HomeMy WebLinkAbout12-6610Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MAR"1 SON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(71?; 243-3341
Attorneys for Plaintiff
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MEMBERS 1~` FEDERAL CREDIT
UM ON.
Plaintiff
:FAMES R. L[NN and
RUFINA F3. SAI,AS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COI.JNTY, PENNSYLVANIA
NO. 2012 - G~ ~~ CIVIL TERh1
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (2(1) days after this Complaint and Notice are
served, by entering a written appearance personally orby attorney and f-fling in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR_ LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYEK, GO TO OR TELEPHONE "THE OFFICE SET FORTH BELU'W. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY I3E ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFI~EF: LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE: FEE OR NO FEE:
II~ YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAVv YER.
Contact:
Cumberland County Bar Association
32 South. Bedford Street _ ° / p 3 ~7 S ~d °`~Y
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166 G~`~ ,l_ G3 /
v.
Defendants
NOTICE REQUIRED UNDER THE FAIR
DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED) AND
THE PENNSYLVANIA UNFAIR TRADE PRACTICES
ACT AND CONSUMER PROTECTION L,AW,
73 PA. CON. STAT. ANN. §201, ET SEQ. ("THE ACTS")
~I~o the extent the Acts may apply, please be advised of the following:
The amount of the original debt is stated in the Complaint attached hereto.
2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is
owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Fal ler, is filing
this Complaint on behalf of the Creditor.
~. The debt described in the Complaint attached hereto and evidenced by the copies of the note
will be assumed to be valid by the Creditor's law firm, unless the Debtor(s). within thirty
(30) days after receipt of this notice, disputes the validity of the debt or some portion thereof.
~. Il~the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of this
notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain
verification of the debt and a copy of the verification will he mailed to the Debtor(s) by the
Creditor's law firm.
~. If the Creditor who is named as Plaintiff in the attached Complaint is not the original
Creditor, and if the Debtor(s) makes a request to the Creditor''s law firm within thirty days
from the receipt of this notice, the name and address of the oriinal Creditor will be mailed
to the Debtor(s) by the Creditor's law firm.
6. Requests can be made to:
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALI_E,R
Attn: Christopher E. Rice, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
* THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A
DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916 r~
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R. Christopher VanLandingham, Esquire
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Attorney I.D. No. 307424 ~~~~ --+ ~
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MAR"I'SON DEARDORFF WILLIAMS OTTO GII
ROY & FALLER r-
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MARTSON LAW OFFICES :
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(717) 24>- 3341
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Attorneys for Plaintiff ~ .
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MEMBERS 1'` FEDERAL CREDIT
I1MON.
Plaintiff
,IAMI~S R LINN and
RUFINA B. SALAS,
v.
Defendants
IN THE COURT OF COMMON PI_F.A> OF
CUMBERLAND COUNTY, PF;NNSY[.VANIA
NO. 2012 - ~ ~ f'a CIVIL TER>V1
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSiJRE
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 confi~rence in an effort to resolve
this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a
conciliation conference. 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) 822-528$ extension
2510 and request appointment of a legal representative at no charge to you. Once }-~ou have been
appoi nted a legal representative, you must promptly meet with that legal representative within twenty
(20) days of the appointment date. During that meeting, you must provide the legal representative
with all requested financial information so that a loan resolution proposal can be prepared on your
behalf. If you and your legal representative complete a financial worksheet in the format attached
hereto. the legal representative will prepare and file a Request for Conciliation Conference with the
Court. which must be filed with the Court within sixty (60) days of the service upon you of the
foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an
oppol•tunit} to meet with a representative of your lender in an attempt to work out reasonable
arrangements with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps
to be eligible for a conciliation conference. It is not necessary for you to contact Mid]?enn Legal
Services for the appointment of a legal representative. However, you must provide your lawyer with
all requested financial information so that a loan resolution proposal c,an be prepared on yourbehalf:
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 most be filed with the
Court within sixty (60) days of the service upon you of the foreclosure complaint If you do so and
a conciliation conference is scheduled, you will have an opportunity to meet with a representative
of your lender in an attempt to work out reasonable arrangements with your lender before the
mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE
THF. STF,PS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREF,.
Respectfully submitted:
MARTSON LAW OFFICES
Date : ~ ~" , ~ s 11 ~_ .~ ,~}
By: ____
Christopher E. Rice, Esquir
LD. No. 90916
Seth T. Mosebey, Esquire
LD. No. 203046
Ten .East High Street
Carlisle, PA 17013-3093
(717)243-3341
Attorneys for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial F'Vorksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete~your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers:
State: Zip: __ _
Yes ^ No ^ Listing date; _Price: $ --
Realtor Phone: -~~---~~
Yes ^ No ^ -____.-~~-
Home:
Cell:
Email: _
# of people in household: How long?
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
Firs# Mortgage Lender: _
Type of Laan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan. Number:
}fate: Zip: _~_-
Home: Office: _ _ __
Cell: ~ Other;
How long? __
Date You Closed Yous Loan:
Total Mortgage Payments Amount: $
Date of Last Payment:
Primary Reason for Default:
Included Taxes ~ Insurance:
State: Zip: ~__~
Office: _
Other: ^.____
[s the loan in Bankruptcy'? Yes ^ No ^
If yes, provide names, location of court, case number & attorney:
Assets Amouni Owed: Value:
Home: $ $
Other Real Estate: $ $ -
Retirement Funds: $ $ -
Investments: $ $ _
Checking: $ $
Savings: $ $ -'
Other: $ $ _
Automobile #1: Model: yam;
Amount owed: Value:
Automobile #2: Model: yew;
Amount owed: Value:
Other transportation (automobiles. boats motorcxcles)• Model:_
Year. Amount owed: Value
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Exyenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mort a e Food
2 Mort Utilities '
Car Pa ens Condo/Nei .Fees
Auto Insurance Med. not covers
Auto fuel/re airs Other ro . a ent
Install. Loan Pa ent Cable T"V
Child Su ort/Alim. S endin Mone
Da /Child Care/Tuit. Other epees
Amount Available for Monthly Mortgage Payments Hased on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ^ No ^
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax;
2.
l;mail:
Have you made application for Homeowners Emergency Mortgage; Assistance I'ro~,ram
(HEMAP} assistance?
Yes ^ No ^
If yes, please indicate the status of the application:
Have you had any prior negotia#ions with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ^ No ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name);
Servicing Company (Name):
Contact:
Phone:
:Phone;
IlWe, ,authorize the above
named to use/refer this information to my lender,~servicer far the so}e
purpose of evaluating my financial situation for possible mortgage options. U~~,'e
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature
Co-Borrower Signature
Uate
Late
Please forward this document along with the following informQtion to lender and
lender's counsel:
Proof of income
Past 2 bank statements
`~ Proof of any expected income for the last 45 days
~' Copy of a current utility bill
1
~` Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
~'~ Listing agreement (if property is currently on the market)
F.P71l~Cl;enis,l t7pA9embeislsY,l~4?O CurrenP114702?Consuvction Services Linn~114~P _'23 coml wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth "I'. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DF,ARDORFF WILLIAMS OTTO GILROY & FALLER
?VIARTSON LAW OFFICES
10 E~:ast High Street
Carlisle, PA 17013
1:717) 243-3341
Attorneys for Plaintiff
'VIF.MBERS 1 ~` FEDERAL CREDIT
iNI(>N.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
JAMES R. LINN and
RUFTNA 13. SALAS,
NO. 2012 - CIVIL TERN[
Defendants
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, comes the Plaintiff, Members 1S1 Federal Credit Union, by and through its
attorneys, Martson Law Offices, and files this Complaint in Mortgage Foreclosure against
Defendants. James R. Linn and Rufina B. Salas, and in support thereof avers as follows:
1. Plaintiff, Members 1 `Federal Credit Union ("Plaintiff'), is a federally chartered credit
union Located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055.
2. Defendant James R. Linn is an adult individual with a last known address of 1366
Kiner Boulevard, Carlisle, Pennsylvania 17015.
3. Defendant Rufina B. Salas is an adult individual with a last known address of 1366
Kiner Boulevard, Carlisle, Pennsylvania 17015.
4. On or about July 12, 2006, Defendants entered into, among other things, aClosed-End
Note, Disclosure, Loan and Security Agreement ("Note") with Plaintiff to borrow X75,000.00, and
agreed to make 239 semi-monthly payments in the amount of $452.38, and one final payment in the
amount of $450.84 in satisfaction of the principal balance. A true and correct cop}~ of the executed
Note is attached hereto as Exhibit "A" and is incorporated herein by reference..
5. In consideration for the Note, Defendants executed a Mortgage in favor of Plaintiff
encumbering the real property located at 1366 Kiner Boulevard, Carlisle, Pennsylvania (the
"Property"). A true and correct copy of the Mortgage is attached hereto and incorporated herein as
Exhibit "B."
6. The Mortgage was recorded on August 3, 2006, in the Recorder of Deeds Office for
Cumberland County, Pennsylvania at Deed Book 1961, Page 226.
7. Defendants are the owners of the Property.
8. The Mortgage has not been assigned.
9. Plaintiff knows of no other persons holding an ownership interest in the. Property.
] 0. Defendants have defaulted under the Note, by and including, but not limited to,
allowing a material adverse change in their financial condition, and failing to make payments as
required under the Note.
1 1. as authorized under the Note and/or Mortgages, Plaintiff has declared the unpaid
balance of the Note immediately due and payable.
12. The total sum due and owing under the Note, as of September 8, 2012.. is itemized as
follo~~~s:
Principal $41,970.73
Interest (through 9/8/12) $ 1,744.36
Late Charge: $ 45.20
Costs of Suit (estimated) $ 500.00
Attorney Fees (estimated) $ 5,000.00
Total: $49,260.29*
*Plus interest per diem at $8.96, along with additional costs and fees inci.irred, until
paid in full.
1 ~. Plaintiff specifically reserves the right to increase the Costs of Suit and attorney Fees
listed above should additional services be requested and/or costs/charges/fees be incurred as a result
of the collection of the money owed and foreclosure of the Property.
14. Plaintiff has complied with the provisions of Section 403 of Act No. 5, ~ I P.S. § 403.
WHEREFORE, Plaintiff, Members 151 Federal Credit Union, demands judgment against
Defendants James R. Linn and Rufina B. Salas under the Nate in th.e amount of $49,260.29, plus
interest from September 8, 2012, at the rate of $8.96 per day until the debt is paid ins full.
MARTSON LAVV OFFICF,S
By. ~~ ,G~ ~ . '~,,
Christopher E. Rice., Esquire
I.D. No. 90916 -
Seth T. Mosebey, Esquire
LD. No. 203046
"hen East High Street
Carlisle, PA 17013-3093
Date: J0~''z~~/iL ~~I~)2.43-3341
Attorneys for Plaintiff
EXHIBIT "A"
5000 Louise Dnva, P.O. Box 10
Methanicsburq, PA 17055
~1j`
MEMBERS 1•
r.eo.,e,a.relle
:R'b NAME AND ADDREbb
R LINN
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed: he tunouM d Total of Paymentb: The emounl
RATE: me coat DI your utwd ae a The dollar amount the ere:dll w1M aedll Provided to y u or on yDUr you will haw paid pher you haw
yeany rate ' cool you. 6ehU1. made all payments a6 slJteduled.
7.79 % • j 33,589.88 • j 75,000.00 j 108,589.e8
Vanabb Rata; II your loco hoe • wdabb nb ee Mdkabtl abew Ula Annual Parunlap• RW may hu•ua dudnp • 1•rm of Ws vaneactlon II tM (Irldsxl 1]larlpee. Tne
aetlH union wyl adtl a rrlarpln of to Ma index value. TM nb wNl dlanpe monlHy on tM MI dry or Iha mmM. TM b wN1 Haver M Mpher Ulan tM maximum rUe Ubwetl Dy
law. and tI will never be Ina sift . My InbnY nb trlovsee will rsNl st nxrn prym•nb o11M nnN amount. F EnmpN, a Your ban wee for SS,OaO al 15% br ee
monMe and IM AMUU P•runbpe Rab bena•M W 2% albr one yar. Itle brnl or your loan woub kwew DY nbMha
P~M1rntl RUC 11 dlarAad. IM bllowinp applNe to yar Ian:
fX1 Automatic Paymnt Dlseounbd Rab: Because you Tana spread ro make your nquNW moMny paymenb
L your ANNUAL PERCENTAGE RATE Ms seen 6tcamNd D
20K
7M ANNUAL PER
E
T rwpl en eutomaod OeWaion rnm your ChecMMlySavlnpe
y .
.
C
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AGE RATE d
the Aldomaac Payn•M DierauMatl Rab. Thb nla wNl ir10RaN by .2 N yw aria Ma wbmsee payment amnp
rover the wbm We paymerHe. In atYtll a wn
IM eMlx or Ms inorsan wW bs p extend Me term W
F
l etlosed saws M ula ANPB1Al PERCEMAGE RATE Dox la
msnl a feY b Ilwllain IwlstleM tondo In your sacount to
,
your
oan.
or
on a SS.O110.00Ian br 60 months an0 yw Una tlb wbmalk payment artargamenl, yev rob vets husaae l0 10. nmpb, B your Aulomege Payment Oiwvunled Rafe la IO%
0%. muwrp In t sdditlonal payment.
VarlabN RW PnMTd Lana. II your loan Ia ^ wdaWS orb loan antl you quNNy for • pnhmd rM, ywr pnhHr dlamunl a leren U els Gme you bke wl your ben. This
neat pnbrrW ANNUAL PERCENTAGE RATE wIN than wry aocadblp b Iriargn In 9t• Index (n d•tlo•ad abovR
PERCENTAGE RATE a 12% at Ms IIrrM you lake the loan
your inilie Pnbmd ANNU/LL PERCENTAGE RATE
i .For exempla, N a vAabb nl• bsn'a iMtiU ANNUAL
,
w
RATE w+N titan wry aaoMlnp b IM Intln, n dslyotad In Ms'Vsllads Rats' proWebn aDOw. be N/A%. Your kNlrl galsned ANNUAL PERCENTAGE
Fbatl Bala PnbnW Lwna I( your ban is a Bxad rats ban antl you qualy for a prelerrs0 nu, yow ANNUAL PE EMAGE RATE role to Me Dnfansd ANNUAL
PERCENTAGE RATE diudosad above for a loop a your Moaned aMw remains b attaa.
Number of Peym•nb Amount vt PRymenb Pryrmnt Fnqu•nry When Paym•nb An Oua ropaAy Irolrrirlte: YOU may oMaln pro
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Your i surance hom anytxtd you want That is ac
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y 1 lit ~h~ y~ I~yt~~at tM irlaurenre Irom the
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rove: t 5460.84 Final Due • On OBrotY2018 NIA
Saeuny: Coletsral eeluxinp oalar locos wNh the eredN urlbn eta pooch or property
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your Maras erMlor depoen In Ino uadH union, and: x
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Da charged a lab ree U 5% of your acME111p payment not tetra IMO emwnt yow raqulnd dspwe belenp, 8 any. ~ WA j WA
npeymM/: yw PRY • . yw not m WY a Mu N Yow aclmme w
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75,ooo.oD
Amount Paltl to otlxrs on your behell (0
be)
AMOUNT GIVEN TO YOU DIRECTLY j 5B,85D.87 So.oo To NNxbwu tae 5 To
fo.NO To Mxwwa LW 5 To
AMOUNT PAID ON YOUR ACCOUNTS t8,t40.13 j To 5 To
5 To f v oD TD rw
PREPAID FINANCE CHARGE j 0.00 f To Neid SOlu•m S To AMa ceuln>n.
OTHER (Describe): 1388 KINER BLVD
and/or Deposits of 5 5 - - _.. _ _..
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man an oortower, vw apras MM aN dls mndebne or Uls ban and eeaasy apnarrwnb povemMp W s ban s1uM app Io hoM IoHHH entl ssvanlN. You eckrbwledpa Mat you nave
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canbin n paq t.
80 01 ER'S SIONATU END E
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^ ER ^ •OT O ER ^ ^COSIGNER ATE
X (SEAL)
^ O•MAI(ER ~ -OTHER OWNER ^ ••COSIGNER DATE
x (SEAL.)
MAKER •OT 0 ER ^CO-SIGNER DATE
(Sr:AI) 7 I
C R •O HER OWNER ^ ^CO-SIGNER DATE
X ISFiA1)
^ CO-MAKER .OTHER OWNER ~ ^CO-SIGNER GATE
X (SEAL)
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al W IoHWy •M beN•IIRN xeeb ullGr M ben, end N•1 a>Npnwo •Ib prrnYen •n IIG •Iplq• br Ylwnnw.
rM Iwle•IYIe MWOry. 1 eM ]. noel w araw•ne b 1•rrrrer my (wA •IIaIMNb b1 b•unnG: A APPLICANT
1. IAl1pHCW b ib mYxwe• mwonpNP~ eNY) wa you w urMer 7o nn IM rlRHdube m• ~"' '^' I (vE~b ~Np1
Z. IAPPecae• b leeeeary co••raM 6r~ Yw w under •0• •mry alG q yolR bent 0 ^ LJ LJ
owe year home for w•p•e ar Ix•rl ]e holm w nonce TO m ee •IMweeW In•+ay Gb IH ywr ben ANO •n pna•ner 'np
N a4HNbn, H yow ben •wwlb r a,sm,ea IM IaNawb ~ ~I wa Mw been ao wsnlHlp br Je eryx a more bebr• Ile. Gat ^ O ^ o
ppl1rHynn~y ~~ yyawu mry~1N N eRwrlon mGt •bo M •rbw•I.0 In erHn b GbrIrIYM •Hybllry.
3M.y o nMaeh~AOMN Mirl~ongiWMOelHlonq bMe'ome 1/JOB~o~ DS R•~WO C~,orrPl•+ IArtDly xrtaydl orpgGbralry •n•ry rrnaw. eoec• ^ O ^
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o" MMiw Gb al rry IoW) Ww•rle• v,IN w we tleb a as •ppNplbn. My Moon one tllllnrlrlah •rli wNrl anti b Glnw •nY G• aemp•n e1Mr prwn aw w • e nn tp Inwnnw
t•arm•nr a clam oanWnba Y m•r•rbpy IeW IMomrlbn a eorle•Ye fG M PY1pGe of mbb•INnp InhrrMen aenw Irq orry /~iP~~IHw~i wllii not M w•O In eolbrnnl.i ail ePPI uel.
wlNah h • crilM •na •u•lwb e W h pnlen to •nMW •ne a1Nl pnlNn. Do nor •lo dlb pPlfeNlon x •n11rr Ppflo.bN eMG• • 61.nk
oboe •pc•• new na wen aompbbe, IM tlNly he• na NlrGa end Iabd IM ePPlkesan •ntl N N• aPplk Hurl hn net awn Nnw•M.
CREDIT INSU~RA' NCE APPLIED FOR: NOTE: ONLY ON! APPLICANT MAY APPLY FOR p8A81LRy COVERAGE
Yes ~, No Single Credit Li/e ~ Total Premium ^ Yes Q No Credit Disabilty ~ Total Premium
Yes Cxj No Joint Credit LHe
lydiurs whirl) eDpiran9a): ^ ApplloM Co-PppliraM f 0.00 IMicale whlM appkanlU : ^ Applkanl ~ Co-Appllunl ; j 0.00
rw •n a slyy ter ale typo a cw.np. br a acre. b IMla.ra w nl. •nPlr wn.
PP ICAN 5 SI NATUR qTE OF BIRTH ATE ICANTS SIG A DATE OF BIRTH ATE
IP_
N11Gpid700.]t IASEP-WORD r ~]/ee Rav. 11nt o.n. ~ ,r ~ COPYRgNi tU1 Nme•a. uYNUGOnp•na.Inc NlipnY na•ma
JAMES R LINN
N THESE AGREEMENTS THE WORDS 'CREDIT UNION' MEANS MEMBERS 167 FEDERAL CREDIT UNION
NAMED AS BORROWER(S).
LOAN AGREEMENT SECURITY AGREEI
?aymentsJFinance Charges: For value received, you promix to pay, at
the Credit Union's office, ell 8fnoun4 due. All payments shall be made
pureuanl to the disGosure statement on page 1 of this dowment. You
wLIN be ~m«aGemon ltt~e rsccehe~tlWeE d~uaa ~u t 6~Ltparouk ha ~ qua nlt~d }Drente
prefened reN that you confirwe b saUSiv V1e cahrxiibona of that preferted
rate It ycu tail to pay any instaNment by a tithe It Is due, you well pay
additional Interest on the overdue anwunt.
Alloutlon Of Psymertb arld AddlGorNl Psymsnp: Payments entl
credits shall ba appked In the fdbwklp order: arty amounts pant due; any
fees or Glargea owing, InGudnp any insurance pranhrns; aarued Irneroat
or finance Gtarrppes: oulaundlrlp pnrlGpal. Payments made In additbn b
regularly schedWed payments stroll Oe eppN/W in the same order.
Preferred Rata: tl you gwkN for a prefened rate as dsdosod anpsg e 1 of
this doclxnenl or m a sepan s pnlsmW rete eddandlrm, you urld/srstind
that you must meet the oondltlons disclosed b you In order b qualyv for the
preferred rek and must txxllinue to meet those carldkbna In order [o kxp
your prckmed nle. If you IsN to meet those conditbns, your rats wlp
increase, thereby extending Iha terms oaf your loan. You promtae b I:onlinue
you rw IaigO ~r~iceleve tMmprofir~rted~ratetlons under this Agreement even II
ute Charges: It u maNe a late pa nl, you agree to pay a late rdnarge
it one ie disclossdYOOn page t G Ihis document,
Properlyy lrquranCa: It you obtain a loan severed by a motor vehkb or
other laiipibb property, you must obtain insurance which protects tl1e credit
unbn hom financal k»s. The amount and wwrapa IN tM propwty
insurance must be ac~ePtable b the aedt urdon. Such a pohry must
provide et leas) fire, then, combined addkional coverapea and cdlialon
~nsunnca. It must contain a Lou Payade Gauss erMOrsemanl naming the
credit union as lien hrNder. You may pWsh Vds insurance from an spell of
your choice and dreG the agent to send the credit unbn a copy of the
policy.
Debtor Rasponslbllity: You prondae to hotly credk union of any cllanpe h
your name eddrcsa a empb. ympern4 Vou(ypromias not b apply for a loan U
yYyOUr obl~lpahh'o~r1 as~dkp to tDheb l~ W fhe~aedN e~xlens n aYclartpmrtd~se
to inform Credo unbn of any haw irdtxmaUon which re18W to your adllly b
repay your oblipalbn. You Promise not b submit felae or InarzureN
Inlortnalion or wnlNUky conceal Inlwrrlallon regarding your dedilwarthineaa,
credo atandinp, or uedk capaGry.
0717711006
WORDS YOU' YOUR' AND YOURS' MEAN THOSE
ew. kin and NI {xpi'~In~dltuna IncurrW b~ me cndN
M i NCYrIry YLLinit In tM oprvpertPr G Ye{ornlE,AaonYW
id. TM 1{CYrlly kpnal kCludN {p Inuesa{a,
Nom b N{ aicund ppngny, proG{ids hom •ny
ritl property and al{ famings ncNritl howl Mr
Pto~ifry y1rM i{ i~CYf~tY kr Nds loan Or br my
yy pro caaren nepcN 1n
moniy howihold i repot menu an as a1Nd1, or ^n norrpurchase
2. you wIN rat chmae loulion a, rlt a tnnsler 1M cohbral unbas you Mw
ule aetlN urYOnY_pR wllsan tonaenl
7. You waNSnt al nave oood tltla b IM oolhlxal, Irei a NI aicudN Inlsmsu
exw pl Nrt p k va un n entl sxupt M arty klareat al a nonto-
nuliir owner of the Iwro rota Mi aphid tM aQsenroM k, the Wlinlad
DNu
A. You wiN Wy atl Is» , awasmanu, end INm aoalml or ilNChatl b tln orooem
igryamant amen u al u aaal unlars rspuan end wNl daNntl the Dnparry
agavlst rWwra t parry dame
a, you wiN mahlah h irla to cover any whidi or aMr wovanY h wNdr tM
uedrt has ^ ^ ry hlerssl. this Inwfrpana vN M h s form 11ntl a
.ngtml x ,_---.. ~ abN utbn~YOU~WII ytgd~! coo uadN unbn write groat
You IunMr au tM v x union b provldi v?ur hwnnu Sank. Crm/ar
vdN Mds~nmowal wry mu for wAlkaNOn of wegwriuaavarepepv
unbp si wl s e M toa~ayouMaln odNidui e~yibW li pnMnharay to IM pro(sdon Mattel e
credit unbn.
a. OhkNMiliM nleM avt.ny lkmreiRi tlnli'ioa un:Piiwnh'ti re~ae.. w
apne b as~pp~n11 a~ )auNaon awNhk/MUn (10) days whabwr addihonat tNacqor
Ni uaAt 8n teal N muwry to purled IM Gadll unbn ag l posslbb~
loo.
7. s • MaWI as ~rNpprmn h Yti Lan ApriamarU ahouM amt, tln aadil union hu
ha aumamy, ~ s dl daf~ b~epwen arxa al ~ coNalenl h IavAW
manta/. k W rJf . IM u or tlu as 1 Wm a aulhedzad
and
$tstlttory Usn: If yw ors in default, IeOercl Wvr gives the credt urNOn Iha
nght to a the balance of sharp andlor dividends in w aecotml(a at
tfle tlme a fauk b saUaly this Ioan. Once you arc in Qelault, the R
union msY exerdae aNa rip l without fuNler notice b you.
Delay in Enforcamenl: Crodil Unbn may delay enbrcing any of the Uadit
union rights lx1dM this apre@RNrk without bllrlg them.
Irregular PsymanbupTfie creWl unkm may accept late paymenla or partial
Creel tu~rin r g^lepunder thk a~preesmYsr^pitM in IuN, without fosup any of Iha
Co-makeyn: if you are aigninp U1ia apreemenl as a co•maker, ycu agree to
ece~ltha W Do1~0f ymouaTtiebcr elk Union doeiWnotl havedtot not~ly yosYU that this
egteernenl has not been paid. TM Crctlk union may extend fta terms of
paymeM~alnd o lI ~aee ry ceamty wthout nolilying or rekasing you from
spo kY preement.
ConlncNal PNage of 6Mrn: You plidpi all your sMna and diposki In the
cntllt union, lodudirry Nlun atldNbna, n aecunty for Nib ban. In case you
tliNUIL Me CredN unlan cosy sppy Ulife shares ant tlapoalu b tlu paymml
of ill soma due al the Ume of Mhu1L hdudkg coW a colNCUon and
msonabN aaomeya ten, mat Ni cntllt union may Incur, up to 21ya of Ina
unpaid Drlnclpal era Inbmt No INn or right to knPma a Mn orl sham and
depwM atoll apply to anY of your snipe which may be Mld In an 'IndWidual
Rellnmenl AceoYM" a -Keogh Plan"
e. The CridN union
eels wMeh Ihs v
B.
to. Thla r
heirs,
apoolMatl u Your Allonwan•Fad la penam
Nets ere necessary b p eel Ule dolsteral anda~w
epnsrrem rfanss
mower, our oOYUuillom una~r Nlli elYeamenl sn
q puaNy roapomiDle to wlRll the temY o1 Nia
1 oMy binds you. Dul your axewlon, idminlnroon,
610D 2/99
You ere being asked b puaranl9e this tlebL Think uroNlly belore you do. II the bonowx doesn't pay 1 a debt, you wNl have to. Be rote you wn atlord to
pay d you have b. and that you want to accept this msponsibibty.
You may Mw to pry up to IM IuN amount or the dab! if the borrower does not pay. Vou may also have pay Isle lees or colleelbn costa, wnlU increase Ihia
amount.
TM credibr can cdleG This debt Imm YOU without first trying to CONeG Irom the borrower. The cradka n use Ina same collection methods acsinal you iMl
ran bs used against the borrawat, auto as sWnp you, pamlaning yow wages, olc. 11 Nis debt Is ever In ebuN, that IaG may become a pan o{your credit
record. This notice is not Ina contrail that makes you treble fro the debt.
F. 4J7ag 1107
APPRO 9yrlimr, Mf.. SIr~~0r1
Pape 2 of 2
EXHIBIT "B"
Przpareq By: MCmbers 1st FCU
5000 Louise Drive
'vtechanicsburg, PA 17055
When recorded mail CO.~-~~-' - - - -
FtRST AMERrC'f1N fITL~ rNSfRts1 NCl
LF.NDk'2S axj yaR'TAOE
~za~r Evclr~ a ~~NUE, SUITE aoo
CLEVL,'LAND, OHID adll3
AT7:N.• F'TlIZU
P~>Ri4et~ 222. W [~ ~ ~ Sao ~
MORTGAGE
:14ade 07/12/200b _
Between
JAMES R LfNN ANA RUhTNA B SAI.AS
ereina ter cal artgagor")
And
_v1EMl3ERS ls~~ FEDERAL CREDIT Y1NfON
., ... 'v I~~U
~' C:
~~il.~{f?kP,l,_ ,,,
GaGa ~U(~ a 9(~ 1~ 1.1.
~~ ~~~r~
(hereinAfter called "Mortgagee")
Whereas, Mortgagor has ex~uted and delivered to Mortgagee a certain Mortgage Note (hereinafter
^alled the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of
~ 7S 000.00 lawful money of the United States of America, and has provided therein
for payment of any Additional moneys loaned or advanced thereunder by Mortgagee, together with
catntaining c rte a other terpinsvand conditions all of whi h are pouf tally ncorporAted here nhby d
reference;
Now, Tfierefur~e, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor toeated in MONROF
~n~wt~tct-np _ ~'~~mberlflpd - _County, Pennsylvania
SirE EXHIBIT "A"
which currently has the address of 136b TCINER T3LVD fStrcztJ
Carlisle Pennsylvania
[Cityl
a.cc~ No
~~PN~p
170ts ._.
[zip Coda
Page 1 OF 4
~4tI9~fPG0225
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To HAWC and To Hold the same unto Mortgagee, its successors and assi~ms, forever-
Provided, Howovor, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payabla by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shal l keep and perform each of the
other covenants, conditions and agrooments hereinafter set forth, than this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) the Note secured heraby shall evidtlnce and this Mortrtggage shall cover attd bo steurity for any
ftituro loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are full y paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become duo and payabla, alt taxes, assessments, sower and water
rents, and all other charges and ola;ms assessed or levied from lima to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in Herr or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged promises and pay and discharge all
mechanics' lions which may be filed against said premises and which shall or might have priority in Tian
or payment to the debt secured heraby, (c) pay and discharge any documentary stamp or other tax,
includrng interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may fmm time to time
require upon the buildings and improvements now or hcraeftar erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (o) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
~3) Mortgagor shall maintain all buildings and improvements subject to this .Mortgage in good and
substantial repair, as determined 6y Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged promises at any reasonable hour for the purpose of inspecting the ardor, condition and repair
of the buildings and improvements eructed thereon.
Acct No APP~_. ~ _ Pepe 2 of 4
8K! 96 I PG0227
(~) Tn the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fai Is to
ntainte.in the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the
principal debt secured hereby, and collect the same as a part of seed principal debt.
(5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the
mortgaged premises, any debt, lion or charge which would be prior to, or on a parity with, tho lien of this
Mortgage.
(6) in case default be made for the space: of thirty (30) days in the payment of airy installment of
principal or interest pursuant to the torms ofthe Note, or in the performance by Mortgagor of any of the
ether obligations of the Notc or this Mortgage, tho entire unpaid balance of said principal sum, additional
loans ear advances and all other sums paid by Mortgagee pursuant to the terms otPthe Note or this
Mortgage, together with unpaid interest thesreon, shall at the aptien of Mortgagee and without notice
become immediately due and payable, and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with
casts of quit wtd an attorney's commission for cal Icetion of five percent (5°/n) of the total indebtedness or
$200, whichever is the larger amount. Mortgagor hesreby forever waives and releases all errors in said
proceedings, waives stay of execution, the right of inquisition and extension of timo of payment, agrees
to condemnation of any parry leviod upon by virtue of any such axcouticn, and waives all exemptions
from levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums securod by this Mortgage, this Mortgage and the estate conveyed shall
terminate and becornc void. After such occurrence, Mortgagoo shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs, Mortgagees may charge Mortgagor a foe for releasing this
Mortgage, but only if tho fee is paid to a third parry far services rendered and the charging of the fee is
}~ermitteed under Appl icabla Law.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto and their respective heirs, esxeeutars, administrators, successors and
assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each
shall be joint and several.
ncc, No .__._ al~p1D Page s ar a
~~K r~~ i Pcozzs
Witness the due execution hereof the day and year
~~..~,!~
R I.INN
S SAIAS
Commonwealth of Pennsylvania )
) SS:
County of (71A~FRi~~, )
On this, the 1 day of ,2006 betbre me,
~»~ ~ -, t~X~. ; t e unFiT dorsi0nod ofi`icer, personally appeared
SatlSfaCtGrlty prOVen 1Q
meta e e person a w o i ) cribe to the within Mortgage, and acknowledged that
he/she executed the same for the purposes therein contained.
Tn Witness Whereof, I hereunto set my hand and official seal.
..
My commission expires:
COMMO WGALTW (1F P„eNNBYY.UANtA
Norarial coal
Melissa J. Gre9nwood, Notary PublfC
Lower Allan "M+p. Cumberland County
My Commission ~xpireB May 12, 2007
Member, ~enncyl~arna AeccclaUon of NctsrtnC
Nlembera 1sT rederal Credit Union, Mortgagee within named, hereby certifies that its residence
iy 5000 jaouisc Drive, Mechanicsburg, PA ] 7055. ~~
aY _~~ ..._._. -.
Acct No _ ___ Apply . _ _ Page 4 of A
E~~1961PG0229
EXHIBIT A
All that certain property situated in the Township of Monroe,
~n the County of Cumberland, Commonwealth o#: Pennsylvania ,
and bea.ng described as follows: 22240771001. Being more
fully described in a deed dated January 11, 2006 and reccarded
,Tanuary 18, 2006, among the land records of the County and
State set Earth above, in Deed Volume 272 and Page 4028.
Pex~[nanent Marcel Number; 22240771001
JAMES R. LIMN
1366 KINER HOUI+EVARD, CARLISLE PA 17013
T~oan Reference Number 160452
Fixst American Order No: X853163
zdentifi.er: FIRST AMERICAN LENDERS ADVANTAGE
IIII~I1111~11111111111~~IN~ -
AB 3163
FIRST AMERICAN' LENpER5 pQYANTAGE
MORTGAGE
Illil) Illillli llllllllliliilllllllllllllllllilll
~~
.~ , _.. _
a p
V
~~~9~i~GO~~a
VERIFICATION
I, Dan Summers, Collections Manager far Members I S` Federal Credit Union, acknowledge
that I have the authority to execute this Verification on behalf of Members 1 S` Federal Credit Union
and certify that the foregoing Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of this document is that of counsel and not
my own. I have read the document and to the extent the Complaint is based upon information which
I have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent the content of the Complaint is that of counsel, I have relied upon counsel in making
this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
MEMBERS I sT FEDERAL CREDIT UNION
Y~
Dan Summers, Collections Manager
F:IFILES1CIirnu\ 11470 Members i a\ 11470 Curtent\I 1470.222 Condnution Serviw.Linn\11470.222.wm l.wp4
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
f~;LEi~-~f=F1t~
C± ~ ~,~~ r'~OTHOt~t? f +Y
~a~~ttp of ~1trNbrrl,~~m
212 NOY -9 AM 8~ 36
~;~ tip. cuM~~RC.a~~ eou~r~
f~F~~~E AFT..:- e~~Ri~F PENNSY~,VANiA
Members 1st FCU Case Number
vs. 2012-6610
James R. Linn (et al.)
SHERIFF'S RETURN OF SERVICE
11/05/2012 03:55 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Crystal Salas,
step daughter, who accepted as "Adult Person in Charge" for James R. Linn at 1366 Kiner Boulevard,
Monroe Township, Carlisle, PA 17015.
--
DE IS FRY, DES Y
11/05/2012 03:55 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Crystal Salas,
Daughter, who accepted as "Adult Person in Charge" for Rufina B. Salas at 1366 Kiner Boulevard,
Monroe Township, Carlisle, PA 17015.
SHERIFF COST: $50.45
November 07, 2012
DE IS FRY, D
SO ANSWERS,
RON R ANDERSON, SHERIFF
.;c) ~cuntySuite Shenft, Teleasoft, Ino_
FARLESUients11 1470 Mernbersist\1 1470 CurrenN 1470222 Construction Serviceslinn\i 1470.222.mot,staymptl C=
41
—0
Christopher E. Rice, Esquire :2-1 M n :;v
Attorney I.D.No. 90916 V)r-
CD
Seth T. Mosebey, Esquire -.-I
Attorney I.D.No. 203046 C-)
CD
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS I s'FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants IN MORTGAGE FORECLOSURE
PLAINTIFF'S MOTION TO LIFT THE STAY
AND NOW,comes Plaintiff Members l"Federal Credit Union,by and through its attorneys,
MARTSON LAW OFFICES, and files this Motion to Lift the Stay as follows:
1. Plaintiff, Members 1" Federal Credit Union ("Plaintiff"), is a federally chartered
credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055.
2. Defendant James R. Linn is an adult individual with a last known address of 1366
Kiner Boulevard, Carlisle, Pennsylvania 17015.
3. Defendant Rufina B. Salas is an adult individual with a last known address of 1366
Kiner Boulevard, Carlisle, Pennsylvania 17015.
4. Plaintiff filed a Complaint in Mortgage Foreclosure in the above-captioned mortgage
foreclosure action on October 25, 2012, and forwarded a copy of the Complaint in Mortgage
Foreclosure to the Cumberland County Sheriff for service upon Defendants.
5. The Complaint in Mortgage Foreclosure included a Notice ofthe Cumberland County
Residential Mortgage Foreclosure Diversion Program as well as the Financial Worksheets. (See
Complaint in Mortgage Foreclosure).
6. According to the Sheriffs Return of Service, Defendants were served with the
Complaint in Mortgage Foreclosure on November 5, 2012. A true and correct copy of the Sheriff's
Return of Service is attached hereto and incorporated herein as Exhibit"A."
7. Per Administrative Order dated February 28,2012,a 60 day Automatic Stay is placed
on all residential mortgage foreclosure actions in Cumberland County.
8. In order to participate in the Cumberland County Mortgage Diversion Program,
Defendants were required to file a Request for Conciliation Conference within 60 days of the date
of service of the Complaint. Said 60 day deadline expired on or about January 4, 2013.
9. Upon information and belief, Defendants have not filed a Request for Conciliation
Conference in this matter and have not opted into the Diversion Program.
10. No judge has previously ruled in this matter.
11. Plaintiffhas written to Defendants requesting concurrence in this Motion. Defendants
have not concurred with this Motion.
WHEREFORE, Plaintiff requests this Court issue an Order lifting the Stay in this matter.
MARTSON LAW OFFICES
By:
Christopher E. Rice, Esq
I.D.I xTZh
Ono
No. 90916
Seth T. Mosebey, Esquire
I.D. No. 203046
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: April 23, 2013 Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members V Federal Credit
Union. Any information obtained will be used for that purpose.
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor OFFiCe OF TRE$HERIFF
Members 1st FCLI
. Case Number
vs.
James R. Linn (et al.) 2012-6610
SHERIFF'S RETURN OF SERVICE
11/05/2012 03:55 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Crystal Salas,
step daughter,who accepted as"Adult Person in Charge"for James R. Linn at 1366 Kiner Boulevard,
Monroe Township, Carlisle, PA 17015.
DE IS FRY, DEPOTY
11/05/2012 03:55 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by handing a true copy to a person representing themselves to be Crystal Salas,
Daughter, who accepted as"Adult Person in Charge"for Rufina B. Salas at 1366 Kiner Boulevard,
Monroe Township, Carlisle, PA 17015.
DE IS FRY,9ji-K
SHERIFF COST: $50.45 SO ANSWERS,
November 07, 2012 RbNW FANDERSON, SHERIFF
(c)CounlysLiite siiera,,rcir-osoft,im.
A
CERTIFICATE OF SERVICE
I,Mary M. Price,an authorized agent for Martson Deardorff Williams Otto Gilroy&Faller,
hereby certify that a copy of the foregoing Motion to Lift the Stay was served this date by depositing
same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. James R. Linn
Ms. Rufma B. Salas
1366 Kiner Boulevard
Carlisle, PA 17015
MARTSON LAW OFFICES
By:
M Price
Ten ast High Street
Carlisle, PA 17013
Dated: �41asll3 (717) 243-3341
MEMBERS I"FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants IN MORTGAGE FORECLOSURE
ORDER
AND NOW,this day of t4a 2013,upon consideration ofPlaintiff s
Motion to Lift the Stay, it appearing that Defendants have not opted in to the Cumberland County
Residential Mortgage Foreclosure Diversion Program by filing a Request for Conciliation
Conference within 60 days of the date of service upon them of the Amended Complaint in this
action, and it further appearing that the 60 day deadline to file the said Request has expired, said
Motion is hereby granted and it is Ordered that the Stay is hereby lifted.
BY THE COURT,
J.
Distribute to:
,?ristopher E. Rice Esquire
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
Counsel for Plaintiff
r. James R. Linn
s. Rufina B. Salas
1366 Kiner Boulevard
Carlisle, PA 17015
Pro Se Z:m rn
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Christopher E. Rice, Esquire
Attorney I.D. No. 90916 ;' s
Seth T. Mosebey, Esquire = f r1 w
Attorney I.D. No. 203046 2913 JUN � 3
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER ` � �r°
�
MARTSON LAW OFFICES ["UMBERL AND COUNTY
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS ls'FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
V.
: NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS, :
Defendants : IN MORTGAGE FORECLOSURE
PRAECIPE
TO THE PROTHONOTARY:
Please enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendants James R. Linn and Rufina B. Salas in the amount of$49,260.29, plus interest from
September 8,2012,at the rate of$8.96 per day until the debt is paid in full,along with any additional
costs or attorney fees incurred thereafter, for failure to file an Answer to Plaintiffs Complaint.
I do hereby certify that written notice of intention to file this Praecipe was mailed to
Defendants James R. Linn and Rufina B. Salas on May 28, 2013, which date is subsequent to the
date default occurred and at least ten (10) days prior to the date of this Praecipe.
MARTSON LAW OFFICES
By:
X# J, 6�W_�
.3 Christopher E. Rice, Esquir
I.D. Number 90916
Seth T. Mosebey, Esquire
I.D. No. 203046 j�,tl z)
Ten East High Street
Carlisle, PA 17013 `7,!0
(717) 243-3341
Dated: 6/�)//3 Attorneys for Plaintiff
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Plaintiff
MEMBERS I" FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
: NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: James R. Linn DATE OF NOTICE: May 28,2013
1366 Kiner Blvd.,Carlisle,PA
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717)249-3166
MARTSON LAW OFFICES
By: J
Seth T. Mosebey, Esquire
This is a debt collecting firm attempting to collect a debt for Members 1" Federal Credit Union.
Any information obtained will be used for that purpose.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Plaintiff
MEMBERS 1" FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: Rufina B. Salas DATE OF NOTICE: May 28,2013
1366 Kiner Blvd.,Carlisle,PA
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone(717) 249-3166
MARTSON LAW OFFICES
By: v
S
4��-p
eth T. Mosebey, Esquire
This is a debt collecting firm attempting to collect a debt for Members Is`Federal Credit Union.
Any information obtained will be used for that purpose.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS V FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
: NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
Seth T. Mosebey,Esquire,being duly sworn according to law, deposes and says that he has
authority to make this affidavit on behalf of his client,and to the best of his knowledge,information
and belief, Defendant James R.Linn,above named is not in the military service of the United States
of America, that he has knowledge that the said Defendant's last known address is: 1366 Kiner
Boulevard, Carlisle, Pennsylvania 17015. Said Defendant's place of employment is unknown.
-,2� J, 0"�f,
Seth T. Mosebey, Esqu' e
Sworn to and subscribed before me
this L34 day of , 2013.
At',) •L/� MONWEALTH OF PENNSYLVANIA
(� �'s' Notarial Seat
N a ublic Mary M.Price,Notary Public
Ceri, 9oro,Cumberland County
�isslon Expires Aug.18,2015
e/ANIA pgSp6IATi0N OF NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1"FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
: NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
Seth T. Mosebey,Esquire,being duly sworn according to law, deposes and says that he has
authority to make this affidavit on behalf of his client,and to the best of his knowledge,information
and belief, Defendant Rufina B. Salas, above named is not in the military service of the United
States of America, that he has knowledge that the said Defendant's last known address is: 1366
Kiner Boulevard,Carlisle,Pennsylvania 17015. Said Defendant's place of employment is unknown.
J�
Seth T. Mosebey, Esquire
Sworn to and sub cribed before me
this day o , 2013.
�w 'G
ti, ^
Nq/arEjublic
COtWONWE4LTH OF PENNSYLVANIA
Notarial Seal
;mary M.PriceL No
Public
eoro,Crland County
mission Ex Aug.18,2015
memo %-VANTA QATION Of NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1 S`FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND )
Seth T. Mosebey, Esquire, being duly sworn according to law, deposes and says that he is
an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for
the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania
Rules of Civil Procedure, a notice of intention to enter default judgment against Defendant James
R. Linn was given to him by mail on May 28, 2013.
J,
Seth T. Mosebey, Esquire
Sworn to and subscr'bled
before me this day of ' 2013.
NgTar,4ublic COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M.Price,Notary Public
Carlisle Boro,Cumberland County
My commission Expires Aug.18,2015
MEMBER,PENNSYI VANIA ASSOCIATION OF NOTARIES
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS F" FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. :
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF CUMBERLAND )
Seth B. Mosebey,Esquire, being duly sworn according to law, deposes and says that he is
an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for
the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania
Rules of Civil Procedure, a notice of intention to enter default judgment against Defendant Rufma
B. Salas was given to her by mail on May 28, 2013.
J'
Seth T. Mosebey, Esquire
Sworn to and subsc ibed
before me this�day o , 2013.
No ry blic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M.Price,Notary Public
cariisie Boro,Cumberiand County
my Commission Expires Aug.18,2015
MEMW t,PENNSYLVANIA ASSOCIATION OF NOTARIES
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY&FALLER,hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
James R. Linn
1366 Kiner Boulevard
Carlisle, PA 17015
Rufina 8. Salas
1366 Kiner Boulevard
Carlisle, PA 17013
MARTSON LAW OFFICES
By Aw)141, -
M r0A. Price
16 E High Street
Carlisle, PA 17013
Dated:
This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit
Union. Any information obtained will be used for that purpose.
FAFILES\Clients\l 1470 Members st\11470 Current\11470.222 Construction Services.Linn\11470.222.pra.default.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS Isl FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
TO: JAMES R. LINN
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on the 13 day of June, 2013,the following Judgment was
entered against you in the above-captioned action: Judgment in the amount of$49,260.29, plus
interest from September 8,2012,at the rate of$8.96 per day until the debt is paid in full,along with
any additional costs or attorney fees incurred atherea , ilure to ile an Answer Plaintiff s
Complaint.
Date: �'/3•/3 �....•� .
Prothonotary
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
James R. Linn
1366 Kiner Boulevard
Carlisle, PA 17015
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS F" FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
TO: RUFINA B. SALAS
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on the 13"-day of June, 2013, the following Judgment was
entered against you in the above-captioned action: Judgment was entered against you in the
above-captioned action $49,260.29, plus interest from September 8, 2012, at the rate of$8.96 per
day until the debt is paid in full,along with any additional costs or attorney fees incurred thereafter,
for failure to file an Answer to Plaintiffs Complaint.
Date: 4 -13 -1
Jotary
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Rufina B. Salas
1366 Kiner Boulevard
Carlisle,PA 17013
r
[�L�µ-(7�Orp^�is p
F ARLES\Clients\11470 Members 1st\11470 Current\l 1470.222 Construction Services.Linn\11470.222.pral.execution.wpd Oil- THE C g jR 0 T O N O 1 A iN r'
2013 SE1 -3 AM R: 29
Christopher E. Rice, Esquire CUMBERLAND COUNTY
Attorney I.D. No. 90916 PENNSYLVANIA
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS I"FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a writ of execution in the above matter,
(1) directed to the Sheriff of Cumberland County;
(2) against James R. Linn and Rufma B. Salas, Defendants; and
(3) execute against real property known as 1366 Kiner Boulevard,Carlisle,Cumberland
County,Pennsylvania, owned by Defendant James R. Linn,and identified on Exhibit"A"attached
hereto.
Principal Balance: $41,970.73
Late Charge: $ 45.20
Interest past due as of September 8, 2012: $ 1,744.36
Interest accruing at $8.96 per day from September 8, 2012: $
Court Costs and Fees: $
Attorney's Fees: $ 5,000.00
f afi Total Due: $
4113.7T uf�lplc 4 3D u
so s r pe �L ,.r7y3 6
* To be determined by the Cumberland County Sheriff.
MARTSON LAW OFFICES
By:
!, 5: /L.f
Christopher E. Rice, Esquire
I.D. No. 90916
Seth T. Mosebey, Esquire
I.D. No. 203046
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: 3 - 13 Attorneys for Plaintiff
t -
EXHIBIT "A"
DOCKET NO. 2012 - 6610
Tax Parcel No. 22-24-0771-034
ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania,
bounded and described as follows, to wit:
COMMENCE from an iron pin set at the northwest property corner of lands now or formerly of
David and Linda Smith, said point being located on the eastern property line of lands now or
formerly of William & Vera Brubacker; thence along lands now or formerly of David and Linda
Smith North 56 degrees 57 minutes 03 seconds East a distance of 342.12 feet to an iron pin;thence
along the same North 00 degrees 41 minutes 04 seconds East a distance of 89.45 feet to a point;
thence along the northern right-of-way of Kiner Boulevard by a curve to the right having a radius of
60.00 feet, an arc length of 69.18 feet, a chord bearing of North 03 degrees 43 minutes 45 seconds
West and a chord length of 65.41 feet to the point of beginning;
BEGINNING at a point on the northern right-of-way of Kiner Boulevard, said point being the
southeastern property corner of Lot 1 of the Final Subdivision Plan for John Linn;thence along Lot
1 North 60 degrees 41 minutes 50 seconds West a distance of 107.74 feet to a point; thence along
the same North 44 degrees 34 minutes 46 seconds West a distance of 532.29 feet to a point; thence
along lands now or formerly of Agnes Deel,North 56 degrees 31 minutes 13 seconds East a distance
of 229.29 feet to a point; thence along lands now or formerly of Glenn & Vicki Ocamb and lands
now or formerly of Floyd& Kathleen Eckenroad, South 44 degrees 34 minutes 46 seconds East a
distance of 691.01 feet to a point; thence along the northern right-of-way of said Kiner Boulevard
the following 4 courses and distances:
1) Curve to the left having a radius of 1178.79 feet, an arc length of 36.60 feet, a chord
bearing of South 68 degrees 19 minutes 04 seconds West and a chord length of 36.60
feet to a point;
2) South 67 degrees 08 minutes 23 seconds West a distance of 71.08 feet to a point;
3) South 64 degrees 47 minutes 54 seconds West a distance of 20.08 feet to a point;
4) Curve to the left having a radius of 60.00 feet, a curve length of 105.63 feet,a chord
bearing of South 79 degrees 44 minutes 18 seconds West and a chord length of 92.51
feet to the point of beginning.
BEING identified as LOT 2.
TO BE SOLD AS THE PROPERTY OF JAMES R. LINN ON JUDGMENT ENTERED AT
THE ABOVE NUMBER AND TERM.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916 lip THE PROTHONOTAFN"11
Seth T. Mosebey, Esquire 2013SEP -3 AM11: 29
Attorney I.D. No. 203046
MARTSON LAW OFFICES CUMBERLAND COUNTY
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1"FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members I"Federal Credit Union, 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 1366 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania, and as further
described in Exhibit"A" attached hereto:
I Name and address of owner(s) or reputed owner(s):
James R. Linn
1366 Kiner Boulevard
Carlisle, PA 17015
2. Name and address of defendant(s) in the judgment:
James R. Linn
1366 Kiner Boulevard
Carlisle, PA 17015
Rufina B. Salas
1366 Kiner Boulevard
Carlisle, PA 17015
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Members V Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
Harry Grossman
275 Hillside Drive
New Cumberland, PA 17070
Harry Grossman
c/o David J. Lanza,Esquire
2132 Market Street
Camp Hill, PA 17011
United States Department of the Treasury
Internal Revenue Service
500 Woodward Avenue
Detroit, MI 48226
United States Department of the Treasury
228 Walnut Street
Harrisburg, PA 17108
Internal Revenue Service
Attn: Collection Advisory Group Manager
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
Internal Revenue Service
Attn: Collection Advisory Group Manager
600 Arch Street, Room 3259
Philadelphia, PA 19106
4. Name and address of the last recorded holder of every mortgage of record:
Members I" Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record lien on the
property:
None.
6. Name and address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
None.
7. Name and address of every other person of whom the plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
Rufma B. Salas
1366 Kiner Boulevard
Carlisle, PA 17015
1 verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
MARTSON LAW OFFICES
Date: By: Christopher E. Rice, Esquire
EXHIBIT "A"
DOCKET NO. 2012 - 6610
Tax Parcel No. 22-24-0771-034
ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania,
bounded and described as follows, to wit:
COMMENCE from an iron pin set at the northwest property comer of lands now or formerly of
David and Linda Smith, said point being located on the eastern property line of lands now or
formerly of William & Vera Brubacker; thence along lands now or formerly of David and Linda
Smith North 56 degrees 57 minutes 03 seconds East a distance of 342.12 feet to an iron pin;thence
along the same North 00 degrees 41 minutes 04 seconds East a distance of 89.45 feet to a point;
thence along the northern right-of-way of Kiner Boulevard by a curve to the right having a radius of
60.00 feet, an arc length of 69.18 feet, a chord bearing of North 03 degrees 43 minutes 45 seconds
West and a chord length of 65.41 feet to the point of beginning;
BEGINNING at a point on the northern right-of-way of Kiner Boulevard, said point being the
southeastern property comer of Lot I of the Final Subdivision Plan for John Linn;thence along Lot
I North 60 degrees 41 minutes 50 seconds West a distance of 107.74 feet to a point; thence along
the same North 44 degrees 34 minutes 46 seconds West a distance of 532.29 feet to a point;thence
along lands now or formerly of Agnes Deel,North 56 degrees 31 minutes 13 seconds East a distance
of 229.29 feet to a point; thence along lands now or formerly of Glenn & Vicki Ocamb and lands
now or formerly of Floyd& Kathleen Eckenroad, South 44 degrees 34 minutes 46 seconds East a
distance of 691.01 feet to a point; thence along the northern right-of-way of said Kiner Boulevard
the following 4 courses and distances:
I Curve to the left having a radius of 1178.79 feet, an arc length of 36.60 feet,a chord
bearing of South 68 degrees 19 minutes 04 seconds West and a chord length of 36.60
feet to a point;
2) South 67 degrees 08 minutes 23 seconds West a distance of 71.08 feet to a point;
3) South 64 degrees 47 minutes 54 seconds West a distance of 20,08 feet to a point;
4) Curve to the left having a radius of 60.00 feet, a curve length of 105.63 feet,a chord
bearing of South 79 degrees 44 minutes 18 seconds West and a chord length of 92.51
feet to the point of beginning.
BEING identified as LOT 2.
TO BE SOLD AS THE PROPERTY OF JAMES R. LINN ON JUDGMENT ENTERED AT
THE ABOVE NUMBER AND TERM.
Christopher E. Rice, Esquire flL.E 0_0 F F IrCE
Attorney I.D. No. 90916 0!` THE PROTHONO j-A y
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046 7013 SEP —3 AM 11 29
MARTSON LAW OFFICES CUMBERLAND Conti[.Y
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 15`FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
: NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2
TAKE NOTICE that the Sheriff's Sale of Real Property will be held on December 4,2013,
by the Cumberland County Sheriff's Office, at the Cumberland County Courthouse, 1 Courthouse
Square, Carlisle, Pennsylvania, at 10:00 a.m., prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly
consisting of a statement of the measured boundaries of the property,together with a brief mention
of the buildings and any other major improvements erected on the land (SEE LEGAL
DESCRIPTION ATTACHED HERETO).
THE LOCATION of the property to be sold is 1366 Kiner Boulevard, Carlisle,
Pennsylvania 17015.
THE JUDGMENT under or pursuant to which the property is being sold is docketed to:
No. 2012-6610, Cumberland County C.C.P., Pennsylvania.
THE NAME OF THE OWNER OR REPUTED OWNER OF THE PROPERTY IS James
R. Linn.
A SCHEDULE OF DISTRIBUTION, being listed of the persons and/or government or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received and
to be disbursed by the Sheriff(for example,to banks that hold mortgages and municipalities that are
owed taxes) will be filed by the Sheriff within thirty(30) days after the sale, and distribution of the
proceeds of the sale in accordance with this schedule will, in fact,be made unless someone objects
by filing exceptions to it within ten(10)days of the date it is filed. Information about the Schedule
of Distribution may be obtained from the Sheriff of Cumberland County, Cumberland County
Courthouse, 1 Courthouse Square, Room 303, Carlisle, Pennsylvania 17013, (717) 240-6390.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY OR PROPERTY RIGHTS. It has been issued either because there is a Judgment
against you or because the sale of real property described herein may affect an interest you have in
the real property. It may cause your property to be held,sold or taken to pay the Judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
Cumberland County Bar Association
34 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
MARTSON LAW OFFICES
By: C"�/'
Christopher E. Rice, Esquire
I.D. 90916
Seth T. Mosebey, Esquire
I.D. 203046
10 East High Street
Carlisle, PA 17013
�y (717) 243-3341
Date: / '3 " �3 Attorneys for Plaintiff
EXHIBIT "A"
DOCKET NO. 2012 - 6610
Tax Parcel No. 22-24-0771-034
ALL that certain tract of land situate in Monroe Township, Cumberland County, Pennsylvania,
bounded and described as follows, to wit:
COMMENCE from an iron pin set at the northwest property comer of lands now or formerly of
David and Linda Smith, said point being located on the eastern property line of lands now or
formerly of William & Vera Brubacker; thence along lands now or formerly of David and Linda
Smith North 56 degrees 57 minutes 03 seconds East a distance of 342.12 feet to an iron pin;thence
along the same North 00 degrees 41 minutes 04 seconds East a distance of 89.45 feet to a point;
thence along the northern right-of-way of Kiner Boulevard by a curve to the right having a radius of
60.00 feet, an arc length of 69.18 feet, a chord bearing of North 03 degrees 43 minutes 45 seconds
West and a chord length of 65.41 feet to the point of beginning;
BEGINNING at a point on the northern right-of-way of Kiner Boulevard, said point being the
southeastern property corner of Lot I of the Final Subdivision Plan for John Linn;thence along Lot
I North 60 degrees 41 minutes 50 seconds West a distance of 107.74 feet to a point; thence along
the same North 44 degrees 34 minutes 46 seconds West a distance of 532.29 feet to a point; thence
along lands now or formerly of Agnes Deel,North 56 degrees 31 minutes 13 seconds East a distance
of 229.29 feet to a point; thence along lands now or formerly of Glenn & Vicki Ocamb and lands
now or formerly of Floyd& Kathleen Eckenroad, South 44 degrees 34 minutes 46 seconds East a
distance of 691.01 feet to a point; thence along the northern right-of-way of said Kiner Boulevard
the following 4 courses and distances:
1) Curve to the left having a radius of 1178.79 feet,an arc length of 36.60 feet,a chord
bearing of South 68 degrees 19 minutes 04 seconds West and a chord length of 36.60
feet to a point;
2) South 67 degrees 08 minutes 23 seconds West a distance of 71.08 feet to a point;
3) South 64 degrees 47 minutes 54 seconds West a distance of 20.08 feet to a point;
4) Curve to the left having a radius of 60.00 feet, a curve length of 105.63 feet,a chord
bearing of South 79 degrees 44 minutes 18 seconds West and a chord length of 92.51
feet to the point of beginning.
BEING identified as LOT 2.
TO BE SOLD AS THE PROPERTY OF JAMES R. LINN ON JUDGMENT ENTERED AT
THE ABOVE NUMBER AND TERM.
c
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
. �E PROTHONO T Ai%
Seth T. Mosebey, Esquire 01
Attorney I.D. No. 203046 2013 SEP _3 AM It: 29
MARTSON LAW OFFICES
10 East High Street CUMBERLAND COUNTY
Carlisle, PA 17013 PENNSYLVANIA
(717) 243-3341
Attorneys for Plaintiff
MEMBERS I"FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
NOTICE UNDER RULE 2958.2 OF
JUDGMENT AND EXECUTION THEREON
Notice of Defendants' Rights
TO: James R. Linn
A judgment in the amount of$49,260.29 has been entered against you and in favor of the
plaintiff without any prior notice or hearing based on a confession of j udgment contained in a written
agreement or other paper allegedly signed by you. The court has issued a writ of execution which
directs the sheriff to levy upon and sell certain real property owned by you to pay the judgment. The
sheriff's sale has been scheduled for December 4, 2013.
You may have legal rights to defeat the judgment or to prevent or delay the sheriff's sale.
I. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND
PRESENT IT TO A JUDGE WITHIN THIRTY(30)DAYS AFTER THE DATE ON WHICH THIS
NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
II. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND
PRESENT IT TO A JUDGE WITHIN THIRTY(30)DAYS AFTER THE DATE ON WHICH THIS
V
l
NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
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 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.
Cumberland County Bar Association
34 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
MARTSON LAW OFFICES
By
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: 3 Attorneys for Plaintiff
Christopher E. Rice,Esquire
! D-0FF1'CE
Attorney I.D. No. 90916 CF THE PRO THONO TAR`-
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046 2013 SEP -' 3 AM ft 29
MARTSON LAW OFFICES CUMBERLAND COUN T
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS I"FEDERAL CREDIT IN THE COURT OF COMMON PLEAS OF
UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants IN MORTGAGE FORECLOSURE
NOTICE UNDER RULE 2958.2 OF
JUDGMENT AND EXECUTION THEREON
Notice of Defendants' Rights
TO: Rufina B. Salas
A judgment in the amount of$49,260.29 has been entered against you and in favor of the
plaintiff without any prior notice or hearing based on a confession ofludgment contained in a written
agreement or other paper allegedly signed by you. The court has issued a writ of execution which
directs the sheriff to levy upon and sell certain real property owned by you to pay the judgment. The
sheriffs sale has been scheduled for December 4,2013.
You may have legal rights to defeat the judgment or to prevent or delay the sheriff s sale.
1. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND
PRESENT IT TO A JUDGE WITHIN THIRTY(30)DAYS AFTER THE DATE ON WHICH THIS
NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
11. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND
PRESENT IT TO A JUDGE WITHIN THIRTY(3 0)DAYS AFTER THE DATE ON WHICH THIS
t
NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
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 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.
Cumberland County Bar Association
34 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
MARTSON LAW OFFICES
By C�'4 5-. /Z'—'
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Seth T. Mosebey, Esquire
Attorney I.D. No. 203046
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: Attorneys for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 2012-6610 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1ST FEDERAL CREDIT UNION Plaintiff(s)
From JAMES R. LINN and RUFINA B. SALAS
(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
of GARNISHEES)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,
(2) 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$41,970.73 Plaintiff Paid$
Interest PAST DUE AS OF SEPTEMBER 8,2012-$1744.36 -INTEREST ACCRUING AT$8.96
PER DAY FROM SEPTEMBER 8,2012
Attorney's Comm. % $5000.00 Law Library$.50
Attorney Paid$199.20 Due Prothonotary$2.25
Other Costs$45.20-LATE FEES
Date: Sept.3,2013
David D. Buell,Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name : Christopher E.Rice, Esq.
Address: Martson Law Offices,Ten East High Street,Carlisle,PA 17013-3093
Attorney for: Plaintiff
Telephone: 717-243-3341
Supreme Court ID No. 90916
Christopher E. Rice, Esquire ,
Attorney I.D. No. 90916 ?963 SEP 24 PM `� i u S �a
Seth T. Mosebey, Esquire ` I
Attorney I.D. No. 203046 CUMi3ERLANI) C-MBER _/dk:;PENNSYLY OU T , PENNSYr
VAMARTSON LAW OFFICES f �;.
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1St FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
NO. 2012 - 6610 CIVIL TERM
JAMES R. LINN and
RUFINA B. SALAS,
Defendants : IN MORTGAGE FORECLOSURE
AFFIDAVIT OF NOTIFICATION
Christopher E.Rice,Esquire,attorney for Plaintiff,first having been duly affirmed according
to law, deposes and says that on or about the 23rd day of September, 2013, he notified all lien
creditors and any other parties listed in the 3129.1 affidavit of the sheriff's sale in the above-
captioned action. Notification was sent by regular mail. The 3817 certificates of mailing are
attached hereto.
Affirmed and subscribed to before me this�day of September, 2013.
N to Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal Christopher E. Rice, Esquire
Mary M.Price,Notary Public
carllsle Bm,Cumberland County I.D. No. 90916
me commtwon Evire-S Aug.18,2015 Ten East High Street
1IgN OF NOTARIES
Carlisle, PA 17013-3093
(717) 243-3341
Date: 9/24/13 Attorneys for Plaintiff
C
UNITED STATES Certificate Of 30VISOd Sn
POSTAL SERVIC& Mailing
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This forth may be used(or domeaffe and Intematbnal mall. M
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275 Hillside Drive
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Camp Hill, PA 17011 ,r
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UNITEDST/dTES -TOV1SCid SM ;
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228 Walnut Street
Harrisburg, PA 17108
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This Certificate of Mailing provides evidence that mail has been presented to USPS®for mailing.
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"°!� UNITEDSTJITES Certificate Of
1'OST/�L SERVICE Mailin 30Vlsod sn
This CertHicats 01 Mailing provides evidence that mall has been presented to USPS®for mailing.
This Conn may be used for domestic and international mail.
From:
INIARTSON LAW OF c;sn to c
10 East High Street �yp� T� N R
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To: Internal Revenue Service o,/ dd U31SVH
"
Attn: Collection Advisory Group Manager .
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
PC Fnrrn 3817 Andl 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of
POSTAL SERVICE* Mailing 3Odlsod sn"den
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Certificate form y b Of Maed ford mastic a n�tethat mail l Mon. n presented to USPS®for mailing.
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To: Internal Revenue Service
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600 Arch Street, Room 3259
Philadelphia, PA 17055
7�
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UNITEDSTATES Certificate Of
POSTAL SERVICEat Mailing 39d15Od sn
This Certlfieate of Mailing provides evidence that mail has been presented to LISPS®for mailing.
This torn may be used for domestic and International mall.
From:
th
:vIARTSON LAW OFFI S C�� o M o
10 East High Street Q,� N R o
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To: Members 1st Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
PR Fnrm 3817 And 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of
POSTAL SERVICEn Mailing 3!E)tI1sOd sn
This Cert"Icate of Man"provides evidence that mail has been presented to USPS®for mailing.
This form may be used for domestic and International mail.
From: M
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ti OI
MARTSON LAW OFFICES N N s
10 East High Street LL
10-,S-V H
To: Rufina B. Salas
1366 Kiner Boulevard
Carlisle, PA 17013 b,`:
Pc Fnrm 3817 Andl 2007 PSN 7530-02-000-9065
, e
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Notification was
served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage
prepaid, addressed as follows:
James R. Linn
Rufma B. Salas
1366 Kiner Boulevard
Carlisle, PA 17015
MARTSON LAW OFFICES
By , '
Mdry6f. Price
10 East High Street
Carlisle, PA 17013
Dated:
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
y�- PRO
THE K
/A AN 9/ t; I
CUMBERLAND COUNTY
Members 1st ECU
vs.
James R. Linn (et al.)
Case Number
2012-6610
SHERIFF'S RETURN OF SERVICE
09/23/2013 03:14 PM - Deputy Jamie DiMartle, 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 1366 Kiner Boulevard, Monroe - Township, Carlisle, PA
17013, Cumberland County.
09/23%2013 03:14 PM - Deputy Jamie DiMartle, 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 Allison Sassani, Daughter
in Law, who accepted as "Adult Person in Charge" for James R. Linn at 1366 Kiner Boulevard, Monroe
Township, Carlisle, PA 17015, Cumberland County.
08/23/2013 03:14 PM - Deputy Jamie DiMartle, 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 Allison Sassani, Daughter
in Law, who accepted as "Adult Person in Charge" for Rufina B. Sales at 1366 Kiner Boulevard, Monroe
Township, Carlisle, PA 17015, Cumberland County.
11/15/2013 As directed by Christopher E Ricn, Attorney for the P|aindff, Sheriffs Sale Continued to 3/12/2014
03/11/2014 Ronny R Anderson, Sheriff, being duly sworn according to \ew, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1.002.83 SO ANSWERS,
March 14, 2014 RONNYR ANDERSON, SHERIFF
ca,'*���'mw� ^��
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woountywqe. releosott,mc
On September 9, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA,
Known and numbered as, 1366 Kiner Boulevard,
Carlisle, as Exhibit "A" filed with this
in writ and by this Reference incorporated herein.
1 Date: September 9, 2013
0
•
By:
teal
Real Estate Coordinator
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No. 2012-6610 Civil Term
MEMBERS 1ST FCU
vs.
JAMES R. LINN,
Rufina B. Salas
Atty.: Christopher E. Rice
DOCKET NO. 2012-6610.
Tax Parcel No. 22-24-0771-034.
ALL that certain tract of land situ-
ate in Monroe Township, Cumber-
land County, Pennsylvania, bounded
and described as follows, to wit:
COMMENCE from an iron pin set
at the northwest property corner of
lands now or formerly of David and
Linda Smith, said point being located
on the eastern property line of lands
now or formerly of William 8s Vera
Brubacker; thence along lands now
or formerly of David and Linda Smith
North 56 degrees 57 minutes 03 sec-
onds East a distance of 342.12 feet
to an iron pin; thence along the same
North 00 degrees 41 minutes 04 sec-
onds East a distance of 89.45 feet to
a point; thence along the northern
right-of-way of Kiner Boulevard by a
curve to the right having a radius of
60.00 feet, an arc length of 69.18 feet,
a chord bearing of North 03 degrees
43 minutes 45 seconds West and a
chord length of 65.41 feet to the point
of beginning;
BEGINNING at a point on the
northern right-of-way of Kiner Boul-
evard, said point being the south-
eastern property corner of Lot I of the
Final Subdivision Plan for John Linn;
thence along Lot I North 60 degrees
41 minutes 50 seconds West a dis-
tance of 107.74 feet to a point; thence
along the same North 44 degrees 34
minutes 46 seconds West a distance
of 532.29 feet to a point; thence along
lands now or formerly of Agnes Deel,
North 56 degrees 31 minutes 13 sec-
onds East a distance of 229.29 feet
to a point; thence along lands now
or formerly of Glenn 8s Vicki Ocamb
and lands now or formerly of Floyd
& Kathleen Eckenroad, South 44
78
degrees 34 minutes 46 seconds East
a distance of 691.01 feet to a point;
thence along the northern right-
of-way of said Kiner Boulevard the
following 4 courses and distances:
1) Curve to the left having a ra-
dius of 1178.79 feet, an arc length of
36.60 feet, a chord bearing of South
68 degrees 19 minutes 04 seconds
West and a chord length of 36.60
feet to a point;
2) South 67 degrees 08 minutes
23 seconds West a distance of 71.08
feet to a point;
3) South 64 degrees 47 minutes
54 seconds West a distance of 20.08
feet to a point;
4) Curve to the left having a radius
of 60.00 feet, a curve length of 105.63
feet, a chord bearing of South 79
degrees 44 minutes 18 seconds West
and a chord length of 92.51 feet to
the point of beginning.
BEING identified as LOT 2.
TO BE SOLD AS THE PROPERTY
OF JAMES R. LINN ON JUDGMENT
ENTERED AT THE ABOVE NUMBER
AND TERM.
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:
October 11, October 18 and October 25, 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.
arie Coyne, Ed' o
SWORN TO AND SUBSCRIBED before me this
25 da of October, 2013
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot -News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717 - 255 -8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
be IJatriotNews
Now you know
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 the Assistant Controller 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.
`emr..u2su ar dtano..)_(WVTJ3
012 -6610 Civil Term
EMBERS 1ST FCU
vs.
JAMES R. LINN
Ruflna B. Sales
Atty: Christopher E Rice
DOCKET NO. 2012-6610
Tax Parcel No. 22 -24 -0771 -034
ALL that certain tract of land situate in
Monroe Township, Cumberland County,
Pennsylvania, bounded and described as
follows, to wit:
COMMENCE from an iron pin set at fhe
northwest property corner of lands now or
formerly of David and Linda Smith, said
point being located on the eastern property
line of lands now or formerly of William &
Vera Brubackcr, thence along lands now or
formerly of David and Linda Smith North
56 degrees 57 minutes 03 seconds East a
distance of 342.12 feet to an iron pin; thence
along the same North 00 degrees 41 minutes
04 seconds East a distance of 89.45 feet to a
point; thence along the northern right-of-way
of Kiner Boulevard by a curve to the right
having a radius of 60.00 feet, an arc length
of 69.18 feet, a chord bearing of North 03
degrees 43 minutes 45 seconds West and
a chord length of 65.41 feet to the point of
beginning;
BEGINNING at a point on the northem
right-of-way of Kiner Boulevard, said point
he.inv the snutheastern nrnnertv comer' of
suiN
This ad ran on the date(s) shown below:
10/13/13
10/20/13
10/27/13
Sworn to an
1
subscribed before me this 11 day of November, 2013 A.D.
ry ublic
MMONWEALTH OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel, Notary Public
Washington Twp., Dauphin County
My Commission Expires Dec. 12, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES