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Home My WebLink About13-0006ZOf3 JAS ~~M~~ .2 ~M 1I: ~~ PF ~S r~ ~ BUNT ;~ H~A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIItE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIItO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIItE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 JOSEPH F. RIGA, ESQUIItE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T Bank 285 Grand Avenue 200 Southlake, TX 76092 v. Brandon Klawitter 204 South 19th Street Camp Hill, PA 17011 Attorneys for Plaintiff Cumberland County Court of Common Pleas ` ~3-~ ~V< Number ~ 1 ~ r ~ COMPLAINT IN MORTGAGE FORECLOSURE S ~~i163.'~ a~ 12~~4~~b File # 69290 Page 1 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing 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 plaintiff. 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 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. Prothonotary of Cumberland County 1 Courthouse Square Hanover Street Carlisle, PA 17013 717-240-6195 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Prothonotary of Cumberland County 1 Courthouse Square Hanover Street Carlisle, PA 17013 717-240-6195 File # 69290 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T Bank, duly organized and doing business at the above-captioned. address. 2. The Defendant is Brandon Klawitter, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 204 South 19th Street, Camp Hill, PA 17011. 3. On July 2, 2007, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as nominee for Aegis Wholesale Corporation which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1999, Page 4168, such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On September 6, 2012, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc. as nominee for Aegis Wholesale Corporation to M&T Bank, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Instrument Number 201229599, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 204 South 19th Street, Camp Hill, Pennsylvania 17011. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due June 1, 2012 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File # 69290 Page 3 7. The following amounts are due on the mortgage: Principal Balance $ 145,117.44 Interest through January 18, 2013 $ 6,727.73 (Plus $25.84 per diem thereafter) Late Charges $ 391.60 Attorney's Fee $ 1,650.00 Escrow Advance $ 1,3 81.61 Mortgage Insurance Premiums (MIP) $ 250.42 Property Inspections $ 84.00 GRAND TOTAL $ 155,602.80 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested required. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $15 5,602.80, together with interest at the rate of $25.84 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEI BERG AND CONWAY,P.C. BY: [ ] TERREN . McCABE, ESQUIRE [ ] MARC S. WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET GAIRO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [/] HEIDI R. SPNAK, ESQUIRE [ )MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAII., ESQUIRE [ )CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE [ ]JOSEPH F. RIGA, ESQUIRE [ ]JOSEPH I. FOLEY, ESQUIRE Attorneys for Plaintiff File # 69290 Page 4 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WE ERG AND CONWAY,P.C. BY: [ ] TERRENC J. McCABE, ESQUIRE [ ] MARC S. WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET GAIRO, ESQUIlZE [ ]ANDREW L. MARKOWITZ, ESQUIRE /] HEIDI R. SPIVAK, ESQUIRE [ ]MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE [ ]JOSEPH F. RIGA, ESQUIRE [ ]JOSEPH I. FOLEY, ESQUIRE Attorneys for Plaintiff M&T Bank v. Brandon Klawitter File # 69290 Page 5 -• F `, tM r ~ Z J F D b !' ALL THAT CERTAIN piece ar parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by D.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 25,1958, as follows: ~•~ , BEGINNING of a point on the southwesterly side of South 19th Street, said point being marked by an "X" on the concrete walk, at the distance of 132.9 feet southeast of the in#ersection of the southwesterly side of South 19th Street and the southeasterly side i}f Dickinson Avenue; thence extending along the said side of South 19th Street, South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk, at a corner of No. 59, Section "A" of the hereinafter mentioned plan of lots; thence along the same South 54 degrees 23 minutes West, 120 feet to a corner of Lot No. 63, Section "B" on said Plan; thence along the same Nor#h 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No. 61, Section "B" on said'Plan; thence along the same North 54 degrees 23 minutes East,120 feet to the point and place of BEGINNING. BEING Lot No. 60, Sec#ion "B" on a plan of lots, entitled "College Park" which said Plan is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No. 01-22-0536-224 BEING the same premises which Michael P. Milonopoulos, a single person, by deed dated October 11, 2006 and recorded October 13, 2006 in Cumberland County In Deed Book 277, Page 597, granted and conveyed unto Edward S. Shearer, a single person. BEING the same premises which became vested in Brandon Klawitter by deed of Edward S. Shearer, dated July 2, 2007 and recorded contemporaneously herewith in the Office of the Recorder of Deeds in and for Cumberland County. e: rev ~._ rv „ .~ :1: 0 :l. , : + ,'ir ~ ~' r (CMF07-00170.PFDlCMF07-00170/24) BK 1999PG~ 186 M~:T Bank IN THE COURT OF COMMON PLEAS ~ ~ ~' Plaintiff CUMBERLAND COUNTY, PENNSY~N[~ ~-~~ ~~'~{'..'y ~r--. ~~ fV Brandon hla~~~itter ~ ~ Civil { v -~~ ~ ~ r~ ~ _____ _ _ Defendant ~' ~ .T ~ ~~:. ~ --~ c~ -<: ~-, , W~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE . DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have 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) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed 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 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 are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work 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 THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. l ~~ I is Date Respectfully s b fitted: [Signature of ounsel for Plaintiff) 69290 Page 2 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # tiUKKUwr;R 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: Email: # of people on household: State: Zip: Price $ Realtor Phone: How long? State: Office: Other: Zip: Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: First Mortgage Lender: Type of Loan: How long? Yes ^ No ^ Listing date: Loan Number: Second Mortgage Lender: Type of Loan: Loan. Number: Date You Closed Your Loan: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Yes ^ No ^ Home: Cell: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile # 1: Model: Yew.: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles boats motorcycles)• Model Year: Amount owed: Year: Monthly Income Name of Employers: 1. Value: 2. 3. Additional Income Description (not wages): 1 • monthly amount: 2• monthly amount: _ Borrower Pay Days: Co-Borrower Pay Days: Monthtv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fueUrepairs Other prop. payment Install. Loan Payment Cable TV Child SupportlAlim. Spending Money Da /Child Care/Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based 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 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes O No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my fmancial situation for possible mortgage options. I/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information 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 Letter explaining reason for delinquency and any supporting documentation (hardship letter) /~ Listing agreement (if property is currently on the market) Phone: Phone: 3 McCABE,WEISBERG& CONWAY,P.C. i 'S E i`'�i'� BY: CHRISTINE L. GRAHAM-ID#309480 123 South Broad Street,Suite 1400 2093 MAR 22 AEA 9-* 59 Philadelphia,Pennsylvania 19109 'UM8ERIAND 215 790-1010 PENNSYLVANIA M&T Bank Cumberland County Court of Common Pleas Plaintiff No. 13-6-Civil V. Brandon Klawitter Defendant MOTION TO LIFT STAY OF PROCEEDINGS Plaintiff,M&T Bank,hereby motions this Court to remove the captioned mortgage foreclosure action from the Cumberland County Residential Mortgage Foreclosure Program("the Program"), and in support thereof avers as follows: 1. This is an action in mortgage foreclosure brought by M&T Bank against Brandon Klawitter. 2. This case is currently under a stay pursuant to paragraph(b) of the Cumberland County Administrative Order dated February 28, 2012, which establishes the Mortgage Foreclosure Diversion Program. 3. Brandon Klawitter was served a true and correct copy of the original complaint in mortgage foreclosure, filed on January 17, 2013 to his last known address of 204 South 19' Street, Camp Hill, Pennsylvania 17011. the A true and correct copy of the Sheriff's return of service is attached hereto as Exhibit"A". 4. Brandon Klawitter was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet on January 17,2013 to his last known address of 204 South 191 Street, Camp Hill, Pennsylvania 17011. A true and correct copy of the Notice of Residential Mortgage Foreclosure Diversion Program is attached hereto as Exhibit`B". 5. It has been more than sixty days since Defendant(s) was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet and Defendant(s)has not elected to participate in the Program by taking the affirmative steps identified in the Notice of Residential Mortgage Foreclosure Diversion Program,and has not filed a Request for Conciliation Conference. 6. For the reasons set forth herein,the aforementioned stay of proceedings should be lifted to allow Plaintiff to proceed with the instant mortgage foreclosure action. WHEREFORE, it is respectfully requested that the Court enter an Order lifting the stay of proceedings, and for such further relief as the Court deems appropriate. MCCABE,WEISBERG&CONWAY,P.C. I By. CHRISTINE L.G QUIRE • t • McCABE,WEISBERG AND CONWAY,P.C. BY: CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 Attorneys for Plaintiff 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank Cumberland County Court of Common Pleas Plaintiff No. 13-6-Civil V. Brandon Klawitter Defendant CERTIFICATE OF SERVICE I,Christine L. Graham,Esquire,hereby certify that a true and correct copy of Plaintiff s Motion to Lift the Stay of Proceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012,was served on the below named person(s)by regular first class mail,postage prepaid,on March 21, 2013. Brandon Klawitter 204 South 19`' Street Camp Hill, Pennsylvania 17011 Dated: 3�1f,� (23L'- ,p CMU-STINE L.GRA , SQUIRE 3� t� SHERIFFS OFFICE OF CUMBERLAND COUNTY �4 Ronny R Anderson Sheriff �4�'+�t11 at�au►Lrr�yfl� Jody S Smith Chief Deputy • ! Richard W Stewart Solicitor ,FRCE OF THE$j�IR F M&T Bank ' vs. Case Number Brandon Klawitter 2013-6 SHERIFF'S RETURN OF SERVICE 01/17/2013 07:37 PM Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Brandon Klawitter at 204 South 19th Street, Camp Hill,PA 17011.. RYAN BURGETT, DEPUTY SHERIFF COST: $58.00 SO ANSWERS, January 23, 2013 RbNtn R ANDERSON,SHERIFF ._ (c)County$uite SheN'raleoeoti,im, M&'I"Bank IN T14E COURT OF COMMON PLEAS-OF' Plaintiff CUMBERLAND COUNTY, PENNSYIAI�$A . -*"X +.' = !xl ► ° 'Ic Brandon Klawitter S • � Civil r- Defendant < a ,y s* c - =C .. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSITAV 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 a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference.First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you.Once you have been appointed 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 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 are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work 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 THE STEPS REQUIRED BY THIS NOTICE.THIS PROGRAM IS FREE. Respectfully b itted: �a ) Date [Signature of aunsel for Plaintiff] 69290 Page 2 r FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet 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: State: Zip: Is the property for sale? Yes 0 No 0 Listing date: Price$ Realtor Name: Realtor Phone: Borrower Occupied? Yes 0 No 0 Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 i ` OF THE PRO McCABE,WEISBERG& CONWAY,P.C. BY: CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 20 13 NAR 26 AM (1: 2`j 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 CUMBERLAND COUN T;' 21 790-1010 PENNSYLVANIA M&T Bank Cumberland County Court of Common Pleas Plaintiff No. 13-6-Civil V. Brandon Klawitter Defendant ORDER AND NOW, this 24' day of h"%-K 20 13 , upon consideration of Plaintiff's Motion to Lift the Stay of Proceedings Pursuant to Cumberland County AdAhistrative Order dated February 28, 2012, and any opposition thereto, it is hereby ORDERED and DECREED that: The stay of proceedings is hereby lifted, and Plaintiff may proceed with it's action in mortgage foreclosure in accordance with the applicable rules of civil procedure. BY THE COURT: J. ,. McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 1 7616 EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 L= KEVIN T. MCQUAIL,ESQUIRE-ID#307169 c CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 MUD ANN E. SWARTZ,ESQUIRE-ID#201926 �? JOSEPH F.RIGA,ESQUIRE-ID#57716 C) �� ao JOSEPH I. FOLEY, ESQUIRE-ID#314675 r" -'�Q CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 �C-) a°r! 123 South Broad Street, Suite 1400 X CD __. —'D`c Philadelphia, Pennsylvania 19109 (215)790-1010 o M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Brandon Klawitter Number 13-6-CIVIL Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Brandon Klawitter,in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal $ 155,602.80 Interest from 01/19/13 to 04/17/13 $ 2,299.76 Total ' $ 157,902.56 McCABE,WEISBERG AND CONWAY,P.C. BY: [ ]Terrence f. McCabe,Esq. [ arc S. Weisberg,Esq. [ ]Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. [ ]Andrew L.Markowitz, Esq. [ ] Heidi R. Spivak,Esq. [ ] Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ]Joseph I. Foley,Esq. [ ]Celine P. DerKrikorian, Esq. Attorneys for Plaintiff AND NOW,this ,l,?day of A-tC 1 ( ,2013,Judgment is entered in favor of Plaintiff,M&T Bank and against Defendant,Brandon Klawitter,in rem only and not in personam,and damages are assessed in the amount of$157,902.56,plus interest and costs. Vo.50 0,# PA A r 181 857 BY E PR HON Y: g 89 tf�3 R"�iceo Not McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-6-CIVIL Brandon Klawitter Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH,OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Brandon Klawitter, is not in the Military;or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendant,Brandon Klawitter, is over eighteen(18)years of age,and resides as follows: Brandon Klawitter 204 South 19th Street Camp Hill, Pennsylvania 17011 McCABE SBERG AN CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS DAY [ ] Terrence .McCabe,Esq. [ ]Marc .Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF 12013 [ ] Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T. McQuail,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T. LaManna,Esq. NOTARY PUBLIC" [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. CUMMONN'EN�'n��p}:NNSYLYANIA Attorneys for Plaintiff NOTARIAL f;EAL Maleekah%it'aanks-NotaryPubliE M`( ' COMM CO MMISSIIONEXPIRES APRi 06,22'015 r ( v Results as of:Apr-17-2013 07:17:43 Department of Defense Manpower Data Center SCRA 3.0 Status Report i Pursuant to Servicemem1rss Civil Relief Act Last Name: KLAWITTER First Name: BRANDON Middle Name: Active Duty Status As Of: Apr-1 7-2013 On Active Duty On Active Duty Status Date Active Duty Start Data Active Duty End Date Status Service Component NA NA ,� No NA t This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status I s Component NA - NA -_ - No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HIsIHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component { NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of r the individual on the active duty ttatus date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO,NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aa#.� - r A ..+ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 t;� ' The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. 'The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). .This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause:an erroneous certificate to be provided. Certificate ID: S224D429XOB41AO McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215)790-1010 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Number 13-6-CIVIL Brandon Klawitter Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH:OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Brandon Klawitter 204 South 19th Street, Camp Hill,Pennsylvania 17011 McCAB EISBERG AND V7PNW SWORN AND SUBSCRIBED BY: BEFORE ME THIS DAY [ ] Terrence J.McCabe,Esq. [ arc S. We'sberg,Esq. [ ] Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. ,2013 [ ]Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak,Esq. OF [ ] Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. D [ ] Christine L. Graham,Esq. [ ] Brian T. LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F. Riga, Esq. [ ] Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. OI41MONWEA0- cf PENNSV IA Attorneys for Plaintiff Maleekah Wiltbnnks-Notary:Publie City of Philadelphia,Philadelphia County MY COMMISSION EXPIRES APR.06,2015 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ, ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN, ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM, ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-11)#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-6-CIVIL Brandon Klawitter Defendant CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". i McCAB ISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED B BEFORE ME THIS DAY [ ] Terrence J.McCabe,Esq. [ arc S. Weisb rg,Esq. [ ] Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. OF 1 ,2013 [ ] Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak,Esq. a [ ] Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ J Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. COMMON%EAJP,, OF PENNSYLVANIA Attorneys for Plaintiff INOTA17771AL E A L Maleekah V;{lzbanks-Notary:PU61ie City of Phdadeipma,Philadelphia Cajrrty. MY COMMISSION EXPIRES APR.06,2015 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE,WEISBERG AND CONWAY"P.C. BY: [ ] Terrence J.McCabe,Esq. [ arc S.Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ] Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T. LaManna,Esq. ( ]Ann E. Swartz,Esq. [ ]Joseph F.Riga, Esq. [ ]Joseph 1. Foley, Esq. [ ]Celine P.DerKrikorian, Esq. Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary April 4, 2013 To: Brandon Klawitter 204 South 19th Street Camp Hill, Pennsylvania 17011 M&T Bank Cumberland County Court of Common Pleas vs. Number 13-6- CIVIL Brandon Klawitter NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A LISTED sr CNCUENTRA EN ESTADO DE REBELDIA FOR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WIT14 THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y PORNO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA suYo. AL NO TOMAR LA AGAINST YOU WITHOUTA HEARING AND YOU MAY LOSE YOUR PROPERTY ACCION DEBIDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,00 TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BrLOW, Ti-iis OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOSIMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORDTO HIRE A LAWYER,THIS OrFICEMAYBE ABLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TO PROVIDE YOU WITH INFORMATION ABOUTAGENCIES THAT MAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMA06N ACrRCA DE EMPLEAR A UN ABOGADO, Cumberland County Bar Association SI USTED NO PUEDEPROPORC10NAR PARAEMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Hanover Street INFoRmAcON ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS Carlisle,Pennsylvania 17013 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARTO (800)990-9108 REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street franover Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,WEISBERG AND CONWry,P.C. BY: Terrence J.McCabe,Esquire ]*arc S. Weisberg,Esquire Edward D.Conway,Esquire \,_L_-Wargaret Gairo,Esquire Andrew L.Markowitz,Esquire Heidi R. Spivak,Esquire Marisa I Cohen,Esquire Kevin T.McQuail,Esquire Christine L.Graham,Esquire Brian T.LaManna,Esquire Ann E. Swartz,Esquire Joseph F. Riga,Esquire Joseph I.Foley,Esquire Attorneys for Plaintiff hm n OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Brandon Klawitter No. 13-6-CIVIL Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. ` Prothonota X Judgment b Default 1 l Money Judgment ' , a' ,w.r Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION C-) 2 FILE NO.: 13-6-CIVIL Civil Term ° t M&T Bank r%_"21 V. AMOUNT DUE: $157,902.56 M Ma. Brandon Klawitter INTEREST: from 04/18/13 —< c n C)C $3,634.40 at$25.96 ATTY'S COMM.: 2 C:) = n COSTS: 4 �- -G TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s) 204 South 19th Street,Camp Hill,Pennsylvania 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 131 r3 BY: [ ] Terrence J.McCabe,Esq. ] Marc S. Weisberg,Esq. [ J Edward D. Conway,Esq: [ ]Margaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ] arisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. a •�O n,�Q F [✓✓Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. I C)3.7s J 0 t [ ]Joseph I. Foley,Esq. [ ] Celine P.DerKrikorian,Esq. I, t� Attorneys for Plaintiff Firm:MCCABE,WEISBERG AND CONWAY Address:123 S. Broad Street, Suite 1400 Philadelphia,PA 19109 Attorney for: Plaintiff Telephone: (215)790 1010 �S Fes" Supreme Court ID No. 307169 ti . 'So LL_ Ir LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by D.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 25, 1958, as follows: BEGINNING at a point on the southwesterly side of South 19th Street, said point being marked by an "X"on the concrete walk,at the distance of 132.9 feet southeast of the intersection of the southwesterly side of South 19th Street and the southeasterly side bf Dickinson Avenue;thence extending along the said side of South 19th Street, South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk, at a corner of No. 50,Section "A" of the hereinafter mentioned plan of lots;thence along the same South 54 degrees 23 minutes West 120 feet to a corner of Lot No. 63, Section"B"on said Plan; thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No.61, Section "B"on said'Plan;thence along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No.60, Section"B" on a.plan of lots, entitled"College Park"which said Plan Is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No. 01-22-0536-224 RB5678 204 South 19th Street,Camp Hill,Pennsylvania 17011. BEING the same premises which EDWARD S. SHEARER,A SINGLE PERSON,by deed dated July 2,2007 and recorded July 16,2007 in the office of the Recorder in and for Cumberland County in Deed Book 1999,Page 4168, granted and conveyed to Brandon Klawitter,a single person,in fee. TAX MAP PARCEL NUMBER: 01-22-0536-224 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE- ID#17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 cam -,., HEIDI R.SPIVAK,ESQUIRE-ID#74770 3 w -; MARISA J.COHEN,ESQUIRE-ID#87830 �°ym KEVIN T.McQUAIL,ESQUIRE-ID#307169 -r} CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 Nr" BRIAN T.LaMANNA,ESQUIRE-ID#31.0321 -< �c ' ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 )> r, Zfl CD JOSEPH I. FOLEY,ESQUIRE-ID#314675 c "" 123 South Broad Street,Suite 1400 o Philadelphia,Pennsylvania 19109 '{ - 215 790-1010 M&T Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 13-6-CIVIL Brandon Klawitter Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 204 South 19th Street,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Brandon Klawitter 204 South 18th Street Camp Hill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 4. Name and address of the last recorded holder of every mortgage of record: Name Address M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg,Pennsylvania 17055 5. Name and address of every other.person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 South 19th Street Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite 4204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S. Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S. Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: �Z May 13,2013 [ ] Terrence J.McCabe,Esq. ]Marc S. Weisberg,Esq. DATE [ ]Edward D. Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ] Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [t4thristine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F. Riga,Esq. [ ]Joseph i. Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by D.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 25, 1958, as follows; BEGINNING at a point on the southwesterly side of South 19th Street,said point being marked by an"X"on the concrete walk,at the distance of 132.9 feet southeast of the Intersection of the southwesterly side of South 19th Street and the southeasterly side bf Dickinson Avenue;.thence extending along the said side of South 19th Street,South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk, at a corner of No. 59,Section "A" of the hereinafter mentioned plan of tots;thence along the same South 54 degrees 23 minutes West, 120 feet to a corner of Lot No. 63, Section"B"on said Plan; thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No.61, Section "13"on said*Plan;thence along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No.60, Section"B" on a.plan of lots, entitled"College Park"which said Plan is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No. 01-22-0530-224 RB5678 204 South 19th Street,Camp Hill,Pennsylvania 17011. BEING the same premises which EDWARD S. SHEARER,A SINGLE PERSON,by deed dated July 2,2007 and recorded July 16,2007 in the office of the Recorder in and for Cumberland County in Deed Book 1999,Page 4168, granted and conveyed to Brandon Klawitter,a single person,in fee. TAX MAP PARCEL NUMBER: 01-22-0536-224 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#1.7616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 a MARISA J. COHEN,ESQUIRE-ID#87830 c-1 v -mot KEVIN T. McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 rn a rr=i-�-° BRIAN T.LaMANNA,ESQUIRE-ID#310321 r'nt +a ANN E.SWARTZ,ESQUIRE-ID#201926 cn JOSEPH F.RIGA,ESQUIRE-ID#57716 --� JOSEPH I.FOLEY,ESQUIRE-ID#314675 <C) a-I 123 South Broad Street,Suite 1400 = Philadelphia,Pennsylvania 19109 D (215)790-1010 y CIVIL ACTION LAW "� Q M&T Bank COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Brandon Klawitter Number 13-6-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 Your house(real estate)at 204 South 19th Street,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle, Pennsylvania 17013 to enforce the court judgment of$157,902.56 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to M&T Bank the back payments, late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Hanover Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Hanover Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described In accordance With a survey and plan thereof made by D.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 25, 1958, as follows: BEGINNING at a point on the southwesterly side of South 19th Street, said point being marked by an 'Von the concrete walk,at the distance of 132.9 feet southeast of the Intersection of the southwesterly side of South 19th Street and the southeasterly side of Dickinson Avenue;thence extending along the said side of South 19th Street, South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk, at a corner of No. 59,Section "A"of the hereinafter mentioned plan of lots;thence along the same South 54 degrees 23 minutes West, 120 feet to a comer of Lot No. 63, Section"B"on said Plan;thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No.61, Section"B"on said'Plan;thence -along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No. 60, Section 11131' on a plan of lots, entitled"College Park"which said Plan Is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No. 01-22-0536-224 RB5678 204 South 19th Street,Camp Hill,Pennsylvania 17011. BEING the same premises which EDWARD S. SHEARER,A SINGLE PERSON,by deed dated July 2,2007 and recorded July 16,2007 in the office of the Recorder in and for Cumberland County in Deed Book 1999,Page 4168, granted and conveyed to Brandon Klawitter,a single person,in fee, TAX MAP PARCEL NUMBER:01-22-0536-224 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 1.3-6 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due M&T BANK Plaintiff(s) From BRANDON KLAWITTER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $157,902.56 L.L.: .50 Interest FROM 4/18/13-$3,634.40 AT$25.96 Atty's Comm: Due Prothy: $2.25 Atty Paid: $206.75 Other Costs: Plaintiff Paid: Date: 5 115113 David D.B ell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name:CHRISTINE L. GRAHAM,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No.307169 McCABE,WEISBERG AND CONWAY,P.C. • BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 c KEVIN T. MCQUAIL,ESQUIRE-ID#307169 r' �,. CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 - BRIAN T. LAMANNA,ESQUIRE-ID#310321 ter- I o� ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA, ESQUIRE-ID# 57716 ° JOSEPH I.FOLEY, ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 v . 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-6-CIVIL Brandon Klawitter Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 24th day of July, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBE C BEFORE ME THI"4 DAY BY: [ ]Terrence abe,E Ire [ ]Marc S.Weisberg,Esquire OF ,2013 [ ]Edward D.Conway, squire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire ' [ ]Kevin T.McQuail,Esquire 0 r — [ ] Christine L.Graham,Esquire WBrian T.LaManna,Esquire NOTARY PUBLIC [ ]Ann E. Swartz,Esquire [ ]Joseph F. Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MAIA KUSHICK,Notary public City of Philadelphia,Phoa.County Commission Empires May 10,2017 McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321. ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-6-CIVIL Brandon Klawitter Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 204 South 19th Street,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Brandon Klawitter 204 South 18th Street Camp Hill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File#69290 Page I r 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg,Pennsylvania 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 South 19th Street Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 81h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section File#69290 Page 2 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None I verify that.the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. July 24,2013 McCABE,WEISBE co ---- DATE BY: [ ]Terrence e,E [ ]Marc S. Weisberg,Esquire [ ]Edward D.Conway ire [ ]Margaret Gairo,Esquire [ ]Andrew L.Mark z,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ] vm T.McQuail,Esquire [ ]Christine L.Graham,Esquire Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re:M&T Bank v.Brandon Klawitter.et al. Cumberland County;Number: 13-6-CIVIL File#69290 Page 3 McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Brandon Klawitter Number 13-6-CIVIL Defendant DATE:July 24,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Brandon Klawitter PROPERTY:204 South 19th Street,Camp Hill,Pennsylvania 17011 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT:$157,902.56 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of I ien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Check type of mail or service: `� U.S.POSTAGE?PITNEY BOWES Name and Address of Sender °Certified °Recorded Delivery(International) MCCttbe,Weisberg and Conway,P.C. °COD °Registered 123 S:Broad St.,Suite 2080 °Delivery Confirmation °Return Receipt for Merchandise Philadelphia,PA 19109 °Express Mail °Signature Confirmation r 0 ATTN: S.Wiltbanks 69290 °fns°red 02 ; 109 $ 019.20 0001377494JUL. 24. 201.3 Line Article Number Postage 1 M&T Bank Tenants/Occupants Plaintiff 204 South 19th Street Camp Hill,Pennsylvania 17011 V. Brandon Klawitter Defendant 2 Commonwealth of Pennsylvania Department of Public Welfare '`6� dd bi y Bureau of Child Support Enforcement P.O.Box 2675 �. a Harrisburg,PA 17105 Ql, ATTN: Dan Richard x Z r 3 Commonwealth of Pennsylvania Inheritance Tax Office X11 J. j' 110 North 8"Street Suite#204 Philadelphia,PA 19107 4 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor,Strawberry Square Department#280601 Harrisburg,PA 17128 5 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O.Box 8486 Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 7 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 8 Commonwealth of Pennsvlvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg,PA 17128-1230 ATTN: Sheriffs Sales 9 ` United States of America Internal Revenue Service Technical Sunaort Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 10 Domestic Relations Cumberland County P.O.Box 320 Carlisle,PA 17013 11 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 12 United States of America c/o United States Attorney for the 2010-5387 District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 13 United States of America c/o Attv General of the United States U.S.Dent of Justice,Room 5111 950 Pennsvlvania Avenue NW Washington,DC 20530-0001 14 United States of America c/o Attv General of the United States U.S.Dent of Justice,Room 4400 950 Pennsvlvania Avenue NW Washington,DC 20530-0001 15 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg,Pennsylvania 17055 16 M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 Total Number of Pieces Total Number of Pieces Listed by Sender Received at Post Office 16 ,r 2013 AUG 26 PM 2* 05 CUMBERLAND COUNTY McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ, ESQUIRE- ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID#87830 KEVIN T. MCQUAIL, ESQUIRE- ID#307169 CHRISTINE L. GRAHAM, ESQUIRE- ID#309480 BRIAN T. LAMANNA, ESQUIRE- ID#310321 ANN E. SWARTZ, ESQUIRE- ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY, ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank Cumberland County Plaintiff Court of Common Pleas V. Number 13-6- CIVIL Brandon Klawitter Defendant MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Brandon Klawitter, at his last-known address of 204 South 19th Street,Camp Hill,Pennsylvania 17011. The process server was not able to serve the Defendant because defendant not found.Deputy stated that 10 attempts made. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit «A„ 2. Pursuant to Pennsylvania Rule of Civil Procedure 430,Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendant and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". 3. As a result of the investigation,a special Order of Court is required permitting service by regular and certified mail at the Defendant last known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. 5. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendant,Brandon Klawitter,the Plaintiff will be prejudiced. WHEREFORE,Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Notice of Sheriffs Sale of Real Property upon the Defendant, Brandon Klawitter, by regular mail; certified mail, return receipt requested, and by posting at the last-known address of Defendant and the mortgaged premises known in this herein action as 204 South 19th Street, Camp Hill, Pennsylvania 17011. McCAB , EIS RG CO AY,P. BY: [ ] Terr e J. McCabe,Esquire [ ] Marc S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz,Esquire [ ] Joseph F. Riga, Esquire Joseph I. Foley, Esquire Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE- ID# 17616 EDWARD D. CONWAY,ESQUIRE - ID#34687 MARGARET GAIRO, ESQUIRE- ID# 34419 ANDREW L. MARKOWITZ, ESQUIRE- ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID#87830 KEVIN T. MCQUAIL, ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE- ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ, ESQUIRE- ID#201926 JOSEPH F. RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY, ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank Cumberland County Plaintiff Court of Common Pleas V. Number 13-6- CIVIL Brandon Klawitter Defendant MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. McCA SB G AND C NWAY,P.C. B [ ] T nce J. McCabe, Esquire ] Marc S. Weisberg, Esquire [ ] dward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE- ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE- ID# 17616 EDWARD D. CONWAY,ESQUIRE - ID#34687 MARGARET GAIRO, ESQUIRE- ID# 34419 ANDREW L. MARKOWITZ, ESQUIRE- ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J.COHEN, ESQUIRE- ID#87830 KEVIN T. MCQUAIL, ESQUIRE-ID#307169 CHRISTINE L.GRAHAM, ESQUIRE- ID#309480 BRIAN T. LAMANNA, ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE- ID#57716 JOSEPH I. FOLEY, ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 M&T Bank Cumberland County Plaintiff Court of Common Pleas V. Number 13-6- CIVIL Brandon Klawitter Defendant CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he/she served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 22nd day of August, 2013, upon the following: Brandon Klawitter 204 South 19th Street Camp Hill, Pennsylvania 17011 McVceJ.El ER CON AY,P.C. BY: [ ] e, Esquir e ] Marc S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire [ ] Christine L. Graham,Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire !f] Joseph I. Foley, Esquire �kttorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCAB , EIS ERG ONWAY,P.C. BY: [ ] TKward e J. McCabe, Esquire [ ] Marc S. Weisberg, Esquire [ ] D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire Joseph I. Foley, Esquire Attorneys for Plaintiff M&T Bank v.Brandon Klawitter Cumberland County; CCP;Number 13-6-CIVIL File Number: 69290 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ��str nt t.aErt fjp7,4�� Jody S Smith d Chief Deputy Richard W Stewart Solicitor r- M&T Bank Case Number vs. Brandon Klawitter 2013-6 SHERIFF'S RETURN OF SERVICE 07/01/2013 04:17 PM-Deputy Shawn Harrison, 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 204 South 19th Street, Camp Hill -Borough, Camp Hill, PA 17011, Cumberland County. 08/01/2013 12:02 PM -Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Brandon Klawitter, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found" at 204 South 19th Street, Camp Hill, PA 17011, defendant could not be located at this address prior to expiration date, 10 service attempts were made. SHERIFF COST: $942.16 SO ANSWERS, August 05, 2013 RONP R ANDERSON, SHERIFF AFFIDAVIT OF GOOD I Jill 111111111111111111111111111111 FAITH INVESTIGATION *112710* File#:513-0018PA Subject: Brandon Klawitter Last-known Address: 204 South 19th St,Camp Hill,PA 17011 STATE OF NEW YORK • COUNTY OF SUFFOLK ss.: Christina Sattler,the undersigned,being duly sworn,deposes and says,that I am over the age of eighteen and not a party to this action.I reside in the STATE OF NEW YORK. I conducted a good faith investigation into the whereabouts of the Brandon Klawitter at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date DueDiliggnee Remarks 07/30/2013 PROPERTY 204 South 19th St,Camp Hill,PA 17011 ADDRESS: INQUIRY OF LOCAL Directory Assistance: The subject has a 07/30/2013 TELEPHONE telephone listing for the above stated last-known COMPANY: address. Search'results found the number of (717)635-8004 associa ed with the subiect. 07/30/2013 INTERNET SEARCH: Search results show the subject resides at the above_stated last-known address. 07/30/2013 DEATH RECORDS: Social Security Death Index has no record for the subiect. 07/30/2013 LOCAL TAX Search was unable to confirm a mailing address IRECORD INQUIRY forte above stated property addreas.. 1,Christina Sattler,reviewed and signed this affidavit on 07/30/2013. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge,information and belief. S om t and rib re me 40 g p 4p - _20 Christina Sattler Services,Inc. Attorney Outsourcing Supp C#1.421841 2E;�t4 untington Quadrangle,Suite 2SO4 elville,NY 11747 Notary Public, Firm Ref# 5 13-0018PA V!RONICA ANN IRVING State of New York No.U 1 1R0273373 Qualified in Suffolk County Commission Expires December 24,2016 Brandon Klawitter in Camp Hill, PA I WhitePages Page I of 2 WhitePacle • First name lbrandon kla itter • *Last name r • City, State or ZIP 17011 Submit--Query -] Advertisement: a Wh t Brandon Klawitter's Horne i ..firth 5P 8UT-.OW ",: TOO JE rUR. -GET- jn FREE. 1 Result for Brandon Klawitter in Camp Hill, PA 5—eela—m-pLp- Qrsearch: Lost na nt only .Brandon A Klawitter (Age 30.34) 2• S 19th St Cairnp Hill,PA 3, Associated people: Jessica C Klawitter + Additional Suggestions i, Brandon A Klawitter 2. Carlisle—jjd Dillsburg,PA 1 Associated people: Antony J Poulin + more... 5e9.fvljjisti n..g Loading... ://www.wli"tePages.com/name/brandon-klawitter/17011 7/30/2013 Brandon Klawitter in Camp Hill,PA I WhitePages Page 2 of 2 (D 2013 WhitePages Inc.-PLLvAq4 Policy and TeF�_�fU e httpJ/www.whitepages.coin/name/brandon-klawitter/17011 7/30/2013 Free People Search I WhitePages Page 1 of 2 WhitePages ' • First name 113randon • * Last name I Klawitter • City, State or ZIP Camp Hill PA �� Submit Query Advertisement:See What Brandon Klawitter's Home is Worth Wiu ii Plack Star Jest Experterice. VW IL Brandon A Klawitter Claim & Edit Save Address to Mailer Home (717) 635-8004 204 S 19th St Camp Hill, PA 17011-5517 Age: 30-34 Associated: Jessica C Klawitter t � Ia1 k;a f .rtr rr .ti Market-Stoma vy FiatvdGtl P�� .Jf .)� http://www.whitepages.com/name/Brandon-A-Klawitter/Camp-Hill-PA/2swpj6v 7/30/2013 Free People Search WhitePages Page 2 of 2 aif �` Pr EtG�SDtt Sal � �8t ®AN p Z Fetch Q—T AdCboices,> Rd Tb'wnsnkp i 6 2013 Wl ifeNages Inc. - Nriva licy_ and erm§ of Use http://www.whitepages.com/name/Brandon-A-Klawitter/Camp-Hill-PA/2swpj6v 7/30/2013 Page 1 of 2 IRBsearch Person Search Results Records: 1 to 10 of 10 Search Terms Used - SSN: 196-68-xxxx; All Full Name Age/DOB Address Dates Phone Information 1. BRANDON A KLAWITTER 30 204 S 19TH ST Jul 07-Jul 13 Gender:Male Sep xx,1982 CAMP HILL PA 17011-5517 196-68-xxxx LexID:3932474455 We Also ❑ Phones ❑ Property ❑ Business ❑ Email Found: Plus Records Affiliations Address 2. BRANDON A KLAWITTER 128 COLD SPRINGS RD Jun 08.Oct 08 Gender:Male DILLSBURG PA 17019.1549 196.68-xxxx LexID:3932474455 3. BRANDON A KLAWITTER 30 113 NOVEMBER DR APT 1 Jul 06-Sep 07 Gender:Male Sep xx,1982 CAMP HILL PA 17011-5039 196-68-xxxx LexID:3932474455 4. BRANDON A KLAWITTER 30 212 E MAIN ST STE 210 ^^YAug 07 Gender:Male Sep xx,1982 MECHANICSBURG PA 17055-6519 196-68-xxxx LexID:3932474455 S. BRANDON A KLAWITTER 30 113 NOV DR Aug 06 Gender:Male Sep xx,1982 CAMP HILL PA 17011 196-68-xxxx LexID:3932474455 6 BRANDON A KLAWITTER 30 9720 CARLISLE RD APT 5 Jun 04-Jul 06 Gender:Male Sep xx,1982 DILLSBURG PA 17019.9681 196-68-xxxx LexID:3932474455 7. BRANDON A KLAWITTER 30 243 WALTON ST Jun 03-Jun 05 717-774.7006 Gender:Male Sep xx,1982 LEMOYNE PA 17043.2025 MCBRIDE J&LISA 196.68-xxxx LexID:3932474455 BRANDON A KLAWITTER 30 100 LOGAN RD Aug 02-Dec 04 Gender:Male Sep xx,1982 DILLSBURG PA 17019.9501 196-68-xxxx LexID:3932474455 9 BRANDON A KLAWITTER 30 1487 ENGLISH DR Apr 04 Gender:Male Sep xx,1982 MECHANICSBURG PA 17055-5686 196.68-xxxx LexID:3932474455 10. BRANDON A KLAWITTER 141 N 72ND ST Sep 01-Aug 02 Gender:Male HARRISBURG PA 17111.5261 196.68-xxxx LexID:3932474455 https://secure.accurint.com/app/bps/main 7/30/2013 Page 2 of 2 Records: 1 to 10 of 10 Your DPPA Permissible Use: Use in the Normal Course of Business Your GLBA Permissible Use: Authorized by Consumer https:Hsecure.accurint.com/app/bps/main 7/30/2013 -Social Security Death Index (SSDI) Records - Social Security Death Index SSDI Records ... Page 1 of 2 Loa In 1 Subscribe Home About Us F^Help- Learning Center store Questions?Call 1-866-641-3297 Search All Collections Death Records in the Social Security Death Index Newspapers (SSDI) i Recent Obituaries Discover Your Family's Past in: Newspaper Archives Newspaper Archives(1690-2010) All of GenealoavBank Historical Obituaries Historical Obituarles(1704-1999) Recent Obituaries(1977-Today) Birth Records Marriage Records Passenger Lists Newspaper Articles Your search did not match any Items in Social Security Death Index. Legal.Probate&Court Photos&Illustrations Suggestions v More Check your spelling. --- -- --' Try inserting wildcards in place of any easily misread letters,like"Mo??oy"or "Mo'oy."The question mark wildcard will match any single character,and the Other Genealogy Records asterisk will match up to five characters.Learn More • Try searching for other distinctive information about your ancestor using the Social Security Death Index ! "Include keywords"field. Historical Books Historical Documents African-American Newspapers Irish-American Newspapers I Need Help Searching Your Ancestors? Contact Us Now Toll Free 1-866-223-8535 Our family history consultants are here to help. 11am-7pm EST ZS}.YS'SM1 a i;?033o�fir W3b�'5a4zx��x� aaz&fl�xaroti. # �;3?�o�SCSNti°6WWd3Kr33" Try another search! Last Name First Name Middle Initial ti ft r http://www,genealogybank.com/gbnk/ssdi/?Maine=&frame=&minit=&birthy_0=&birthy_... 7/30/2013 .Social Security Death Index(SSDI)Records- Social Security Death Index SSDI Records ... Page 2 of 2 Date Information ......... . .. ............ ......... .. „ .......... .............. . .............................., ,... .... Born Between year'._ and year _.. Died Between year and year Last Known Residence City County State Any !�!� OR ZIP Code OR Non-U.S. Location Social Security Number Details State SSN Issued Any "I Social Security Number: 196-68-9538 °. Search Tins Clear Form I Begin Search o Stay connected.Follow us! in the news contact us ( affiliates privacy policy terms of use ( site map ( blog http://www,genealogybank.com/gbnkJssdi/?Iname=&frame=&minit=&birthy_0=&birthy_.., 7/30/2013 FILED-OFFICE GF THE PROTHONOTARY 2013 AUG 29 FM 2: 02 CUMBERLAND COUNTY PENNSYLVANIA M&T Bank Cumberland County Plaintiff Court of Common Pleas V. Number 13-6- CIVIL Brandon Klawitter Defendant ORDER AND NOW, this fday of 4vf" , 2013, the Plaintiff is granted leave to serve the Notice of Sheriff s Sale of Real Property upon the Defendant,Brandon Klawitter,by regular mail and by certified mail, return receipt requested, to his last known address of 204 South 19th Street, Camp Hill,Pennsylvania 17011, and by posting the mortgaged premises of 204 South 19th Street, Camp Hill, Pennsylvania 17011. BY TH OURT: Commowealth of Pennsylvania In the Court of Common Pleas of Cumberland County CASE NO.: 13-6-CIVIL AFFIDAVIT OF SERVICE M and T Bank c map C/3 _. Brandon Klawitter =;::o -U / CD Cn Commonwealth of Pennsylvania County of Dauphin ss. �� r C3 L r I,Michael B.Reneker, a competent adult,being duly sworn according to law,depose and say that :30 AM D 09/12/2013,I served Brandon Klawitter at 204 South 19th Street,Camp Hill,PA 17011 in the marin r cl. firm.d below: ❑ Defendant(s)personally served. ❑ Adult family member with whom said Defendant(s)reside(s). Relationship is ❑ Adult in charge of Defendant(s)residence who refused to give name and/or relationship. ❑ Manager/Clerk of place of lodging in which Defendant(s)reside(s). ❑ Agent or person in charge of Defendant's office or usual place of business. ❑ an officer of said Defendant's company. ® Other: The documents were posted to the premises. a true and correct copy of Order;Notice of Sheriff's Sale of Real Property issued in the above captioned matter. x ./ -- Sworn to and subscribed b fore me on this Michael B. Reneker day of ta►�ri 2013. ROSS 1 Huntington Quadrangle, Suite 2SO4 Melville, NY 11747 (516) 284-5850 LIC Atty File#: 133458 - Our File# 28052 CO /ONIWEALTH OF PENNSYLVANIA C , Notarial Seal John F.Shinkowsky,Notary PubUC Lower Paxton Twp.,Dauphin County MY Commission Expires Sept 28,2014 Member.Pennsvivania Association of Notaries 0r i 133458 McCABE,WEISBERG AND CONWAY, P.C. �1fAti�`re ^itAj '� BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 MARC S. WEISBERG,ESQUIRE-ID# 17616 2013 OCT 23 AM 11: 35 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID#34419 PENNSYLVANIA D ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 HEIDI R. SPIVAK)ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank Cumberland County Court of Common Pleas Plaintiff V. Brandon Klawitter Number 13-6- CIVIL Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney, being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he/she is counsel for the above-named Plaintiff; 2. That on September 10,2013, in accordance with the attached Court Order,Plaintiff served a true and correct copy of the Notice of Sheriff s Sale of Real Property upon the Defendant, Brandon Klawitter,by regular mail,certificate of mailing and certified mail,return receipt requested, addressed to his last-known address of 204 South 19th Street, Camp Hill ,Pennsylvania 17011. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". 3. That on September 12,2013,in accordance with the attached Court Order,Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Brandon Klawitter,by posting the same at the mortgaged premises of 204 South 19th Street, Camp Hill, Pennsylvania 17011. A true and correct copy of the Sheriff's Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "B". MICA SBERG CONWAY, P.C. BY: [ ]Te nce J.McCabe, [ ]Marc S. Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ] Margaret Gairo, Esq. [ ]Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff SWORN AND SUBSCRIBED BEFORE ME THIS `Z DAY OF �1�V , 2013 �Vv NOTAR PU LIC 00=11n ONVF�F ENIltB n NOTAi iAL SEAL v�n"A Kimberly Lynn lUcCiu;(e}, Not Public City isF,hilacielpnia,.Phila.County Hwy Commission Expires Sapte. er 7,,20,18 9-z qd F Ii. i)I• T Ff C F'f Z C1 T i`i f.�t•�«7:�F�`r' 2013 AUG 29 PV, 2: 0 CUMBERLAt"D COUNTY PENNSYLVANIA M&T Bank Cumberland County Plaintiff Court of Common Pleas V. Number 13-6- CIVIL Brandon Klawitter Defendant O.RD .ER AND.NOW,this eC i day of P[,t 1a;)--- ,2013,the.Plaintiff is granted leave to serve. the Notice of Sheriff s Sale of Real Property upon the Defendant,Brandon Klawitter,by regular mail and by certified mail, return.receipt requested,to his last known address of 204 South 19th Street, Carnp Hill,Pennsylvania 17011,and by posting the mortgaged premises of 204 South 19th Street, Camp Hill,.Pennsylvania 1701 l.. BY THE COURT: X� � J. Copy 0Ut1*(q-C( ,r.` ote EXHIBIT A Postal Service1r. CERTIFIED RECEIPT 'C'\.. (Domestic Mail/ Coverage Provided) M I MRS R. , �4r ,ti �•S �<t1. � S� v`• Yagr , n Postage ^� fiAT/�� ru Ceitilled Fee dReturn ROPOlp(Fee Pos�,rt1t•R, C7 (Endorsement Required) {.Cp 11 0 Restdciod Delivery Foe O iJ�tiS.•` (Endorsement Required) y �' n Total Postage&Fees $ ( L PSi!'.N F� r-4 rn n t P' o.; or PO 009 City,S ,e,ZIP+4 )r � ill 11• i P. 0 p w CL � � 5 L Q o r. C> s NO0 o HE QQ do t a � � ❑ C] q O a-,. .cad m cl jq u o D b b m u Paa a' -0 0 0°0 i a U CD cn of o •o [� ca V M •r+ .-r N M d" Vl �O (� 00 01 d EXHIBIT B Commowealth of Pennsylvania In the Court of Common Pleas of Cumberland County CASE NO.: 13-6-CIVIL AFFIDAVIT OF SERVICE M and T Bank • vs. Brandon Klawitter commonwealth of Pennsylvania county of Dauphin ss. 1,Michael B.Reneker,a competent adult,being duty sworn according to law,depose and say that at 11:30 AM on 09/12/2013,I served Brandon Kiawitter at 204 South 19th Strcet,Camp Hill,PA 17011 in the manner described below: ❑ Defendant(s)personally served. ❑ Adult family member with whom said Defendant(s)reside(s). Relationship is ❑ Adult in charge of Defendant(s)residence who refused to give name and/or relationship. ❑ Manager./Clerk of place of lodging in which Defendant(s)reside(s). ❑ Agent or person in charge of Defendant's office or usual place of business. ❑ an officer of said Defendant's company. ® Other: The documents were posted o the premises. a true and correct copy of Order;Notice of Sheriff's Sale of Real Property issued in the above ca/p/tioned matter. X Zzl �a�„ Sworn to and subscrib bgfore me on t r. is Michael B. Reneke I day of en kri- 201 ROSS 1 Huntington Quadrangle, Suite 2SO4 Melville, NY 11747 (516) 284-5650 NOTARY BL Atty File: 133458 - Our File# 28052 CO ONWEAL•TH OF PENNSYL=Uc ANIA seal I y,Notary Pub i Dauphin County es Sept 28,2014 � C= emr.Pennsvivanla Association of Notaries ("n S tl cr,•. • ` �� rV �rT7 r—X -(p UH L ' i COPY 133458 � i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , - Sheriff �� „ay,01. C tt rl ,.1 s 3� Jody S Smith 6 Chief Deputy , z' — !i r- Richard W Stewart �' Solicitor OP-tCE '"' E'F,',ERIFF ' M&T Bank Case Number vs. Brandon Klawitter 2013-6 SHERIFF'S RETURN OF SERVICE 07/01/2013 04:17 PM - Deputy Shawn Harrison, 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 204 South 19th Street, Camp Hill-Borough, Camp Hill, PA 17011, Cumberland County. 08/01/2013 12:02 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Brandon Klawitter, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found" at 204 South 19th Street, Camp Hill, PA 17011, defendant could not be located at this address prior to expiration date, 10 service attempts were made. 09/03/2013 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013 11/06/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, PA on November 06, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of M &T Bank, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,079.06 SO ANSWERS, November 26, 2013 RONR ANDERSON, SHERIFF ill.CO f /. C',ch. a•as' not , Co, 5V 4,4 91A0 77 e #2090 95-- i u.^.1vSiute She,,ff.Tri:;soft.In . McCABE,WEISBERG AND CONWAY,P.C. a BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff • MARC . WEISBERG,ESQUIRE-ID# 17616 EDWARD I). CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 M&T Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. NO: 13-6-CIVIL Brandon Klawitter Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at:204 South 19th Street,Camp Hill,Pennsylvania 17011,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Brandon Klawitter 204 South 18th Street Camp Hill,Pennsylvania 17011 2. Name and address of Defendant in the judgment: Name Address Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 r,y 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 4. Name and address of the last recorded holder of every mortgage of record: Name Address M&T Bank 285 Grand Avenue,200 Southlake,Texas 76092 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg,Pennsylvania 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 204 South 19th Street Camp Hill,Pennsylvania 17011 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service • Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America do U.S. Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America do U.S. Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: C b L c May 13,2013 [ ] Terrence J.McCabe,Esq. ]Marc S. Weisberg,Esq. DATE [ ]Edward D.Conway,Esq. [ ] Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [v]thristine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ]Joseph I. Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAiN piece or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by p.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 26, 195B, as follows: BEGINNING at a point on the southwesterly side of South 19th Street,said point being marked by an"X"on the concrete walk,at the distance of 132,9 feet southeast of the Intersection of the southwesterly side of South 19th Street and the southeasterly side Of Dickinson Avenue; thence extending along the said side of South 19th Street,South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk,at a corner of No. 50,Section "A"of the hereinafter mentioned plan of lots;thence along the same South 54 degrees 23 minutes West, 120 feet to a corner of Lot No.63, Section"B"on said Plan;thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No.61, Section"B"on said'Plan;thence along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No.60, Section"B"on a plan of lots, entitled"College Park"which said Plan is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. '19th Street. BEING KNOWN as Parcel No. 01-22.0536-224 RB5678 204 South 19th Street,Camp Hill,Pennsylvania 17011. BEING the same premises which EDWARD S. SHEARER,A SINGLE PERSON,by deed dated July 2,2007 and recorded July 16,2007 in the office of the Recorder in and for Cumberland County in Deed Book 1999,Page 4168, granted and conveyed to Brandon Klawitter,a single person, in fee. TAX MAP PARCEL NUMBER: 01-22-0536-224 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE- ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW M&T Bank COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Brandon Klawitter Number 13-6-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Brandon Klawitter 204 South 19th Street Camp Hill,Pennsylvania 17011 Your house(real estate)at 204 South 19th Street,Camp Hill,Pennsylvania 17011 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$157,902.56 obtained by M&T Bank against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to M&T Bank the back payments,late charges,costs,and reasonable attorney's fees due. To fmd out how much you must pay,you may call McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may fmd • out the price bid by calling McCabe, Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act in-imediately after the sale. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Hanover Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Hanover Street Carlisle,Pennsylvania 17013 (800)990-9108 • LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by D.P. Raffensperger, Registered Surveyor of Lemoyne, Pennsylvania, dated November 26, 1956, as follows: BEGINNING at a point on the southwesterly side of South 19th Street,said point being marked by an "X"on the concrete walk,at the distance of 132.9 feet southeast of the intersection of the southwesterly side of South 19th Street and the southeasterly side Of Dickinson Avenue;thence extending along the said side of South 19th Street, South 35 degrees 37 minutes East, 60 feet to a point, marked by an "X" in the concrete walk, at a corner of No.59,Section "A"of the hereinafter mentioned plan of lots;thence along the same South 54 degrees 23 minutes West, 120 feet to a corner of Lot No. 63, Section"B"on said Plan;thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No.61, Section "B"on said'Plan;thence along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No. 60, Section"B" on a plan of lots, entitled"College Park"which said Plan is recorded in Plan Book 4, Page 83, Cumberland County Records. HAVING thereon erected a dwelling commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No. 01-22-0536-224 RB5678 204 South 19th Street,Camp Hill,Pennsylvania 17011. BEING the same premises which EDWARD S. SHEARER,A SINGLE PERSON,by deed dated July 2,2007 and recorded July 16,2007 in the office of the Recorder in and for Cumberland County in Deed Book 1999,Page 4168, granted and conveyed to Brandon Klawitter,a single person,in fee. TAX MAP PARCEL NUMBER: 01-22-0536-224 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-6 Civil COUNTY OFCUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK Plaintiff(s) From BRANDON KLAWITTER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $157,902.56 L.L.: .50 Interest FROM 4/18/13-$3,634.40 AT$25.96 Atty's Comm: Due Prothy: $2.25 Atty Paid: $206.75 Other Costs: Plaintiff Paid: Date: 5/15/13 - David D.Bu-11,Prothonot.r - (Seal) ; : /L 'i__- _ AO('1/_ Deputy REQUESTING PARTY: Name: CHRISTINE L. GRAHAM,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S. BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No.307169 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle,Pa. This_,__��l day of Q,v 201_1_ Prothonotary 1a O. Natw _47 LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 RB5678 204 South 19th Street, 2013-6 Civil Term Camp Hill,Pennsylvania 17011. BEING the same premises which M&T BANK EDWARD S. SHEARER, A SINGLE vs. PERSON, by deed dated July 2, WITTER 2007 and recorded July 16,2007 in Atty.: BRANDON nce the office of the Recorder in and for At Terrance McCabe Cumberland County in Deed Book ALL THAT CERTAIN piece or par 1999 Page 4168, granted and con cel of land situate in the Borough of veyed to Brandon Klawitter,a single Camp 1-1111,County of Cumberland, person,in fee. Pennsylvania,bounded and described TAX MAP PARCEL NUMBER:Ol in accordance With a survey and plan R 22-0536-224. thereof made by or of enl yne, Penn- sylvania,Surveyor dated November 25, 195B, as follows: point on the BEGINNING at a p southwesterly side of South 19th Street, said point being marked by an"X" on the concrete walk, at the distance of 132.9 feet southeast of the Intersection of the southwest- erly side of South 19th Street and the southeasterly side Of Dickinson he Avenue;thence extending g said side of South 19th Street,South 35 degrees 37 minutes East,60 feet to a point, marked by an"X"in the concrete walk,at a corner of No.59, Section "A" of the hereinafter men- tioned plan of tots;thence along the same South 64 degrees 23 minutes West, 120 feet to a corner of Lot No. 63, Section"B on said Plan; thence along the same North 35 degrees 37 minutes West, 60 feet to a stake at a corner of Lot No. 61, Section "B on said Plan;thence along the same North 54 degrees 23 minutes East, 120 feet to the point and place of BEGINNING. BEING Lot No.60,Section"B"on a plan of lots,entitled"College Park" which said Plan is recorded in Plan Book 4,Page 83,Cumberland County Records. HAVING thereon erected a dwell- ing commonly known as 204 S. 19th Street. BEING KNOWN as Parcel No.01- 22-0536-224. 72 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: July 26, August 2 and August 9, 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. , f);,___- \I _.---- isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this • da of Au•ust, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 26,2014 The Patriot-News Co. "" 1900 Patriot Drive hepatrioluv' evu s Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the 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 1900 Patriot Drive, 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 he 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 he 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. I 2013-6 ChM Term MAT BANK This ad ran on the date(s)shown below: vs. BRANDON KLAWITTER 07/28/13 Atty: Terrance McCabe 08/04/13 ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp 1-1111, I 1 08/11/13 County of Cumberland, Pennsylvania, bounded and described in accordance With a survey and plan thereof made by L Raffensperger, Registered Surveyor of Lemoyne,Pennsylvania,dated November 25, 195B,as follows: Sworn to .nd subscribed be •re m: this day of August, 2013 A.D. BEGINNING at a point on the southwesterly Y g side of South 19th Street,said point being r / •marked by an"X"on the concrete walls at the distance of 132.9 feet southeast of the _ ma. IL ` 11 _ A (' Intersection of the southwesterly side of �'U b l is South 19th Street and the southeasterly side ' Of Dickinson Avenue; thence extending' along the said side of South 19th Street, • South 35 degrees 37 minutes East,60 feet to a point,marked by an"X"in the concrete — CC kMOi`uV"`t ^r PENPkSYL`Jr i`1A walk,at a comer of No.59,Section"A of the { Seal hereinafter mentioned plan of'tots;thence + it r Lyur Notary'Public along the sameSouth 64 degrees 23 minutes Kit OP e. Dauphin Count' West, 120 feet to a corner of Lot No.63, ,;,,r,x,tir r 1"ur'.res Dec. 12,2016 Section"B on saktliece along the same North 35 degrees 37 minutes West, rr; „r.q SCCsAftUN OF NOTARIES 60 feet to a stake at a corner of Lot No.61, Section"B on said Plan;thence_along_the same North 54 degrees 23 minutes East,120 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Home Loan Mortgage Corp is the grantee the same having been sold to said grantee on the 6th day of November A.D., 2013, under and by virtue of a writ Execution issued on the 15th day of May, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 6, at the suit of M & T bank against Brandon Klawitter is duly recorded as Instrument Number 201400303. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this (aft- day of liktir____, A.D. 0Z,0/� / i 44r g, / / Recorder of Deeds Recorder o • ds,Cumberland County,Carlisle,PA My Commis ion Expires the First Monday of Jan.2018