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Home My WebLink About13-0076M~ T Bank .Plaintiff vs. Scott Se}'more and Deborah Seymore Defendants FORM 1 IN THE COURT OF COMMON PLEAS ~' N r CUMBERLAND COUNTY, PENNSYI Ni~ ,~ ~ ;;,~ :~ ~~ 13~ ~ ~ i ~ -a~,- ~~ Civil ~ ~ ~, ~ ~~ ~'°' ~ ~~ .. rr NOTICE OF RESIDENTIAL MORTGAGE FORECLO~i~~ 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. Rem uQy su miffed: ~/ -` Date [Signature of Counsel for Plaintiff] 61164 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 obj ections to the claims set forth against you. You are warned that ifyou 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 AVISO Le han demandado a usted en la torte. 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 cone 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 torte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notification. Ademas, la torte 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 pare usted. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI LISTED 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 LISTED 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File # 61164 D....e 1 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is M&T Bank ,duly organized and doing business at the above-captioned address. 2. The Defendant is Scott Seymore, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 6033 Deerfield Commons, Shippensburg, PA 17257. 3. The Defendant is Deborah Seymore, who is the mortgagor and real owner of the mortgaged properly hereinafter described, and his/her last-known address is 6033 Deerfield Commons, Shippensburg, PA 17257. 4. On October 30, 2007, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Bank of America which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book Instrument Number 200742326, such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. On February 16, 2012, the aforesaid mortgage was thereafter assigned by Bank of America to M&T Bank, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Book Instrument Number 201204752, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 6 Feather Drive, Shippensburg, Pennsylvania 17257. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due August 1, 2011 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 # 61164 Page 3 B. The following amounts are due on the mortgage: Principal Balance $ 246,31.8.29 Interest through December 26, 2012 $ 25,607.60 (Plus $47.24 per diem thereafter) Late Charges $ 572.04 Attorney's Fee $ 1,650.00 Escrow Advance $ 4,466.44 Mortgage Insurance Premiums (M1P) $ 252.74 Property Inspections $ 168.00 GRAND TOTAL $ 279,035.11 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. 9. 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, Plaintiffdemands in rem Judgment against the Defendant in the sum of$279,035.11, together with interest at the rate of $47.24 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY,P. BY• TERRENCE J. 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. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ )BRIAN T. LAMANNA, ESQUIRE [ ]JOSEPH F. RIGA, ESQUIRE ( )JOSEPH I. FOLEY, ESQUIRE Attorneys for Plaintiff File # 61164 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, WEISBERG AND CONWAY,P.C. B TERRENCE 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 [ ]JOSEPH F. RIGA, ESQUIRE [ ]JOSEPH I. FOLEY, ESQUIRE Attorneys for Plaintiff M&T Bank v. Scott Seymore and Deborah Seymore File # 61164 Page 5 • ~ $~ ~~ ~~ ` -- ,~,,,~ .~„L~ :~ a~.'7:r..i '~~+~. ~~' al.... ALL the following described real estate lying and being situate in Southampton Township, Cumberland County, Aennsyivania, more particularly described as follows: BEGINNING at a set iron pin on the eastern side of Feather Drive, a 50-Foot wide street, at corner of Lat 74 as shown on plan of lots hereinafter referred to; thence by said Lot 74, North 88 degrees 33 minutes 24 seconds East 149.25 Feet to a set iron pin on line of Lot 78 on said plan; thence by said Lot 78, South 6 degrees 3 I minutes 35 ! seconds West 90.88 feet to a set iron pin; thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern side of the aforementioned Feather Drive; thence along the eastern side of Feather Drive, North 1 degree 26 minutes 36 seconds West 86.36 feet to a set iron pin; thence continuing along the same on a curve to the right, said curve having a radius of 325 feet, an arc length of 3.64 Feet, and bearing North I degree 6 minutes 46 West to a set iron pin on the eastern side of Feather Drive, a 50-foot wide street, at corner of Lot 74 on said plan, the place of beginning. SEiNG Lot 73, containing 12,867 square feet, as per subdivision of land for Timberland Estate, Phase 2, prepared ~ by Martin and Martin, Inc., dated March 14, 2006, with revisions, recorded in Cumberland County, Pa., Plan Book Volume 94, Page 14. THE ABOVE DESCRIBED REAL ESTATE is the same which Rine Land Development, ]nc. by deed dated October 24, 2007 and intended to be recorded immediately prior to the recording of this instrument in the- Office of the Recorder of Deeds of Cumberland County, Pennsylvania conveyed unto Scott Seymore and Deborah Seymore, his wife. F ORIVI 1 M&T Bank Plaintiff VS. Scott Seymore and Deborah Seymore Defendants IN THE COURT OF CUMIVION PLEAS ~' ~,V, C(JMB6R.LAND COITNTY, PENNSYL~NI~ ,,,~ ~~ ~ ~:rn v> ~ r 'ex{'-. ~ '13-1 P Ci il ~~ ~ --; v ~~ ~, ~ r m~ N =~" NOTICE OF RESIDENTIAL MORTGAGE FORECLO~L~- 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. Date Re~ u yQs~ miffed: ~/ ~" [Signature of Counsel for Plaintiff) 61164 Page 1 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: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people on household: Mailing Address (if different): City: Phone Numbers: State: Zip: Office: Other: Email: # of people on household: How long? First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Yes ^ No ^ Listing date: Yes ^ No ^ State: Zip: rii~c ,v Realtor Phone: State: Zip: Home: Office: Cell: Other: How long? Home: Cell: Date You Closed Your Loan: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: 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: Amount owed: Value: Automobile #2: Model: Amount owed: _ Value: Other transportation (automobiles, boats, motorcycles): Year: Amount owed: Monthlv Income Name of Employers: 1 2. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Year: Year: Model Value: Co-Borrower Pay Days: Monthlv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fueUrepairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. 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: Dave you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ [f 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 financial 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: Phone: Phone: 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) 3 McCABE,WEISBERG AND CONWAY,P.C. BY: TE RRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET CAIRO,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 C= C= CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 -O:x '." BRIAN T.LAMANNA,ESQUIRE-ID#310321 rn W -q I rn M- ANN E.SWARTZ,ESQUIRE-ID#201926 r- x= --arr, JOSEPH F.RIGA,ESQUIRE-ID#57716 (,,r- > JOSEPH L FOLEY,ESQUIRE-ID#314675 r-;i-, CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 Ci 123 South Broad Street,Suite 1400 C Philadelphia,Pennsylvania 19109 (215)790-1010 _A M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Scott Seymore and Deborah Seymore Number 13-76 CIVIL Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants, Scott Seymore and Deborah Seymore, in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure,and assess damages as follows: Principal $ 279,035.11 Interest from 12127/12 to 03122/13 $ 4,062.64 Total $ 283,097.75 McCABE,WEISBERG AND CONWAY,P.C. BY: Terrefice J.M abe,Esq. Marc S. Weisberg,Esq, Edward D.Clway,Esq. . _fmargaret 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�day of 4ri 1 __,2013,Judgment is entered in favor of Plaintiff, M&T Bank, and against Defendants, Scott Seymore and Deborah Seymore, in rem only and not in personam, and damages are assessed in the amount of$283,097.75,plus interest and costs. BY JTH PROftVNOWvhN%y: *1(P,50F1AATr/ A W 00 at 18rz% •44 C 'nal ftqr-.� G"041, ae 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 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants 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 Defendants,Scott Seymore and Deborah Seymore, are not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions ofthe Servicemembers Civil ReliefAct,50 U.S.C.App.§501,et seq.;and that the Defendants,Scott Seymore and Deborah Seymore,are over eighteen(18)years of age,and reside as follows: Scott Seymore 6033 Deerfield Commons Shippensburg, Pennsylvania 17257 Deborah Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,P.C. BY: BEFORE ME TH DAY Terfence Jj*AcCatW,-Esq. [ ]Marc S.Weisberg,Esq, Edward D(Conway,Esq. P- Margaret Gairo,Esq. 201 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 Velle Ann E. Swartz,Esq, ( J Joseph F.Riga,Esq. N La Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. l filarba; j Attorneys for Plaintiff ra , CRY Of Phila&jAjj� RRY CO 4 C'x",- MMIWON EXPI --_--!ESL4N-l2,20!' : Department of Defense Manpower Data Center Results as of:Mar-22.201308:08:33 SCRA 3.0 40 ,%Ws Repoft Prur9VANt to See mb Civil R.efi f Act Last Name: SEYMORE First Name: SCOTT Middle Name: Active Duty Status As Of: Mar-22-2013 NA NA NA F This response Its ` ,halted on tua Date gar * i r ,n Active Duly Start Qeh► � G w w a. NA NA This rosponse retiecta 'ind ai IeR pr-04 Status Date i a 4 ' K" .;Gt NA NA i TMs response relMcis wAxdter gut#Naf to report for active duty Upon searching the data banks of the Department of Defense Manpowe � r ved on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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. yt LA a� Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 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.deNnselink.miVfagtpis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fait 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: R222WA631032F40 I Department of Defense Manpower Data Center Results as of:Mar-22-201309:0933 SCRA 3.0 4DStaves Report Pursuant to ServiGemembers Civil Rehef Act Last Name: SEYMORE First Name: DEBORAH Middle Name: Active Duty Status As Of: Mar-22-2013 a NA NA r, ,,..,, "' NA 1 10 This response yt fetus Date e , u -s, .. ,� Active Duty Sart Delis NA = � r- ' ts. NA � . sr wr` i't This response reflects W110 left activ ys vacedi*_ Status Date 4 Y NA w;'..+r, - ,'� NA This response reifecta gow } report for adhre duty 1I or Upon searching the data banks of the Department of Defense Manpowef ;Wz an the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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. JL r ss Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 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 Servioemembers 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:http://www.defenselink.miVfaq/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(NOAH 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: P2V66A038032V00 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. Number 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS 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 addresses of the Defendants are: Scott Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 Deborah Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME TH DAY [ ]Te ence .Mc abe,Esq. [ ]Marc S.Weisberg,Esq. [ ]Edward .Conway,Esq. j-'fTAargaret Gairo,Esq. OF 013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. OTARY PUBL [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. ® n � �'" �� "° Attorneys for Plaintiff Barbara J. I'byer-Pd&ry Public City of Philadelphia,Philadelphia Count' k4y COMMISSION'EXPIRES JAN.12,201,' 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. Number 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants 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 Defendants that judgment would be entered against them within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME TH DAY [ ]Te ence J cCabe,Esq. [ ]Marc S.Weisberg,Esq. OF ,2013 [ ] Edward D. onway,Esq. [-J Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. 116J [ ] Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. N ARY PU [ ]Ann E. Swartz Esq.q [ ]Joseph F.Riga,Esq. Q [ )Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. N &' `� Attorneys for Plaintiff Barbara t its d Fit Y City of Philakr'r'`.a,P hsa Gvurr'' WIYGOif l c'"vN cPIRES!AN:12,2C' 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. McCAB ,WEISBERG AND CONWAY,P.C. BY: b"' [ ]Terre ce J. Cabe,Esq. [ ]Marc S. Weisberg,Esq. [ ]Edward D. C nway,Esq. [,IUargaret 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 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ' Cumberland County Courthouse,Carlisle,Pennsylvania 17013 ! Curt Long Prothonotary March 11,2013 To: Scott Seymore 6033 Deerfield Commons Shippensburg, Pennsylvania 17257 M&T Bank Cumberland County VS. Court of Common Pleas Scott Seymore Deborah Seymore Number 13-76 CIVIL 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 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE O POR ABOGADO Y FOR NO HABER RADICADO FOR 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 WITHOUT AHEARING ANDYOUMAY LOSE YOURPROPERTY 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 ALOUNA,DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTBNCIABN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DBRECHOS IMPORTANTES, HIRING A LAWYER, USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OPFICEMAYBE ABLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TOPROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHATMAYOFFER TELEFONEA LA OFICINA EXPUSO ABAJO.F.STA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMACIN ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association SJ USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMAcONACERCADE LAS AOENCIASQUEPUEDENOFRECERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINOON HONORARIO, Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,WEISBERG AND CONWAY,P.C. BY: [ ]Terrence J.McCabe,Esqu' L_. [ ]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 [ ;f Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E.Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire Attorneys for Plaintiff hm F- x Bbl I, OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS b j I�' t Cumberland County Courthouse, Carlisle,Pennsylvania 17013 Curt Long r G Prothonotary March 11, 2013 To: Deborah Seymore 6033 Deerfield Commons Shippensburg, Pennsylvania 17257 M&T Bank Cumberland County Vs. Court of Common Pleas Scott Seymore Deborah Seymore Number 13-76 CIVIL 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 USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADTCADO 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 MAYLOSE 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,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA YUSTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORDTO HIRE A LAWYER,THIS OFFICE MAYBE ABLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TO PROVIDE YOU WITH INFORMATION ABOUTAGENCIESTHATMAYOFFER TELEFONEA LA OFICINA EXPUSO ABAJO.ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NOPUEDEPROPORCIONARPARAEMPLEARUNABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMAC16NACERCADE LAS AGENCIASQUEPUEDENOFRECERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,(WEISBERG AN))CONWAY,P.C. BY: [ ]Terrence J.McCabe,Esquire [ j 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 [.,f-Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E.Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire Attorneys for Plaintiff hm Fx6i� aH OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Scott Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 M&T Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothono X Judgment by Default Money Judgment 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. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Deborah Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 M&T Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. Number 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGME has been entere the above pro ing as indicated below. Pro ono �. X Judgment by Default Money Judgment 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 FILE NO.: 13-76 CIVIL Term M&T Bank na �- V. AMOUNT DUE: $283,097.75 Scott Seymore and Deborah Seymore INTEREST: from 03/23/13 ' $11,960.78 at$46.54 ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: - Un 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) 6 Feather Drive Shippensbura,Pennsylvania 1.7257 (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 gamishee(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 gamishee(s). (Indicate)Index this writ against the gamishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: June 7,2013 BY: rkas %t4't� [ ] Terrence McCabe,Esq. [ J Marc S.Weisberg,Esq. ( J Edward D.Conway,Esq. ,.1. ] argaret Gairo,Esq. S [ ] Andrew L. Markowitz,Esq [ ] Heidi R.Spivak,Esq. j `� n [ ] Marisa J. Cohen,Esq. [ ] Kevin T.McQuail,Esq. al , )lam r\1A of [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. [ ] Joseph F.Riga,Esq. CAF [ ]Joseph L Foley,Esq. [ ] Celine P.DerKrikorian,Esq. 1 Attorneys for Plaintiff ti Firm:MCCABE,WEISBERG AND CONWAY Address:123 S.Broad Street, Suite 1400 1 s O Philadelphia,PA 19109 Attorney for:Plaintiff f / CT Telephone:Court 1 790 1010 Supreme Court LLNo. out LEGAL DESCRIPTION ALI, the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a set iron pin on the eastern side of Feather Drive, a 50-foot wide street, at corner of Lot 74 as shown on plan of lots hereinafter referred to; thence by said Lot 74, North 88 degrees 33 minutes 24 seconds East. 149.25 feet to a set iron pin on line of Lot 78 on said plan;thence by said Lot 78, South 6 degrees 31 .minutes 35 seconds West 90.88 feet to a set iron pin; thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern :side of the aforementioned Feather Drive; thence along the eastern side of Feather Drive,North 1 degree 26 minutes 36 seconds West 86.36 feet to a set iron pin; thence continuing along the sarne on a curve to the right, said curve having a radius of 325 feet, an are length of 3.64 feet, and bearing North I degree 6 minutes 46 West to a set iron pin on the eastern side of Feather Drive, a 50-foot wide street,at corner of Lot 74 on said plan,the place of beginning. BEING Lot 73, containing 12,867 square feet,as per subdivision of land for Timberland Estate, Phase 2,prepared by Martin and Martin, Inc., dated March 14, 2006, with revisions, recorded in Cumberland County, Pa,, Plan Book Volume 94, Page 14. THE ABOVE DESCRIBED REAL ESTATE is the same which Rine Land Development, Inc. by deed dated October 24,2007 And intended to be recorded immediately prior to the recording of this instrument in the Office of the }recorder of 'Deeds of Cumberland County, Pennsylvania conveyed unto Scott Seymore and Deborah Scyinore,his wife. 6 Feather Drive, Shippensburg,Pennsylvania 17257. BEING the same premises which RINE LINE DEVELOPMENT INC.,A PENNSYLVANIA CORPORATION by deed dated October 24,2007 and recorded November 8,2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No.#200742325 granted and conveyed to Scott Seymore and Deborah Seymore,his wife, in fee. TAX MAP PARCEL NUMBER: 39-14-0169-289 ?AcCABE,WEISBERG AND CONWAY,P.C. _ BY: TERRENCE J.McCABE,ESQUIRE-ID#1.6496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 -C_r Ma � t"t ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 �r1i HEIDI R. SPIVAK,ESQUIRE-ID#74770 %f-'- r MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.Mc QUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 3z 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. NO: 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants 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: 6 Feather Drive, Shippensburg,Pennsylvania 17257,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 Owners or Reputed Owners Name Address Scott Seymour 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 Deborah Seymour 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 2. Name and address of Defendants in the judgment: Name Address Scott Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 Deborah Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 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 1100 Wehrle Drive Williamsville,New York 14221 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 1100 Wehrle Drive Williamsville,New York 14221 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 6 Feather Drive Shippensburg,Pennsylvania 17257 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#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 13-76 Civil District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste. 220 Harrisburg,PA 17108-1754 and U.S. Post Office and Courthouse 700 Grant Street, Suite 400 Pittsburgh,PA 15219 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: (k r tk�� June 7,2013 [ ] Terrence J. cCabe,Esq. [ ] Marc S.Weisberg,Esq. DATE ( ] Edward D.Conway,Esq. [e-l-WZargaret 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 LEGAL DESCRIPTION ALI, the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a set iron pin on the eastern side of Feather Drive, a 50-foot wide. street, at corner of Lot 74 as shown on plan of lots hereinafter rcfe:rred to; thence by said Lot 74, North 88 degrees 33 minutes 24 seconds Fast. 149.25 feet to a set iron'pin on line of Lot 78 on said plan; thence by said Lot 78, South 6 degrees 31 minutes 35 seconds West 90.88 feet to a set iron pin; thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern side of the aforementioned Feather Drive; thence along the eastern side of Fcather Drive,North 1 degree 26 minutes 36 seconds West 86.36 feet to a set iron pin; thence continuing along the same on a curve to the right, said curve having a radius of 325 feet, an are length of 3.64 feet, and bearing North degree 6 minutes 46 West to a set iron pin on the eastern side of Feather Drive, a 50-foot wide;street,at corner of Lot 74 on said plan, the place of beginning. BEING Lot 73, containing,12,867 square feet,as per subdivision of land for Timberland Estate, Phase 2,prepared by Martin and Martin, Inc.., bated March 14, 2006, with revisions, recorded in Cumberland County, Pa., Plan Book VOItI1T1C 94, Page 14, THE A13OVE DESCRIBED REAL ESTATE is the same which Rine Land Development, Inc, by deed dated October 24, 2007 and intended to be recorded immediately prior to the recording of this instrument in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania conveyed unto Scott Seymore and Deborah Seymore,his wife. 6 Feather Drive, Shippensburg,Pennsylvania 17257. BEING the same premises which RINE LINE DEVELOPMENT INC.,A PENNSYLVANIA CORPORATION by deed dated October 24,2007 and recorded November 8,2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No.#200742325 granted and conveyed to Scott Seymore and Deborah Seymore,his wife,in fee. TAX MAP PARCEL NUMBER:39-14-0169-289 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 Z� " KEVIN T. McQUAIL,ESQUIRE-ID#307169 "' E) CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 -< � : BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 C JOSEPH F.RIGA,ESQUIRE-ID#57716 w JOSEPH I.FOLEY,ESQUIRE-ID#314675 —t CP 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 Scott Seymore and Deborah Seymore Number 13-76 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Scott Seymore Deborah Seymore 6033 Deerfield Commons 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 Shippensburg,Pennsylvania 17257 Your house(real estate)at 6 Feather Drive,Shippensburg,Pennsylvania 17257 is scheduled to be sold at Sheriff's Sale on December 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$283,097.75 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 Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALI., the following described real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: BEG INNING at a set iron pin on the eastern side of Feather Drive, a 50-foot wide street, at corner of Lot 74 as shown on plan of lots hereinafter referred to; thence by said Lot 74, North 88 degrees 33 minutes 24 seconds Fast 149,25 feet to a set iron pin on line of Lot 78 on said plan; thence by said Lot 78, South 6 degrees 31 minutes 35 seconds West 90.88 feet to a set iron pin; thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern side of the aforementioned Feather Drive; thence along the eastern side of Feather Drive,North 1 degree 26 minutes 36 seconds West 86.36 feet to a set iron pin; thence continuing along the same on a curve to the right, said curve having a radius of 325 feet, an arc length of 3.64 feet, and bearing North degree 6 minutes 46 West to a set iron pin on the eastern side of Feather Drive, a 50-foot wide street, at corner of Lot 74 on said plan, the place of beginning. BEING Lot 73, containing 12,867 square feet,as per subdivision of land for Timberland Estate, Phase 2, prepared by Martin and Martin, Inc., dated March 14, 2006, with revisions, recorded in Cumberland County, Pa., Plan Hook Volume 94, Page 14. THE ABOVE DESCRIBED REAL ESTATE is the same which Rine Land Development, Inc. by deed dated October 24, 2007 and intended to be recorded immediately prior to the recording of this instrument in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania conveyed unto Scott Seymore and Deborah Seymore,his wife. 6 Feather Drive, Shippensburg,Pennsylvania 17257. BEING the same premises which RINE LINE DEVELOPMENT INC.,A PENNSYLVANIA CORPORATION by deed dated October 24,2007 and recorded November 8,2007 in the office of the Recorder in and for Cumberland County in Deed Book Instrument No. #200742325 granted and conveyed to Scott Seymore and Deborah Seymore,his wife, in fee. TAX MAP PARCEL NUMBER: 39-14-0169-289 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-76 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 SCOTT SEYMORE AND DEBORAH SEYMORE (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: $283,097.75 L.L.:$.50 Interest FROM 3/23/13-$11,960.78 AT$46.54 Arty's Comm: Due Prothy: $2.25 Arty Paid: $254.75 Other Costs: Plaintiff Paid: Date: 6/12/13 David D.Buell,Prothonota (Seal)-t Deputy REQUESTING PARTY: :Name-MARGARET GAIRO,ESQUIRE Address MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone:215-790-1010 Supreme Court ID No.34419 j McCABE,WEISBERG AND CONWAY,P.C. Attorneys for Plaintiff BY; TERRENCE J.McCABE,ESQUIRE-ID# 16496 r:T; r.. y MARC S. WEISBERG ESQUIRE-ID# 17616 rr''..° - % fi/ r �w EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419r j p ANDREW L. MARKOWITZ,ESQUIRE-ID# 28�Qp,� 1: 3 MARISA J. OHEN,ESQUIRE-IID# 87830 PE)YNSYCV,Q OZ1�jY KEVIN T. MCQUAIL,ESQUIRE-ID# 307169 � � CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T.LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID# 201926 JOSEPH F. RIGA,ESQUIRE-ID# 57716 JOSEPH 1.FOLEY, ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN, ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 M&T Bank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-76 CIVIL Scott Seymore and Deborah Seymore Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 5th day of December,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,W BERG AND CONWAY,P.C. BEFORE ME THIS DAY gy. < [ ]Terrence J.McCabe,Esquire [ Marc$. Weisberg,Esquire OF 2013 [ ]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 T B I [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire COMMONWEALTH OF PENNSYLVANIA N IAL SEAL Public Attorneys for Plaintiff OTAR KELSEY HEATH,Notary City of Philadelphia,Phila.County M Commission Expires September 23,2017 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: 13-76 CIVIL Scott Seymore and Deborah Seymore Defendants 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 6 Feather Drive,Shippensburg,Pennsylvania 17257,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 Owners or Reputed Owners Name Address Scott Seymour 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 Deborah Seymour 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 2. Name and address of Defendants in the judgment: Name Address Scott Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 File#61164 Page I Deborah Seymore 6033 Deerfield Commons Shippensburg,Pennsylvania 17257 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 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 Rineland Development Inc. 19 Independence Drive Shippensburg,PA 17257 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 6 Feather Drive Shippensburg,Pennsylvania 17257 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#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 File 461164 Page 2 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,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 File#61164 Page 3 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. December 5,2013 McCABE,WEISBERG AND CONWAY,P.C. DATE V`. ' BY: l. [ ]Terrence J.McCabe,Esquire [ arc 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 [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff Re: M&T Bank v. Scott Seymore.et al. Cumberland County;Number: 13-76 CIVIL File 961164 Page 4 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. Scott Seymore and Deborah Seymore Number 13-76 CIVIL Defendants DATE: December 5,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Scott Seymore and Deborah Seymore PROPERTY:6 Feather Drive, Shippensburg,Pennsylvania 17257 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $283,097.75 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on January 8,2014 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.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 lien 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. b� z fC O� V1 A W N ~ O�bNO r °nom � rn o7 A A z b d '0 c7 A�C r eb W d 0 x b xJHd `1" d � - tdC� dv� .. "' C� Y `�7", zJt� dC� r� o� H vi �►� ❑❑ ❑❑❑n CD rb fo o C ° r. C ° N ° w o z c o ° B F o fD CD � °, a o 0 0 3 0 0 d o Q, fo -1 � a o C fD M A A "� ro I,r day � � � � ft oom fro bC*l o 4t -1 H = - H .r ;rlbcn ,., l. < o < O C fD OD :0 In~ G. to C C ~ O C d O. i0+, r A p ►°*, y J V] a C c. tb .� N va y N • 3 w � � oo �. yo o o cn o � o � C 0 w CD eD o k = w o & c J A 0 00 Q �o CON C to ° COI m qt 11098 oO s w N 00 N CA N ��/yA C" n dnC `dp� � �. yL" Y ".L"iC� mn �xibC" b7b � ;bCJb N A mA e°e O 00 B O A C > � o d td -9 O f K d C) c a A y' CD o A eo = w a o a CA 4 o k o � C It C ., .� 7J �a r/1 T es 00 V1 `rJ O n C: f9 A v F+ b C f'SD A ICJ O fD b N fD bTA °' � �' .°► o � n 'T'• "'dam C o o "'jy t+� s � A 3 � ywB � '"' Y v) J O r., A7' `"9 J �' ►� v !S V1 y ►� �.+ O O W G A C A T C oNO O 00 A f tj A e ft J N A OD rp IfD C � n A � O - A O " A 000 CD C A N 'Y w w w O W C �p A 7 T O 3 a � e ro aA A � f1i A � o B $, e ro � y n A A N o M d d fo ow rQ O v. � O � O C O+ R f O < ►O" A G O C 0, O V A O Y n O tv co ft tD CII O+ A A d A y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' 1r at Conditrf rt Jody S Smith Chief Deputy r. r ^ r r:. r Richard W Stewart Solicitor 0, ,J 't B E IR L A l i PENNSYLVANIA M&T Bank vs. Case Number Scott Seymore (et al.) 2013-76 SHERIFF'S RETURN OF SERVICE 09/23/2013 11:54 AM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 6 Feather Drive, Shippensburg, PA 17257, Cumberland County. 10/08/2013 04:01 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Deborah Seymore at 6033 Deerfield Commons, Southhampton Twp., Shippensburg, PA 17257, Cumberland County. 10/08/2013 04:01 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Deborah Seymore at 6033 Deerfield Commons, Southhampton Twp., Shippensburg, PA 17257, Cumberland County. 10/08/2013 04:01 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Deborah Seymore, Wife. , who accepted as"Adult Person in Charge"for Scott Seymore at 6033 Deerfield Commons, Southhampton Twp., Shippensburg, PA 17257, Cumberland County. 11/12/2013 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriff's Sale Continued to 1/8/2014 01/08/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on January 08, 2014 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Scott Dietterick, on behalf of Federal Home Loan Mortgage Corp, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,154.82 SO ANSWERS, January 24, 2014 RONNY R ANDERSON, SHERIFF 6 o pd aeh. a as' pd.Co, err Iel-csot Oilri 3 • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-76 Civil Term Office of the Recorder of Deeds of Cumberland County, Pennsylvania M&&T BANK conveyed unto Scott Seymore and Deborah Seymore,his wife. vs. 6 Feather Drive, Shippensburg, SCOTT SEYMORE, Pennsylvania 17257. Deborah Seymore BEING the same premises which Atty.:Terrance McCabe RINE LINE DEVELOPMENT INC., ALL the following described real A PENNSYLVANIA CORPORATION estate lying and being situate in by deed dated October 24, 2007 Southampton Township, Cumber- and recorded November 8,2007 in land County, Pennsylvania, more the office of the Recorder in and for land County in Deed Book particu described as follows: Instrument No.#200742325 granted BEGINNING at a set iron pin on and conveyed to Scott Seymore and the eastern side of Feather Drive, a Deborah Seymore,his wife,in fee. 50-loot wide street, at corner of Lot TAX MAP PARCEL NUMBER:39- 74 as shown on plan of lots herein- 14-0169-289. after referred to; thence by said Lot 74,North 88 degrees 33 minutes 24 seconds East 49.25 feet to a set iron pin on line of Lot 78 On said plan; thence by said Lot 78, South 6 de- grees 31 minutes 35 seconds West 90.88 feet to a set iron pin; thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern side of the afore- mentioned Feather Drive; thence along the eastern side of Feather Drive, North I degree 26 minutes 36 seconds West 86.36 feet to a set iron pin;thence continuing along the same on a curve to the right, said curve having a radius of 325 feet,an arc length of 364 feet, and benring North I degree 6 minutes 46 West to a set iron pin on the eastern side of Feather Drive,a 50-foot wide Street, at corner of Lot 74 on said plan,the place olbeginning. BEING Lot 73,containing 12,867 square feel, as per subdivision of land for Timberland Estate,Phase 2. prepared by Marlin and Martin,Inc., dated March 4,2006,with revisions, recorded in Cumberland County,Pa„ Plan Rook Volume 94,Page 14. THE ABOVE DESCRIBED REAL ESTATE is the same which Rine I.and Development, Inc. by deed dated October 24, 2007 and intended to be recorded immediately prior to the recording of this instrument in the 106 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, 4ditor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 _ ArA•L[ ,/ Notary WRIPIMMOMINIMINIMONWMIMINNONIMMONIMMOD NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. a ipatriotiNews 2020 Technology Pkwy Suite 3.00 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds In and klic said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. ,PUBLICATION COP This ad ran on the date(s)shown below: 10/13/13 MT BANK 10/20/13 vs. SCOTT SEYMORE 10/27/13 Deborah Seymore •Atty: Terrance McCabe ALL the following described real estate lying and being situate in Southampton Township, e Cumberland County, Pennsylvania, more particu described as follows: BEGINNING at a set iron pin on the eastern ' Sworn to•an• s bscribed before me th'011 ay of November, 2013 A.D. side of Feather Drive,a 50.-loot wide street, at corner of Lot 74 as shown on plan of lots I .) I / hereinafter referred to;thence by said Lot • ��a- 74,North 88 degrees 33 minutes 24 seconds A'A Ark East 49.25 feet to a set iron pin on line of • -ry P • Lot 78 On said plan;thence by said Lot 78, South 6 degrees 31 minutes 35 seconds West 90.88 feet to a set iron pin;thence South 88 degrees 33 minutes 24 seconds West 136.67 feet to a set iron pin on the eastern side of the �f`??E"^t l`J ! " ` PENNSYLVANIA aforementioned Feather Drive;thence along -° ~-- ---- the eastern side of Feather Drive,North I degree 26 minutes 36 seconds West 86.36 feet nily t_y rtr? a ! rer PtahliC to a set iron pin;thence continuing along the `'�sr cr,0.t n ' •, )iuphdn Cou nty� same on a curve to the right,said curve having ^yrr;misslon Explrss Dec.22,2016 A,� a radius of 325 feet,ai.....,n..b�if 364 feet, t�l r4i t PENNSYLVANIA ASS00�1 4iri n d OTARIE5 and bearing North I degree 6 minutes 46 West to a set iron pin on the eastern side of Feather . Drive,a 50,footwide Street,at corner of Lot COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal Home Loan Mortgage Corp is the grantee the same having been sold to said grantee on the 8th day of January A.D., 2013, under and by virtue of a writ Execution issued on the 12th day of June, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 76, at the suit of M & T bank against Scott Seymore and Deborah Seymore is duly recorded as Instrument Number 201404229. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of F , A.D. a O l ) W cii . LaeL �, De/9u iv Recorder bf Deeds Recorder of Deeds,Cumberland County,Car8sle,PA My Commission Expires the First Monday of Jan.2018 •