HomeMy WebLinkAbout13-1153
F.\FILES\Clients\I 1470 Memberslst\11470 Current\11470.243 Johnston111470.243.complaintl
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT
UNION,
Plaintiff
v.
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant
213 MAR -4 P~ !2= ~'
CUMBE~L~-tr'~ COUl~i'Y
PE~dNSYLYaNIA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~ ~ '/S CIVIL TERM
IN MORTGAGE FORECLOSURE
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 Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A 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 MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER
Contact:
Cumberland County Bar Association
32 South Bedford Street ~ ,,:
Carlisle, Pennsylvania 17013 ~~~~ ~S ~ ~ ~~
Telephone (717) 249-3166 ~
,~~ 7a y~
NOTICE REQUIRED UNDER THE FAIR
DEBT COLLECTION PRACTICES ACT,
15 U.S.C. §1601 (AS AMENDED) AND
THE PENNSYLVANIA UNFAIR TRADE PRACTICES
ACT AND CONSUMER PROTECTION LAW,
73 PA. CON. STAT. ANN. §201, ET SEQ. ("THE ACTS")
To the extent the Acts may apply, please be advised of the following:
The amount of the original debt is stated in the Complaint attached hereto.
2. The Plaintiff who is named in the attached Complaint is a Creditor to whom the debt is
owed. The Creditor's law firm, Martson Deardorff Williams Otto Gilroy & Faller, is filing
this Complaint on behalf of the Creditor.
The debt described in the Complaint attached hereto and evidenced by the copies of the note
will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty
(30) days after receipt of this notice, disputes the validity of the debt or some portion thereof.
4. If the Debtor(s) notifies the Creditor's law firm within thirty (30) days of the receipt of this
notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain
verification of the debt and a copy of the verification will be mailed to the Debtor(s) by the
Creditor's law firm.
5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original
Creditor, and if the Debtor(s) makes a request to the Creditor's law firm within thirty days
from. the receipt of this notice, the name and address of the original Creditor will be mailed
to the Debtor(s) by the Creditor's law firm.
6. Requests can be made to:
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
Attn: Christopher E. Rice, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
THIS DOCUMENT MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A
DEBT FOR THE PLAINTIFF AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT
UNION,
Plaintiff
v.
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
IN MORTGAGE FORECLOSURE
COMPLAINT
AND NOW, comes the Plaintiff, MEMBERS 1st FEDERAL CREDIT UNION, by and
through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and
files this Complaint in Mortgage Foreclosure upon the following:
1. Plaintiff, Members 1st Federal Credit Union ("Plaintiff'), is a federally chartered
credit union located at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055.
2. Defendant, Josephine S. Johnston a/k/a Jody S. Johnston ("Defendant"), is an adult
individual residing at 311 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania
17050.
3. Defendant is the owner of the real property located at 311 Indian Creek Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050 ("Real Property"), and more fully
described in a certain deed recorded in the Recorder of Deeds Office of Cumberland County, Book
142, Page 468, which is subject to the Mortgage described below.
4. On or about February 14, 2008, Defendant executed a Promissory Note (the "Note")
with Plaintiff in the amount of $85,000.00. A true and correct copy of the Note is attached hereto
as Exhibit "A" and is incorporated herein by reference.
5. As security for the performance of her obligations under the Note, Defendant, as
Mortgagor, made, executed and delivered to Plaintiff, as Mortgagee, a mortgage upon the Real
Property (the "Mortgage"). A true and correct copy of the Mortgage containing a complete legal
description of the Real Property is attached hereto and incorporated as Exhibit "B."
6. The Mortgage has not been assigned.
7. Defendant is the owner of the Real Property, and Plaintiff knows of no other persons
holding an ownership interest in the Real Property.
8. Plaintiff has made demand for payment of all sums due and owing thereunder, but
payment has been refused.
9. Plaintiff provided Defendant with notice of the period in which Defendant's default
may be cured, but Defendant has failed to cure her default.
10. As authorized under the Mortgage, the loan obligation to Plaintiff from Defendant
has been accelerated.
11. The total sum due and owing from Defendant under the Note, as of February 15,
2013, is itemized as follows:
Principal:
Late Fees:
Interest as of February 15, 2013:
Court Costs and Fees (estimated):
Attorney Fees:
Total as of February 15, 2013:
$76,118.62
$153.45
$2,296.98
$500.00*
$7,600.00
$86,669.05
Plus interest accruing at $16.14 per day from February 15, 2013, until paid in
full.
*To be determined by the Cumberland County Sheriff.
12. Plaintiff specifically reserves the right to increase the Court Costs and Fees, and
Attorney Fees listed above should additional services be requested and/or costs/charges/fees be
incurred as a result of the collection of the money owed and foreclosure of the Real Property.
13. Pursuant to the notice provision of Act 6, 41 P.S. § 403, and Act 91, 35 P.S.
§ 1680.403(c) (collectively, the "Notice"), Plaintiff sent notices of intention to foreclose mortgage
and of the mortgage assistance program dated November 29, 2012, to Defendant by certified mail,
return receipt requested.
WHEREFORE, Plaintiff demands judgment against Defendant under the Note in the
amount of $86,669.05, plus interest from February 15, 2013, at the rate of $16.14 per day until the
debt is paid in full.
MARTSON LAW OFFICES
By: ~--'''v`r ~j~'~'-
Christopher E. Rice, Esquire
I.D. No. 90916
R. Christopher VanLandingham, Esquire
I.D. No. 307424
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: ~t/l,~C~ ~ , 2013 Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit
Union. Any information received will be used for that purpose.
EXHIBIT "A"
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EXHIBIT "B"
Prepared 13y: Members 1st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
Return To: Members 1st FCU
Real Estate Department
5000 Louise Drive
Mechanicsburg, PA 17055
(717)-795-6026
MORTGAGE
Made 02/l9/ZOOS ,
Between
JOSEPHINE S JOHNSTON
ere na ter ortgagor
And
MEMBERS 1~ FEDERAL CREDIT UNION (hereinafter called "Mortgagee"}
~~-.
Whereas, Mortggagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note") oT even date herewith, payable to the order o!" Mortgagee in the principal sum of
s-B-SaI(}0.00 ,lawful nsoney of the United States of America, and has provided therein
....for paymenTofairy addit3orra7 moneys loaned'ii~ sd~an~l-t)ter~ttnder iiy~MifRgagea: togetherwith __ _ --- .
interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and
containing certain other terms and conditions, all of tivhich are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, inconsideration of said debt or prtncipal sum and as security For the
payment of the same and interest as aforesaid, together with alt other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located in_ HAMPDEN
~WNSH]P C'trmhnrlanri County, Pennsylvania
which currently has the address of 31 ] INDLAN CR EK Dljjy~
(Street)
Mechanicsburg ,Pennsylvania 17050
(City] (Zip Code)
Acn xo q~~ 24577114 Page ~ of o
To~ether with the buildings and improvements erected thereon, the appurtenances thereunto
belong ng and the reversions, remainders, rents, issues and profits thereof.
To Have and To Hold the same unto Mortgagee, fls successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgaggee the aforesaid debt or principal sum,
including additlonal loans or advances and ail other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shalt become void.
This Mortgage is executed and delivered subSect to the following covenants, conditions and
agreements:
(i) The Note secured hereby shall evidence and this Mortgage shalt cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortggagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the pr7ncipal debt.
(2) From tune to time until said debt and interest are fully patd; Mortgagor shalL• (a) pay-and- - -- ~- -
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and ali other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in Ifen or payment to the debt
secured hereby, (b) pay a]1 ground rents reserved fmm the mortgaged premises and pay and discharge alJ
mechaNcs' liens which may be filed against said premises and which shall or might have priority in_lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming pa able on the Note
evidendng the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
char es; provided, however, that Mortggogee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subJect to this Mortgage in good and
substantial repair, as determined by Mortgaggee, Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hourTor the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
pcc~ t.o AppID 24577114 Page z or a
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fans to
maintain the buildings and improvements as aforrsai , Mortga ee may do so, add the cost thereof to the
principal debt secured hereby, and collect the same as a pars o~said principal debt.
{5} Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the
mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this
Mortgage.
(!i) In case default be made for the space of thirty (3t)} days to the payment of any installment of
principal or interest pursuant to the terms of the Nole, or in thtt performance by Mortgagor of any of the
other obligations of the Note or this Mongage, the entire unpaid balance of said prindpal sum, additional
loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this
Mortgage, together with unpaid interest thereon, sfiali at the option of Mortggages and without notice
become immtdiately due and payable, and foreclosure proceedings may bebrought forthwith on this
Mangyge and prosecuted to judgment, execution and sale for the collection of the same, together with
costs of"suit and an attorney's commission for collection of flue percent (596) of the total indebtedness or
5200, whichever is the larger amount. Mortgagor hereby forever waives and releases aI! errors !n said
proceedings, waives stay of execution, the right of inquistvoa and extension of t[me of payment, agrees
to condemnation of any parry levied upon by virtue of any such execution, and waives all exemptions
from levy and sale of any pioperty that riow is ar hereafter "may be exempted by litw~ - "
(7} Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall
terminate and become void, After such occurrence, Mortgagee shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing tilts
Mortgage, but only if the fee is paid to a third party or sernces rendered and the charging of the fee is
permuted under App]icable Law.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and
assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each
shall be joint and sevtra .
Acct ~o AppIU 24577114 Page 3 or 4
Witness the due execution hereof the day and year first above itte
,---
JO NINE S JOHN TON
Commonwealth of Pennsylvania )
~~~ f,~~ } ss:
County of ~r~~~~~ }
On this, the 1~ day of _~h _5 ,~~~' 2008 ,before me.
e n g d officer, personalty appeazed
1~SFPHINF 4 Ir1NNQTCIN
-satisfaetori y roven tome-to be~the erson(s) whose-name s}-.islare subscribed to-the urithin-Mongage. and
p _. ,
acfcrtowledg that he/she executed the same for the purposes therein contained.
In Witness Whereof, 1 hereunto set my hand and official seal.
My commission expires:
Members in Federal Credit Union, Mortgagee within named, hereby certifies that its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055. ~y
By~G~L ~ia~
Acct No APPID 24577114
Pege a or 4
VERIFICATION
I, ~ eau ic~, n~.,n r, as an employee of Members 1"Federal Credit Union, acknowledge
I have the authority to execute this Verification on behalf of Members 1~' Federal Credit Union and
certify that the foregoing Complaint in Mortgage Foreclosure is based upon information which has
been gathered by my counsel in the preparation of the lawsuit. The language of this document is that
of counsel and not my own. I have read the document and to the extent the Complaint is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent the content of the Complaint is that of counsel, I have relied
upon counsel in making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
MEMBERS 1ST FEDERAL CREDIT UNION
F:\FII.ES\C6em,\I 1470 Ataa~6ertlrt\11470 Current\11470.243 Johnuon\I 1470.242.wmplaiml
~« ~~~
o~ ~e ~~a~~n~~~y
Christopher E. Rice, Esquire ~~~~ ~a~' ~ ~~ ~2' ~ ~
Attorney I.D. No. 90916 Clv~,,, 6,~/!an e/ ~o~n'J
R. Christopher VanLandingham, Esquire ~~~J,`vah~B
Attorney I.D. No. 307424 ~
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT
UNION,
Plaintiff
v.
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. /,3 -/~53CIVIL TERM
IN MORTGAGE FORECLOSURE
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,
you may be able to participate in acourt-supervised conciliation conference in an effort to resolve
this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must
contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension
2510 and request appointment of a legal representative at no charge to you. Once you have been
appointed a legal representative, you must promptly meet with that legal representative within twenty
(20) days of the appointment date. During that meeting, you must provide the legal representative
with all requested financial information so that a loan resolution proposal can be prepared on your
behalf. If you and your legal representative complete a financial worksheet in the format attached
hereto, the legal representative will prepare and file a Request for Conciliation Conference with the
Court, which must be filed with the Court within sixty (60) days of the service upon you of the
foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable
arrangements with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps
to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal
Services for the appointment of a legal representative. However, you must provide your lawyer with
all requested financial information so that a loan resolution proposal can be prepared on your behalf.
If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will
prepare and file a Request for Conciliation Conference with the Court, which must be filed with the
Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and
a conciliation conference is scheduled, you will have an opportunity to meet with a representative
of your lender in an attempt to work out reasonable arrangements with your lender before the
mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE
THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
L.~w~--~- S~
Christopher E. Rice, Esquire
I.D. No. 90916
R. Christopher VanLandingham, Esquire
I.D. No. 307424
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: /~~-~ ~ , 2013 Attorneys for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Caurt of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete• your request for hardship assistance, your lender must consider your
circumstances to determine passible options while working with your
Please provide the following infomaation to the best of your knowledge:
Borrower names}:
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:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender: _
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amaunt: $
Date of Last Payment:
Primary Reason for Default:
How long?
Home: Office: _
Cell: Other: _
How long?
Date You Closed Your Loan:
Included Taxes & Insurance:
State• Zip:
Is the loan in Bankruptcy? Yes ^ No ^
If yes, provide names, location of court, case number 8c attorney:
Asset Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Yom:
Amount owed: Value:
~utomobite #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):
i . monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Exuenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mort Food
2 Mo Utilities
Car Pa ens CondoJNei .Fees
Auto Inauranee Med. not cove
Auto fueUre airs Other ant
Install. Loan P ent Cable TV
Child Su rt/Alim. S din Mon
Da /Child CarcfTuit. Other
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 (Off ce): Fax:
Emai 1:
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?
Yes ^] Nv ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Servicing Company (Name):
Contact:
Phone:
Phone:
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. UWe
understand that Uwe am/are under no obligation to use the services provided by the above
named
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
_~ Proof of any expected income for the last 45 days
V Copy of a current utility bill
Letter explaining reason far delinquency and any supporting documentation
-1 (hardship letter}
V Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUI1, _
Ronny RAnderson OF THE PROTHONOTAR'r
Sheriff
Jody S Smithu rr1-14# 7013 MAR 18 AM 3: 56
Chief Deputy
Richard W Stewart CUMBERLAND COUNTY
PENNSYLVANIA
Solicitor OFFICE Or THE SKRIFF
Members 1 st FCU
VS. Case Number
Josephine S Johnston 2013-1153
SHERIFF'S RETURN OF SERVICE
03/08/2013 05:06 PM-Deputy Ryan Burgett, being duly swom 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:Josephine S Johnston at 311 Indian Creek Dr., Hampden Twp., Mechanicsburg, PA
17050.
SHERIFF COST: $38A6 SO ANSWERS,
March 12, 2013 RON R ANDERSON, SHERIFF
(c)Cnu;ttYSuite Sheriff,7eteoso t,Inc.
FILED.OFFIc -
Michael J.Pykosh,Esquire (IF THE PRO'TH014o-
ID#58851 T E
A R Y
Dethlefs-Pykosh Law Group,LLC 20 13 MA y ptf 1:
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-9446 PUMBERLAND coljN-ry
Fax—(717)975-2309 PENNS YLA
mpykosh@dplqlaw,com VAlkney for Defendant,
5T
MEMBERS 1 : IN THE COURT OF COMMON PLEAS OF
FEDERAL CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 13-1153
JOSEPHINE S. JOHNSTON,'
a/k/a JODY S. JOHNSTON,
Defendant IN MORTGAGE FORECLOSURE
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 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.
Michael J. Pykosh, Esquire Date
Defendant's Counsel/ Legal Representative
Jos�hing S. John- ton, a/k/a Jody S. Johnston, Defendant Date
Michael J.Pykosh,Esquire
ID#58851
Dethlefs-Pykosh Law Group,LLC
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-9446
Fax—(717)975-2309
moykosh0—dP-1qlaw.corn
ST Attorney for Defendant
I
MEMBERS : IN THE COURT OF COMMON PLEAS OF
FEDERAL CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 13-1153
.JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON,
Defendant IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICES
I hereby certify that a Copy of the foregoing DEFENDANT'S REQUEST FOR
CONCILIATION CONFERENCE, was hereby served by depositing the same within the custody
of the United States Postal Service, First Class, postage prepaid, addressed as follows:
Members 1st Federal Credit Union
c/o Christopher E. Rice, Esquire
Martson Deardorff Williams Otto Gilroy & Faller
10 East High Street
Carlisle, PA 17013
Respectfully Submitted,
Date: o By:
Mi6- e�JPykosh, Esquire
ID# 58851
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, PA 17011
717-975-9446
Attorney for Defendant
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS OF
CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. CIVIL ACTION
rnw
c
r
NO. 13-1153 CIVIL M;;0,
JOSEPHINE S. JOHNSTON, <>
a/k/a JODY S. JOHNSTON, �"" "
Defendant �.�,
`s C)�-.
CASE MANAGEMENT ORDER
AND NOW, this 2'7% day of May, 2013,the parties having agreed to a conciliation
conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on ± o�� Q?0/3 , at lm. in Chambers
No. 4 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 within 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.
a. -r
5. All proceedings in,this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
Kevin . Hess, P.J.
✓Christopher E. Rice, Esquire
10 East High Street /
Carlisle, PA 17013 /
For the Plaintiff
Michael J. Pykosh, Esquire
2132 Market Street
Camp Hill, PA 17011
For the Defendant
:rlm
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CL
MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS OF
CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. CIVIL ACTION
NO. 13-1153 CIVIL
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON,
Defendant
ORDER
AND NOW,this day of June, 2013, at the request of counsel for the parties,
the conciliation conference in the above matter set for June 28, 2013, is continued to Friday, July
19, 2013, at 2:30 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin . Hess, P. J.
✓Christopher Rice, Esquire
10 E. High Street
Carlisle, PA 17013
For the Plaintiff
-, Michael Pykosh, Esquire
2132 Market Street ,T
Camp Hill, PA 17011 _
For the Defendant M CV c.... �
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4
MEMBERS 1 IT FEDERAL IN THE COURT OF COMMON PLEAS OF
CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. CIVIL ACTION
NO. 13-1153 CIVIL
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON,
Defendant
ORDER
AND NOW, this 7 2 day of July, 2013, following conciliation conference with
counsel, it appearing that the only realistic option in this case is the sale of the subject real estate
and it appearing also that the property is listed for sale,this matter is removed from the
Cumberland County Mortgage Foreclosure Diversion Program and the stay in this matter is
terminated.
BY THE COURT,
Kevin . Hess, P. J.
/hristopher VanLandingham, Esquire
10 E. High Street
Carlisle, PA 17013
For the Plaintiff
Michael Pykosh, Esquire
2132 Market Street
Camp Hill, PA 17011
For the Defendant J �y
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FAFILES\C1ienls111470 Members]st\11470 Current\]1470,243 Johnston\11470.243.pra.default.wpd t t I-E D—V��F 1 t't
Christopher E.Rice, Esquire Or PiE PRO TH ii,�
Attorney I.D. No. 90916
R. Christopher VanLandingham,Esquire 2013 AUG 28 AM 9: �
Attorney I.D. No. 307424 CUMBERLAND COUNTY
MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER PENNSYLVANIA
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Plaintiff
MEMBERS 1sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
TO THE PROTHONOTARY: PRAECIPE
Please enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant Josephine S. Johnston a/k/a Jody S. Johnston in the amount of$86,669.05,plus interest
from February 15, 2013, at the rate of$16.14 per day until the debt is paid in full, along with any
additional costs or attorney fees incurred thereafter, for failure to file an Answer to Plaintiffs
Complaint.
I do hereby certify that written notice of intention to file this Praecipe was mailed to
Defendant Josephine S. Johnston a/k/a Jody S. Johnston on August 15, 2013, which date is
subsequent to the date default occurred and at least ten (10) days prior to the date of this Praecipe.
MARTSON LAW OFFICES
�l�•.��+ -C�Li By: ��--
���+ ✓ Christopher E. Rice, Esquire
��y0� I.D. Number 90916
R. Christopher VanLandingham, Esquire
I.D. No. 307424
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: �/ /� Attorneys for Plaintiff
FAFI LEST lients\I 1470 Wnnbu,Ist\I 1470 Current\11470.243 Johnston\]1470.243.10daynotice.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1 ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
TO: Josephine S. Johnston DATE OF NOTICE: August 15, 2013
a/k/a Jody S. Johnston
311 Indian Creek Drive,
Mechanicsburg, PA 17050
and
C/o Justin Johnston
1403 William Street
Baltimore MD 21230
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 (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MARTSON LAW OFFIC S
By:
Christ pher E. Rice, Esquire
I.D. No. 90916
R. Christopher VanLandingham, Esquire
I.D. No. 307424
This is a debt collecting firm for Members 1"Federal Credit Union. Any information
obtained will be used for that purpose.
FAFILES\Clients\11470 Members Ist\11470 Current\I 1470.243 Johnston\]1470.243.pra.de(au1t.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
AFFIDAVIT AS TO MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he
has authority to make this affidavit on behalf of his client, and to the best of his knowledge,
information and belief, Defendant Josephine S. Johnston a/k/a Jody S. Johnston , above named is
not in the military service of the United States of America, that he has knowledge that the said
Defendant's last known address is:'311 Indian Creek Drive,Mechanicsburg, Pennsylvania 17050.
Said Defendant's place of employment is unknown.
Christopher E. Rice, Esquire
Sworn to and subsc ibed before me
this: ay of , 2013. COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
LAW t Mary M.Price,Notary Public
Carlisle Boro,Cumberland County
N to Public My Commiss3 Expires Aug.18,2015
MEMSK,PENNSYLVAtM ASSOM71ON OF NOTARIES
FAFILES\Clients\11470 Members 1st\t 1470 CurrenAl 1470.243 Johnston\]1470.243.pra.default.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff :
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA )
: SS
COUNTY OF CUMBERLAND )
Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he
is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys
for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania
Rules of Civil Procedure,a notice of intention to enter default j udgment against Defendant Josephine
S. Johnston a/k/a Jody S. Johnston was given to her by mail on August 15, 2013.
Christopher E. Rice, Esquire
Sworn to and subscribed
before me this day of , 2013.
l. pCOMMONWEALTH OF PENNSYLVANIA
N haublic Notarial seal
Mary M.Price,Notary Public
Carlisle Boro,Cumberland County
My Commission Expires Aug.18,2015
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY& FALLER, hereby certify that a copy of the foregoing Praecipe was served this date
by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed
as follows:
Josephine S. Johnston
a/k/a Jody S. Johnston
311 Indian Creek Drive,
Mechanicsburg, PA 17050
and
Josephine S. Johnston
C/o Justin Johnston
1403 William Street
Baltimore MD 21230
MARTSON LAW OFFICES
B
Y ,
Mai Price
10 East High Street
Carlisle, PA 17013
Dated: LFI' 'lj
This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit
Union. Any information obtained will be used for that purpose.
J`AF1LES\C1ients\11470 Members 1st\I 1470 Current\i 1470.243 Johnston\]1470.243.pra.default.wpd
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
TO JOSEPHINE S. JOHNSTON a/k/a JODY S. JOHNSTON:
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on the oVl"4day of_ , 2013, the following
Judgment was entered against you in the above-captioned action:judgment in the amount of
$86,669.05, plus interest from February 15, 2013, at the rate of$16.14 per day until the debt is
paid in full, along with any additional costs or attorney fees incurred thereafter, for failure to file
an Answer to Plaintiffs Complaint.
Date: 1�_ c�cis '/j' •�
Prothonotary
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Josephine S. Johnston
C/o Justin Johnston
1403 William Street
Baltimore MD 21230
r-It —OFFICE
THE f ^^�� T�iCe}/� y f t
tite IL R NO f1�4R �
F:\FILES\Clients\l 1470 Members 1st\l]470 Current\I 1470.243 Johnston\l 1470.243.pra.exe
Christopher E. Rice, Esquire 2013 SEP —4 PF1 3 12
Attorney I.D. No. 90916
R. Christopher VanLandingham, Esquire CUMBERLAND COUNTY
Attorney I.D. No. 307424 PENNSYLVANIA
MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle,PA 17013
(717)243-3341
Attorneys_for Plaintiff
MEMBERS 1sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON :
Defendant : IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
UPON A DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please issue writ of execution upon a judgment entered by default in the above matter,
(1) directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Defendant Josephine S. Johnston a/k/a Jody S. Johnston;
(3) and enter this writ in the judgment index against Defendant Josephine S. Johnston
a/k/a Jody S. Johnston;
as a lis pendens against real property in Cumberland County,
Pennsylvania, owned by Josephine S. Johnston a/k/a Jody S. Johnston, and
located at 311 Indian Creek Drive, Mechanicsburg, Pennsylvania 17050 (a
copy of the legal description is attached hereto);
(4) Amount due $79,069.05
Interest from February 15, 2013, at $16.14 per day $
Attorneys' fees $71,600.00
31F-VG
/61&.Z5 N
Costs to be added $
* To be determined by the Sheriff of Cumberland County, Pennsylvania.
(5) Please attach the Affidavit Pursuant to Rule 3129.1 that Plaintiff prepared and is
being filed simultaneously with this Praecipe.
Certification
I certify that:
(a) This Praecipe is based upon a judgment entered by default, and
(b) Notice will be served at least thirty days prior to the date of the sheriff's
sale of real property pursuant to Rule 3129.2.
MARTSON LAW OFFICES
By:_ 6z /' �-- 'e'—'
Christopher E. Rice, Esquire
Attorney I.D. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. 302424
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: C/_ l3 Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members 1st Federal Credit
Union. Any information obtained will be used for that purpose.
DOCKET NO. 2013-1153
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land,known and designated as Lot No. 12,Block
"F,"Plan No.6 of Indian Creek,Hampden Township,Cumberland County,Pennsylvania as prepared
by D.P. Raffensperger, Registered Surveyor, dated March 27, 1972, and recorded in the Recorder
of Deeds Office of Cumberland County on May 9, 1972, in Plan Book 23, Page 3.
BEGINNING at a point on the West side of Indian Creek Drive (50 feet) said point being
451 feet north of the Northwest intersection of Indian Creek Drive and Shasta Way;thence along lot
No. 11, South 77 degrees 28 minutes West,a distance of 213.50 feet to a point;thence along lot No.
37 and 38,North 9 degrees 22 minutes West, a distance of 85.13 feet to a point; thence along Lot
No. 13,North 77 degrees 28 minutes East, a distance of 208.82 feet to a point on the West side of
Indian Creek Drive, South 12 degrees 32 minutes East, a distance of 85 feet to a point,the place of
BEGINNING.
HAVING THEREON ERECTED a brick and aluminum raised ranch with a one-car
integral garage, known as 311 Indian Creek Drive.
BEING the same premises which Steven T. Allen and Myra Z. Allen, husband and wife,
conveyed unto Jody S. Johnston by Deed dated June 25, 1996, and recorded in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book 142, page 468.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 13-1153 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Members 0 Federal Credit Union Plaintiff(s)
From Josephine S.Johnston a/k/a Jody S.Johnston
(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 GARNISHEES)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s) and from delivering any property of the
defendant(s)or otherwise disposing thereof,
(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$79,069.05 Plaintiff Paid$
Interest from February 15,2013,at$16.14 per day
Attorney's Comm. % Law Library$$.50
Attorney Paid$ 187.21 Due Prothonotary$2.25
Other Costs$Attorneys' Fees $7,600.00
Date: Sept. 4,2013
David D.Buell,Prothonotary
(`ek1l)
B
2
Deputy
REQUESTING PARTY:
Name : Christopher E. Rice,Esq.
Martson Law Offices
Address: 10 East High St.
Carlisle,PA 17013
Attorney for:Plaintiff
Telephone: 717-243-3341
Supreme Court ID No. 90916
C.r-
F:\FILES\Clients\11470 Members 1st\I 1470 Current\11470.243 Johnston\11470.243.not l.wpd
Christopher E. Rice, Esquire 2013 SEP —4 N1 3: 42
Attorney I.D. No. 90916 �I �
CUMBERLAND CUMBERLAND ��� .
R. Christopher VanLandingham, Esquire PENNSYLVANIA COUNTY
Attorney I.D.No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY &FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1 ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE that the Sheriff's Sale of Real Property(Real Estate)will be held on December
4, 2013, by the Cumberland County Sheriff's Office at the Cumberland County Courthouse located at
One Courthouse Square, Carlisle, PA 17013 at 10:00 a.m.,prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property,together with a brief mention of the buildings
and any other major improvements erected on the land (SEE LEGAL DESCRIPTION ATTACHED).
THE LOCATION of the property to be sold is 311 Indian Creek Drive, Mechanicsburg,
Pennsylvania 17050.
THE JUDGMENT under or pursuant to which the property is being sold is docketed to:
Members IS1 Federal Credit Union v.Josephine S.Johnston a/k/a Jody S.Johnston,No.2013-1153,Court
of Common Pleas, Cumberland County, Pennsylvania.
THE NAME OF THE OWNER(S) OR REPUTED OWNER(S) OF THE PROPERTY ARE
Josephine S.Johnston a/k/a Jody S.Johnston,311 Indian Creek Drive,Mechanicsburg,Pennsylvania 17050.
s
A SCHEDULE OF DISTRIBUTION,being listed of the persons and/or government or corporate
entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed
by the Sheriff(for example,to banks that hold mortgages and municipalities that are owed taxes)will
be filed by the Sheriff within thirty(30) days after the sale, and distribution of the proceeds of the sale
in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to
it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be
obtained from the Sheriff of Cumberland County, Cumberland County Courthouse, One Courthouse
Square, Carlisle, PA 17013 , (717) 240-6390.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY OR PROPERTY RIGHTS. It has been issued either because there is a Judgment against
you or because the sale of real property described herein may affect an interest you have in the real
property. It may cause your property to be held,sold or taken to pay the Judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL ADVICE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle,Pennsylvania 17013
Telephone(717)249-3166
MARTSON LAW OFFICES
r4"� 5-.
Christopher E. Rice, Esquire
I.D. 90916
R. Christopher VanLandingham, Esquire
I.D. 307424
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: Attorneys for Plaintiff
This is a debt collecting firm attempting to collect a debt for Members 1St Federal Credit
Union. Any information obtained will be used for that purpose.
DOCKET NO. 2013-1153
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land,known and designated as Lot No. 12,Block
"F,"Plan No.6 of Indian Creek,Hampden Township,Cumberland County,Pennsylvania as prepared
by D.P. Raffensperger, Registered Surveyor, dated March 27, 1972, and recorded in the Recorder
of Deeds Office of Cumberland County on May 9, 1972, in Plan Book 23, Page 3.
BEGINNING at a point on the West side of Indian Creek Drive (50 feet) said point being
451 feet north of the Northwest intersection of Indian Creek Drive and Shasta Way;thence along lot
No. 11, South 77 degrees 28 minutes West,a distance of 213.50 feet to a point;thence along lot No.
37 and 38, North 9 degrees 22 minutes West, a distance of 85.13 feet to a point; thence along Lot
No. 13,North 77 degrees 28 minutes East, a distance of 208.82 feet to a point on the West side of
Indian Creek Drive, South 12 degrees 32 minutes East, a distance of 85 feet to a point,the place of
BEGINNING.
HAVING THEREON ERECTED a brick and aluminum raised ranch with a one-car
integral garage, known as 311 Indian Creek Drive.
BEING the same premises which Steven T. Allen and Myra Z. Allen, husband and wife,
conveyed unto Jody S. Johnston by Deed dated June 25, 1996, and recorded in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book 142, page 468.
L..tL.
F:\FILES\Clients\11470Memberslst\I 1470 Current\11470.243 Johnston\]1470.243.pra.exe ft CCjj ,,�
Li F` 1 F'1 H�f..�f'� jl� -•y
Christopher E. Rice, Esquire 2013 SEP _4
Attorney I.D.No. 90916 PM 3. 12
R. Christopher VanLandingham, Esquire CUMBERLAND COUNT)
Attorney I.D. No. 307424 PENNSYLVANIA
MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Plaintiff
MEMBERS 1sT FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 2013-1153 CIVIL TERM
JOSEPHINE S. JOHNSTON,
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members I"Federal Credit Union,Plaintiff in the above action, sets forth as of the date the
Praecipe for Writ of Execution Upon a Default Judgment was filed the following information concerning
the real property located at 311 Indian Creek Drive,Mechanicsburg, Pennsylvania 17050 (see legal
description attached hereto):
1. Name and address of owners:
Josephine S. Johnston a/k/a Jody S. Johnston
311 Indian Creek Drive
Mechanicsburg,PA 17050
Josephine S. Johnston a/k/a Jody S. Johnston
Inmate No. OU4833
SCI Muncy
P.O. Box 180
Muncy, PA 17756
2. Names and addresses of Defendants in the judgment:
Josephine S. Johnston a/k/a Jody S. Johnston
311 Indian Creek Drive
Mechanicsburg, PA 17050
Josephine S. Johnston a/k/a Jody S. Johnston
Inmate No. OU4833
SCI Muncy
P.O. Box 180
Muncy, PA 17756
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
None.
4. Name and address of the last recorded holder of every mortgage of record:
None.
5. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None.
7. Name and address of every other person or whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Justin Johnston
1403 William Street
Baltimore MD 21230
I verify the statements made in this Affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand false statements herein are made subject to the penalties
of 18 Pa. C.S. § 4909 relating to unsworn falsification to authorities.
MARTSON LAW OFFICES
By
Christopher E. Rice, Esquire
Attorney I.D. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. 302424
10 East High Street
Carlisle, PA 17013
(717)243-3341
Date: 9 �3 Attorneys for Plaintiff
F:\FILES\Clients\l 1470 Members 1st\11470 Current\I 1470.243 Johnston\11470.243.aff.3129.amended.wpd
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Christopher E.Rice,Esquire
Attorney I.D.No. 90916 • < _
R. Christopher VanLandingham,Esquire
Attorney I.D.No. 307424 ° }
MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER I
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
•
Plaintiff •
v. : NO. 2013-1153 CIVIL TERM
•
JOSEPHINE S. JOHNSTON,
•
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1St Federal Credit Union, Plaintiff in the above action, sets forth as of the date
the Praecipe for Writ of Execution Upon a Default Judgment was filed the following information
concerning the real property located at 311 Indian Creek Drive, Mechanicsburg, Pennsylvania
17050 (see legal description attached hereto):
1. Name and address of owners:
Josephine S. Johnston a/k/a Jody S. Johnston
311 Indian Creek Drive
Mechanicsburg, PA 17050
Josephine S. Johnston a/k/a Jody S. Johnston
Inmate No. OU4833
SCI Muncy
P.O. Box 180
Muncy, PA 17756
2. Names and addresses of Defendants in the judgment:
Josephine S. Johnston a/k/a Jody S. Johnston
311 Indian Creek Drive
Mechanicsburg, PA 17050
Josephine S. Johnston a/k/a Jody S. Johnston
Inmate No. OU4833
SCI Muncy
P.O. Box 180
Muncy, PA 17756
3. Name and address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
None.
4. Name and address of the last recorded holder of every mortgage of record:
None.
5. Name and address of every other person who has any record lien on the property:
None.
6. Name and address of every other person who has any record interest in the property
and whose interest may be affected by the sale:
None.
7. Name and address of every other person or whom the plaintiff has knowledge who
has any interest in the property which may be affected by the sale:
Justin Johnston
1403 William Street
Baltimore MD 21230
Cumberland County Adult Probation Office
4 East Liberty Avenue
Carlisle, PA 17013
I verify the statements made in this Affidavit are true and correct to the best of my personal
4
knowledge or information and belief I understand false statements herein are made subject to the
penalties of 18 Pa. C.S. § 4909 relating to unsworn falsification to authorities.
MARTSON LAW OFFICES
By 5 /2f
Christopher E. Rice, Esquire
Attorney I.D. 90916
R. Christopher VanLandingham, Esquire
Attorney I.D. 302424
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: /6 / / Attorneys for Plaintiff
DOCKET NO. 2013-1153
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land,known and designated as Lot No. 12,Block
"F,"Plan No.6 of Indian Creek,Hampden Township,Cumberland County,Pennsylvania as prepared
by D.P. Raffensperger, Registered Surveyor,dated March 27, 1972, and recorded in the Recorder
of Deeds Office of Cumberland County on May 9, 1972, in Plan Book 23, Page 3.
BEGINNING at a point on the West side of Indian Creek Drive (50 feet) said point being
451 feet north of the Northwest intersection of Indian Creek Drive and Shasta Way;thence along lot
No. 11, South 77 degrees 28 minutes West,a distance of 213.50 feet to a point;thence along lot No.
37 and 38, North 9 degrees 22 minutes West, a distance of 85.13 feet to a point; thence along Lot
No. 13,North 77 degrees 28 minutes East, a distance of 208.82 feet to a point on the West side of
Indian Creek Drive, South 12 degrees 32 minutes East, a distance of 85 feet to a point, the place of
BEGINNING.
HAVING THEREON ERECTED a brick and aluminum raised ranch with a one-car
integral garage, known as 311 Indian Creek Drive.
BEING the same premises which Steven T. Allen and Myra Z. Allen, husband and wife,
conveyed unto Jody S. Johnston by Deed dated June 25, 1996, and recorded in the Office of the
Recorder of Deeds in and for Cumberland County in Deed Book 142, page 468.
F:\FILES\Clients\11470 Members Ist\11470 Current\11470.243 Johnston\11470.243.aff.mailing.wpd
•
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Christopher E. Rice, Esquire ca }
Attorney I.D. No. 90916 1 c
R. Christopher VanLandingham, Esquire
Attorney I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER •
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
MEMBERS 1ST FEDERAL CREDIT : IN THE COURT OF COMMON PLEAS OF
UNION, : CUMBERLAND COUNTY, PENNSYLVANIA
•
Plaintiff
v. : NO. 2013-1153 CIVIL TERM
•
JOSEPHINE S. JOHNSTON,
•
a/k/a JODY S. JOHNSTON
Defendant : IN MORTGAGE FORECLOSURE
AFFIDAVIT
I, Christopher E. Rice, Esquire, counsel for Plaintiff in the above action,hereby certify that
Notice of Sheriff's Sale of 311 Indian Creek Drive,Mechanicsburg,Pennsylvania 17050was served
by regular mail at the address set forth in the Amended Affidavit Pursuant to Pa.R.C.P. 3129.1,with
the return address of the Plaintiff appearing thereon, to the following:
Justin Johnston
1403 William Street
Baltimore MD 21230
Cumberland County Adult Probation Office
4 East Liberty Avenue
Carlisle, PA 17013
There are attached hereto as Exhibit "A," Certificates of Mailing, U.S. Postal Service
Form 3817, confirming mailing to such entities.
MARTSON LAW OFFICES
By. A
Christopher E. Rice, Esquire
Sworn t' and subscribed before me
thi ,l, day of , 2013. COMMONWEALTH OF PENN SYLVANIA
' / l! Notarial Seal
Mary M.Price Notary Public
Ca„isle Boro,Cumberland County
No blic MEMBER,Cfhmission Expires Aug.18,2015
A..VAr0A,ASSOI!lTION OF NOTARIES
39V.LSOd Sn
UNITED STATES Certificate Of SERVICE* Mailing
Mailing provides evidence that mail has been presented to USPS®for mailing. r
This Certificate of 9 P ti 01 M o
This form may be used for domestic and International mail. � C r p�
From: NO
to N r E
8 N P
VL Aar k 3ON LAW OFFIC �),� 49 0 i
10 East High Street , ,N o I
•
LarrsIe, PA 171113 2 i 1 U> i 2131SdH
0 a'
ZU13 '•.ti• t
To Justin Johnston \ 'f�0
1403 William Street y • 4:
Baltimore, MD 21230
-41:'4 T 11:—/
PS Form 3817 Anril 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of 3Jv.ISOd Sn
POSTAL SERVICE* Mailing
This Certificate of Mailing provides evidence that mail has been presented to USPS®for mailing. M
This form may be used for domestic and International mall.
From: i 01 *r•? O
u°,i N , E
viA `SCAN LAW OFFICES+ 1 a F 0 w
10 East High Street jP 4 2
2,arise, ' , 1 u °
H31SVH
0 0(11 .
- •• P 7:L ,j•i
To: Cumberland County.Adult Pro at '.2;_ 'Sf � �•'�1 -Cam,,.
4 East Liberty Avenue
Carlisle, PA 17013 '., .� 7 4
PC Form 3817 Anril 2007 PSN 7530-02-000-9065
•
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit was served this date
by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed
as follows:
Josephine S. Johnston a/k/a Jody S. Johnston
311 Indian Creek Drive
Mechanicsburg, PA 17050
Josephine S. Johnston a/k/a Jody S. Johnston
Inmate No. OU4833
SCI Muncy
P.O. Box 180
Muncy, PA 17756
Justin Johnston
1403 William Street
Baltimore MD 21230
MARTSON LAW OFFICES
By: y / p
Ma, Price
Dated: /4/543
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson '
Sheriff
JodySSmith ttitv �t ll1H1) t, f frry�, `f,
Chief Deputy 20 4 JAN 21 All
11: 35
Richard W Stewart
Solicitor
�
Solicitor _ C _ s P ' 'Ns Y�. J�JJA `T Y
Members 1st FCU Case Number
vs.
Josephine S Johnston aka Jody S. Johnston 2013-1153
SHERIFF'S RETURN OF SERVICE
09/06/2013 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: Josephine S. Johnston, but was unable to locate the
Defendant in his bailiwick. He therefore deputized the Sheriff of Lycoming County to serve the within Real
Estate Writ, Notice and Description, in the above titled action, according to law.
09/27/2013 12:19 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 311 Indian Creek Drive, Hampden Township,
Mechanicsburg, PA 17050, Cumberland County.
10/21/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Lycoming County upon Josephine Johnston, personally, at SCI Muncy, Box 180, Rte 405, Muncy, PA
17756. So Answers: Michaeln Cascher, Deputy Sheriff.
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$105,000.00 to Attorney Christopher Rice on behalf of
Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, being the buyer in this
execution, paid to the Sheriff the sum of$
12/30/2013 Proposed Schedule Of Distribution Posted, all parties notified.
SHERIFF COST: $1,262.61 SO ANSWERS,
January 15, 2014 RONNK ANDERSON, SHERIFF
a•as pd. 6.
. hue
6t-#
(C;
County Suite Sheriff,Telecsoft.Inc.
On September 6, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA,
Known and numbered as, 311 Indian Creek Drive,
Mechanicsburg, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
Date: September 6, 2013
By:
OA 0_1( ()\--%et 604
Real Estate Coordinator
SO :01 17 S d3S (101
v1
V,�
l
•
LXII 41 CUMBERLAND LAW JOURNAL 10/11/13
Writ No.2013-1153 Civil Term
MEMBERS 1ST FCU
vs.
JOSEPHINE S.JOHNSTON aka
Jody S.Johnston
Atty.: Christopher E.Rice
ALL THAT CERTAIN piece or par-
cel of land,known and designated as
Lot No. 12, Block"F," Plan No. 6 of
Indian Creek, Hampden Township,
Cumberland County, Pennsylvania
as prepared by D.P. Raffensperger,
Registered Surveyor,dated March 27,
1972,and recorded in the Recorder of
Deeds Office of Cumberland County
on May 9, 1972, in Plan Book 23,
Page 3.
BEGINNING at a point on the West
side of Indian Creek Drive (50 feet)
said point being 451 feet north of
the Northwest intersection of Indian
Creek Drive and Shasta Way;thence
along lot No. 11,South 77 degrees 28
minutes West, a distance of213.50
feet to a point; thence along lot No.
37 and 38, North 9 degrees 22 min-
utes West, a distance of 85.13 feet
to a point; thence along Lot No. 13,
North 77 degrees 28 minutes East,a
distance of 208.82 feet to a point on
the West side of Indian Creek Drive,
South 12 degrees 32 minutes East,
a distance of 85 feet to a point, the
place of BEGINNING.
HAVING THEREON ERECTED a
brick and aluminum raised ranch
with a one-car integral garage,known
as 311 Indian Creek Drive.
BEING the same premises which
Steven T. Allen and Myra Z. Allen,
husband and wife, conveyed unto
Jody S.Johnston by Deed dated June
25, 1996,and recorded in the Office
of the Recorder of Deeds in and for
Cumberland County in Deed Book
142,page 468.
69
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.
A
L sa Marie Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
25 day of October, 2013
C-4 _'�..r.1 / I �s
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
Ormammoremeomanronsammass
The Patriot-News Co.
202Q Technology Pkwy e pieii at s
Suite 3.00 . •
Mechanicsburg, PA 17050 Now you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
134153 Chdl This ad ran on the date(s)shown below:
MEMBERS 1ST -
vs. 10/13/13
,B F'. t: •.. aka ' .
Christopher Jody S.Johnston E Rice , / 10/20/13
-
ALL THAT CEIHAIN piece or parcel � �� 10/27/13
of land, known and designated as Lot //>
No 12, Block"F," Plan No.6 of Indian c/// - -�
Creek Hampden lbwnsbip, Cumberland
County,Pennsylvania as prepared by D.P. !/
Raffensperger, Registered Surveyor, dated
March 27,1972,and recorded in the Recorder
of Deeds Office of Cumberland County on Sworn to and subscribed before ,this 11 day of November, 2013 A.D.
May 9,1972,in Plan Book 23,Page 3. r 1
BEGINNING at a point on the West side-of
Indian Creekbrive(50 feet)said point being '
451 feet north of the Northwest intersection � �, ' - — '�
of Indian Creek Drive and Shasta Way,
• U•liC
thence along lot No.11,South 77 degrees 28
minutes West,a distance of213.50 feet to a
point;thence along lot No:37 and 38,North
9 degrees 22 minutes West,a distance of
85.13 feet toapoint;thence along Lid No.13, =�`i`10 `"y' �1-�H OF PENNSYLVANIA
North Tldegrees 2&a�utes a distance �� C" aro?s eai
of 208.82 feet to a e t side of 9iolly lyran 4rd�tErl Notary Public
Indian Creek Drive,South-12�degrees 32 Washingt n a�vp.,1 auphinCounty
minutes East,a distance of 85 feet to a point, . i y Comm..,ission.Expires Dec.12,2016
the place of BEGINNING. �EtdNSYLVANtA 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 Members 1st Federal Credit Union 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 4th day of September, A.D., 2013, out of the Court of Common Pleas of said County as of Civil
Term, 2013 Number 1153, at the suit of Members 1st Federal Credit Union against Josephine S.
Johnston a/k/a Jody S. Johnson is duly recorded as Instrument Number 201401523.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this � � day of
___1) /_, A.D. d261��f
/61- ._ (U. Ai-AA:g1
n�
Z. Recorder of Deeds
Recorder r'eeds,Cumberland County,Carlisle,PA
My Commission Expires the First Monday of Jan.2018