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HomeMy WebLinkAbout13-1012~~ i ; _ ~~i ~ r~E-- 1 + 2~~i3 FtB 22 P'n~ 12~ ~ 2 C~ ~ `~~ rv L ~,~ ~ .I..~, McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIItE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIItO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUII2E - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUII2E - ID #314675 123 South Broad Street, Suite 1400 Attorneys for Plaintiff Philadelphia, Pennsylvania 19109 (215) 790-1010 Federal National Mortgage Association c/o Seterus, Inc. 14523 SW Millikan Way, Suite 200 Beaverton, OR 97005 v. /~ I ~f Number ~ ~j - I V l ~ V Kathryn T. Dillard 185 Chain Saw Road Dillsburg, PA 17019 COMPLAINT IN MORTGAGE FORECLOSURE /~~~ t/t/I"~ ~ l ~3/~ ~~. ~ CoSCoI~, File # 68622 Page 1 Cumberland County Court of Common Pleas 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 OFFERLEGAL 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 cone. 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 notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 file # 68622 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is Federal National Mortgage Association, a government sponsored enterprise having offices located at the above address. 2. The Defendant is Kathryn T. Dillard, who is the mortgagor and real owner ofthe mortgaged property hereinafter described., and her last-known address is 185 Chain Saw Road, Dillsburg, PA 17019. On September 4, 2003, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Suntrust Mortgage, Inc. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1834, Page 4404, such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On May 7, 2007, the aforesaid mortgage was thereafter assigned by Suntrust Mortgage, Inc to Mortgage Electronic Registration Systems, Ina (HERS), by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Book 737, page 1167, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. On October 25, 2011, the aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc. As Nominee for Suntrust Mortgage, Inc., Its Successors and Assigns to Suntrust Mortgage, Inc., by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Instrument Number 201131478, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. On February 17, 2012, the aforesaid mortgage was thereafter assigned by Suntrust Mortgage, Inc. to Federal National Mortgage Association, Plaintiff herein, by Assignment of Mortgage, recorded in the Office ofthe Recorder of Cumberland County in Assignment of Mortgage Instrument Number 201206822, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 213 Forge Road, Boiling Springs, Pennsylvania 17007. File # 68622 Page 3 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November 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. 9. The following amounts are due on the mortgage: Principal Balance $ 97,443.99 Interest through September 27, 2012 $ 5,556.98 (Plus $15.35 per diem thereafter) Late Charges $ 130.72 Attorney's Fee $ 1,650.00 Escrow Advance $ 1,607.90 Property Inspections $ 90.00 GRAND TOTAL $ 106,479.59 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. 10. 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. WHEREFORE, Plaintiffdemands in rem Judgment against the Defendant in the sum of $106,479.59, together with interest at the rate of $15.35 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.C. BY: [ ] TERRENCE J. McCABE, ESQUI [ ] MARC S. WEISBERG, ESQUI [ ]EDWARD D. CONWAY, ESQ RE [ ]MARGARET GAIRO, ESQUIRE ~,L] ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff File # 68622 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. BY: [ ] TERRENCE J. cCABE, QU E [ ] MARC S. WEISBERG, ESQUI E [ ]EDWARD D. CONWAY, ESQ IRE [ ]MARGARET GAIRO, ESQUI E ANDREW L. MARKOWITZ, ESQUIRE `~] HEIDI R. SPNAK, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE Attorneys for Plaintiff Federal National Mortgage Association v. Kathryn T. Dillard File # 68622 Page 5 E~~~i~ H136FZB2 SCHEDULE A ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF SOUTH MIDDLETON, COUNTY OF CUMBERLAND, ANO STATE OF PENNSYLVANIA BEING MORE PARTICULARLY DESCRIBED IN A DEED RECORDED IN BOOK 184 AT PAGE 661 AMONG THE LAND RECORDS OFTHE COUNTY SET FORTH ABOVE. PARCEL ID: 44-28-2100-149 KNQWN AS: 213 FORGE ROAD I C=er-ti fy lhis io be recorded in Cumbcrla~d County PA t Recorder of Deeds ~! 994P~3761 .FORM 1 Federal National Mi~rtgage Association Plaintiff VS. Kathryn T. Dillard Defendant IN THC; COURT OF COMMON PI I;A~.t~F ~..., ~ CUML3I:R[,AND COUNTY, PFNNSYI.,~#1N~ ~~~ "~'~ ~ ~ s~i-Y: ~ ~~ e~ "~~~ ..-.~,~ Civil ~--N- :,:.-fl? ~~ _ ,- ~ __._ -.a NOTICE OF RESIDENTIAL MORTGAGE FORECLOS~JI~E 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 (7l 7) 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. [f 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. ,v Date Respectfully submi ed r [Signature of Counsel for aintiff] 68622 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: State: Zip: Yes ^ No ^ Listing date: Price $ Realtor Phone: Yes^No^ State: Zip: Home: Office: Cell: Other: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: _ Office: Cell: Other: Email: # of people on household: First Mortgage Lender: Type of Loan: How long? Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: 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: Year: Amount owed: _ Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs 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: 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 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: Phone: 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 obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements f 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 FILED-OFFICE OF THE PROTHONOTAR'i 2413 APR -8 AM 9: 15 U'A SYLVAN1ANTY 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 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Federal National Mortgage Association Cumberland County Plaintiff Court of Common Pleas V. Number 13-1012 Civil Kathryn T. Dillard Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above-captioned matter. McCABE,WEISB AND C NWAY,P.C. BY: '41 [ ]Terrence J.McCabe squire [ ]Marc S. Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L. Markowitz,Esquire ['-'l 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 .0 [ ]Joseph I.Foley,Esquire 6 1 Attorneys for Plaintiff / D SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �ILED-OF FiC Sheriff .3F TF1,E PROTHON(j 1ARY Jody S Smith 2013 MAY—3 PH , Chief Deputy Richard W Stewart CUMBERLAND COUNry Solicitor OFFICE OFTK, l � PENNSYLVANIA Federal National Mortgage Association Case Number vs. Kathryn Dillard 2013-1012 SHERIFF'S RETURN OF SERVICE 04/08/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kathryn Dillard, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/22/2013 06:00 PM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Michael Carr, husband of defendant, who accepted for Kathryn Dillard, at 185 Chain Saw Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, May 02, 2013 RbNK9 R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoff,Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber w PETER J.MANGAN,ESQ. Sheriff Solicitor Reuben 13 Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy,Administration FEDERAL NATIONAL MORTGAGE ASSOCIATION c/o SETERUS, INC. Case Number vs. KATHRYN T. DILLARD 13-1012 CIVIL SHERIFF'S RETURN OF SERVICE 04/22/2013 06:00 PM-DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE(CIMF)AND NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE MICHAEL CARR, HUSBAND, WHO ACCEPTED AS "ADULT PERSON IN CHARGE"FOR KATHRYN T. DILLARD AT 185 CHAIN SAW ROAD, DIILLSBURG, PA 17019. 66REY STRINE, DEPUTY SHERIFF COST: $95.90 S7AERS, April 30, 2013 RICHARD P KELIERLEBER, SHERIFF cpMM)N\N �NNNSYLvANIP Ntariai ShejW E.cook,Notary Pub"c tatty of York,`lock county 2017 Commission Ex res F0' MEMBER,PENN5YLYANIA ASSON±n� NOT LS ARI ------------------—------------------------- ——--------------------------------—-----------------------—------------------------------ NOTARY Affirmed and subscribed to before me this 30TH day of APRIL 2013 (c)CountySuite Sheriff,Teleosoft,Inc. 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 C--' o HEIDI R.SPIVAK,ESQUIRE-ID#74770 3: w ---yi MARISA J.COHEN,ESQUIRE-ID#87830 rn r-• KEVIN T.MCQUAIL,ESQUIRE-ID#307169 -c CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 U) BRIAN T.LAMANNA,ESQUIRE-ID#310321 r�-- � ANN E.SWARTZ,ESQUIRE-ID#201926 'C© �"' o~' JOSEPH F.RIGA,ESQUIRE-ID#57716 Z o CDC) JOSEPH I.FOLEY,ESQUIRE-ID#314675 T> CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Kathryn T.Dillard Number 13-1012 Civil Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant,Kathryn 1'.Dillard,in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal $ 106,479.59 Interest from 09/28/12 to 05/24/13 $ 3,668.65 Total $ 110,148.24 McCABE,WEISBERG AND CONWAY,P.C. BY: [ ] Terrence J.McCabe,Esq. [ Marc S.Weisberg,Esq. [ ] Edward D.Conway,Esq. QJMargaret 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 2013, Judgment is entered in favor of Plaintiff, Federal National Mortgage Association, and against Defend t, Kathryn T. Dillard, in rem only and not it?personam, and damages are assessed in the amount of$110,148.24,p inter nd c ajP O H ARY: rN office Yvlc�le 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#31.0321 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 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-1012 Civil Kathryn T.Dillard Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Kathryn T.Dillard, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendant, Kathryn T. Dillard, is over eighteen(18)years of age,and reside as follows: Kathryn T.Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 Kathryn T.Dillard 213 Forge Road Boiling Springs,Pennsylvania 17007 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED - BY BEFORE ME THIS � DAY ( Terrence J.McCabe,Esq [j] Marc S.Weisberg,Esq. ] Edward D.Conway,Esq. j Margaret Gairo, Esq. OF 2013 j Andrew L.Markowitz,Esq. [ ] Heidi R.Spivak,Esq. ( Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. Christine L.Graham,Esq. ( ] Brian T.LaManna,Esq. NO Y PUBLIC [ ]Ann E.Swartz,Esq. [ J Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Comm Attorneys for Plaintiff �m of a'en►NSriv�r,i� NOTARIAL SEAL DREW KARLBERG,Notary Pubfic C' of Ph Ma,Phila.County A 3,2017 + Department of Defense Manpower Data Center Rrisultc as of:May-28-2013 06:20t87 SCRA 3.0 status Report punt to Servieememben Civil Relief Act Last Name: DILLARD First Name: KATHRYN Middle Name: T Active [duty Status As Of: May-28-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA; "`''.}, _;� T NoVy NA This response refiecls the InRvlduals'acthre d164 49tatus based on tthh@ Active Duty Status Date Leff Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Data Active Duty End Date Status Service Component NA �,, _('..NA °'r-"`'1";�` �• , ,..� �;No' j• NA This response reflects where the Indivdual left active duty status within 367 days preceding thJ Active Duty Status Data 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�+ Statue Service Component NA NA __....... This response reflects whether the Individual or hlalhor_unit has calved 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. lot 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.mit"URA:http://www.defenselink.mil/faq/pis/PC09SLDR.html. if you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3).Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate iD: 2266UD9FVa000OO 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 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-1012 Civil Kathryn T.Dillard Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-]mown mailing addresses of the Defendant is: Kathryn T.Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 Kathryn T.Dillard 213 Forge Road Boiling Springs,Pennsylvania 17007 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED — /J BY: oL BEFORE ME THIS�DAY [ ]•Terrence J.McCabe,Esq. ] rc S.Weisberg,Esq. [ j Edward D.Conway,Esq. argaret Gairo,.Esq. OF r ,2013 [ j Andrew L.Markowitz,Esq. [ j Heidi R. Spivak,Esq. ( ] arise J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [�J Clhristine L.Graham,Esq. [ ]Brian T. LaManna,Esq. NO ARY PUBLIC [ j Amt E.Swartz,Esq. ( ]Joseph F.Riga,Esq. [ ]Joseph 1.Foley,Esq. [ j Celine P.DerKrikorian,Esq. Attorneys for P11aij9g4NSYLv^H1A MNQTARIAL SEAL G,:z.t mRWEF,-,......,,y Public It�►RLBERt3,Notary pow City o!Phgad� Phu 3 fa1� � a, os�3C , 17 Commissbn McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#1761.6 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-I.D#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-1012 Civil Kathryn T.Dillard Defendant CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against 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". SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,P.C.—LD `C— BEFORE ME THIS 28 DAY BY: �7 [ •Terrence J.McCabe,Esq. [ ],Marc S.Weisberg,Esq. ] Edward D.Conway,Esq. [ Margaret Gairo,Esq. OF 2013 [ ]Andrew L.Markowitz,Esq. ]Heidi R.Spivak,Esq. J�C arisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. hristine L.Graham,Esq. [ ] Brian T. LaManna,Esq. N AR-Y PUBLIC [ ]Ann E.Swartz,Esq. [ ]Joseph F. Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P. DerKrikorian,Esq. CCMMM4WZAL 1pFPENNSYLVANIA Attorneys for Plaintiff NOTANAL SEAL. DREW KARLSERG,Notry Pubkc 0 ° adelphi hs APM County 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 unswom falsification to authorities. McCABE,WEISBERG AND CONWAY,P.C. BY: [ ]Terrence J.McCabe,Esq. ]Alare S.Weisberg,Esq. [ ] Edward D.Conway,Esq. Qfiargaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ ]Heidi R.Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T.McQuail, Esq. IL4<hristine 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 '1\4ay l 3, 2013 ; To: Kafhryn T, Dillard ' 213 Forge Road Boiling Springs, Pennsylvania 1.7007 Federal National Mortgage Association Cumberland. County vs, Court of Common Pleas Katbryn T. Dillard Number :13-10.12 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO EN'T'ER ,TUDGMEN'I'BY DEFAULT IMPORTANT NOTICE NoTrrICACTON IMPORTANTE YOU ARE IN`DrFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTFD SE FNCUENTRA 1:N FSTADO DE REBFLDIA POR NO 1dAB1;R WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESrNTADO UNA COMI'ARFCENClA ESCRiTA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FOR'T'H AGAINST YOU. UNLrsS YOU ACT WITHIN TEN(10) rSCRITO C014 FSTE 7'RIBUNTAi.SITS DFI'I,NSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY Br ENTERED RFCL.AMOS FORMULADCIS E.N CONTRA SUMO. AL NO TOMAR LA AGAINSTYOUWITHOUTAHr ARING AND YOU MAY LOSEYOURPROPER'1'Y ACCION DEBIDA DENTRO DE DIrZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NUMF1CAC10N, Lil, TRIBUNAL [,ODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO NOT HAVr A LAWYrR,007'OOR'I'EI.1;1'1-IONE TIIF OI FICr SET FORTI I SENTFNCIAENSUCON'I'RA Y US'1'IiD I'ODRIA PL"•RDL'•R BIENES IJOIROS BELOW. THIS OFFtcr CAN PROviDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTFD Lr DFBIi TOMAH FSTF PAPLL A SU ABOGADO IF YOU CANNOTAFFORDTO HIRE ALAWYER,I'HIS OFFICE MAY BEA13LE INMEDIATA1,4ENTE. SI USTr) NO TIFNE A UN ABOOADO,VA A 0 `rOPROVIDFYOUWITIi INFORMATION ABOUT AGENCIES THAT MAY OFFER TELEFONEA LA OFICINA HXPUSO ABAJO.ESTA OFICINA LO PUL'DE LEGAL SERVICES TO ELIGIBLE PERSONS AT A_REDUCED Vim Olt NO FEE. PROPORCIONAR CON INFORMACION ACL•RCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association S I USTFD NO PUEDE PROPORCIONAR PARA FMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUFDE SFR CAPAZ DE PROPORCIONARL.O CON Cat-lisle,Pennsylvania.17013 INFORMACION ACFRCA DE LAS AG I'.NCIAS QUE PUEDEN 0FREcrR LOS (800)990-9108 SERVICIOS Lt GALFs A I'li14SONAS E1,1;6IRI,I"'S EN UN 1•IONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Associntion 32 South 4tlford Street Ycnsylvania 17013 �, •- /-' oo)990, 68 MCCABE,WE,-Kd3TRG iD`C;6� ,1'.C. BY: ]Terl•ence J. Me e Esgy �� [ ] Marc S,/ cisberg,Esquire { ] Edward D.C a(vay,rsc�r[re [ ] Margaret Gairo,I squire ( ]Andrew L. arkowitz, Esquirc [ ] Heidi R. Spivak, Esquire J Marisa J.Cohen, Esquire [ ]Kevin'I'. McQuail, E'squirc ( ]Christine L. Graham,Esquire ] Brian T. LaManna, Esquire C 1 Ann,E, Swaitz,Esquire [1 Joseph F. Riga, Esquirc ( .l Joseph I. Foley,Esquire Attorneys for Plaintiff ch . • • 1Y _ T • T "((//��,�✓•(�rte/,/��./ OFFICE OF THE PROTHONOTARY l4 , COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary May 13, 2013 To: Kathryn T. Dillard 185 Chain.Saw Road Dillsburg, Pennsylvania 17019 Federal National Mortgage Association Cumberland County ; vs. Court of Common Pleas Kathryn T. Dillard Number 13-1012 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER.JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN EST'ADO DE REBELDIA POR NO HABER YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PERSONALMENTE WRrfINO WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE F.SCRIITO CON rSTET TRIBUNAL SUDS DEFT NSOSIU OBJII'CIONES O LOS CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) RF.CLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST You WITHOUT AHEARING AND YOU MAY LOSE YOUR PROPERTY ACTIONACION,DEL T DEDIET.(10) RA, DE LAFECHADEESDE NOTIFICATION, EL TRIBUNAL, POORA, SIN NECESIDAD DE OR OTHER(MPORTANT RIGHTS. COMPA(tECER LISTED L"N CUR"1'L"• lJ OIR 1'REUBA ALGUNA, D(CfA t YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SENTL•NCIAEN SU CONT'RA Y USTIs)PODRIA PERDER Bims U oTROs DO NOT HAVE A LAWYER.GO TO OR TELEPHONE TI IE OFFICE SET FORTH DFRF.CHOS Itv11'U CONT R BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 'USTED LF, DL"•BE T'OMAR ESTE PAPEL A SU ABOGADO HIRING A LAWYER. INMEDIATAMENTE. SI LISTED NO T'IENE.' A UN ABOGADO, VA A 0 IFYOUCANNOTAFFORDTOHIREALAWYER,THISOPFICEMAYBEABLE TELEFONEA LA OFICINA EXPUSO ABAJO. 1:.STA OFICINA L0 MADE TOPROVIDEYOUWIT'H.INFORMATIONABOUTAGENCIESTIEEORN OFFER PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN LEGAL.SERVICES TO ELIGIBLE:PERSONS AT A REDUCED PEE OR NO FEE. ABOGADO, Cumberland County Bar Association SI UST'ED NO PUEDE PROPORCIONAR PARA EMPLGAR UN ABOGADO, LSTA OFICINA PUEDE SER CAPA7 DE PROPORCIONARLA CON 32 South Bedford Street INFORMACi6N ACERCA DIE LAS AGENCIAS QUE PUEDEN OFRL•CER LOS Carlisle,Pennsylvania 17013 SERVICIOS LEGALES n PERSONAS I:I_EGIBI,ES EN UN HONORARIO (800)990-9108 REDUCIDONI NINGON HONORAR10. Cumbe out ar Association 32 Sou d2d Street 17013 Carli Tfisylvana -9108 McCAI3E ASE BERG AY,P.C. BY: [ ]Terrence J. abe,Es "e [ ] Marc, Weisberg, 13squire [ ]Edward D onway,Es uire [ ]Margaret Gairo, Esquire [ ] Andrew Markowitz,Esquire [ ]Heidi R. Spivak, I'squire [ ]Marisa J. Cohen,Esquire [ ]Kevin T.M.cQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian'f. LaManna, Esquire ] Ann E. Swartz,Esquire [d.]Joseph F.Riga,Esquire [ ]Joseph I. Coley,Esquire Attorneys for Plaintiff ch �Xl�l b1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Kathryn T.Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. No. 13-1012 Civil Kathryn T.Dillard Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary *,,, .� X Judgment by Default Money Judgment -4113 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: Kathryn T.Dillard 213 Forge Road Boiling Springs,Pennsylvania 17007 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. No. 13-1012 Civil Kathryn T.Dillard Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment 3 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.: 13-1012 Civil Federal National Mortgage Association Term V. AMOUNT DUE: $110,148.24 C r. Kathryn T. Dillard INTEREST: from 05/25/13 $1,865.33 at$18.11 CD ATTY'S COMM.: i< CD COSTS: Z C= TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s) 213 Forge Road,Boiling Springs,Pennsylvania 17007 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE:��� BY: ]Terrence J.M abe,Esq. [ ] Marc S.Weisberg,Esq. Edward D.Conway,Esq. Y < Margaret Gairo,Esq. Andrew L.Markowitz,Esq. [ ] Heidi R.Spivak,Esq. 0 Ov [ ] Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. Christine L.Graham,Esq. ( ] Brian T.LaManna,Esq. Ann E.Swartz,Esq. [ ] p Riga, q• Joseph F.Ri Esq. Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff -�—� Print Name: Firm: MCCABE,WEISBERG AND CONWAY Address:123 S. Broad Street, Suite 1400 / Philadelphia,PA 19109 �6;k.e,)S (OAttorney for: Plaintiff &i SD44_ Telephone:(215)790 1010 Supreme Court ID No. c # 0�3S Ao �� LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground,with the improvements thereon erected, situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of the concrete road leading from Carlisle to Boiling Springs, which point is also a corner of land now or formerly of Earl H. DeWalt; thence by the line of said land eastwardly a distance of two hundred fifty-two feet, more or less,to a point on a line parallel with the center line of the concrete road aforesaid, and distant there from two hundred fifty (250) feet distant line,ninety (90) feet to a point in said two hundred fifty(250) feet distant line and at corner of lot of ground now or formerly of Charles H. B. Kennedy; thence westwardly along the Kennedy line, a distance of two hundred fifty-two feet, more or less, to a point in the center line of the concrete road aforesaid; thence along the center line of the said concrete road, northwardly a distance of ninety (90) feet,to the place of beginning. HAVING ERECTED THEREON a ranch type dwelling house, known and numbered as 213 Forge Road, Pennsylvania 17007 BEING the same premises which VIRGINIA D. BLAKE, FORMERLY KNOWN AS VIRGINIA D. BENDER AND GREGORY A. BLAKE, HER HUSBAND by deed dated August 27, 1998 and recorded September 1, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 184, Page 661, granted and conveyed to Kathryn T. Dillard. TAX MAP PARCEL NUMBER: 40-28-2100-149 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 "o rn`rx CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 Ni ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 � _ 123 South Broad Street,Suite 1.400 �=? Philadelphia,Pennsylvania 19109 c' 215 790-1010 ✓ -� Federal National Mortgage Association CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 13-1012 Civil Kathryn T.Dillard Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 213 Forge Road,Boiling Springs,Pennsylvania 17007,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Kathryn Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 2. Name and address of Defendant in the judgment: Name Address Kathryn T.Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 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 Federal National Mortgage c/o Seterus,Inc. Association 14523 SW Millikan Way, Suite 200 Beaverton,Oregon 97005 4. Name and address of the last recorded holder of every mortgage of record: Name Address Federal National Mortgage c/o Seterus,Inc. Association 14523 SW Millikan Way,Suite 200 Beaverton,Oregon 97005 Wachovia Bank,National Association 301 South College Street VA 0343 Charlotte,North Carolina 28288-0343 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 213 Forge Road Boiling Springs,Pennsylvania 17007 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 V Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL,Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America 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. 13 BY: &"�� �.�_ [ ] Terrence McCabe,Esq. ( ] Marc S.Weisberg,Esq. DATE [ ] Edward .Conway,Esq. [Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ] Heidi R.Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ] Kevin T.McQuail,Esq. ( ] Christine L.Graham,Esq. ( ] Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. ( ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. ( ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground, with the improvements thereon erected, situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of the concrete road leading from Carlisle to Boiling Springs, which point is also a corner of land now or formerly of Earl H. DeWalt; thence by the line of said land eastwardly a distance of two hundred fifty-two feet,more or less,to a point on a line parallel with the center line of the concrete road aforesaid, and distant there from two hundred fifty(250) feet distant line,ninety(90) feet to a point in said two hundred fifty(250) feet distant line and at corner of lot of ground now or formerly of Charles H. B. Kennedy;thence westwardly along the Kennedy line, a distance of two hundred fifty-two feet, more or less,to�a point in the center line of the concrete road aforesaid;thence along the center line of the said concrete road, northwardly a distance of ninety(90) feet, to the place of beginning. HAVING ERECTED THEREON a ranch type dwelling house, known and numbered as 213 Forge Road, Pennsylvania 17007 BEING the same premises which VIRGINIA D. BLAKE, FORMERLY KNOWN AS VIRGINIA D. BENDER AND GREGORY A. BLAKE, HER HUSBAND by deed dated August 27, 1998 and recorded September 1, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 184, Page 661, granted and conveyed to.Kathryn T. Dillard. TAX MAP PARCEL NUMBER 40-28-2100-149 i T 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 r� KEVIN T.McQUAIL,ESQUIRE-ID#307169 C-) CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 °M° ANN E.SWARTZ,ESQUIRE-ID#201926 z70 = -0m JOSEPH F.RIGA,ESQUIRE-ID#57716 cn� I o CD JOSEPH 1. FOLEY,ESQUIRE-ID#314675 r= L� --s c:) 123 South Broad Street,Suite 1400 vs° =z Philadelphia,Pennsylvania 19109 _o C) (215)790-1010 D °• y r'' CIVIL ACTION LAW Federal National Mortgage Association COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Kathryn T.Dillard Number 13-1012 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: 'Kathryn T. Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 Your house(real estate)at 213 Forge Road,Boiling Springs,Pennsylvania 17007 is scheduled to be sold at Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$110,148.24 obtained by Federal National Mortgage Association 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 Federal National Mortgage Association 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 ALL THAT CERTAIN lot of ground, with the improvements thereon erected, situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of the concrete road leading from Carlisle to Boiling Springs, which point is also a corner of land now or formerly of Earl H. DeWalt; thence by the line of said land eastwardly a distance of two hundred fifty-two feet,more or less,to a point on a line parallel with the center line of the concrete road aforesaid, and distant there from two hundred fifty(250)feet distant line, ninety(90) feet to a point in said two hundred fifty(250)feet distant line and at corner of lot of ground now or formerly of Charles H. B. Kennedy;thence westwardly along the Kennedy line, a distance of two hundred fifty-two feet,more or less, to a point in the center line of the concrete road aforesaid;thence along the center line of the said concrete road, northwardly a distance of ninety(90) feet, to the place of beginning. HAVING ERECTED THEREON a ranch type dwelling house,known and numbered as 213 Forge Road, Pennsylvania 17007 BEING the same premises which VIRGINIA D. BLAKE, FORMERLY KNOWN AS VIRGINIA D. BENDER AND GREGORY A. BLAKE, HER HUSBAND by deed dated August 27, 1.998 and recorded September 1, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 184, Page 661, granted and conveyed to Kathryn T. Dillard. TAX MAP PARCEL NUMBER: 40-28-2100-149 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1012 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCATION Plaintiff(s) From KATHRYN T.DILLARD (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: $110,148.24 L.L.: $.50 Interest FROM 5/25/13-$1,865.33 AT$18.11 Atty's Comm: Due Prothy: $2.25 Atty Paid: $197.50 Other Costs: Plaintiff Paid: Date: 615113 David D.Buell,ProthonotaryG�, (Sea➢) ax: o m 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 I 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 rn- rn KEVIN T. MCQUAIL,ESQUIRE-ID# 307169 -,rI CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 ' BRIAN T.LAMANNA, ESQUIRE-ID#310321 'j y j ANN E. SWARTZ,ESQUIRE-ID#201926 CD-'n JOSEPH F.RIGA,ESQUIRE-ID# 57716 o o JOSEPH I. FOLEY,ESQUIRE-ID#314675 3' v CELINE P.DERKRIKORIAN,ESQUIRE-ID# 313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-1012 Civil Kathryn T.Dillard Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 24th day of July, 2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WEISBERG AND CONWAY,P.C. BEFORE ME THIS 2k_DAY BY: J ]Terrence J.McCabe,Esquire ]Marc S.Weisberg,Esquire OF ✓ 12013 [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Iylarisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [vi Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire NOTAR PUBLIC [ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire [ J Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire I Attorneys for Plaintiff MONWE LTM 0P'PENNSILVANIA DREW NOTA IAL SEAL - �7 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 Federal National Mortgage Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-1012 Civil Kathryn T.Dillard Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 213 Forge Road,Boiling Springs,Pennsylvania 17007,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Kathryn Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 2. Name and address of Defendant in the judgment: Name Address Kathryn T.Dillard 185 Chain Saw Road Dillsburg,Pennsylvania 17019 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 Federal National Mortgage c/o Seterus,Inc. Association 14523 SW Millikan Way,Suite 200 Beaverton,Oregon 97005 File#68622 Page I 4. Name and address of the last recorded holder of every mortgage of record: Name Address Federal National Mortgage c/o Seterus,Inc. Association 14523 SW Millikan Way,Suite 200 Beaverton,Oregon 97005 Wachovia Bank,National Association 301 South College Street VA 0343 Charlotte,North Carolina 28288-0343 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 213 Forge Road Boiling Springs,Pennsylvania 17007 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 File#68622 Page 2 f 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 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. July 24,2013 McCABE,WEISBERG AND CONWAY,P.C. DATE BY: Cam/ [ ]Terrence J.McCabe,Esquire [ Marc S. Weisberg,Esquire [ ]Edward D. Conway,Esquire ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] . arisa 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:Federal National Mortgage Association v.Kathryn T.Dillard.et al. Cumberland County;Number: 13-1012 Civil File#68622 Page 3 T 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 Federal National Mortgage Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Kathryn T.Dillard Number 13-1012 Civil Defendant DATE: July 24,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Kathryn T.Dillard PROPERTY: 213 Forge Road,Boiling Springs,Pennsylvania 17007 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $110,148.24 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 4,2013 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution,will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. .: 5 R^ T r. Check type of mail or service: w P., " F:"-.'.Y EO::E$ Name and Address of Sender ❑Certified ❑Recorded Delivery(Intemational) �r'y ,McCabe,Weisberg and Conway,P.C. 0 COD ❑Registered -, r •423 S.Broad St.,Suite 2080 0 Delivery Confirmation ❑Return Receipt for Merchandise _ -{ '� •. � Philadelphia,PA 19109 0 Express Mail 11 signature Confirmation ATTNPS.Wiltbanks 68622 u"d 02 i !os (�•-•". 0 -- 000137742..1 j1,i 24, 7013 Line Article Number Postage s F 1 Federal National Mortgage Association Tenants/Occupants Plaintiff 213 Forge Road Boiling Springs,Pennsylvania 17007 V. Kathryn T.Dillard Defendant 2 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement s P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard 3 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8"Street Suite#204 Philadelphia,PA 19107 4 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor,Strawberry Square Department#280601 Harrisburg,PA 17128 5 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O.Box 8486 Harrisburg,PA 17105-8486 6 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 7 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 8 Commonwealth of Pennsvlvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg,PA 17128-1230 ATTN: Sheriffs Sales Y 9 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 10 Domestic Relations Cumberland County P.O.Box 320 Carlisle,PA 17013 11 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste..311 Scranton,PA 18503 12 United States of America c/o United States Attorney for the 2010-5387 District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street,Ste.220 Harrisburg,PA 17108-1754 13 United States of America c/o Attv General of the United States U.S.Dept of Justice,Room 5111 950 Pennsvlvania Avenue NW Washington,DC 20530-0001 14 United States of America c/o Attv General of the United States U.S.Dept of Justice,Room 4400 950 Pennsvlvania Avenue NW Washington,DC 20530-0001 15 Wachovia Bank,National Association 301 South College Street - VA 0343 - - Charlotte,North Carolina 28288-0343 16 Federal National Mortgage Association c/o Seterus,Inc. 14523 SW Millikan Way,Suite 200 Beaverton,Oregon 97005 Total Number of Pieces Total Number of Pieces Listed by Sender Received at Post Office 16 - a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - Sheriff of d otbett'Jody S Smith 1 i i<'I 114 Li {, Chief Deputy 'l Richard WStewart r ;-: Solicitor QFF'IcE OF THE SHERIFF r ti i'4—11' v! V f':, .,k e A Federal National Mortgage Association Case Number vs. Kathryn Dillard 2013-1012 SHERIFF'S RETURN OF SERVICE 06/10/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kathryn Dillard, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 06/27/2013 07:10 PM -Deputy Tim Black, 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 213 Forge Road, South Middleton -Township, Dillsburg, PA 17007, Cumberland County. 07/29/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of York County upon Michael Carr, who accepted for Kathryn T. Dillard, at 185 Chain Saw Road, Dillsburg, PA 17019. So Answers: Michael S. Eckard, Deputy Sheriff. 09/04/2013 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, 1 Courthouse Square, Carlisle, PA 17013, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Barbara A. Fein on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $977.53 SO ANSWERS, September 18, 2013 RONINK ANDERSON, SHERIFF a -as 6)- eki 93°31 A?-if c ,91/77 ic)Coen:ySuite Sheriff Teieosoft,Inc. • On June 10, 2013 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 213 Forge Road, Boiling Springs, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: June 10, 2013 By: t 7 Real Estate Coordinator li {1: LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2013-1012 Civil Term FEDERAL NATIONAL MORTGAGE ASSOCIATION vs. KATHRYN DILLARD Atty.:Terrance McCabe ALL THAT CERTAIN lot of ground, with the improvements thereon erect- ed,situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of the concrete road lead- ing from Carlisle to Boiling Springs, which point is also a corner of land now or formerly of Earl H. DeWalt; thence by the line of said land east- wardly a distance of two hundred fifty-two feet,more or less,to a point on a line parallel with the center line of the concrete road aforesaid, and distant there from two hundred fifty (250)feet distant line,ninety(90)feet to a point in said two hundred fifty (250) feet distant line and at corner of lot of ground now or formerly of Charles H. B. Kennedy; thence westwardly along the Kennedy line, a distance of two hundred fifty-two feet, more or less, to a point in the center line of the concrete road afore- said; thence along the center line of the said concrete road, northwardly a distance of ninety (90)feet, to the place of beginning. HAVING ERECTED THEREON a ranch type dwelling house, known and numbered as 213 Forge Road, Pennsylvania 17007. BEING the same premises which VIRGINIA D. BLAKE, FORMERLY KNOWN AS VIRGINIA D. BENDER AND GREGORY A. BLAKE, HER HUSBAND by deed dated August 27, 1998 and recorded September 1, 1998 in the office of the Recorder in and for Cumberland County in Deed Book 184, Page 661, granted and conveyed to Kathryn T. Dillard. TAX MAP PARCEL NUMBER:40- 28-2100-149. 44 • PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. J sa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 9 day of August, 2013 4 V.i✓,/d I' Notary pam,rwics.s e�wanaa N�)1AI3tAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co.1900 Patriot Drive � patriotIX��� Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know I CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2013.1012 Chill'Term This ad ran on the date(s)shown below: FED RAL NATIONAL MORTGA E., ASSOCIATION 07/28/13 vs. KATHRYN DILLARD 08/04/13 Atty: Terrance McCabe 08/11/13 Al .Z,THAT CERTAIN lot of ground,with the tprovements'thereon erected,situate in the lbwnship of South Middleton,County j of Cumberland, and Commonwealth of Pennsylvania, bounded and descn'bed o follows: Sworn to ;. subscribe. .efore me t 23 •ay of August, 2013 A.D. BEGINNING at a point in the center line f of the concrete road leading from Carlisle to Borg Springs,oor formerly .� r — �' , of land now or formerlyoof Earl i-I.DeWalt; - � � - thence by the line of said land eastwardly a Ota • . IC distance of two hundred fifty-two feet,more or less,to a point on a line parallel with the center line of the concrete road aforesaid, and distant there from two hundred fifty (250)feet distant line,ninety(90)feet to ^'v a point in said two hundred s- f 6 -�,l.+Jf!!�!d/� distantlineandatcomerofimo groan Notariril Seal or formerly of Charles H.a Kennedy Holly Lynn Warfel,Notary Public { weslw aloe edY thence - along the distance Washinyto-,Twp.,Dauphincounty °°°• J_.__ 11Y Commission Expires Dec. 12,d.AiI+^J 2016orNP-ic'iYANT A 7 n 0-7_t =_1 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal National Mortgage Assoc is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 5th day of June, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1012, at the suit of Federal National Mortgage Assoc against Kathryn T. Dillard is duly recorded as Instrument Number 201333631. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ! if day of A.D. 07 Q a 144:1‘ 81 41" Recorder of Deeds Recorder of Deeds,Cumberland County,Carlisle,PA My Commission Expires the Fast Monday of Jan.2014