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PHELAN HALLINAN, LLP
Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
PENNYMAC MORTGAGE INVESTMENT TRUST
HOLDINGS I, LLC
6101 CONDOR DRIVE
MOORPARK, CA 93021
Plaintiff
~.
HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355
Defendant
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM ,
3_ ~ ~ Civi
NO.
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 310304
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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.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800)990-9108
File #: 310304
Plaintiff is
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, LLC
6101 CONDOR DRIVE
MOORPARK, CA 93021
2. The name(s) and last known address(es) of the Defendant(s) are:
HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
On 08/22/2006 HARRY L. SAMPSON and CAROL M. SAMPSON made, executed and
delivered a mortgage upon the premises hereinafter described to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR FIRST NLC
FINANCIAL SERVICES, LLC, DBA THE LENDING CENTER which mortgage is
recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage
Book 1966, Page 3154. By Assignment of Mortgage recorded 08/06/2012 the mortgage
was assigned to PLAINTIFF which Assignment is recorded in. Assignment of Mortgage
Instrument No. 201223587.The mortgage and assignment(s), if any, are matters of public
record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g);
which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if
those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 07/01/2011 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of Mortgagor to make such payments after a date specified
File #: 3103(14
by written notice sent to Mortgagor, the entire principal balance and all interest due
6
thereon are collectible forthwith.
The following amounts are due on the mortgage as of 09/28/2012:
Principal Balance $165,257.31
Interest $21,857.78
06/01/2011 through 09/28/2012
Late Charges $0.00
Property Inspections $27.00
Escrow Deficit 7 629.55
TOTAL $194,771.64
7
8
9.
10
Plaintiff is not seeking a judgment of personal liability (or an ul personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
The mortgage premises are vacant and abandoned.
CAROL M. SAMPSON was a co-record owner of the mortgaged premises as a tenant by
the entirety. By virtue of CAROL M. SAMPSON's death on or about 08/18/2010, her
ownership interest was automatically vested in the surviving tenant by the entirety.
Plaintiff hereby releases CAROL M. SAMPSON, from liability for the debt secured by the
mortgage.
File #: 310304
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$1.94,771.84, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property,
PHELAN HALLINAN, LLP
By:
Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
File #: 3 ] 0304
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, having erected thereon a two and one-half story concrete
block dwelling house and other outbuildings, situate in Dickinson Township, Cumberland County,
Pennsylvania, bounded and described as follows:
Beginning at a point in the center of the State Highway leading from Carlisle to Shippensburg,
locally known as the Walnut Bottom Road, which point is also in the western line of a public road
leading from the said Walnut Bottom Road to the York Road thence along the western line of
said last mentioned public road, South 31 degrees East, 291 feet to a stake in line of lands now or
formerly of Margaret R. Stuart; thence along said land now or formerly of Margaret R. Stuart,
South 62 degrees 15 minutes West 150 feet to a steak, thence still continuing along lands now
formerly of Margaret R. Stuart, North 31 degrees West 291 feet to a point in the center of the
said Walnut Bottom Road, thence along the center of said Walnut Bottom Road, North 62
degrees 15 minutes East 150 feet to a point, the Place of BEGINNING
Containing 1 acre, more or less.
BEING THE SAME premises which Jones Family Trust, William M. Jones and Fannie E.
Jones, co Trustees, husband and wife by deed dated 9/28/04 recorded 9/30/04 in Cumberland
County in book 265 page 2388 then granted and conveyed to Harry L. Sampson and Carol M.
Sampson, husband and wife.
PARCEL NO.: 08-11-0294-006
PROPERTY ADDRESS: 2212 WALNUT BOTTOM ROAD, CARLISLE, PA 17015-7932
PARCEL # 08-11-0294-006.
File #: 310304
VERIFICATION
Evan Johnston
hereby states that he/she is
Default Spedalist
of PENNYMAC
LOAN SERVICES, LLC, servicing agent for Plaintiff in this matter, that he/she is authorized to
make this Verification, and verify that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his/her information and belief. The
undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec.
4904 relating to unsworn falsification to authorities.
DATE: ~ ' ~ ~ 2 O l 3
File#: 310304
Name: SAMPSON
/,_
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Na ~ Evan Johnston
Title: Default Spedalist
PENNYMAC LOAN SERVICES, LLC
File #: 310304
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~~t} IN THE COURT OF COMMON
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l PLEAS
Plaintiff(s) OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
Defendant(s)
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NOTICE OF RESIDENTIAL MORTGAGE ~r
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FORECLOSURE DIVERSION PROGRAM p
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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, yo maythc haw
able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with yd1Tx len~te4'. '_
If you do not have an attorney, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services
at (717} 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal
representative at not charge to you. Once you have been appointed a legal representative, you must promptly meet
with the legal representative within twenty (20) days of the appointment date. During that meeting, you must
provide the legal representative with all the requested fmancial 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. 1f you do so
and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of yotu~ lender
in attempt to work out a reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible
for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of
a legal representative. However, you must provide your lawyer with all the requested financial information so that a
loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in
the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court,
which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If
you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of
your lender in an attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit
proceeds forward,
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
F~~ ~~LJ13
Date Signature of Counsel for Plaintiff
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 ^ No ^ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied: Yes ^ No ^
Mailing Address (if different)
City: State: Zip:
Phone Numbers: Home; Office:
Cell: Other:
Email:
# of people in household: How long?
• • .. ~
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in 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 Payments Amount: $ Included Taxes and Insurance:
Date of Last Payment:
Primary Reason for Default:
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:
Automobile #2: Model:
Amount owed:
Other transoortation (automobiles. boats. motorcvclesl
Year: Amount owed:
Value:
Model:
Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1.
2.
Borrower Pay Days:
Monthly Gross
Monthly Gross
Monthly Gross
Monthly Amount:
Monthly Amount: _
Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently pavine)
Monthly Net
Monthly Net
Monthly Net
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2" Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other Prop. Payment
Install. Loan Payment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and Expenses:
Have you been working with a Housing Counseling Agency?
Yes ^ No ^
If yes, please provide the following information:
Counseling Agency:
Value:
Year:
Year:
Counselor:
Phone (Office):
Email:
Fax:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ^ No ^
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone:
~, ~ ~
I/We, ,authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/we
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Borrower Signature Date
Please forward this document along with the following information to lender and
lender counsel:
~ Proof on income
~ Past 2 bank statements
~ Proof of any expected income for the last 45 days
d Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
d (hardship letter)
listing agreement (if property is currently on the market)
V Copy of 2 years of federal income tax returns
V Copy of deed
FORM 3
Plaintiff(s)
vs.
Defendant(s)
REQUEST FOR CONCILIATION CONFERENCE
Civil
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant
Signature of Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Date
Date
FORM 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s)
AND NOW, this day of
CASE MANAGEMENT ORDER
Civil
20 ,the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in acourt-supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILEO-O HC
Sheriff tira �a ti;: THE PROTHONO iliP�;.;
�� la at�ubr4
Jody s smith 2013MAR 18 AM g: 55
Chief Deputy
Richard W Stewart � ,rcM CUMBERLAND COUNTY
Solicitor OF'NOEOFTHE RIFF PENNSYLVANIA
PennyMac Mortgage Investment Trust Holdings I, LLC Case Number
vs.
Harry Lee Sampson 2013-850
SHERIFF'S RETURN OF SERVICE
02/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry
for the within named Defendant to wit: Harry Lee Sampson, but was unable to locate the Defendant in his
bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not
Found"at 2212 Walnut Bottom Rd, Carlisle, PA. Residence is vacant.
03/08/2013 06:27 PM-Deputy Jason Kinsler, 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: Harry Lee Sampson at 2007 Walnut Bottom Rd., Carlisle, PA 17015.
SON KINSLER, DEPUTY
SHERIFF COST: $40.00 SO ANSWERS,
March 12, 2013 RbNlirY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Telecsoff,Inc.
F 1 LED-UFF,C
F TFIE 3'ROTHW OTARY
PHELAN HALLINAN, LLP 2013 J(tN 25 AM 10: O9 Attorney for Plaintiff
Adam H. Davis, Esq., Id. No.203034 CUMBERLAND COUNTY
1617 JFK Boulevard, Suite 1400 PENNSYLVANIA
One.Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE CUMBERLAND COUNTY
INVESTMENT TRUST HOLDINGS I,
LLC COURT OF COMMON PLEAS
VS. CIVIL DIVISION
HARRY L. SAMPSON No. 13-850-CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against HARRY L. SAMPSON,
Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as
follows:
As set forth in Complaint $194,771.64
TOTAL $194,771.64
I hereby certify that (1) the Defendant's last known addresses are 2007 WALNUT
BOTTOM ROAD, CARLISLE, PA 17015-9355 and 2212 WALNUT BOTTOM ROAD,
CARLISLE, PA 17015-7932, and(2) that notice has been given in accordance with Rule
Pa.R.C.P 237.1.
Date Z7/ v �rlilfv�^�
Adam H. Davis, Esq., Id. Nd.203034
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: 3
PHS#310304 PROTHONOTARY
310304
at u►�-�4I(I,
GILD 3 aI3A
�b�l W
PHELAN HALLINAN, LLP Attorney for Plaintiff
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
PENNYMAC MORTGAGE CUMBERLAND COUNTY
INVESTMENT TRUST HOLDINGS I, COURT OF COMMON PLEAS
LLC ,
CIVIL DIVISION
VS.
No. 13-850-CIVIL
HARRY L. SAMPSON
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of
Congress of 1940, as amended.
(b) that defendant HARRY L. SAMPSON is over 18 years of age and has last
known addresses at 2007 WALNUT BOTTOM ROAD;CARLISLE, PA 17015-9355 and 2212
WALNUT BOTTOM ROAD, CARLISLE, PA 17015-7932.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date
-T
Phelan Hallinan,LLP
Adam H. Davis, Esq., Id:No.203034
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1.400
.One Penn Center Plaza, Philadelphia, PA 19103
21.5-563-7000
310304
Department of Defense Manpower Data Center Results as of:Jun-24-20'3'2.05.24
SCRA 3.0
status.'kepott
Pursuant to Sery cctncinbors Civil RelidAd
Last Name: SAMPSON
First Name: CAROL
Middle Name: M
Active Duty Status As Of: Jun-24-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA - - No NA
This response reflects the individuals'.active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA - ..No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Dale 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
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.
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
Department of Defense Manpower Data Center Results as of:Jun-24-2013 12:05:22
SCRA 3.0
Stag Report
' - P=uant in Scry ceme-inbcrs Civil Relief Act
Last Name: SAMPSON
First Name: HARRY
Middle Name: L
Active Duty Status As Of: Jun-24-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA - No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Dale
Active Duty Start Date Active Duty End Date Status Service 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 His/Her 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
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.
ot
ct
4t )4. ,
040
44-
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
(Rule of Civil Procedure No! 236) =Revised
PENNYMAC MORTGAGE CUMBERLAND COUNTY
INVESTMENT TRUST HOLDINGS I,
LLC COURT OF COMMON PLEAS
VS. ,
CIVIL DIVISION
HARRY L. SAMPSON
No. 13-850-CIVIL
Notice is given that a Judgment in the above captioned matter has been entered
against you on a�S
c3t
.B y:
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION DBTAINED WILL BE USED FOR,THAT PURPOSE: IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
310304
PENNYMAC MORTGAGE INVESTMENT TRUST COURT OF COMMON PLEAS
HOLDINGS 1,LLC CIVIL DIVISION
Plaintiff
V. NO. 13-850-CIVM
HARRY L.SAMPSON
Defendant(s) CUMBERLAND COUNTY
TO: HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
DATE OF NOTICE: '(P
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN,AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRPI°TEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 1.7013
(717)249-3166
By:
J. atha4 )bb.Esq..Id.No.31.2174
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PHS#310304
PENNYMAC MORTGAGE INVESTMENT TRUST COURT OF COMMON PLEAS
HOLDINGS I,LLC CIVIL'DIVISION .
Plaintiff
V. NO. 13-850-CIVIL
HARRY L.SAMPSON
Defendant(s) CUMBERLAND COUNTY
TO: HARRY L.SAMPSON
2212 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-7932
DATE OF NOTICE: t3j
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE—IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE.OF THIS NOTICE,A JUDGMENT.MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAX OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
(71.7)249-3166
By: _-.
J athan Lobb,Esq.,Id.No.312174
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PHS#310304
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 13-850-CIVIL
HARRY L.SAMPSON
Defendant(s)
CUMBERLAND COUNTY
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due $194,771.64
Interest from 06/26/2013 to Date of Sale $5,187.24
($32.02 per diem)
TOTAL $199,958.88
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
Note: Please attach description of property.
PHS#310304 =M F-1 r�
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA `
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC
Plaintiff
V.
HARRY L.SAMPSON
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Filed:
Address where papers may be served:
z�Z' HARRY L. SAMPSON
Phelan Hallinan,LLP 2007 WALNUT BOTTOM ROAD
Adam H.Davis,Esq.,Id.No.203034 CARLISLE,PA 17015-9355
Attorney for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land,having erected thereon a two and one-half story concrete block
dwelling house and other outbuildings, situate in Dickinson Township,Cumberland County,Pennsylvania,
bounded and described as follows:
Beginning at a point in the center of the State Highway leading from Carlisle to Shippensburg,locally known
as the Walnut Bottom Road,which point is also in the western line of a public road leading from the said
Walnut Bottom Road to the York Road thence along the western line of said last mentioned public road,
South 31 degrees East,291 feet to a stake in line of lands now or formerly of Margaret R. Stuart;thence
along said land now or formerly of Margaret R.Stuart,South 62 degrees 15 minutes West 150 feet to a steak,
thence still continuing along lands now formerly of Margaret R. Stuart,North 31 degrees West 291 feet to a
point in the center of the said Walnut Bottom Road,thence along the center of said Walnut Bottom Road,
North 62 degrees 15 minutes East 150 feet to a point,the Place of BEGINNING
Containing I acre,more or less.
TITLE TO SAID PREMISES IS VESTED IN Harry L. Sampson and Carol M. Sampson, h/w,
by Deed from Jones Family Trust and William M. Jones and Fannie E. Jones, co-trustees, h/w,
dated 09/28/2004, recorded 09/30/2004 in Book 265, Page 2388. By virtue of the death of Carol
M. Sampson on or about 8118 12010 title to the premises became vested solely in Harry L.
Sampson, as surviving tenant by the entirety.
PREMISES BEING: 2212 WALNUT BOTTOM ROAD,CARLISLE,PA 17015-7932
PARCEL NO. 08-11-0294-006.
PHELAN HALLINAN LLP FILED-OFFICE
Attorneys for Plaintiff
Adam H. Davis,Esq., Id. No.203034
F T HE P' 'QT 0N0TA1A 1
1617 JFK Boulevard, Suite 1.400
One Penn Center Plaza 2913 JUN 25 AM 10: 1
Philadelphia, PA 19103
215-563-7000 CUMBERLAND COUNTY
PEN -YLVANIA
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, COURT OF COMMON PLEAS
LLC
Plaintiff CIVIL DIVISION
V. NO.: 13-850-CIVIL
HARRY L.SAMPSON .
Defendant{s} CUMBERLAND COUNTY
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91. because:
{ } the mortgage is an FHA Mortgage
{ } the premises is non-owner occupied
{X} the premises is vacant
( ) Act 91 procedures have been fulfilled
{ } Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
By: (/!-o"
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id.No.203034
Attorney for Plaintiff
d
k
PENNYMAC MORTGAGE INVESTMENT TRUST COURT OF COMMON PLEAS
HOLDINGS I; LLC
Plaintiff CIVIL DIVISION
V. NO.: 13-850-CIVIL
HARRY L. SAMPSON
Defendant(s) CUMBERLAND COUNTY
AFFIDAVIT PURSUANT TO RULE 3129.1
PENNYMAC•MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC,Plaintiff in the above action,by the undersigned
attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property
located at 2212 WALNUT BOTTOM ROAD,CARLISLE,PA 17015-7932.
I. Name and address of Owner(s)or reputed Owner(s):
Name. Address(if address cannot be reasonably ascertained,
please so indicate)
HARRY L.SAMPSON 2007 WALNUT BOTTOM ROAD,
CARLISLE,PA 17015-9355
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
HARRY L.SAMPSON 2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
3. Name and last known address of every judgment creditor whose judgment is a record.lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate) , -y
COMMONWEALTH OF PA BUREAU OF P.O.BOX 281230 -t7-• `'' �'--
COMPLIANCE. HARRISBURG,PA 17128-1230 M.
COMMONWEALTH OF PA DEPT.OF P.O.BOX 280948 3> to C)
REVENUE BUREAU OF COMPLIANCE HARRISBURG,PA 17128-0948 rte_
0
7'C-)
PA DEPARTMENT OF REVENUE BUREAU P.O.BOX 280946
OF COMPLIANCE HARRISBURG,PA 17128-0946 T >t-.<
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained, please indicate)
None.
PHS #31.0304
6 � Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 2212 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-7932
DEPARTMENT OF PUBLIC WELFARE, P.O.BOX 8486
TPL CASUALTY UNIT,ESTATE WILLOW OAK BUILDING
RECOVERY PROGRAM HARRISBURG,PA 17105
COMMONWEALTH OF PENNSYLVANIA, 6TH FLOOR,STRAWBERRY SQ.,DEPT 280601
BUREAU OF INDIVIDUAL TAX, HARRISBURG,PA 17128
INHERITANCE TAX DIVISION
DOMESTIC RELATIONS OF 13 NORTH-HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM_704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date: 16Z 2 By:
Phelan Hallinan,LLP
Adam H.Davis,Esq.,Id. No.203034
Attorney for Plaintiff
PHELAN HALLINAN,LLP
1.61.7 JFK Boulevard,Suite 1400
One Penn Center Plaza,Philadelphia,PA 19103
215-563-7000
PHS #310304
PENNYMAC MORTGAGE INVESTMENT TRUST COURT:OF COMMON PLEAS
HOLDINGS I, LLC
CIVIL DIVISION -
Plaintiff
: NO.: 13-850-CIVIL
VS.
HARRY L. SAMPSON : CUMBERLAND BOUNTY-rl
Defendant(§) : =={
�
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NOTICE OF SHERIFF'S SALE OF REAL PROPERTY `v cn CD I
S
G p`11
TO: HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house(real estate) at 2212 WALNUT BOTTOM ROAD, CARLISLE,PA 17015-7932 is
scheduled to be sold at the Sheriff's Sale on 12/04/2013 at-10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$194,771.64 obtained by
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC(the rnortgagee) against you. In
the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule
31.29.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open.the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO.SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
(800) 990-9108
r•
SHORT DESCRIPTION
By virtue of a Writ of Execution No. 13-850-CIVIL
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, LLC
V.
HARRY L. SAMPSON
owner(s) of property situate in DICKINSON TOWNSHIP, CUMBERLAND County,
Pennsylvania,being
2212 WALNUT BOTTOM ROAD, CARLISLE,PA 17015-7932
Parcel No. 08-11-0294-006.
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $194,771.64
Attorneys for Plaintiff
Phelan Halllinan, LLP
,= b
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of.land,:having erected thereon a two and'one-half story concrete block
dwelling house and other outbuildings,situate in Dickinson Township,Cumberland County,Pennsylvania,
bounded and described as follows:'
Beginning at a point in the center of the State Highway leading from Carlisle to Shippensburg,locally known
as the Walnut Bottom Road;which point is also in the•western line of a public road leading from the said
Walnut Bottom Road to the York Road thence along the western line of said last mentioned public road,
South 31 degrees East,291 feet to a stake in line of lands now or formerly of Margaret R. Stuart; thence
along said land now or formerly of Margaret R.Stuart,South 62 degrees 15 minutes West,1.50 feet to a steak,
thence still continuing along lands now formerly of Margaret R. Stuart,North 31 degrees est 291 feet to a
point'in the center of the said Walnut Bottom Road,thence along the center of said Walnut Bottom Road,
North 62 degrees 15 minutes East 150 feet to a point,the Place of BEGINNING
Containing 1 acre, more or less.
TITLE TO SAID PREMISES IS VESTED IN Harry L. Sampson and Carol M. Sampson, h/w,
by Deed from Jones Family Trust and William M. Jones and Fannie E. Jones, co-trustees, h/w,
dated 09/28/2004, recorded 09/30/2004 in Book 265, Page 2388. By virtue of the death of Carol
M. Sampson on or about 811812010 title to the premises became vested solely in Harry L.
Sampson, as surviving.tenant by the entirely.
PREMISES BEING: 2212 WALNUT BOTTOM ROAD,CARLISLE;PA 17015-7932
PARCEL NO.08-11-0294-006.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 13-850 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due PENNYMAC MORTGAGE INVESTMENT TRUST
HOLDINGS,1,LLC Plaintiff(s)
From HARRY L.SAMPSON
(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 gamishee(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: $194,771.64 L.L.:$.50
Interest FROM 6/26/13 TO DATE OF SALE($32.02 PER DIEM)-$5,187.24
Atty's Comm: Due Prothy:$2.25
Atty Paid:$188.75 Other Costs:
Plaintiff Paid:
Date: 6/25/13
i D.Buel rothonotary
(Seal) r By:
Deputy
REQUESTING PARTY:
Name: ADAM H.DAVIS,ESQUIRE
,Address:PHELAN HALLINAN,LLP
1617 JFK BLVD.,SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA,PA 19103
Attorney for:PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No.203034
i
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, =,
LLC PH#310304 �G"> .A
DEFENDANT SERVICE TEAM/lxh -^J Co illm-
HARRY L.SAMPSON COURT NO.:13-850-CIVIL
SERVE HARRY L.SAMPSON AT: TYPE OF ACTION ,
2007 WALNUT BOTTOM ROAD XX Notice of Sheriff's Sale
CARLISLE,PA 17015-9355 SALE DATE: December 4,2013 tGQ C-,
SERVED G ^
Suved and made known to HARRY L.SAMPSON,Defendant on the day of ! 20 J L at -4
o'clock M.,at ` 0o'l-k1FLWT 'MfA ON) ,in the manner described below:
!Defendant personally served.
Adult family member with whom Defendant(s)reside(s).
Relationship is
_Adult in charge of Defendant's residence who refused to give name or relationship.
_Manager/Clerk of place of lodging in which Defendant(s)reside(s).
Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
_Other: ii,,��yy'' e
Description: Age q6 Height Weight 's RacWMSex (v` Other
I, �tN6C' �C�II�a competent adult,hereby verify that I personally handed a true and correct copy of the
Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
DATE: �l3 NAME:
PRINTED NAME: ANZe-UKA ��tN
TITLE: Moc>r s S S -
NOTSERVED
On the da of 20 at o'clock_.M.,I, a competent adult hereby
state tha�endant TN F�'ecause:
_Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant)
No Answer on at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
(215)563-7000
E3-cY' i Iii:
t= THE FRO i1-{ONUTA€VI
Phelan Hallinan, LLP
Lobb, Esq., Id. No.312174 2:"., 3 OCT if 10'J i1TORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 i7UMBE fil AND COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
Jonathan.Lobb @phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT • Court of Common Pleas
TRUST HOLDINGS I, LLC •
Plaintiff • Civil Division
v. • CUMBERLAND County
HARRY L. SAMPSON • No.: 13-850-CIVIL
Defendant
PLAINTIFF'S MOTION TO REASSESS DAMAGES
Plaintiff, by its Attorneys, Phelan Hallinan, LLP,moves the Court to direct the
Prothonotary to amend the judgment in this matter, and in support thereof avers the following:
1. Plaintiff commenced this foreclosure action by filing a Complaint on February 15,
2013.
2. Judgment was entered on June 25, 2013 in the amount of$194,771.64. A true
and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked
as Exhibit"A".
3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment
containing a dollar amount must be entered for the amount claimed in the complaint and any item
which can be calculated from the complaint,i.e. bringing the interest current. However,new items
cannot be added at the time of entry of the judgment.
4. The Property is listed for Sheriffs Sale on December 4, 2013.
804066
5. Additional sums have been incurred or expended on Defendant's behalf since the
Complaint was filed and Defendant has been given credit for any payments that have been made
since the judgment. The amount of damages should now read as follows:
Principal Balance $165,257.31
Interest Through December 4, 2013 $41,408.79
Legal fees $2,075.00
Cost of Suit and Title $856.05
Property Inspections $258.00
Property Preservation $3,240.00
Escrow to be paid $201.00
Escrow Deficit $12,942.22
Suspense/Misc. Credits ($400.46)
TOTAL $225,837.91
6. Plaintiff paid the following in property preservation during the time the loan was in
default:
10/23/2012 REKEY COST $95.00
10/23/2012 WINTERIZATION $185.00
10/25/2012 PROPERTY PRESERVATION $35.00
11/28/2012 PHOTOS $20.00
1/11/2013 INTERIOR TRASH REMOVAL $2,250.00
1/11/2013 ROOF REPAIR $135.00
1/11/2013 REKEY COST $80.00
1/11/2013 ENVIRONMENTAL REPAIR $100.00
5/2/2013 GRASS CUT $100.00
6/19/2013 GRASS CUT $60.00
7/12/2013 GRASS CUT $60.00
7/26/2013 GRASS CUT $60.00
8/26/2013 GRASS CUT $60.00
TOTAL $3,240.00
7. Plaintiff paid the following in taxes and insurance during the time the loan was in
default:
4/10/2011 TAX ADVANCE $1,959.80
804066
7/20/2011 TAX ADVANCE $44.35
7/20/2011 TAX ADVANCE $362.20
7/20/2011 TAX ADVANCE $83.36
7/20/2011 TAX ADVANCE $422.95
7/20/2011 TAX ADVANCE $348.31
7/20/2011 TAX ADVANCE $2,068.86
3/26/2012 CITY TAX $401.15
4/3/2012 TAX ADVANCE $362.20
8/20/2012 TAX ADVANCE $1,977.52
10/16/2012 HOMEOWNERS INSURANCE $796.98
11/29/2012 HOMEOWNERS INSURANCE $194.00
12/27/2012 HOMEOWNERS INSURANCE $201.00
1/28/2013 HOMEOWNERS INSURANCE $201.00
2/27/2013 HOMEOWNERS INSURANCE $182.00
3/26/2013 HOMEOWNERS INSURANCE $200.00
4/30/2013 HOMEOWNERS INSURANCE $195.00
5/30/2013 HOMEOWNERS INSURANCE $201.00
7/2/2013 HOMEOWNERS INSURANCE $194.00
7/30/2013 HOMEOWNERS INSURANCE $200.98
8/1/2013 HOMEOWNERS INSURANCE $201.00
8/5/2013 TAX ADVANCE $2,144.56
TOTAL $12,942.22
8. The judgment formerly entered is insufficient to satisfy the amounts due on the
Mortgage.
9. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to
inclusion of the figures set forth above in the amount of judgment against the Defendant.
10. Plaintiffs foreclosure judgment is in rem only and does not include personal
liability, as addressed in Plaintiffs attached brief.
11. In accordance with Cumberland County Local Rule 208.3(9),Plaintiff sent a copy of
its proposed Motion to Reassess Damages and Order to the Defendant on September 24, 2013 and
requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant.
804066
A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of
mailing are attached hereto, made part hereof, and marked as Exhibit"B".
12. No judge has previously entered a ruling in this case.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the
judgment as requested.
Phelan Hallinan,LLP
DATE: / Q 13), 7 By:
athan Lobb, Esquire
ATTORNEY FOR PLAINTIFF
804066
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Jonathan.Lobb@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT Court of Common Pleas
TRUST HOLDINGS I, LLC •
Plaintiff : Civil Division
v.
• CUMBERLAND County
HARRY L. SAMPSON • No.: 13-850-CIVIL
Defendant
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFF'S MOTION TO REASSESS DAMAGES
I. BACKGROUND OF CASE
HARRY L. SAMPSON and CAROL M. SAMPSON, DECEASED executed a Promissory
Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance
premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was
secured by a Mortgage on the Property located at 2212 WALNUT BOTTOM ROAD,
CARLISLE, PA 17015-7932. The Mortgage indicates that in the event of a default in the
mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other
items, in order to protect the security of the Mortgage.
In the instant case, Defendant defaulted under the Mortgage by failing to tender numerous,
promised monthly mortgage payments. Accordingly, after it was clear that the default would not be
cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently
entered by the Court, and the Property is currently scheduled for Sheriffs Sale.
804066
Because of the excessive period of time between the initiation of the mortgage foreclosure
action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are
outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums,
costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage
in order to protect its interests. It is also appropriate to give Defendant credit for monthly payments
tendered through bankruptcy, if any.
II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT
It is settled law in Pennsylvania that the Court may exercise its equitable powers to control
the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E.,
Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase
Home Mortgage Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The
Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its
judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489
(Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998).
Union National Bank of Pittsburgh v. Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991).
The Supreme Court of Pennsylvania recognized in Landau v. Western Pa.Nat. Bank,445
Pa. 117, 282 A.2d 335 (1971),that the debt owed on a Mortgage is subject to change and, in fact,
can be expected to change from day to day because the bank must advance sums in order to protect
its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must
protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d
826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the
judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality
804066
•
Company v. Burns,414 Pa. 495,200 A.2d 335 (1971). Plaintiff submits that if it goes to sale
without the requested amended judgment, and if there is competitive bidding for the Property,
Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to
protect its interests. Conversely, amending the in rem judgment will not be detrimental to
Defendant as it imputes no personal liability.
In B.C.Y. v. Bukovich,the Pennsylvania Superior Court reiterated its long standing rule that
a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa.
Super. 157, 390 A.2d 276 (1978). In the within case,the amount of the original judgment does not
adequately reflect the additional sums due on the Mortgage due to Defendant's failure to tender
payments during the foreclosure proceeding and the advances made by the mortgage company. The
Mortgage plainly requires the mortgagor to tender to the mortgagee monthly payments of principal
and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagor is
also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance
premiums,fire insurance premiums,taxes and other assessments relating to the Property. The
mortgagor has breached the terms of the Mortgage, and Plaintiff has been forced to incur
significant unjust financial losses on this loan.
III. THE FORECLOSURE JUDGMENT IS IN REM ONLY
The within case is a mortgage foreclosure action,the sole purpose of which is to take the
mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage
foreclosure is strictly in rem and does not include any personal liability. Newtown Village
Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer
804066
Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania
Rule of Civil Procedure 1141(a).
However, Pennsylvania law requires that the foreclosure action demand judgment for the
amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for
bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the
mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would
receive the amount of the in rem judgment from the Sheriff.
IV. INTEREST
The Mortgage clearly requires that the Defendant shall promptly pay when due the principal
and interest due on the outstanding debt. In addition,the Note specifies the rate of interest to be
charged until the debt is paid in full or otherwise satisfied. Specifically,interest from 30 days prior
to the date of default through the date of the impending Sheriffs sale has been requested.
V. TAXES AND INSURANCE
If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure
proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale,
Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the
outstanding balance due on the loan. If the Property were damaged in a fire,Plaintiff would not be
able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums.
Most importantly,the Mortgage specifically provides that the mortgagee may advance the
monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is
simply seeking to have the Court enforce the terms of the Mortgage.
804066
VI. ATTORNEY'S FEES
The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done
throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91
letters, loan documents, account records, title reports and supporting documents, preparing and
reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1
Notice, Department of Defense search, entry of judgment, the writ of execution process, lien
holder notices, and all of the other legal work that goes into handling the mortgage foreclosure
lawsuit.
The Mortgage specifically provides for Plaintiff's recovery of its attorney fees. The
amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the
loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded
that a request of five percent of the outstanding principal balance is reasonable and enforceable as
an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan
Association v. Street Road Shopping Center, 68 D&C 2d 751, 755 (1974).
In Federal Land Bank of Baltimore v. Fetner,the Superior Court held that an attorney's fee
of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super.
1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included
in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton
Realty, 662 A.2d 1120 (Pa. Super. 1995). Plaintiffs legal fees are not a percentage but are
significantly less than what is permitted by Pennsylvania law.
804066
VII. COST OF SUIT AND TITLE
Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in
the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff
paid to date as a result of the mortgage default.
The title report is necessary to determine the record owners of the property, as Pa.R.C.P.
1144 requires all record owners to be named as Defendants in the foreclosure action. It is also
necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale
purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens
on the property, whether the Defendants are divorced (which could affect service of the
complaint), and numerous other legal issues. The title bringdown is necessary to identify any
new liens on the property or new owners between the time of filing and complaint and the writ
date.
The Freedom of Information Act inquiries and the investigation into Defendants'
whereabouts are necessary to effectively attempt personal service of the complaint and notice of
sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1
and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriff's sale date, as
their interests will be divested by the Sheriff's sale.
Accordingly,the modest sums Plaintiff has incurred for the costs of suit and title were
necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred.
The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its
foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from
the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of
suit and title in their entirety, which will not cause harm to the Defendants.
804066
VIII. PROPERTY INSPECTIONS AND PRESERVATION
The terms of the mortgage provide for property inspections and property preservation
charges. The lender or its agent may make reasonable inspections of the property pursuant to the
terms of the mortgage. When a borrower defaults under the terms of the mortgage,the lender
may do, or pay for, whatever is reasonable to protect its interest in the collateral, including
property maintenance. Any amounts disbursed by the lender for property inspections and
preservation become additional debt of the borrower secured by the mortgage. The lender may
charge the borrower for services performed in connection with the default, for the purpose of
protecting the lender's interest in the property, including property inspections and valuation
costs.
When a loan is in default,the lender's risk increases. Mortgage companies typically have
a vendor visit the premises to determine if any windows need to be boarded up, if the property is
vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any
problems at the mortgaged premises,then the mortgage company may proceed to take whatever
steps are necessary to secure the collateral, such as boarding windows, winterizing, removing
hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks,
which are referred to in the industry as "property preservation". These services avoid code
violations and avoid the property becoming an eyesore in the neighborhood. Property
preservation helps maintain property values in the neighborhood.
Accordingly, line items included in Motions to Reassess Damages for property
inspections and property preservation represent amounts which the mortgage company has paid
out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract.
804066
Since the terms of the mortgage provide that such expenses by the mortgage company become
part of the borrower's debt secured by the mortgage, those expenses are properly included in the
Plaintiff's Motion to Reassess Damages.
IX. CONCLUSION
Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by
legal proceedings, and such delays require the mortgagee to expend additional sums provided for by
the Mortgage,then the expenses necessarily become part of the mortgagee's lien and should be
included in the judgment.
Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess
Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance
with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would
recover the monies it expended to protect its collateral.
WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the
judgment as requested.
Phelan Hallinan,LLP
DATE: j8 /3 /,a By: fr
' athan Lobb, Esquire
Attorney for Plaintiff
804066
Exhibit "A"
804066
•
FILED-OFFICE
1;F THE PROTHONOTARY
PHELAN HALLINAN, LLP 0 3��UN 2 JQ: Attorney for Plaintiff
Adam H. Davis, Esq., Id. No.203034 CUMBERLAND COUNTY
1617 JFK Boulevard, Suite 1400 PENNSYLVANIA
One.Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE : CUMBERLAND COUNTY
INVESTMENT TRUST HOLDINGS I,
LLC : COURT OF COMMON PLEAS
vs. : CIVIL DIVISION
HARRY L. SAMPSON : No. 13-850-CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY: -
Kindly enter judgment in favor of the Plaintiff and against HARRY L.SAMPSON,
Defendant(s)for failure to file an Answer to Plaintiff's Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises,and assess Plaintiff's damages as
follows:
•
As set forth in Complaint $194,771.64
TOTAL $194,771.64
I hereby certify that(1) the Defendant's last known addresses are 2007 WALNUT
BOTTOM ROAD, CARLISLE,PA 17015-9355 and 2212 WALNUT BOTTOM ROAD,
CARLISLE, PA 17015-7932, and(2) that notice has been given in accordance with Rule
Pa.R.C.P 237.1. �1 l
Date C/SVI7 C���C►' �yi f�Gs-w..
Adam H. Davis,Esq.,Id.No.203034
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED. -
DATE: _t I" _ `'3 %44 A
PH$#310304 PROTHONOTARY
310304
auNt+-: ,3�1�y
tvicit(e �� --pq aa)s
Exhibit "B"
804066
PHELAN HALLINAN, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia,PA 19103
(215) 563-7000
FAX#: (215) 563-3459
Phelan Hallinan, LLP Representing Lenders in
Pennsylvania
September 24, 2013
HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
RE: PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC v. HARRY L.
SAMPSON
Premises Address: 2212 WALNUT BOTTOM ROAD CARLISLE,PA 17015
CUMBERLAND County CCP,No. 13-850-CIVIL
Dear Defendant,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your
concurrence with the requested relief that is,increasing the amount of the judgment. Please
respond to me within 5 days,by 9/30/2013.
Should you have further questions or concerns,please do not hesitate to contact me.
Otherwise,please be guided accordingly.
Very truly yours,
Jonathan Lobb,Esq.,Id. No.312174
Attorney for Plaintiff
Enclosure
804066
Name and Phelan•Hallinan,LLP I c
Address. 1617 JP'K Boulevard,Suite 1400
Of Sender One Penn Center Plaza X CV A
Philadelphia,PA 19103 .. .KVM i
.1 Line Article Number Name of Addressee,Street,and P t Office Address Pow w III
4
1 .•*•M. HARRY•L sAMPSO1J 50.46. °
2007 WALNUTBOTTOMROAD � w
. ;i CARLISLE,PA 17013-93 .
2 •••4 HARRY L.SAMPSON $0.4t +�' °�a°
2212 WALNUT B{T1 Ct7M ROAD V.
CARLISLE,PA 17015-7932 f.'
y
RE:HARRY L.SAMPSON(CUM ERLANI) PH#80406611200 Page I of 1 , S0.9 Y:s3
Toldllionbcrof Total Number of Picas Pier. ^ —
Piami Listed Seedeo Received*Pest Office React tNw+c of The fea dalsuion of value a required m W 6oaustic seed arogodiond tegisttfed ma �yyj Cy
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ill piao,subitei oci a limit of$300.000 per oaarrtnoe.The motor.'Memaits WnDb, .. .
,,
The lentimae indemnity papbte 8$33.000 for rcpeteisd meit,scm with optional i>u: " 4•
8900 S913 sal Silt for tim�niuesofeosente, = �
Form 3877 Facsimile '+^.i
•
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.
xF
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Jonathan.Lobb@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT • Court of Common Pleas
•
TRUST HOLDINGS I, LLC
Plaintiff • Civil Division
v.
• CUMBERLAND County
•
HARRY L. SAMPSON : No.: 13-850-CIVIL
•
Defendant
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages,
and Brief in Support thereof, were sent to the following individual on the date indicated below.
HARRY L. SAMPSON HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355 CARLISLE, PA 17015-7932
Phelan Hallinan,LLP
DATE: 1e1343 By
J athan Lobb, Esquire
ATTORNEY FOR PLAINTIFF
804066
•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
PENNYMAC MORTGAGE INVESTMENT • Court of Common Pleas
•
TRUST HOLDINGS I, LLC
Plaintiff • Civil Division
v. • CUMBERLAND County
•
HARRY L. SAMPSON : No.: 13-850-CIVIL
Defendant
RULE
AND NOW, this 17" day of Otril L.✓ 2013, a Rule is entered upon the Defendant
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY THE COURT
J.
mC3
--,
t-"
V...r ,..)
804066
onathan Lobb,Esq., Id.No.312174
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia,PA 19103
TEL: (215)563-7000
FAX: (215)563-3459
MARRY L. SAMPSON --'HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355 CARLISLE, PA 17015-7932
GT I ``S 804066
0/08
804066
I iEa rROTHONO TA:\
2313 OCT 21 AM 10: 10
CUMBERLAND COUNTY
PENNSYLVANIA
Phelan Hallinan, LLP
Allison F. Zuckerman, Esq., Id. No.309519 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
allison.zuckerman@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT : Court of Common Pleas
•
TRUST HOLDINGS I, LLC
Plaintiff • Civil Division
•
vs. • CUMBERLAND County
HARRY L. SAMPSON • No.: 13-850-CIVIL
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's October 9, 2013 Rule directing
the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individual on the date indicated below.
HARRY L. SAMPSON HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355 CARLISLE, PA 17015-7932
Phe . allinan, rl
DATE: I A, By:
All'..n ' rman, - q., Id. No.309519
ttomey or Pia'.
804066
•
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f' r t Ali it,_
2.;!3 yqs^4� y�
l€13 i4U f0: O
PHELAN HALLINAN,LLP Attorney for P1aititit4DC BLAND coc���
John Michael Kolesnik,Esq.,Id.No.308877 � l�r���'� VAN I
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
John.Kolesnik@phelanhallinan.com
215-563-7000
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,PENNSYLVANIA
PENNYMAC MORTGAGE INVESTMENT TRUST CUMBERLAND COUNTY
HOLDINGS I,LLC .
Plaintiff, COURT OF COMMON PLEAS
•
v. CIVIL DIVISION
•
HARRY L.SAMPSON No.: 13-850-CIVIL
Defendant(s) .
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.2(a)Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c)on each of
the persons or parties named,at that address,set forth on the Affidavit and as amended if
applicable.A copy of the Certificate of Mailing (Form 3817 and/or Certified Mail Return
Receipt stamped by the U.S.Postal Service is attached t 1 •sr ' ''bit"A".
•
Jo t '°chael Kolesnik,Esq.,Id.No.308877
)//0.1 ttorney for Plaintiff
Date:
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PH#804066
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Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Jonathan.Lobb@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT Court of Common Pleas
TRUST HOLDINGS I, LLC •
Plaintiff Civil Division
vs. • CUMBERLAND County
HARRY L. SAMPSON • No.: 13-850-CIVIL
•
Defendant
MOTION TO MAKE RULE ABSOLUTE
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, LLC, by and
through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute
in the above-captioned action, and in support thereof avers as follows:
1. A Motion to Reassess Damages was filed with the Court on October 4, 2013.
2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy
of its proposed Motion to Reassess Damages and Order to the Defendant on September 24, 2013
and requested the Defendant's Concurrence. Plaintiff did not receive any response from the
Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and
certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A.
804066
3. A Rule was issued on October 9, 2013 directing the Defendant to show cause by
October 29, 2013 why the Motion to Reassess Damages should not be granted. A true and
correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B.
4. The Rule to Show Cause was timely served upon all parties on October 18, 2013
in accordance with the applicable rules of civil procedure. A true and correct copy of the
Certificate of Service is attached hereto, made part hereof, and marked Exhibit C.
5. Defendant failed to respond or otherwise plead by the Rule Returnable date of
October 29, 2013.
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiffs Motion to Reassess Damages.
Phelan Hallinan, LLP
DATE: 1/ 12 /13 By: /air
.:'athan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
804066
. .
Exhibit "A"
804066
.1..64 " -
PHELAN HALLINAN, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
FAX#: (215) 563-3459
Phelan Hallinan, LLP Representing Lenders in
Pennsylvania
September 24,2013
HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
RE: PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, LLC v. HARRY L.
SAMPSON
Premises Address: 2212 WALNUT BOTTOM ROAD CARLISLE,PA 17015
CUMBERLAND County CCP,No. 13-850-CIVIL
Dear Defendant,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your
concurrence with the requested relief that is,increasing the amount of the judgment. Please
respond to me within 5 days,by 9/30/2013.
Should you have further questions or concerns,please do not hesitate to contact me.
Otherwise,please be guided accordingly.
Very truly yours,
Jonathan Lobb,Esq., Id.No.312174
Attorney for Plaintiff
Enclosure
804066
Exhibit "B"
804066
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
PENNYMAC MORTGAGE INVESTMENT Court of Common Pleas
TRUST HOLDINGS I, LLC
Plaintiff Civil Division
v. CUMBERLAND County
HARRY L. SAMPSON No.: 13-850-CIVIL
Defendant
RULE
AND NOW,this 941‘,...,. day of62,1 _2013, a Rule is entered upon the Defendant
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY THE COURT
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804066
•
Jonathan Lobb,Esq., Id,No.312174
Phelan Hallinan,LLP
1617 JFK,Boulevard,Suite 140(3
Philadelphia, PA 19103
TEL: (215) 563-7000
FAX: (215)563-3459
SAMPSON HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355 CARLISLE,PA 17015-7932
804066
804066
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•
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LED OF
Lft THE PROTHONOTAk
all 3 OCT 2 AM 10: I 0
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney File Copy
Please Returri
Phelan Hallinan, LLP
Allison F. Zuckerman, Esq., Id. No.309519 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
allison.zuckerman@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT
Court of Common Pleas
TRUST HOLDINGS I, LLC
Plaintiff Civil Division
vs. CUMBERLAND County
FIE„T;z:
HARRY L. SAMPSON L 0
No.: 13-850-CIVIL
•
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's October 9, 2013 Rule directing
the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individual an the date indicated below.
HARRY L. SAMPSON Pe: 'HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355 CARLISLE, PA 17015-7932
Phelan Hallinan,
• s / )
DAIE: By:l
( .1,..Zyckennau) ,Id.No.309519
-Attorney for Plaintiff
804066
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Jonathan.Lobb@phelanhallinan.com
215-563-7000
PENNYMAC MORTGAGE INVESTMENT • Court of Common Pleas
TRUST HOLDINGS I, LLC
Plaintiff • Civil Division
•
vs. • CUMBERLAND County
•
HARRY L. SAMPSON : No.: 13-850-CIVIL
•
Defendant
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute
was served upon the following individual on the date indicated below.
HARRY L. SAMPSON HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD 2212 WALNUT BOTTOM ROAD
CARLISLE, PA 17015-9355 CARLISLE, PA 17015-7932
Phelan Hallinan, LLP
DATE: 47 13 By: /A
J 4'than Lobb,Esq.,Id. No.312174
Attorney for Plaintiff
804066
°H f'nCT110 N 01 '
2013 HOY 14 AM 11: 52
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
PENNYMAC MORTGAGE INVESTMENT Court of Common Pleas
TRUST HOLDINGS 1, LLC
Plaintiff Civil Division
vs. CUMBERLAND County
HARRY L. SAMPSON No.: 13-850-CIVIL
Defendant
ORDER
AND NOW, this /q' day of A,bj&,4%- , 2013, upon consideration of Plaintiff's
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendant shall be and is hereby made absolute and Plaintiff's Motion to Reassess
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance $165,257.31
Interest Through December 4, 2013 $41,408.79
Legal fees $2,075.00
Cost of Suit and Title $856.05
Property Inspections $258.00
Property Preservation $3,240.00
Escrow to be paid prior to December 4, 2013 $201.00
Escrow Deficit $12,942.22
Suspense/Misc. Credits ($400.46)
TOTAL $225,837.91
804066
Plus interest at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
BY T COURT:
J.
j . 1
�1.
804066
• .fr `"- lPtiOTHONOTAi
1Mikl JAN -6 A,K tO: 69
•
•
CUMBERLAND COUNTY
PENNSYLVANIA
•
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE Court of Common Pleas
INVESTMENT TRUST HOLDINGS I, .
LLC Civil Division
Plaintiff
. CUMBERLAND County
v.
No.13-850-CIVIL
HARRY L.SAMPSON
Defendant(s)
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF
PURSUANT TO Pa.R.C.P.,2352
TO THE PROTHONOTARY:
Kindly substitute PENNYMAC HOLDINGS,LLC F/K/A PENNYMAC MORTGAGE
INVESTMENT TRUST HOLDINGS I, LLC as successor Plaintiff for the originally named Plaintiff.
The material facts on which the right of succession and substitution are based as follows:
"By the Certificate of Amendment of Pennymac Mortgage investment
Trust Holdings I, LLC, changing its name from Pennymac mortgage
investment trust holdings I, LLC to Pennymac Holdings, LLC."
Kindly amend the information on the docket accordingly.
Date: 110/P1 By:
Mere ith Wooters,Esq., Id. No.307207
Attorney for Plaintiff
PH#804066
C
•
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE Court of Common Pleas
INVESTMENT TRUST HOLDINGS I,
LLC Civil Division
Plaintiff
CUMBERLAND County
v.
No. 13-850-CIVIL
HARRY L.SAMPSON
Defendant(s)
PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned matter to the use of PENNYMAC
HOLDINGS, LLC F/K/A PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I,LLC,
located 6101 CONDOR DRIVE, SUITE 310,MOORPARK,CA 93021.
Date: ity//y PHELAN HALLINAN,`LP
I
By: / / /
Meredith Wooters,Esq., Id. No.307207
Attorney for Plaintiff
PH#804066
•
•
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE Court of Common Pleas
INVESTMENT TRUST HOLDINGS I,
LLC Civil Division
Plaintiff
•
CUMBERLAND County
v.
•
No. 13-850-CIVIL
HARRY L.SAMPSON
Defendant(s)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of PENNYMAC HOLDINGS, LLC F/K/A
PENNYMAC MORTGAGE INVESTMENT TRUST HOLDINGS I, LLC.
Date: 1/I11 PHELAN HALLINAN,LLP
By: 441, .,I
Meredith Wooters,Esq., Id. No.307207
Attorney for Plaintiff
PH#804066
•
•
•
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
PENNYMAC MORTGAGE • Court of Common Pleas
INVESTMENT TRUST HOLDINGS I,
LLC Civil Division
Plaintiff •
•
CUMBERLAND County
v.
No. 13-850-CIVIL
HARRY L.SAMPSON
Defendant(s)
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of the foregoing Plaintiffs Praecipe to Mark
Judgment to PENNYMAC HOLDINGS, LLC F/K/A PENNYMAC MORTGAGE INVESTMENT
TRUST HOLDINGS I, LLC, Substitution of Party Plaintiff and Entry of Appearance were served
by regular mail on the person(s) on the date listed below:
HARRY L. SAMPSON
2007 WALNUT BOTTOM ROAD
CARLISLE,PA 17015-9355
Date: 1/J/l7 PHELAN HALLINAN, LLP
By: / , ► /UAW&
Meredith Wooters,Esq., Id. No.307207
Attorney for Plaintiff
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFFICE. OF ME SRERIFF
fig
i PRO
-HE THON -u Tf;P
20'r1 R27 PH 00
CUMBE LAND COUNTY
PENNSYLVANIA
PennyMac Mortgage Investment Trust Holdings I, LLC
vs.
Harry Lee Sampson
Case Number
2013 -850
SHERIFF'S RETURN OF SERVICE
10/02/2013 01:08 PM - Deputy Stephen Bender, 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 2212 Walnut Bottom Road, Dickinson - Township,
Carlisle, PA 17013, Cumberland County.
10/08/2013 05:40 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: Harry
Lee Sampson at 2007 Walnut Bottom Rd., Carlisle, PA 17015, Cumberland County.
12/04/2013 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, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at
10:00 AM. He sold the same for the sum of $1.00 to Attorney Joseph Schalk, on behalf of Pennymac
Mortgage Investment Trust Holdings I, LLC, being the buyer in this execution, paid to the Sheriff the sum
of $
SHERIFF COST: $805.75 SO ANSWERS,
February 19, 2014
(c) CountySuite Sheriff, Teleosott, Inc.
RONR ANDERSON, SHERIFF
•
I _•
On September 9, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in.
Dickinson Township, Cumberland County, PA,
Known and numbered as, 2212 Walnut Bottom Road,
Carlisle, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
Date: September 9; 2013
By:
Real Estate Coordinator
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No. 2013-850 Civil Term
PENNYMAC MORTGAGE
INVESTMENT TRUST
HOLDINGS I, LLC
vs.
HARRY LEE SAMPSON
Atty.: Joseph Schalk
By virtue of a Writ of Execu-
tion No. 13-850-CIVIL, PENNYMAC
MORTGAGE INVESTMENT TRUST
HOLDINGS I, LLC v. HARRY L.
SAMPSON owner(s) of property
situate in DICKINSON TOWNSHIP,
CUMBERLAND County, Pennsylva-
nia, being 2212 WALNUT BOTTOM
ROAD, CARLISLE, PA 17015-7932.
Parcel No. 08-11-0294-006.
Improvements thereon: RESIDEN-
TIAL DWELLING.
Judgment Amount: $194,771.64.
103
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.
Lisa Marie Coyn , Editor
SWORN TO AND SUBSCRIBED before me this
da of October, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot -News Co.
2020 Technology Pkwy
- Suite 300
Mechanicsburg, PA 17050
Inquiries - 717- 255 -8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
he ]3atriotXews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and /or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M ", Volume 14, Page 317.
PUBLICATION COPY
2013 -850 C1vlI Term
PENNYMAC MORTGAGE
INVESTMENT TRUST HOLDINGS
I, LLC
vs.
HARRY LEE SAMPSON
Atty: Joseph Schalk
By virtue of a Writ of Execution No.
13- 850 -CIVIL
PENNYMAC MORTGAGE
INVESTMENT TRUST HOLDINGS I,
LLC
v.
HARRY L. SAMPSON
owner(s) of property situate in DICKINSON
TOWNSHIP, CUMBERLAND County,
Pennsylvania, being
2212 WALNUT BOTTOM ROAD,
CARLISLE, PA 17015 -7932
Parcel No. 08 -11 -0294-006.
(Acreage or street address)
Improvements thereon: RESIDENTIAL
DWELLING
Judgment Amount: $194,771.64
This ad ran on the date(s) shown below:
10/13/13
10/20/13
10/27/13
Sworn t
ubscribed before me ,�;s ,1 day of November, 2013 A.D.
Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Hotly Lynn Warfel, Notary Public
Washington Twp., Dauphin County
MY Commission Expires Dec 12, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
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 Pennymac Mortgage Investment Trust Holdings LLC is the grantee the same
having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ
Execution issued on the 25th day of June, A.D., 2013, out of the Court of Common Pleas of said County
as of Civil Term, 2013 Number 850, at the suit of Pennymac Mortgage Investment Holdings I LLC
against Harry L. Sampson is duly recorded as Instrument Number 201406174.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
VIM-C.9n , A.D.
day of
aafq
Recorder of Deeds
Recorder oi Deeds, Cumberland County, Carlisle, PA
My Commission Expires the First Monday of Jan. 2018