.
6. The following amounts are due on the mortgage as of 09/26/2012:
Principal Balance $210,684.61
Interest @ 6.87500% $33,582.44
06/01 /2010 through 09/26/2012
Late Charges $1,083.45
Property Inspections $262.00
Escrow Deficit $15,933.29
TOTAL $261,545.79
7. Plaintiff is not seeking a judgment of personal liab ility (or an in personam judgment)
against the Defendants in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendants have received a
discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage
Foreclosure is in no way an attempt to reestablish such personal liability discharged in
bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant
to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable, have been sent to the Defendants on
the date(s) set forth thereon.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendants in the sum of
$261,545.79, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
File #: 257699
LEGAL DESCRIPTION
ALL that certain lot or tract of land situate in North Newton Township, Cumberland County,
Pennsylvania, more particularly bounded and described pursuant to a Subdivision Plan for Larry
E. Foote, Sr. and H. David Miller, Jr., as recorded in Cumberland County Plan Book 63, Page 19,
as follows:
BEGINNING at a Parker Kalon nail in Nealy Road (T-353), at the northwestern corner of Lot
No. 5 as shown on the above-described subdivision plan; thence by said Lot No. 5, South 37
degrees 29 minutes 47 seconds West 585.00 feet to an iron pin thence by Lot No. 1 as shown on
the above-described subdivision plan, North 52 degrees 30 minutes 13 seconds West 150.00 feet
to an iron pin at the southeastern corner of Lot No. 7 as shown on the above-described
subdivision plan; thence by said Lot No. 7, North 37 degrees 29 minutes 47 seconds East 585.00
feet to a Parker Kalon nail in Nealy Road (T-353); thence in said road, South 52 degrees 30
minutes 13 seconds East 150.00 feet to a Parker Kalon nail in said road, the point and place of
BEGINNING.
CONTAINING 2.01 gross acres and being designated as Lot No. 6 as shown on the above-
described subdivision plan.
BEING known and numbered as 414 Nealy Road, Newville, Pennsylvania.
TOGETHER with and under and subject to notations as shown on said plan.
File #: 257699
UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions
and rights of record, to the extent valid and enforceable and still applicable to the above
described premises.
BEING the same premises which David A. Horst and Martha Yvonne Horst, husband and wife,
by their Deed dated October 21, 2002 and recorded November 1, 2002, in the Office of the
Recorder of Deeds in and for Cumberland County, in Deed book 254, Page 1756, granted and
conveyed unto David A. Horst and Martha Yvonne Horst, husband and wife, Grantors herein.
PROPERTY ADDRESS: 414 NEALY ROAD, NEWVILLE, PA 17241-9472
PARCEL # 30-09-0513-024.
File #: 257699
VERIFICATION
® 1
lY~//~ /t ~ ,hereby states that he/she is of SUNTRUST
MORTGAGE, INC., servicing agent for Plaintiff in this matter, that he/she is authorized to make
this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of his/her information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
DATE: ~ ~Z
File#: 257699
Name: REEDER
~~~
N ~~~ra ~p,b ~~~~
Title:
SUNTRUST MORTGAGE, INC.
File #: 257699
~'.~ ~s' C f ~,..
_ ~ ~~t ~~,~:~ ~fl*a~~~T~a,
~~I~ OCT - I ~1~ 9~ 33~
~~'~`~t~L,~ND COUNTY
~CNNSYLYANIA
SUNTRUST MORTGAGE, INC.
REEDER, JOHN PAUL
REEDER, PAMELA IRENE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
~' ~~~ivil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have an attorney, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at
(717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at not
charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative
within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in attempt to work out a reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all the requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be
filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward,
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Date
Respectfully submitted:
Signature o nsel f r Plaintiff
~l
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Please Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances
to determine possible options while working with your .Please provide the
following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers:
State: Zip:
Yes ^ No ^ Listing date: Price: $_
Realtor Phone:_
Yes ^ No ^
Home:
Cell:
Office:
Other:
Email:
# of people in household: How long?
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household:
First Mortgage Lender:
Loan:
Loan Number:
Second Mortgage Lender:
of Loan:
Loan Number:
State: Zip:
How long?
Date you Closed Your Loan:
Type of
Type
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
l~rimary Reason for Default:
Is the loan in Bankruptcy? Yes ^ No ^
If yes, provide names, location of court, case number & attorney:
Assets
Home:
Other Real Estate:
Retirement Funds:
Investments:
Checking:
Savings:
Other:
Amount Owed:
ValnP•
Automobile # 1: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other trans ortation automobiles boats motorc cles : Model:
Year: Amount owed: Value
Year:
Year:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Ezaenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mort a e Food
2" Mortga a Utilities
Car Payment(s) Condo/Nei .Fees
Auto Insurance Med. (not covered)
Auto fuel/re airs Other prop. payment
Install. Loan Pa ment Cable TV
Child Su ort/Alim. S endin Money
Day/Child Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
fIave you been working with a Housing Counseling Agency?
Yes ^ No ^
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office):
Email:
Fax:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ^ No ^
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to
resolve your delinquency?
Yes ^ No ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if you know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone:
I/We, ,authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of
evaluating my financial situation for possible mortgage options. I/We understand that I/we
am/are under no obligation to use the services provided by the above named
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this page along with the following information to lender:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
6. Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
SOtICItOr
.. tJ. ~ f' ii (~ 1 1 i w% ~ J I.I~ ~~.
2~ 12 DCT 3 I PSI 3~ 1 F
~i~r~,~E~~~~~ cr~u~r~,
~'FPd'~SYLV~HI~,
Suntrust Mortgage, Inc.
vs.
John Paul Reeder (et al.)
Case Number
2012-6099
SHERIFF'S RETURN OF SERVICE
10/08/2012 Roriny 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: Pamela I. Reeder, but was unable to locate her 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 Pamela I. Reeder. Request
for service at 414 Nealy Road, Newville, Pennsylvania 17241 is vacant. The Newville Postmaster has
confirmed, Pamela I. Reeder has moved and left no forwarding address.
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: John P. Reeder, 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 John P. Reeder. Request for
service at 414 Nealy Road, Newville, Pennsylvania 17241 is vacant. The Newville Postmaster has
confirmed, John P. Reeder has moved and left no forwarding address.
1 0/1 71201 2 Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 17, 2012
at 2037 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: John P.
Reeder, by making known unto himself personally, at 322 S. Spring Garden Street, Carlisle, Cumberland
County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true
and correct copy of the same. Deputies attempted service at 2 Rush Drive, Apartment 201, Carlisle,
Pennsylvania 17013, but were advised by the leasing office of this residence John P. Reeder was the
previous tenant ending occupancy approximately one month earlier.
10/17/2012 08:37 PM -Ronald Hoover, Deputy :iheriff, who being duly sworn according to law, states that on October
17, 2012 at 2037 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:
Pamela I. Reeder, by making known unto John P. Reeer, Husband of Pamela I. Reeder at 322 S. Spring
Garden Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to her personally the said true and correct copy of the same. Deputies attempted service at 2
Rush Drive, Apartment 201, Carlisle, Pennsylvania 17013, but were advised by the leasing office of this
residence Pamela I. Reeder was the previous tenant ending occupancy approximately one month earlier.
SHERIFF COST: $110.00
October 22, 2012
_ _ .,
'"
RONALD HOOVER, DEPUTY
SO ANSWERS,
RONN R ANDERSON, SHERIFF
?,- THE P? Q 7 ?? tGr
NOTARY
PHELAN HALLINAN, LLP ZY 12 DEC 18 00
"Zachary Jones, Esq., Id. No.310721
1617 JFK Boulevard, Suite 1400 C{JIS RL..AND COUNTY
One Penn Center Plaza PI`S S YLVANIA
Philadelphia, PA 19103
215-563-7000
SUNTRUST MORTGAGE, INC
vs.
JOHN PAUL REEDER
PAMELA IRENE REEDER
Attorney for Plaintiff
: CUMBERLAND COUNT17
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 12-6099-CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against JOHN PAUL REEDER and
PAMELA IRENE REEDER, Defendants for failure to file an Answer to Plaintiff's Complaint
within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and
assess Plaintiff's damages as follows:
As set forth in Complaint
TOTAL
$261,545.79
$261,545.79
I hereby certify that (1) the Defendants' last known addresses are 414 NEALY ROAD,
NEWVILLE, PA 17241-9472 and 322 S SPRING GARDEN ST, CA LISLE, PA 17013-2554,
and (2) that notice has been given in accordance with Rule Pa. 37.1.
Date i a
Za ar es, sq., Id. No.3107210.?1? s0? A
0 or aintiff iassy?3
DAMAGES ARE HEREBY ASSESSED AS INDIC ED. 9- yyl
Noh'cs m
7)
DATE: _ ?o? a
Pxs # 257699 ?OTHONOTA
257699
PHELAN HALLINAN, LLP
Zachary Jones, Esq., Id. No.310721
1617 JFK Boulevard, Suite 1400
Attorney for Plaintiff
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
SUNTRUST MORTGAGE, INC.
VS.
JOHN PAUL REEDER
PAMELA IRENE REEDER
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 12-6099-CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned. attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendants JOHN PAUL REEDER and PAMELA IRENE REEDER
are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended.
(b) that defendant JOHN PAUL REEDER A/K/A JOHN P. REEDER is over 18
years of age and the last known addresses of the defendant are 414 NEALY ROAD,
NEWVILLE, PA 17241-9472 and 322 S SPRING GARDEN ST, CARLISLE, PA 17013-2554.
(c) that defendant PAMELA IRENE REEDER A/K/A PAMELA I. REEDER is
over 18 years of age and the last known addresses of the defendant are 414 NEALY ROAD,
NEWVILLE, PA 17241-9472 and 322 S SPRING GARDEN ST, CARLISLE, PA 17013-2554.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to anthnritiec
Date
?1
257699
Department of Defense Manpower Data Center
taws Report
want to Servicemembffs (civil Relief Act
Last Name: REEDER
First Name: JOHN
Middle Name: PAUL
Active Duty Status As Of: Dec-13-2012
Results as of : Dec-13-2012 12.03*42
SCRA 2.3
On Active Doty On Active Duty Status Dale
Active Duty Start Date Active Duty End Date Status Service Comp-ent
NA- NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service. Component
NA NA
N.
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or Hts/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date
: Ct4er Notification End Date
F Status Service Component
- NA
_ NA No NA
This response reflects whether the individual or his/her unit has received sarly ricttCcdtion to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
-)Of
yE, 4
y6t
Mary M. Snavely-Dixon, Director II
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
(Rule of Civil Procedure No. 236) - Revised
SUNTRUST MORTGAGE, INC.
VS.
JOHN PAUL REEDER
PAMELA IRENE REEDER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 12-6099-CIVIL
Notice is given that a Judgment in the above captioned matter has been entered
against you on $ 1
'./
?1
By:
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Zachary Jones, Esq., Id. No.310721
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
X * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, B(IT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
257699
SUNTRUST MORTGAGE, INC.
Plaintiff
V,
JOHN PAUL REEDER
PAMELA IRENE REEDER
Defendant(s)
TO: JOHN PAUL REEDER
414 NF.ALY ROAD
NEWtiILLE, PA p17241-9472
DATE OF NOTICE:, (I ?- ,
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-6099-CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMP'T' TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PL,`RPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE. IN DEFAULT BECAUSE YOU HAVE, FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COUR'T'
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
Courthouse Square
Carlisle, PA 17013
(717) 240-6195
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(7I7) 249-3166
By: )66
Meredith Wooters, Esq., Id. No.307207
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
P1 IS # 25 7699
SUNTRUST MORTGAGE, INC.
Plaintiff
V.
JOHN PAUL REEDER
PAMELA IRENE REEDER
Defendant(s)
TO: • JOHN PAUL REEDER
322 S SPRING GARDEN ST
CARLISLE, PA 17013-2554
DATE OF NOTICE:
3
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-6099-CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLEC'T' THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF, YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE fN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENTFORCHIMEN"T OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717)240-6195
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
BY: # j
Meredith Wooters, Esq., Id. No.307207
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 .IFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
MIS # 2576;99
SUNTRUST MORTGAGE, INC.
Plaintiff
V,
JOHN PAUL REEDER
PAMELA IRENE REEDER
Defendant(s)
TO: . PAMELA IRENE REEDER
414 NEALY ROAD
NEWVILLE, PA 17241-9472
DATE OF NOTICE:
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-6099-CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHINTEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIFS THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBER'T'Y AVENUE
CARLISLE, PA 17013
017+7) 2j49-3166 ! , }
By:#s1!/Ie?1?ltJ
Meredith Wooters, Esq., Id. No.307207
Attorney for Plaintiff
Phelan Hallman, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
PHS # 257699
SUNTRUST MORTGAGE, INC.
Plaintiff
V.
JOHN PAUL REEDER
PAMELA IRENE REEDER
Defendant(s)
TO, PAMELA IRENE REEDER
322 S SPRING GARDEN ST
CARLISLE, PA 17013-2554
DATE, OF NOTICE:
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-6099-CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FARED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 'THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD 'TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717)240-6195
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
By - )-er'edith Wooters, Esq., Id. No.307207
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 191.03
PHS # 2.57699
AFFIDAVIT OF SERVICE(FNMA)
• PLAINTIFF CUMBERLAND COUNTY
SUNTRUST MORTGAGE,INC.
PHS#257699 Z--
c''
DEFENDANT SERVICE TEAM/lxh -c7
JOHN PAUL REEDER COURT NO.:12-6099-CIVIL : t
PAMELA IRENE REEDER
SERVE PAMELA IRENE REEDER AT: TYPE OF ACTION ,,,
322 S SPRING GARDEN ST XX Notice of Sherif'f's Sale
CARLISLE,PA 17013-2554 SALE DATE: June 5,2013 ` ,
SERVED
Served and made known to PAMELA IRENE REEDER,Defendant on then day of 20 C_-?at
J��r clock f M.,at 2a s i(1A W A'in the manner described below:
Defendant pdrsonally served, r
_Adult family member with whom Defendant(s)reside(s).
Relationship is
_Adult in charge of Defendant's residence who refused to give name or relationship.
_Manager/Clerk of place of lodging in which Defendant(s)reside(s).
Agent or person in charge of Defendant's office or usual place of business.
_ an officer of said Defendant's company.
_Other:
Description: Age at Height Weight I d Race CIL Sex Other
I, eAt - s__, a competent adult,hereby verify that I personall handed a true and correct copy of the
Notice of Aeriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec.4904 relating to
unsworn falsification to authorities.
DATE: -3 3 NAME: 1
PRINTED NAME:
TITLE: rocw 37 ryef— '
NOT S RUED
On the day of 20—,at o clock .M.,I, a competent adult hereby
state thatZSe�endant NOT FOUND because:
Vacant —Does Not Exist _Moved Does Not Reside(Not Vacant)
No Answer on at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
(215)563-7000
• AFFIDA OF SERVICE(FNMA)
PLAINTIFF CUMBERLAND COUNTY
SUNTRUST MORTGAGE,INC.
PHS#257699
DEFENDANT SERVICE TEAM/M
JOHN PAUL REEDER COURT NO.:12-6099-CIVIL
PAMELA IRENE REEDER
SERVE JOHN PAUL REEDER AT: TYPE OF ACTION C:�
C-
322 S SPRING GARDEN ST XX Notice of Sheriff's Sale
3p:r
CARLISLE,PA 17013-2554 SALE DATE: June 5,2013
SERVED
Served and made known to JOHN PAUL REEDER, ndant on the -S day of 20 at
PM.,at r, in the manner described below:
o'clock Xr C!11 I
Defendant p9rsonally served.
Adult family member with whom Defendant(s)reside(s).
Relationship is
Adult in charge of Defendant's residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s)reside(s).
Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
Other:
Description: Age Height Weight /90 Race Sex rO Other
4e
f,1 ty - -P JF
a competent adult,hereby verify that I personally handed a true and correct copy of the
Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities. NAME:
AME:
PRINTED NAME: rumafrl &CA V-s
TITLE:--oroce Nr S'erve-r
J .-
NOT SERVED
On the dav of 20 ,at o'clock_.M.,1, a competent adult hereby
state thaf-DWendant NOT FOUND because:
Vacant —Does Not Exist Moved —Does Not Reside(Not Vacant)
No Answer on at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
(215)563-7000
Phelan Hallman, LLP OF THE
?ROTHONOTAWY
15 km I I w v. 03
Justin F. Kobeski, Esq., Id. No.200392 13 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 UnosyLVARI ERLA14D COUIATY
One Penn Center Plaza G A.
Philadelphia, PA 19103
justin.kobeski@phelanhallinan.com
215-563-7000
SUNTRUST MORTGAGE, INC. Court of Common Pleas
Plaintiff
Civil Division
V.
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
PLAINTIFF'S MOTION TO REASSESS DAMAGES
Plaintiff,by its Attorneys, Phelan Hallinan, LLP,moves the Court to direct the
Prothonotary to amend the judgment in this matter, and in support thereof avers the following:
I Plaintiff commenced this foreclosure action by filing a Complaint on October 1,
2012.
2. Judgment was entered on December 18, 2012 in the amount of$261,545.79. A
true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and
marked as Exhibit "A".
3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1),a default judgment
containing a dollar amount must be entered for the amount claimed in the complaint and any item
which can be calculated from the complaint,i.e. bringing the interest current. However,new items
cannot be added at the time of entry of the judgment.
4. The Property is listed for Sheriffs Sale on June 5,2013.
257699
5. Additional sums have been incurred or expended on Defendants'behalf since the
Complaint was filed and Defendants have been given credit for any payments that have been made
since the judgment. The amount of damages should now read as follows:
Principal Balance $210,684.61
Interest Through May 13, 2013 $42,722.95
Late Charges $216.69
Legal fees $1,300.00
Cost of Suit and Title $928.75
.Mortgage Insurance Premium/Private Mortgage Insurance $4,691.20
Escrow Deficit $14,488.89
TOTAL $275,033.09
6. Plaintiff paid the following in taxes and insurance during the time the loan Was in
default:
8/2/2010 SCHOOL TAX $157.96
8/31/2010 HAZARD INSURANCE $566.92
4/20/2011 CITY TAX $460.78
8/5/2011 SCHOOL TAX $2,598.84
11/18/2011 HAZARD INSURANCE $2,585.60
1/27/2012 HAZARD INSURANCE $2,656.30
4/5/2012 CITY TAX $439.30
8/1/2012 SCHOOL TAX $2,655.99
11/21/2012 HAZARD INSURANCE $2,367.20
TOTAL $14,488.89
7. The judgment formerly entered is insufficient to satisfy the amounts due on the
Mortgage.
8. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to
inclusion of the figures set forth above in the amount of judgment against the Defendants.
9. Plaintiff's foreclosure judgment is in rem only and does not include personll
liability, as addressed in Plaintiff's attached brief.
257699
10. In accordance with Cumberland County Local Rule 208.3(9),Plaintiff sent a copy of
its proposed Motion to Reassess Damages and Order to the Defendant on March 28, 2013 and
requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants.
A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9)and certification of
mailing are attached hereto, made part hereof, and marked as Exhibit `B".
11. No judge has previously entered a ruling in this case.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the
judgment as requested.
Phelan Hallinan,LLP
DATE: ---� By:
Justin F obeski, squire
ATT EY FOR PLAINTIFF
257699
Phelan Hallman, LLP
Justin F. Kobeski, Esq., Id. No.200392 ATTORNEY FOR PLAINTIIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
justin.kobeski@phelanhallinan.com
215-563-7000
SUNTRUST MORTGAGE, INC. : Court of Common Pleas;
Plaintiff ;
Civil Division
V.
CUMBERLAND Count
JOHN PAUL REEDER
PAMELA IRENE REEDER : No.: 12-6099-CIVIL
Defendants
MEMORANDUM OF LAW IN SUPPORT OF
PLAINT'IFF'S MOTION TO REASSESS DAMAGES
I. BACKGROUND OF CASE
JOHN PAUL REEDER and PAMELA IRENE REEDER executed a Promissory Note
agreeing to pay principal, interest, late charges,real estate taxes, hazard insurance premiums, and
mortgage insurance premiums as these sums became due. Plaintiffs Note was secured b�a
Mortgage on the Property located at 414 NEALY ROAD,NEWVILLE, PA 17241-9472 The
Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance a0y
necessary sums, including taxes, insurance, and other items, in order to protect the security of the
Mortgage.
In the instant case,Defendants defaulted under the Mortgage by failing to tender numerous,
promised monthly mortgage payments. Accordingly,after it was clear that the default woul4 not be
cured,Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently
entered b the Court and the Property perty is currently scheduled for Sheriffs Sale.
257699
Because of the excessive period of time between the initiation of the mortgage foreclosure
action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are
outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums,
costs of collection,and other expenses which Plaintiff has been obligated to pay under the Mortgage
in order to protect its interests. It is also appropriate to give Defendants credit fiat monthly
payments tendered through bankruptcy,if any.
11. LEGAL ARGUMENT TO AMEND PLAINTIFFS IN REM JUDGMENT
It is settled law in Pennsylvania that the Court may exercise its equitable powers to!control
the enforcement of ajudgment and to grant any relief until that judgment is satisfied. 20 PlI .E.,
Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319,321 (1958). Qhgae
Home Mortgage Corporation of the Southwest v. Good 537 A.2d 22,24(Pa.Super. 1988).,The
Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its
judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489
(Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 11998).
Union National Bank of Pittsburgh v. Ciongoli,407 Pa.Super. 171,595 A.2d 179(1991).
The Supreme Court of Pennsylvania recognized in Landau v. Western Pa.Nat.Ban
l ,445
Pa. 117, 282 A.2d 335 (1971),that the debt owed on a Mortgage is subject to change and, in fact,
can be expected to change from day to day because the bank must advance sums in order to protect
its collateral. Because a Mortgage lien is not extinguished until the debt is paid,Plaintiff Must
protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545,2:A.2d
826(1939). Because ajudgment in mortgage foreclosure is strictly in rem, it is critical that the
judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco ggglity
257699
Company v. Bums,414 Pa. 495,200 A.2d 335 (1971). Plaintiff submits that if it goes to sale
without the requested amended judgment,and if there is competitive bidding for the Property,
Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanoed to
protect its interests. Conversely, amending the in rem judgment will not be detrimental to
Defendants as it imputes no personal liability.
In B.C.Y. v. Bukovich,the Pennsylvania Superior Court reiterated its long standing rule that
a Court has the inherent power to correct ajudgment to conform to the facts of a case. 2571Pa.
Super. 157, 390 A.2d 276(1978). In the within case,the amount of the original judgment does not
adequately reflect the additional sums due on the Mortgage due to Defendants' failure to tender
payments during the foreclosure proceeding and the advances made by the mortgage company. The
Mortgage plainly requires the mortgagors to tender to the mortgagee monthly payments of Orincipal
and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagors
are also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance
premiums, fire insurance premiums,taxes and other assessments relating to the Property. The
mortgagor s have breached the terms of the Mortgage,and Plaintiff has been forced to incur,
significant unjust financial losses on this loan.
III. THE FORECLOSURE JUDGMENT IS IN REM ONLY
The within case is a mortgage foreclosure action,the sole purpose of which is to t,*e the
mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortg4ge
foreclosure is strictly in rem and does not include any personal liability. Newtown Village
Partnership v. Kimmel,424 Pa. Super 53, 55, 621 A.2d 1036, 1037(1993). Signal Co
257699
Discount Company v. Babuscio,257 Pa. Super 101, 109, 390 A.2d 266,270(1978). Pennsylvania
Rule of Civil Procedure 1141(a).
However,Pennsylvania law requires that the foreclosure action demand judgment for the
amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgmenI I t is for
bidding at the Sheriff s Sale. In the event that a third party real estate speculator were to b'R*d on the
mortgaged property at the Sheriffs Sale and become the successful purchaser,Plaintiff would
receive the amount of the in rem judgment from the Sheriff.
IV. INTEREST
The Mortgage clearly requires that the Defendants shall promptly pay when due the
principal and interest due on the outstanding debt. In addition,the Note specifies the rate of interest
to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from'3O days
prior to the date of default through the date of the impending Sheriff's sale has been request I ed.
V. TAXES AND INSURANCE
If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure
proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale,
Plaintiffs interest very well may be divested,and Plaintiff would sustain a complete loss on the
outstanding balance due on the loan. If the Property were damaged in a fire,Plaintiff would'!,not be
able to obtain insurance proceeds to restore the Property if it did not pay the insurance premj I ums.
Most importantly,the Mortgage specifically provides that the mortgagee may advance the
monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is
simply seeking to have the Court enforce the terms of the Mortgage.
257699
V1. ATTORNEY'S FEES
The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done
throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91
letters, loan documents,account records, title reports and supporting documents,preparing and
reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule1237.1
Notice, Department of Defense search,entry of judgment,the writ of execution process,!lien
holder notices, and all of the other legal work that goes into handling the mortgage foreclosure
lawsuit.
The Mortgage specifically provides for Plaintiff s recovery of its attorney fees. 'the
amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with! the
loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly con4luded
that a request of five percent of the outstanding principal balance is reasonable and enforceable as
an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865);First Federal Savings and Loan
Association v. Street Road Shopping Center,68 D&C 2d 751, 755 (1974).
In Federal Land Bank of Baltimore v. Fetner,the Superior Court held that an attorney's fee
of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344(Pa. S4�per.
1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent i0cluded
in the judgment in mortgage foreclosure action was reasonable. Citicorp v.Morrisville Hapton
R_ eAt
662 A.2d 1120(Pa. Super. 1995). Plaintiffs legal fees are not a percentage but are
significantly less than what is permitted by Pennsylvania law.
257699
V11. COST OF SUIT AND TITLE
Pursuant to the terms of the mortgage,Plaintiff is entitled to recover all expenses incurred in
the foreclosure action. The amount claimed for the costs of suit and title are the expenses plaintiff
paid to date as a result of the mortgage default.
The title report is necessary to determine the record owners of the property, as P�RCR
1144 requires all record owners to be named as Defendants in the foreclosure action. It Is also
necessary to determine whether there are any prior liens to be cleared, so that the Sherift, s sale
purchaser acquires clear title to the property. It is necessary to determine if there are IR� liens
on the property, whether the Defendants are divorced(which could affect service of the
complaint), and numerous other legal issues. The title bringdown is necessary to identif�any
new liens on the property or new owners between the time of filing and complaint and the writ
date.
The Freedom of Information Act inquiries and the investigation into Defendants"
whereabouts are necessary to effectively attempt personal service of the complaint and notice of
sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P13129.1
and 3129.2 to notify all lienholders,owners,and interested persons of the Sheriff's sale date, as
their interests will be divested by the Sheriff s sale.
Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were
necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incur�� ed.
The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its
foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from
the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of
suit and title in their entirety, which will not cause harm to the Defendants.
257699
V111. PROPERTY INSPECTIONS AND PRESERVATION
The terms of the mortgage provide for property inspections and property preservation
charges. The lender or its agent may make reasonable inspections of the property pursuant to the
terms of the mortgage. When a borrower defaults under the terms of the mortgage, the I nder
may do, or pay for, whatever is reasonable to protect its interest in the collateral, including
property maintenance. Any amounts disbursed by the lender for property inspections and
preservation become additional debt of the borrower secured by the mortgage. The lend�r may
charge the borrower for services performed in connection with the default, for the purpo�e of
protecting the lender's interest in the property, including property inspections and valuation
costs.
When a loan is in default,the lender's risk increases. Mortgage companies typically have
a vendor visit the premises to determine if any windows need to be boarded up, if the pr4perty is
vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection revels any
problems at the mortgaged premises, then the mortgage company may proceed to take whatever
steps are necessary to secure the collateral, such as boarding windows, winterizing, removing
hazards or debris, etc. The mortgage company generally pays a vendor to handle these t4l,.,
which are referred to in the industry as"property preservation". These services avoid code
violations and avoid the property becoming an eyesore in the neighborhood. Property
preservation helps maintain property values in the neighborhood.
Accordingly, line items included in Motions to Reassess Damages for property
inspections and property preservation represent amounts which the mortgage company has paid
out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract.
257699
Since the terms of the mortgage provide that such expenses by the mortgage company become
part of the borrower's debt secured by the mortgage, those expenses are properly included in the
Plaintiff s Motion to Reassess Damages.
IX. CONCLUSION
I
Therefore, Plaintiff respectfully submits that if the enforcement of its rights is dela�ed by
legal proceedings, and such delays require the mortgagee to expend additional sums provided for by
the Mortgage,then the expenses necessarily become part of the mortgagee's lien and should be
included in the judgment.
I
i
Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess
Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance
i
with the Mortgage, and has relied on terms of the Mortgage with the understanding that it�ould
i
recover the monies it expended to protect its collateral.
i
WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the
judgment as requested.
i
�I
Phelan Hallinan, LLP
I
DATE: 4)16lj By: f
Justin F obeski, Esquire
Atto y for Plaintiff
i
I
i
257699
I�
i
i
it
ii
III
III
II
ail
I
II
i
I
I
�I
I
Exhibit "A"
257699
L
PHELAN HAL.LINAN,LLP Attorney for Plaintiff
Zachary Jones,Esq.,Id.No.310721
1617 JFK Boulevard,Suite 1400 ► '
One Penn Center Plaza
Philadelphia,'PA 19103
215-563-7000
SUNTRUST MORTGAGE,INC. CUMBERLAND COUNTY -4
VS. COURT OF COMMON PL
JOHN PAUL REEDER CIVIL DIVISION y<
PAMELA IRENE SEEDER
No.12-6999-CIVIL
PRAAECIPE FOR IN RiM JUDGMENT FOR FA&
ANSWER AND ASSMOM OF DAMAGES
TO THE PROTHONOTARY: l
Kindly aderjudgmenti n favor of the Plaintiff and apiust
I
PAMELA MUM RIMM Defendants for failure to file an Answer to Plam firs C
within 20 days fiorn=vioe&aeof and for foreclomm and sale of the mortgaged premises, nd
assess Plaintiffs damages as follows.
As set forth in Complaint $261,545.79
TOTAL $261,545.79
I hereby certify that(1)the Defendants'last known messes are 414 NEALY Rio ,
NEWVILIA PA 17241-9472 and 322 S SPRING GARDEN ST,C LE,PA 17013-�4,
and(2)that notice has been given in acrotdance with Rule P 37.1
Date
.,Id. No.31072
or tiff
DAMAGES ARE MtEBY ASSESSED AS INDICATED.
DATE:
PM#2"6"
257 99
I
I
i
II
�I
I
I
�I
I
III
I
I
I
I
III
I
�I
I
�I
I
�I
II
I
II
I
II
Exhibit "B"
I
257699
PHELAN HALLINAN, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
FAX#: (215) Sb3-3459
Phelan Hallinan, LLI' Representing Lenders in
Pennsylvania and New J rsey
March 28,2013
JOHN PAUL REEDER
PAMELA IRENE REEDER
322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
RE: SUNTRUST MORTGAGE, INC. v. JOHN PAUL REEDER and PAMELA IRENE
REEDER
Premises Address: 414 NEALY ROAD NEWVILLE,PA 17241
CUMBERLAND County CCP,No. 12-6099-CIVIL
Dear Defendants,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9),I am seeking
concurrence with the requested relief that is,increasing the amount of the judgment. Your
respond to me within 5 days, by 4/3/2013. J gment. Please
Should you have further questions or concerns,please do not hesitate to contact me.
Otherwise,please be guided accordingly.
i
Very truly yours,
i
Justi Esq.,Id. No.200392
A'tto, y for PIaintiff
Enclosure
III
i
I
25 699
v
C .
sy9�
6dY W
a F
ti
P
P
' C
r �
a „r .- b
too
u`.
T
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
justin.kobeski@phelanhallinan.com
215-563-7000
SUNTRUST MORTGAGE, INC. Court of Common Pleas'
Plaintiff
V.
Civil Division
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages,
and Brief in Support thereof, were sent to the following individuals on the date indicated below.
PAMELA IRENE REEDER PAMELA IRENE REEDER
JOHN PAUL REEDER JOHN PAUL REEDER
322 S SPRING GARDEN ST 414 NEALY ROAD
CARLISLE, PA 17013-2554 NEWVILLE,PA 17241-9472
PAMELA IRENE REEDER
JOHN PAUL REEDER
2 RUSH DRIVE
APARTMENT 201
CARLISLE, PA 17013-2262
I
Phelan Hallinan, LLP
III
DATE: Q
By:
Justi . Kobeski,Esquire
A ORNEY FOR PLAINTIFF
i
57699
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
SUNTRUST MORTGAGE, INC. Court of Common Pleas
Plaintiff
Civil Division
V.
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
RULE
AND NOW,this Z� day of 2013, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make-Rule Absolute and no hearing will be scheduled on this matter.
B - COURT
J.
rn
can 7
1 .` x;c3
r :z o
C:, zz o
>(Z
257699
ustin F.Kobeski,Esq.,Id.No.200392
Phelan Hallinan,LLP
1617 JFK Boulevard, Suite 1400
Philadelphia,PA 19103
TEL: (215)563-7000 .
FAX: (215) 563-3459
...XPAMELA IRENE REEDER AMELA IRENE REEDER
JOHN PAUL REEDER JOHN PAUL REEDER
322 S SPRING GARDEN ST 414 NEALY ROAD
CARLISLE, PA 17013-2554 NEWVILLE, PA 17241-9472
XAMELA IRENE REEDER
JOHN PAUL REEDER
2 RUSH DRIVE
APARTMENT 201
CARLISLE, PA 17013-2262
'//f257699
257699
E!LED-O F] E:
OF' THE -PROTHONOTARY
Phelan Hallinan, LLP z����� 23 AM 10� 10
Allison F. Zuckerman, Esq., Id. No. l ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
allison.zuckerynan@phelanhallifian.com
215-563-7000
SUNTRUST MORTGAGE, INC. Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's April 15, 2013 Rule directing
the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individuals on the date indicated below.
PAMELA IRENE REEDER PAMELA IRENE REEDER
JOHN PAUL REEDER JOHN PAUL REEDER
322 S SPRING GARDEN ST 414 NEALY ROAD
CARLISLE, PA 17013-2554 NEWVILLE,PA 17241-9472
PAMELA IRENE REEDER
JOHN PAUL REEDER
2 RUSH DRIVE
APARTMENT 201
CARLISLE,PA 17013-2262
Phelaock -n
DATE: By.
oq.,Id.No.309519
Attor n
257699
C-) na Ca
C
_r. . 0a
=M �
-<D GJ• C
C:)
p O��
C-
PHELAN HALLINAN,LLP Attorney for Plaintiff D o cDr"
John Michael Kolesnik,Esq.,Id.No.308877
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 1.9103
215-563-7000
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
SUNTRUST MORTGAGE,INC. CUMBERLAND COUNTY
Plaintiff,
COURT OF COMMON PLEAS
V.
CIVIL DIVISION
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendant(s)
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.2(a)Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa.R.C.P.3129.2(c)on each of
the persons or parties named,at that address,set forth on the Affidavit and as amended if
applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S.Postal Service is attached he to 't"A".
Johofitcliael Kolesnik,Esq.,Id.No.308877
Date:
1 rney for Plaintiff
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS#257699
Name and Phtlan Hallinan,LLP
Address 1617 IItK Boulevard,Suitt 1400 � a c7
Mender One Penn Center Plaza W
U) ra
Philadelohia PA 19103 KYM
< Line Article Number Na£nt or Addressee.Street and Post Office Address III�Pos e _ 9�
I ••s: JOHN PAUL REEDER
PAMELA IRENE REEDER SOd*a A 14
122 S SPRING GARDEN ST w
CARLISLE4 PA 17013-2554 a 11 m
2 •••• JOIN PAUL REF DER BOAS `at
PAMELA IRENE REEDER w's °co
414 NEAL'Y TOAD
NEWVILLL PA 17241-9472...
3 JOHN PAUL REEDER SQ45
< PAMELA IRENE REEDER r
2 RUSH DRIVE r
APARTMENT201
CARLISLE PA 17013.2252
RE:JOHN PAUL REEDER L'UMBERLAND PUS#2576"A 240 Page I of 1 51:80
?OUl tivabcs et TOW Nomba Nom O£Paul tbrmxttey Pet{NUne b£ 77x U18te}Yntibtbf w'.'tx is �.� .
ngvited Oh tit dxbcssicmd ttuctttrtioaai ttgtstet:d zraif,: stnat�.�N
P"ft UVcObyScA1M xowvd&tpwo(rwt Rrt#tktg Eswts)et} _ ierUxtiC9ftSNCtiCktb£twAtreSaiaNe Cbwmnts cnGa£�ptm MS'tt datme:at:eb tteian itt
Via�e a+hlkC!lot.}imil a£SH0,0}O}+cr oecvnrrrt The anaimam infemairybryabk on£wyrcra Mail arrshaadiae i�SSa},
Tte mWtpn@ inL'Eec9itypayaDle 13(25.006£p ttslNercd tm.Y.smt oiM apliCad itwtttnpe.<See:Demtxic Mu7 btatutil
R9b 541J mn!5421 farYaoiutiaix bf to e:. .4"°+
Yorm 3877 Facsimile
257699
Name and Ptcelan Haliinan,LLP
Addiess M* 107 Jt•K t3ouievard,Suite 1400
O°Sender One Penn Center Plaza
Philade: hiu,PA 19103 AZIUJAND-06/05/2013 SALE
V Line Anicle Number Dame of Addressee,Street,and Post OfliceAddress Nosh _ # old
I •s»» TENANT/OCCUPATVT. . . _.. _-.-....- $0.44
414 MEALY ROAD fv
3 NFWVILL' PA 17241-9471
2 +.s»' DOMESTIC RFI.Arms OF ^
CUMBERLAND COUNTY $D.d4
13 NORTH HANOVER STREET o
,. CARLISLE PA J7013
3 »»*• COMMONWEALTH OF PENNSYLVANIA
$DA4
ai 4 v
DEPARTISENT OF WELFARE
P.O.DOX 2675
HARRISBURG PA 17105
4 •,•' INTERNAL REVENUE SERVICE ADVISORY $0.44
1000 LIBERTY AVENUE.ROO.M 704
P1717SBURGH PA 15x22 �t
5 s»»» US.DEPARTMENT OF JUSTICE S0A4 UI
K US.ATTORNEY FOR THE MIDDLE DISTRICT'OF.PA FEDERAL BLDING 228 WALNUT STREET,SUITE 220 '
PO BOX 21734
HARRISBURG PA 1;108-1754 `lji j It
6 MEMBERS 1ST FEDERAL CREDIT UNION $0A4 _.-
5000 LOUISE DRI19E
MFCHANICSBURG PA 17055
7 MF,MBGRS iST FEDERAL CREDIT UNION C/O FIRST AMERICAN TITLE INSURANCE 54.44
LENDERS ADVANTAGE
ATTN:FT1 120
1100 SUPERIOR AVENUE,SUITE 200
CLEVELAND 081044114
.11 699/102i""""P "�f+I�Dltx'Flf 3
Ttrai ttutrtrref 'row Number of P.-o The fill deehvttiat tf�is uqui rd to un 4cimlic mi intemsi.msl re;imed msi,V*smx,tnni irdennitr p3 f bir
Pieces tawd ty Sendrr Raeived»�Pat Office Imiort Emptoyee) fail.amitnxiionot wneetdntic dxanenn.uWer tix�rcu Plsd dactmrsr rramvnxtwniaxnner 8S10.OSd pn
pNcrt mbcetro�tlrv�ulaHA.ei70 in a.a�ram.tyc nw+im.mi<nf.m,iyPay.ufe ai Hatnens asH nsreM7oe h3xtd.
thr nui=n 1nkM%p.).hi is S2S1Wfnrnthern4>a1,,rre vkh mi-A rr.a•sn�,See,?axaie ttaSl M1
RMS913 ud SA21 for limdflirros of esveryf.
-
Form 3877 Facsimile
Phelan Hallinan, LLP
John D. Krohn,Esq., Id. No.3122 4,, 13 k1i 10*' 09 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
,UtAj8E1RL AND
Philadelphia,PA 19103
john.krohn@phelanhallinan.com
215-563-7000
SUNTRUST MORTGAGE, INC.
Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
MOTION TO MAKE RULE ABSOLUTE
SUNTRUST MORTGAGE, INC.,by and through its attorney, hereby petitions this
Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in
support thereof avers as follows:
1. A Motion to Reassess Damages was filed with the Court on April 11, 2013.
2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy
of its proposed Motion to Reassess Damages and Order to the Defendants on March 28, 2013
and requested the Defendants' Concurrence. Plaintiff did not receive any response from the
Defendants. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and
certificate of mailing are attached hereto,made part hereof, and marked as Exhibit A.
3. A Rule was issued by the Honorable Albert H. Masland on or about April 15,
2013 directing the Defendants to show cause by May 6, 2013 why the Motion to Reassess
Damages should not be granted. A true and correct copy of the Rule is attached hereto, made
part hereof,and marked Exhibit B.
4. The Rule to Show Cause was timely served upon all parties on April 22, 2013 in
accordance with the applicable rules of civil procedurie. A true and correct copy of the
Certificate of Service is attached hereto, made part hereof, and marked Exhibit C.
257699
5. Defendants failed to respond or otherwise plead by the Rule Returnable date of
May 6, 2013.
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiff's Motion to Reassess Damages.
Phelan Hallinan, LLP
DATE: � �d � By.
John D. ohn, sq., Id. No.312244
Attorney for Plaintiff
257699
Exhibit "A" -
257699
PHELAN HALLINAN, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
FAX#: (215) 563-3459
Phelan Hallinan, LLP Representing Lenders in
Pennsylvania and New Jersey
March 28, 2013
JOHN PAUL REEDER
PAMELA IRENE REEDER
322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
RE: SUNTRUST MORTGAGE, INC. v. J014N PAUL REEDER and PAMELA IRENE
REEDER
Premises Address: 414 NEALY ROAD NEWVILLE,PA 17241
CUMBERLAND County CCP,No. 12-6099-CIVIL
Dear Defendants,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9),I am seeking your
concurrence with the requested relief that is, increasing the amount of the judgment. Please
respond to me within 5 days, by 4/3/2013.
Should you have further questions or concerns,please do not hesitate to contact me.
Otherwise,please be guided accordingly.
Very truly yours,
Risffi F, K:.bd l` Esq.,Id. No.200392
A too Y:for Plaintiff
Enclosure
257699
Name and Phelan Hallinan,LLP
Address 1617 JFK Boulevard,Suite 1400 +�
Of Sender One Penn Center Plan 4
Philadelphia,PA 14103 KVNS Cj
go
Line Article Number Name of Addressee,Street,and Post Office Address Postalo t3`�
$ I «««« JOHN PAUL REEDER WAS
PAMELA IREN£REEDER 111 4A a
322 S SPRING GARDEN ST
c.
CARLISLE,PA 17013-2554
�. i a+tn
2 **** JOHN PAUL REEDER $0.45
PAMELA IRENE REEDER Vo°o
414 N£ALY ROAD
NEWVILLE PA 17241-9472
3 «««. JOHN PAUL REEDER $0.45
PAMELA IREN£REEDER
2 RUSH DRIVE
APARTMENT 201
CARLISLE,PA 17013-2262
RE:JOHN PAUL REEDER CUMBERLAND PHS#25769911200 Page I of 1 51.80 Aj
ToWtimaerat Teta?h&*warr arcs Pmuetsm Paniamear The ran dedamdanotvaise k oa an dompKe and iotttaadoaar `. ;
no=Law byUndw Rtoo.adat Pon OWao ReonvteiEnAioyic) roetureewwwimor Mal "I ,I .
*m nbjm to a limit or$%0.000 par ooumenoe the mudmam indwejty pyyaW an EtiWw Matt merebaidiae b SSOD.
The maaimmt payable is 523,000 rnrgbmnd malt,aan with optioaal tnintanN.hSaaDanasde Mai Maawl
R900 5912 aad 5424 far tfmiwiaas or
Form 3877 Facsimile
i
257699.
Exhibit "B"
257699
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
SUNTRUST MORTGAGE, INC. Court of Common Pleas
Plaintiff
Civil Division
v..
CUMBERLAND County
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL
Defendants
RULE
AND NOW,this day of 2013,a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiff s Motion to Reassess Damages. If no response is filed with the Court,Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY THE COURT
, /
1 ! ' _ . sic .°
+? J<
1
a7
U> .
(
Y-=
257699
Exhibit "C"
257699
Phelan Hallinan, LLP
Allison F. Zuckerman, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza
Philadelphia,PA 19103
all,ison:zU.k-erni_arY
215-563-7000
SUNTRUST MORTGAGE, INC.
rt
Plaintiff Cou of Common Pleas
V& Civil Division
.
C`�ta��tn
JOIIN PAUL REEDER CUMBERLAND County
PAMELA IRENE REEDER
No.: 12-6099-CIVIL
Defendants
CERTiIhfCAT>CON_ OF SERVICE
I hereby certify that a true and correct copy of the Court's April 15, 2013 Rule directing
the Defendants to show cause as to why plaintiffs.MA110,1,lc� I2cassc�s l? ��9es;;sitould nc�`rli�t.� ��� r
granted was served upon the following individuals oil tt rlatidi.c�a7.ed belc,u►. tAr
PAMELA IRENE REEDER
JOHN PAUL REEDER PAMELA IRENE REEDER
322 S SPRING GARDEN ST JOHN PAUL REEDER
414 MEALY ROAD
CARLISLE,PA 17013-2554 ,
NEWVILLE,PA 17241-9472 �� q �
PAMELA IRENE REEDER -vz Z
JOHN PAUL REEDER ze co
2 RUSH DRIVE
;:0 mr
cor-
APARTMENT 201 ` tN o
CARLISLE,PA 17013-2262 ,, ' a,.
b
C C3 :;
Phelan Hall:i Z-1
DATE:_
?an,Esq.,Id. No.309519
Attoiney[W aintiff
257699
L
Phelan Hallinan, LLP
John D. Krohn, Esq., Id. No.312244
1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza
Philadelphia, PA 19103
jOhn-krohn@phelanhallinan.com
215-563-7000
SUNTRUST MORTGAGE, INC.
• Court of Common Pleas
Plaintiff
vs.
Civil Division
JOHN PAUL REEDER CUMBERLAND County
PAMELA IRENE REEDER
No.: 12-6099-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute
was served upon the following individuals on the date indicated below.
PAMELA IRENE REEDER PAMELA IRENE REEDER
JOHN PAUL REEDER JOHN PAUL REEDER
322 S SPRING GARDEN ST 414 NEALY ROAD
CARLISLE, PA 17013-2554 NEWVILLE, PA 17241-9472
PAMELA IRENE REEDER
JOHN PAUL REEDER
2 RUSH DRIVE
APARTMENT 201
CARLISLE, PA 17013-2262
Phelan Hallinan, LLP
DATE: "09 By:
John D fro , Esq., Id. No.312244
Attorney for Plaintiff
257699
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
SUNTRUST MORTGAGE, INC. Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND Counf
JOHN PAUL REEDER
PAMELA IRENE REEDER No.: 12-6099-CIVIL;?-m �-
Defendants C)
r-�, cn
�l ORDER y, w s`
AND NOW, this I day of� 2013, upon consideration of Plaintiff s 00
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance $210,684.61
Interest Through May 13, 2013 $42,722.95
Late Charges $216.69
Legal fees $1,300.00
Cost of Suit and Title $928.75
Mortgage Insurance Premium/Private Mortgage Insurance $4,691.20
Escrow Deficit $14,488.89
TOTAL $275,033.09
Plus interest at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
��� �• HE COURT:
J.
J. 12E£.dv,
257699
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson !LED-OF�`1'CE
Sheriff [JF T HE PROT1i6N01'APy
�4,iau? of�mnbci~ �d
Jody S Smith 2013 AUG 27 AM 0: .-
Chief Deputy r ' x`
Richard W Stewart "" ` '`" CUMBERLAND COUNTY
Solicitor OFFICE OF TVE SKERIFF r'E N N S Y LVA N I A
Suntrust Mortgage, Inc.
Case Number
vs.
2012-6099
John Paul Reeder(et al.)
SHERIFF'S RETURN OF SERVICE
03/26/2013 08:42 PM -Deputy Valerie Weary, 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 414 Nealy Road, North Newton-Township, Newville, PA
17241, Cumberland County.
04/05/2013 09:12 PM - Deputy Jason Kinsler, 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:
Pamela Irene Reeder at 322 S. Spring Garden Street, Carlisle Borough, Carlisle, PA 17013, Cumberland
County.
04/05/2013 09:12 PM -Deputy Jason Kinsler, 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:
John Paul Reeder at 322 S. Spring Garden Street, Carlisle Borough, Carlisle, PA 17013, Cumberland
County.
06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Joseph Schalk, on behalf of Federal National Mortgage
Association, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $918.63 SO ANSWERS,
August 19, 2013 RbNO R ANDERSON, SHERIFF
pd .
S7j L-L Pd.
a-it,
(c)CountySuite Sheriff,Toleosoft,Inc.
SUNTRUST MORTGAGE,INC. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
NO.: 12-6099-CIVIL
JOHN- P�iUL_REED.ER
_ a-- - ._ . -- - u:..__... _._. . �_... _.. � .. __....__..._... _-
PAMELA IRENE REEDER
Defendant(s) CUMBERLAND COUNTY
PHS#257699
AFFIDAVIT PURSUANT TO RULE 3129.1
SUNTRUST MORTGAGE,INC.,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the
Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 414 NEALY ROAD,
NEWVILLE,PA 17241-9472.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably ascertained,
please so indicate)
JOHN PAUL REEDER 322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
PAMELA IRENE REEDER 322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
JOHN PAUL REEDER 322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
PAMELA IRENE REEDER 322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
MEMBERS 1ST FEDERAL CREDIT UNION 5000 LOUISE DRIVE.
MECHANICSBURG,PA 17055
MEMBERS 1ST FEDERAL CREDIT UNION ATTN: FT1120
C/O FIRST AMERICAN TITLE INSURANCE 1100 SUPERIOR AVENUE,SUITE 200
LENDERS ADVANTAGE CLEVELAND,OHIO 44114
A. . Name and address oflasf recorded hglder'of every mortgage of record: ,
Ndme Address(if address cannot be
reasonably ascertained,please indicate)
None.
1
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
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.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 414 NEALY ROAD
NEWVILLE,PA 17241-9472
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 1.7108-1754
FEDERAL BUILDING
I verify that.the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date:
By:
P n Hallinan,LLP
n Michael Kol"nik,Esq..,Id.No.308877
Attorndy for Plaintiff
SUNTIiUST MORTGAGE, INC. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
-vs., NO.,: 12-6099-CIVIL
JOHN PAUL REEDER
PAMELA IRENE REEDER CUMBERLAND COUNTY
Defendant(s) :
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JOHN PAUL REEDER
PAMELA IRENE REEDER
322 S SPRING GARDEN ST
CARLISLE,PA 17013-2554
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WELL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house(real estate)at 414 NEALY ROAD,NEWVILLE,PA 17241-9472 is scheduled to be sold at
the Sheriff's Sale on 06/05/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,
Carlisle,PA 17013 to enforce the court judgment of$261,545.79 obtained by SUNTRUST MORTGAGE,INC.
(the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in
compliance with Pa.R.C.P. Rule 31-29.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice-on page tWo on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO"SXVF,'Y6UR PROPERTY*AND YOU HAVE OTHER R1611tS*
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
J
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside,the sale if the bid price was grossly inadequate compared
to.the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid.out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong)are filed with the Sheriff
within ten(10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
r
LEGAL DESCRIPTION
ALL the following described real estate lying and.being situate in North Newton Township,
Cumberland County,Pennsylvania,more particularly-66E6d&d-a'-n-d&kiiibe&Wnidirif—to--a—-
Subdivision Plan for Larry E.Foot, Sr. and H. David Miller,Jr., as recorded in Cumberland County
Plan Book 63,Page 19, as follows:
BEGINNING at a parker kalon nail in Nealy Road,Township Road(T-353),at the northwestern
comer of Lot No. 5 as shown on the above described Subdivision Plan;thence by said Lot No. 5,
South 37 degrees 29 minutes 47 seconds West 585.00 feet to an iron pin,thence by Lot No. I as
shown on the above described subdivision plan,North 52 degrees 30 minutes 13 seconds West
150.00 feet to an iron pin at the southeastern comer of Lot No. 7 as shown on the above described
subdivision plan; thence by said Lot No. 7 North 37 degrees 29 minutes 47 seconds East 585.00 feet
to a parker kalon nail in Nealy Road,Township Road(T-353); thence in said road, South 52 degrees
30 minutes 13 seconds East 150.00 feet to a parker kalon nail in said road,the point and place of
BEGINNING.
CONTAINING 2.01 gross acres and being designated Lot No. 6 as shown on the above described
subdivision plan.
TITLE TO SAID PREMISES IS VESTED IN John Paul Reeder and Pamela Irene Reeder,h/w,
by Deed from David A. Horst and Martha Yvonne Horst,h/w, dated 09/26/2006, recorded
09/26/2006 in Book 276, Page 4091.
PREMISES BEING: 414 NEALY ROAD,NEWVILLE,PA 17241-9472
PARCEL NO. 30-09-0513-024.
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 12-6099-CIVIL
SUNTRUST MORTGAGE, INC.
vs.
JOHN PAUL REEDER
PAMELA IRENE REEDER
owner(s) property
Pennsylvania, being situate in NORTH NEWTON TOWNSHIP, Cumberland County,
(Municipality)
414 NEALY ROAD NEVVVILLE PA 17241-9472
Parcel No. 30-09-0513-024.
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $261,545.79
Phelan Hallinan,LLP
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
Philadelphia,PA 1.9103
215-563-7000
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-6099 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due SUNTRUST MORTGAGE,INC.Plaintiff(s)
From JOHN PAUL REEDER,PAMELA IRENE REEDER
(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: $261,545.79 L.L.:$.50
Interest from 12/19/2012 to Date of Sale($42.99 per diem) -- $7,265.31
Arty's Comm: Due Prothy:$2.25
Atty Paid:$258.75 Other Costs:
Plaintiff Paid:
Date:2/25/2013
David D. Buell,P r o�thh o n o t�a
(Seal)
Deputy
REQUESTING PARTY:
Name:JOHN MICHAEL KOLESNIK,ESQUIRE
Address:PHELAN HALLINAN,LLP
1617 HK BOULEVARD,SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA,PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No.308877
TRUE COPY FROM RECORD
In Testimony whereof,I here unto set my hand
and the seal of said Court at carfiste Pa
This c2Sday of 7-3
prpt4onotary
C
PAV
On March 12, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
North Newton Township, Cumberland County, PA,
Known and numbered as, 414 Nealy Road,
Newville, Exhibit "A".filed with this writ
and by this reference incorporated herein.
Date: March 12, 2013
By:
Real Estate Coordinator
bZ :8 v 9Z 933 EIOI
CUMBERLAND LAW JOURNAL
Writ No. 2012-6099 Civil
SUNTRUST MORTGAGE,INC.
VS.
JOHN PAUL REEDER,
Pamela Irene Reeder
Atty.:Joseph P. Schalk
By virtue of a Writ of Execution
NO. 12-6099-CIVIL, SUNTRUST
MORTGAGE, INC. vs. JOHN PAUL
REEDER, PAMELA IRENE REED-
ER owner(s) of property situate in
NORTH NEWTON TOWNSHIP,Cum-
berland County,Pennsylvania,being
414 NEALY ROAD, NEWVILLE, PA
17241-9472.
Parcel No. 30-09-0513-024.
Improvements thereon:RESIDEN-
TIAL DWELLING.
JUDGMENT AMOUNT:$261,545-
.79.
64
s.
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:
April 12, April 19 and April 26, 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.
L sa Marie Coyne, Ilditor
SW TO AND SUBSCRIBED before me this
--26 day of April, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2414
The Patriot-News Co.
1020 Tezhinrology Pkwy t a
Suite 300
Mechanicsbtirg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
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,
2012-6099 Z This ad ran on the date(s)shown below:
S TRUST MORTGAGE,IN
VS. 04/16113
JOHN PAUL REEDER
TParnela Irene Roeder 04123/13
'ktty: Joseph P Schalk 04/30/13
BY virtue of a Writ of Execution No.
12.6099-CIVIL
SUNIRUST MORTGAGE,INC . . . . . . . .
JOHN PAUL REEDER
PAMELA IRENE REEDER Sworn to and subscribed before me this 13 day of May, 2013 A.D.
owners) of Property situate in NORTH
NEWTON TOWNSHIP, Cumberland
County,Pennsylvania,being
(Municipality)
VP
414 NEALY ROAD, NEWVILLE, PA ry ublic
17241-9472
Parcel No.30-09-0513-024.,--,
(Acreage or street address)
Improvements thereon: RESIDENTIAL
DWELLING
JUDGMENT AMOUNT$261,545.79 COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel,Notary Public
Washington TINP.,Dauphin County
My Commission Expires Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIAMON OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
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 5th day of June A.D., 2013,under and by virtue of a writ Execution issued on
the 25th day of February, A.D., 2013, out of the Court of Common Pleas of said County as of Civil
Term, 2012 Number 6099, at the suit of Suntrust Mortgage Inc. against John Paul Reeder and Pamela
Irene Reeder is duly recorded as Instrument Number 201328476.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D.
&S,
Recorder an
ices ir
wn 4 the of Deeds
d County.Carlisle,PA
My 4commmion ms 1he Fal Monday of Jan,2014